Free Information - Felony - District Court of Delaware - Delaware

Case 1:07-cr-00084-JJF Document 1 Filed 06/19/2007 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNTTED STATES OP AMERICA, :
Piarntrrr, 2
v, Criminal Action No. 07-Bq
ROBERT W. SHEPHERD, III,
a/k/a "Mannf’ a/k/a "Jig," :
Defendant. i L E D
FELoNY INFORlVIA \{ J UN 1 9 2007 E
___j I
The United States Attorney for the District of Delaware charges that: F
COUNT I H--A
On or about October 30, 2006, in the Eastern District of Pennsylvania, ROBERT W.
SHEPHERD, IH, a/k/a "Manny, a/k/a "Jig," defendant herein, did knowingly attempt to possess
with intent to distribute, more than tive hundred grams of a mixture and substance containing a
detectable amount of cocaine, a controlled substance, in violation of 21 U.S.C. § 8-4l(a)(1) and
(b)(l)(B)-
All in violation of 21 U.S.C. § 846 and 18 U.S.C.§ 2.
COUNT II
From on or about January 19, 2006 to on or about January 23, 2006, in the Central
District of Califomia, ROBERT W. SHEPHERD, IH, a/k/a "Manny, a/k/a "Jig," defendant
herein, did knowingly engage and attempt to engage in a monetary transaction by, through and to
a financial institution, affecting interstate or foreign commerce, in criminally derived property of
a value greater than $10,000, to wit, the transfer of $18,000 in monetary instruments to a car
dealership for the purpose of leasing a 2005 Mercedes Maybach VIN # WDBVG78J15A00l102,

Case 1 :07-cr-00084-JJF Document 1 Filed 06/19/2007 Page 2 of 3
which monetary instruments were derived from a specified unlawful activity, to wit, the
distribution of cocaine in violation of 21 U.S.C. § 841(a)(1).
Allin violation of 18 U.S.C. §§ 1957 and 2.
NOTICE OF FORFEITURE
Upon conviction of the controlled substance offense alleged in Count 1 of this
Information, ROBERT W. SHEPHERD, IH, a/k/a/ "Manny" a/k/a "Jig," defendant herein, shall
forfeit to the United States pursuant to 21 U.S.C. § 853, any property constituting, or derived
from, proceeds obtained, directly or indirectly, as a result of the said violations and any property
used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of
the said violations,
Upon conviction of the illegal monetary transaction offense alleged in Count H of this
Information, ROBERT W. SHEPHERD, III, a/l forfeit to the United States pursuant to 18 U.S.C. § 982(a)(1):
a. All right, title, and interest in any and all property involved in each offense in violation
of Title 18, United States Code, Section 1956, for which the defendant is convicted, and all
property traceable to such property, including the following: 1) all money or other property that
was the subject of each transaction, transportation, transmission or transfer in violation of
Section 1956; 2) all commissions, fees and other property constituting proceeds obtained as a
result of those violations; and 3) all property used in any manner or part to commit or to facilitate
the commission of those violations.
b. A sum of money equal to the total amount of money involved in each offense, or
conspiracy to commit such offense, for which the defendant is convicted.
1f any of the above—described forfeitable property, as a result of any act or omission of the

C 1:07- -000 4-JJF . D 1 F`| d 06/19/2007 P 3 f3
(a) cannot%>seSlocated:iipont§1e exercise o(i`(ii`ur (b) has been transferred or sold to, or deposited with, a third party;
(c) has been placed beyond the jurisdiction of the couitg _
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot be divided without difficulty;
it is the intent of the United States, pursuant to 21 U.S.C. § 853(p), to seek forfeiture of any other
property of said defendant up to the value of the forfeitable property described above.
COLM F. CONNOLLY
United States Attorney
li In . AFL 1 _ X
I" nL,,·"L/L/L{ --2 `r I.- { _-_._'_'__ -
Douglas_!E. McCann
Assistant United States Attorney
Dated: June 19, 2007