Free Redacted Document - District Court of Delaware - Delaware

Case 1 :07-cr-00070-JJF Document 2 Filed 05/22/2007 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Plaintiff,
v. Criminal Action No. 07- -9-0- Q
DANIEL JonNsoN, i r fl ° __l- " " r ·»._
I .* al `T}-_ A __; ‘
Defendant. 1 · "
INDICTMENT 1
The Grand Jury for the District of Delaware charges that:
COUNT_I
On or about April 18, 2007, in the State and District of Delaware, DANIEL
JOHNSON, defendant herein, did knowingly possess with intent to distribute a mixture and
substance containing a detectable amount of cocaine, a controlled substance, in violation of
Title 21, United States Code, Sections 841(a)(1) and (b)(l)(C), and Title 18, United States
Code, Section 2. I
NOTICE OF FORFEITURE
_ Upon conviction of one or more of the controlled substance offenses alleged in
Counts I above, DANIEL JOHNSON, defendant herein, shall forfeit to the UnitedStates
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,
including but not limited to: [
1995 Chevrolet Tahoe, registration PC87735
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Case 1:07-cr-00070-JJF Document 2 Filed 05/22/2007 Page 2 of 2
omission of the defendant:
(1) cannot be located upon the exercise of due diligence;
(2) has been transferred or sold to, or deposited with, a third party;
(3) has been placed beyond the jurisdiction of the court;
(4) has been substantially diminished in value; or
(5) has been commingled with other property which cannot be divided without
difficulty;
it is the intent of the United States, pursuant to 21 USC. § 853(p), to seek forfeiture of any
other property of said defendant up to the value of the forfeitable property described above.
A TRUE BILL:
` Foreperson
COLM F. CONNOLLY
United States Attorney
BY:
Dougl E. McCann
Assistant United States Attorney
U Dated: May 22, 2007