Free Redacted Document - District Court of Delaware - Delaware

_ Case 1 :07-cr—OOO14-SLR Document 9 Filed O2/06/2007 Page 1 of 2
I IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
I UNITED STATES OF AMERICA, ¤_ U
Plaintiff, ·` I- nnnn I I i`·_ji"j
v. Criminal Action No. 07- I Ll - A
RAFAEL SANTIAGO,
Defendant,
INDICTMENT
The Grand Jury for the District of Delaware charges that:
COUNT I
On or about April 17, 2006, in the District of Delaware, RAFAEL SANTIAGO,
defendant herein, did knowingly distribute, and possess with intent to distribute, a mixture and
substance containing a detectable amount of cocaine, a controlled substance, in violation of 21
U.S.C. § 84l(a)(1) and (b)(1)(C).
COUNT II_
On or about June 15, 2006, in the District of Delaware, RAFAEL SANTIAGO, defendant
herein, did knowingly distribute, and possess with intent to distribute, a mixture and substance
containing a detectable amount of cocaine, a controlled substance, in violation of 21 U.S.C.
§ 841(a)(1)and(b)(1)(C).
NOTICE OF FORFEITURE
Upon conviction of the controlled substance offense alleged in Counts I and II of this
Indictment, RAFAEL SANTIAGO, defendant herein, shall forfeit to the United States pursuant
to 21 U.S.C. § 853, any property constituting, or derived from, proceedgubtainicgicgirebtlyngar D I
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Case 1:07-cr—OOO14-SLR Document 9 Filed O2/06/2007 Page 2 of 2
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 a sum of money substantially in excess of $22,000 and the real property known as
501 Maryland Avenue, Wilmington, Delaware.
If any of the above—described.forfeitable property, as a result of any act or omission of the
defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred or sold to, or deposited with, a third party;
(c) has been placed beyond the jurisdiction of the court;
(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 2l· 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.
A TRUEGBILL:

COLM F. CONNOLLY
United States Attorney
Douglas . McCann
Assistant United States Attomey
Dated: February 6, 2007