‘ “ ` ‘ ` ·‘Z::1,rr¤.na].-' ' Complaint: _? "' _
A ln United States District Court J
S" For the District of Delaware
urlirizp sr/-was oi= Aiviai=
. v.
CASE NUMBER: 0/
Myron Williams , ‘ gg '/(/†/I/I .
Defendant
l, the undersigned complainant, being duly sworn, state the following is true and correct to the best of my knowledge and belief. On or
about January 22, 2008 in the District of Delaware, Defendant Myron Williams did knowingly possess in and affecting interstate
A commerce, a Hrearm, after having been convicted on or about January 24, 2006, of a crime punishable by imprisonment for a term
exceeding one year, in violation of Title 18 United States Code, Section(s) 922(g)§1l and 924{a){2] and further
state that I am a(n) Special Agent, Bureau of Alcohol, Tobacco, Firearms, and Explosives and that this complaint is based on the
following facts:
§__ge_ attached Affidavit
Continued on the attached sheet and made a part hereof: Yei `
Veronica M. Hnat
Special Agent, ATF
Sworn to before me and subscribed in my presence,
§*K’\‘·’¢;q i Acb at U Wilmington, DE
DHTG City and State
The Honorable Leonard P. Stark I {QQ/\Q ’ é
Name &Title of Judicial Officer Signature of dlcial Officer
é’?‘W`T"C`ase`"1 :08-mj-00014-UNA Document 2 Filed O1/23/2008 Page 2 of 4
I, Veronica M. Hnat, being duly sworn, state as follows:
1. Iam a Special Agent with the U.S. Bureau of Alcohol, Tobacco, Firearms, and
Explosives (ATF) and have been so employed for over eighteen years. During
that time, my duties have included the investigation of firearms offenses at both
‘ J the State and Federal levels. Your Affiant is currently assigned to the Operation ·
Disarm Task Force and has been so assigned since October, 2003. During the
course of your affiant’s law enforcement career, your affiant has received law - i i
enforcement training on the investigation of firearms offenses on over hundred
occasions. Your affiant has participated in over one hundred investigations of ,
_ firearms offenses and participated in the seizure of over fifty firearms. You l
Affiant has also had over one hundred conversations with police officers and l
Federal agents about the facts and circumstances of firearms offenses. l
. i
2. Unless otherwise stated, the information in this affidavit is based upon your
aff1ant‘s personal knowledge. \
3. The seizure of the below stated evidence occurred on January 22, 2008, in the city X
of Wihnington, State and District of Delaware, as stated to me by Wilmington §
Police Officers who have personal knowledge of the stated facts. 7
4. On January 22, 2008, at approximately 1236 hours, Wilmington Police were i
dispatched to the 1000 block of Linden Street, in the city of Wilmington, for a '
man with a gun. When they entered the block, they were waved down by a
Hispanic female. She told the Officers that a black male, later identified as
Myron Williams, (herein also named the defendant), pulled a gun on her son,
(herein the victim), and then ran into a residence on the same street that she
pointed out to the Officers. As they were speaking, Myron Williams, the
defendant, came from behind the residence that the Hispanic female identified and
walked into the street. The Hispanic female then yelled "That’s him, that’s the
guy that tried to rob him."
5. The Officers approached Williams and took him into custody. They asked him
- what his name was and he replied Admond Bradley. He told the Officers he was
from Chester, PA. The Officers patted the defendant down for officer safety and
V found a bundle of heroin on the defendant and two additional bundles around the
area where the Officers took him into custody. The Officers observed that the
three bundles appeared to be similar in their packaging and none of the bundles
were marked with any stamps. The approximate weight of the three bundles of
heroin is .97 grams.
. 6. The Officers then interviewed the Hispanic female and she stated that Williams _
knocked on their door; she and the victim looked out the window and the victim - -
said that that was the guy that robbed me. She said that the victim went out the
Case 1 :08-mj—OOO14—UNA Document 2 Filed O1/23/2008 Page 3 of 4
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i r front door and confronted Williams. She stated that they started fighting in the
’ street. She stated that once the fighting started, Williams pulled outa gun and
` fired two shots at the victim. She then stated that the victim ran away and
` Williams ran into the residence she had pointed out earlier. _
~ 7. The Ofhcers interviewed the person inside the residence where the defendant was
l seen running into. The witness stated that he heard the noise out side his house
l and saw two people fighting in the street. He said he saw the defendant with a
l gun and saw him hit the victim around the head area with the gun. He stated that
he heard two gun shots right after that. The witness stated that the defendant then
r came to his house and told- him he was being shot at. The witness stated that he
Q knew the defendant from prior encounters.
I
I 8. The witness then stated that the defendant went into his house and went to the
Z basement and hid the firearm behind a wall in the basement. The witness told the .
E defendant that he could not have that in the house. The witness then stated that
` the defendant went upstairs and left out the back door. The witness took the
Officers to where the defendant placed the firearm. .
l 9. The Officers recovered a Colt, Cobra Special, .38 caliber revolver with the serial
l number partially scratched off. The firearm was loaded with two live rounds and
two spent shell casings.
i 10. The defendant was transported to Wilmington Police Department, he was read his
i Miranda warnings and agreed to speak to one of the Detectives. The defendant
admitted he went to the victim’s house because the victim was “beefing" with
another individual on the street about selling drugs. He stated that he started
r talking to the victim and he said he got jumped. He said while he was being
jumped one of them pulled a gun and shot it. He stated that he saw the gun hit the
ground and he grabbed it and ran. He also stated the he purchased heroin before
he went to the victim’s house.
1 1. A review of the Delaware Justice Information S tem for the defendant’s criminal
history revealed that Wi]liams’ date of birth ig 968. It also indicated that he
has a prior felony conviction and was found guilty of Possession with the Intent to _
Deliver a Narcotic Schedule I Controlled Substance on or about 1/24/2006, in _
Superior Court of Delaware, New Castle County, which is a crime punishable by
imprisonment for a term exceeding one year. .
12. From your affianfs training and experience, and from prior discussions with ATF
Agents who are expertly trained and experienced in determining the interstate
nexus of firearms, your affiant knows that the above mentioned firearm was
· manufactured in a state other than Delaware such that the possession in Delaware
‘ would have necessarily required that the firearm had crossed state lines prior to its
possession in Delaware and such that the possession of that firearm in
Delaware affected interstate commerce.
Case 1 :08-mj—OOO14—UNA Document 2 Filed O1/23/2008 ·Page 4 of 4
13. Based upon your affiant's training and experience, your affiant submits that there _
is probable cause to believe the above mentioned seized firearm contained a frame .
and receiver of a firearm, and that the firearm appeared to be capable of expelling
a projectile by action of an explosive.
14. Wherefore, based upon your affiant's training and experience, our afliant believes
that there is probable cause to believe that the defendant violated 18 USC
922(g)( 1) and 924(a)(2) by possessing in and affecting interstate commerce a
firearm, after having previously been convicted of a felony and t
respectfully requests that the Court issue a Criminal Complaint charging that
offense.
GZ ` fl gra
Veronica M. Hnat
Special Agent, ATF »
Sworn to and subscribed in my presence A
This 23rd day of January, 2008
Honorable Leonard P. Stark .
United States Magistrate Judge y
District of Delaware I
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