Free Redacted Document - District Court of Delaware - Delaware

4 _ - Case 1 :07-cr-00171-JJF Filed 12/13/2007 Page 1 of 3
R5 ~
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE _
UNITED STATES OF AMERICA, _ )
S - Plaintiff g
L g v, g Criminal Action No. 07- f"//.
ANGELA JONES, i . .
> F l L E D g I
Defendant. ) Q _
INDICTMENT r D EC 1 3 20D?
I The Grand- Jury for the District of Delaware charges tliak M I
COUNT ONE MW F
From on or about November 5, 2007, through on or about November 15, 2007, in the State
and District of Delaware, Angela Jones, defendant herein, did knowingly possess in and affecting
interstate and foreign commerce, a firearm, that is, a Cobra, model FS32, .32 caliber handgun, serial I
number FS021 180, after having been convicted on or about March 16, 2001, of a crime punishable
by imprisonment for a term exceeding one year, in the Delaware County Court of Common Pleas
for the Commonwealth of Pennsylvania, in violation of Title 18, United States Code, Sections
922(g)(l) & 924(a)(2). ‘
S COUNTTWO 2
p On or about October 16, 2007, in the State and District of Delaware, Angela Jones, defendant
herein, in connection with the attempted acquisition of a firearm, to wit a Cobra, model CA32, .32 _
caliber handgun, from l\/1il1er’s Gun Center, Inc., a licensed dealer of firearms within the meaning
of Chapter 44, Title 18, United States Code, knowingly made a false and fictitious written statement
_ to Miller’s Gun Center, Inc., which statement was intended and likely to deceive Miller’s Gun
Center, Inc., as to a fact material to the lawfulness of such sale of the said firearm to the defendant

, Case 1:07-cr—00171-JJF Document 14 Filed 12/13/2007 Page 2 of 3
under Chapter 44 of Title 18, in that the defendant executed a Bureau of Alcohol, Tobacco and I
Firearms Form 4473, Firearms Transaction Record, to the effect that she had not been convicted in
any court of a felony or any other crime, for which the judge could have imprisoned her for more
than one year, when in fact she had been convicted on or about March 16, 2001, of a crime
punishable by imprisonment for a term exceeding one year, in the Delaware County Court of
Common Pleas for the Commonwealth of Pennsylvania, in violation of Title 18, United States Code,
Sections 922(a)(6) and 924(a)(2).
COUNT THREE
I On or about October 16, 2007, in the State and District of Delaware, Angela Jones, defendant
herein, knowingly made a false statement and representation to Miller’s Gun Center, lnc., an entity
licensed under the provisions of Chapter 44 of Title 18, United States Code, with respect to
information required under the provisions of Chapter 44 of Title 18, United States Code, to be kept
in the records of Miller’s Gun Center, Inc., in that the defendant executed a Bureau of Alcohol,
Tobacco and Firearms Form 4473, Firearms Transaction Record, to the effect that she had not been .
convicted in any court of a felony or any other crime, for which the judge could have imprisoned her
for more than one year, when in fact she had been convicted on or about March 16, 2001, of a crime
punishable by imprisonment for a term exceeding one year, in the Delaware County Court of
Common Pleas for the Commonwealth of Pennsylvania, inviolation of Title 18, United States Code,
Section 924(a)(l )(A).
COUNT FOUR
On or about November 15, 2007, in the State and District of Delaware, Angela Jones,
defendant herein, knowingly and intentionally possessed cocaine base, a Schedule H narcotic
controlled substance, in violation of Title 21, United States Code, Section 844(a).

. Case 1 :07-cr-00171-JJF Document 14 Filed 12/13/2007 Page 3 of 3 y
E -7 .
- NOTICE OF FOR].ITURE
Upon conviction of one or more of the offenses alleged in Count One of this Indictment,
defendant Anglea Jones shall forfeit to the United States pursuant to 18 U.S.C. § 924(d), 2l U.S.C. i
§ 853 and 28 U.S.C. § 246l(c), any property, real and personal, that constitutes or is derived from
or is traceable to proceeds obtained directly or indirectly from the commission of the above
offense(s); all property, real or personal, that was used to facilitate, or was intended to be used to
facilitate the commission of the offense(s); and, all firearms and ammunition involved in the
commission ofthe offense(s), including but not limited to the following:
Cobra, model FS32, .32 caliber handgun, serial number FS021 180
A box of titty (50) rounds of Fiocchi 7.65 Browning ammunition.
If any of the above-described forfeitable property, as a result of any act or omission of the
defendant: i
(a) carmot 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 ofthe United States, pursuant to 21 U.S.C. § 853(p) as incorporated by 28 U.S.C. §
246l(c), to seek forfeiture of any other property of said defendant up to the value of the forfeitable
i property described above. A
A TRUE BILL:
Foreperson -— _
COLM F. CO OLLY . I
United States ttorney
BY: ~ A
Sha A. ·Weede
Assistant United States Attorney · Dated: December 13, 2007

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