Free Redacted Document - District Court of Delaware - Delaware


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Case 1 :07-cr-00137-JJF Document 3 Filed 10/1 1/2007 Page 1 of 4
T ( { " IN THE UNITED STATES DISTRICT COURT 3
FOR THE DISTRICT OF DELAWARE
plaintiff, l, ak
A v. Criminal Action No. 07- I » U A
I J GRAY, V
afk/a "Dal1mer," :
E Defendant.
_ INDICTMENT
The Grand Jury for the District of Delaware charges that:
L COUNT I
From in or around January 2005, and continuing up to on or about October 30, 2006, in
the District of Delaware, and elsewhere, including the Eastern District of Pennsylvania,
JEFFREY GRAY, a/k/a"Dah1ner," defendant herein, did knowingly conspire, with other
indicted and unindicted co—conspirators known and unknown to the grand jury, to knowingly
distribute, and possess with intent to distribute, more than tive kilograms of a mixture and
substance containing a detectable amount of cocaine, a controlled substance, in violation of 21
U,S.C. § 84l(a)(l) and (b)(l)(A). _
All in violation of 21 U.S.C. § 846. I
COUNT H
On or about October 30, 2006, in the District of Delaware and in the Eastern District of
Pennsylvania, JEFFREY GRAY, afkf a "Dahmer," defendant herein, did knowingly attempt to
possess with intent to distribute more than five hundred grams of a mixture and substance
containing a detectable amount of cocaine, a controlled substance, in violation of 21 U.S.C. § l

Case 1:07-cr—00137—JJF Document 3 Filed 10/11/2007 Page 2 of 4
_ ( 841Ca)(l) and (b)(1)(B).
Allin violation of 21 U.S.C. § 846. ,
COUNT III
On or about the October 30,3%%%,%; {flie District of Delaware and in the Eastern District
of Pennsylvania, JEFFREY GRAY, afk/a "Dah1ner," defendant herein, did knowingly possess a
firearm, to wit, a Smith & Wesson 9mm pistol, model 5906, serial number AIP 7602, in
furtherance of a drug trafficking crime for which he may be prosecuted in a court ofthe United
States, to wit, conspiracy to possess with intent to distribute, and to distribute, more than five
kilograms of 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)(l)(A).
All in violation of 18 U.S.C. § 924(c)(l)(A).
COUNT IV
On or about October 30, 2006, in the Eastern District of Pennsylvania, JEFFREY GRAY,
afk/a "Dahmer," defendant herein, did knowingly conduct and attempt to conduct a financial
transaction affecting interstate and foreign commerce, to wit the delivery of currency to purchase
cocaine, which involved the proceeds of a specified unlawful activity, to wit, the distribution of I
cocaine inviolation of 21 U.S.C, § S4l(a)(l), with the intent to promote the carrying on of
specified unlawful activity, to wit, the distribution of cocaine in violation of 21 U.S,C. §
84l(a)(l), and that while conducting and attempting to conduct such financial transaction knew
that the property involved in the financial transaction, that is monetary instruments in the form of
United States Currency, represented the proceeds of some form of unlawful activity.
All in violation of Title 18, United States Code, Section l956(a)(1)(A)(i) and 2.

Case 1 :07-cr-00137-JJF Document 3 Filed 10/1 1/2007 Page 3 of 4
n E 3 COUNT V
On or about October 30, 2006, inthe Eastern District of Pennsylvania, JEFFREY
GRAY, a/k/a "Dahmer," defendant herein, having been convicted of a crime punishable by
imprisonment for a term exceeding one year, to wit, a conviction on or about January 6, 1997, in
the Superior Court ofthe State of Delaware in and for New Castle County, did knowingly I
possess in and affecting commerce a firearm, to wit, a Smith & Wesson 9mm pistol, model 5906,
serial number AEP 7602, in violation of Title 18, United States Code, Sections 922(g)(l) and
924(a)(2).
NOTICE OF FORFEITURE
Upon conviction of one or more of the controlled substance offenses alleged in Count I of
this Indictment, JEFFREY GRAY, a/lc/a "Dahmer," 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
i violations.
lf any of the above—described forfeitable property, as a result of any act or omission of the
defendant: I
(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 ofthe court;
(d) has been substantially diminished in value; or
(e) has been commingled with other property which cannot be divided without difficulty;
3

we nCLase_1;07;c;rr001r37-JJF. -.Document 3 Filed 10/11/2007 Page 4 of 4
A n ii nit is the intent ofthe United States, pursuant to 21 U.S.C. § S53(p), to seek forfeiture of any other
I property of said det`endant(s) up to the value ofthe forfeitable property described above.
A TRUE BILL:
Foreperson I
COLM F. CONNOLLY
United States Attorney
. sv; ji. {M0
Dougla E. McCann `
Assistant United States Attorney
i
Dated: October 11, 2007 I
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