Free Redacted Document - District Court of Delaware - Delaware

. Case 1 :07-cr-001 15-SLR Document 7 Filed 08/24/2007 Page 1 of 3 .
A0 91 (Rev. 12/93) Criminal Complaint G
. United States District Court _
DISTRICT OF DELAWARE W
UNITED STATES OF AMERICA
v.
_ t Criminal Complaint 07- [C6 W]
CHARLES A. WEBSTER
- ..I` 2 ..
T iitlilt/t@iii§`@
I, the undersigned complainant, being duly sworn, state the following is true and correct to the best of my
knowledge and belief On or about Auggst 23, 2007, in New Castle County, in the District of Delaware defendant,
Charles A. Webster l
did knowingly possess a firearm after having convicted in any court by a crime punishable by imprisonment for more than one year
1
in violation of Title 18 United States Code, Section(s) 922{ g)( it .
i
I further state that I am a(n) Special Agent, ATF and that this complaint is based on the following facts:.
Official Title
SEE ATTACHED AFFIDAVIT
Continued on the attached sheet and made a part hereof: YES
I F i i. E D E J
AUG 2 tl ZGU7 Veronica Hnat .
Special Agent
II S IIISIIIICI COURT . Bureau of Alcohol Tobacco Firearms and Explosives
i
Sworn to before me and subscribed in my presence, ,
Auggst 24, 2007 at Wilmington, DE
Date City and State
Honorable Mary Pat Thynge -
United States Magistrate Judge , _, ‘ uy. l -
Name & Title of Judicial Officer Signa e of Judicia *01 4* r

. Case 1:07-cr-00115-SLR Document 7 Filed 08/24/2007 Page 2 of 3
i I, Veronica M. Hnat, being duly sworn, state as follows: . ·
t
l. l am a Special Agent with the U.S. Bureau of Alcohol, Tobacco, Firearms, and Explosives
(ATF) and have been so employed for over seventeen years. During that time, my duties have
included the investigation of firearms offenses at both the State and Federal levels. Your
Affiant is cturently assigned to the Operation Disarm Task Force and has been so assigned ,
since October, 2003. During the course of your affrant’s law enforcement career, your affiant {
has received law 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. Your Affiant has also
had over one hundred conversations with police officers and Federal agents about the facts
and circumstances of firearms offenses. Your Affiant has been employed as a law
enforcement officer in various capacities since 1989. i
l
2. Unless otherwise stated, the information in this affidavit is based upon your Affiant’s 1
personal knowledge. _
3. The seizure of all the below—stated evidence occurred on August 23, 2007, in Newark,
Delaware (New Castle County), as indicated to me by officers of the New Castle County
Police who have personal knowledge of the stated facts. p
I
4. On August 20, 2007, at approximately 2218 hours, the New Castle County Police responded
to a shooting that occurred at the A l
Delaware. Upon their arrival, they located Charles A. Webster. , who
sustained a gun shot injury to the buttocks. He was transported to the hospital and
subsequently released. He told the police that he did not know who shot him. At the time,
Charles Webster was an active probationer with Delaware State Probation and Parole.
5. On August 22, 2007, at approximately l9l6 hours, the Wilmington Police were at an area
hospital and observe a black female enter the emergency room bleeding from the face. An
interview of a witness, that accompanied the black female, stated that they were shot at by an
unknown black male in the area of 4th and Rodney Streets, Wilmington, Delaware, while ‘
seated inside the black female victim’s vehicle. The Wilmington Police recovered
approximately 14 spent shell casings at the scene of the shooting.
6. On August 23, 2007, Delaware State Probation and Parole Officers, executed an
administrative search warrant at _ _ , - .. " , the
residence of Charles Webster. Located in the residence, in the living room area, under aseat
cushion of the couch, was a loaded Taurus, .38 caliber revolver, serial number UL5475 8.
Also located in the residence, in a hallway closet, in a boot, was a loaded Ruger, model
Vaquero, serial number 5840073, with one spent shell casing inside the firearm. Both
weapons were checked through the National Crime information Center and found to be
stolen. During the administrative search, Webster’s father, who also resides at the above
residence, indicated that the aforementioned firearms were not his.

_ Case 1:07-cr-00115-SLR Document 7 Filed 08/24/2007 Page 3 of 3
7. Also located in a vehicle that was registered to Charles Webster were MapQuest
directions printed from a computer to a location in Marcus Hook, Pennsylvania. Webster
was rnirandized and indicated that he knew who shot him and that they were from Marcus `
Hook. He stated that he was up in Marcus Hook, Pennsylvania earlier in the week and did
‘ his own surveillance at that location. He also indicated that he was at 4th and Rodney Streets,
Wilmington, DE, on 8/22/07, hanging out with his cousin and friends shortly before the
shooting. He stated that people are telling him that he was the target of that shooting.
8. Your affiant reviewed the computer criminal history information for the defendant from the
Delaware Justice Information System (DELJIS), and learned that the defendant has a prior
felony convictions for Assault First, for which he was found guilty on or about 8/20/1998,
Attempt Murder lst, for which he was found guilty of on or about 12/21/ l 991, and Escape A
after Conviction, for which he was found guilty of on or about 3/2/ 1992, all in the New
_ Castle County Superior Court for the State of Delaware, which are all crimes punishable by
imprisonment for a term exceeding one year.
9. From you affiant’s training and experience, and from prior discussions with ATF Agents who I
are expertly trained and experienced in determining the interstate nexus of firearms, your i
affiant knows that the above»mentioned firearms were manufactured in a state other than .
Delaware such that its 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. Q
l0. Based upon your affiant’s training and experience, your affiant submits that there is probable
cause to believe that the above-mentioned seized firearms contained the name and receiver of
a firearm, and that the firearms appeared to be capable of expelling a projectile by action of
an explosive. I
ll. Wherefore, based upon your affiant’s training and experience, your affiant believes that there
is probable cause to believe that the defendant violated 18 U.S.C. 922(g) and 924(a)(2) by
possessing in and affecting interstate commerce firearms, after having previously been
convicted of a felony and respectfully requests that the Court issue a Criminal Complaint ·
charging that offense. _ if Q
eronica M. Hnat A
Special Agent, ATF
Sworn to and subscribed in my presence
This 2 th da f August, 2007
4.-___ rv ..2
no a le ynge ‘ A p ‘ ‘ ‘

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