Free Redacted Document - District Court of Delaware - Delaware

Case 1 :07-cr-00103-JJF Docum nt 10_ Filed 07/24/2007 Page 1 of 3
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1 lN THE UNITED STATES DISTRICT COURT if
R FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, ; ,
Plaintiff [ h
v. - Criminal Action No. 07- I ·‘ Q
` STANLEY LUM,
n Defendant. . E L .
E A JUL 2 ll 2007
The Grand Jury for the District of Delaware charges that: U S. Dmmc COURT
ursmyggot mrLr~.~.rAss
COUNTI
On or about July 02, 2007, in the State and District of Delaware, STANLEY D. LUM,
defendant herein, did knowingly possess with intent to distribute more than five (5) grams of a
mixture and substance containing a detectable amount of cocaine base, a controlled substance, in S
violation of2l U.S.C. § 84l(a)(l) and (b)(l)(B). A
- COUNT II A
On or about July 02, 2007, in the State and District of Delaware, STANLEY D. LUM,
defendant herein, during and in relation to a drug trafficking crime for which he may be
prosecuted in a court of the United States (to wit, the knowing possession with intent to distribute
more than five (5) grams of a mixture and substance containing a detectable amount of cocaine
base, as set forth in Countl of this Indictment and incorporated by reference as if fully set forth
herein), lmowingly%\§?_r9ried a firearm, to wit, a Harrington and Richardson, Model 732, six shot,
.32 EQiber revolver, serial number AL4958l, and knowingly possessed said
firearm in furtherance of said drug trafficking crime, all in violation of 18 U.S.C. § 924(c)(l )(A).

I .-. Case 1 :07-cr-00103-JJF Document 10 Filed 07/24/2007 Page 2 of 3
COUNT III o
A On or about July 02, 2007, in the State and District of Delaware, STANLEY D. LUM,
defendant herein, having been convicted of a crime punishable by a term of imprisonment
exceeding one year, to wit, a conviction on or about February 09, 2004, in the Superior Court in .
and for New Castle County for the State of Delaware, did knowingly possess a firearm in and
affecting interstate commerce, to wit, a Harrington and Richardson, Model 732, six shot, .32
A aliber revolver, serial number AL49581, all in violation of Title l8, United
States Code, Sections 922(g)(1) and 924(a)(2). I
- NOTICE OF FORFEITURE
Upon conviction of the controlled substance offense alleged in Count I of this Indictment,
STANLEY D. LUM, defendant herein, shall forfeit to the United States pursuant to 2l U.S.C. §
853, any property constituting or derived from proceeds obtained, directly or indirectly, as a
result of said violation, and any property used, or intended to be used, in any manner or part to
commit, or to facilitate the commission of, said violation. _ I
1 Upon conviction of the firearms offense alleged in Counts H and 1]] of this Indictment,
STANLEY D. LUM, defendant herein, shall forfeit to the United States pursuant to 18 U.S.C. §
924(d) and 28 U.S.C. § 2461(c) any firearm and ammunition involved or used in the commission
of said offenses. i
If any of the above-described forfeitable property, as a result of any act or omission of the
defendant:
(1) cannot be located upon the exercise of due diligence;
(2) has been transferred or sold to, or deposited with, a third party, ..
2 .

Case 1 :07-cr-00103-JJF Document 10 Filed 07/24/2007 Page 3 of 3
(3)' has been placed beyond the jurisdiction of the court; pi
I (4) has been substantially diminished in value; or n
(5) has been commingled with other property which cannot be divided without
. i ‘ difficulty; -
` it is the intent ofthe United States, pursuant to 21 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. I I
` A TIQIE
I _ lioreperson
n COLM F. CONNOLLY .
__ United States Atto ey ‘
BY: ·- ul" '"WY
Shawn Martyniak A i
Special Assistant Unite States Attorney
Dated: July 24, 2007 A 4
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