United States v. Williams

          MATTHEW SCHNEIDER United States Attorney SHANKAR RAMAMURTHY Assistant U.S. Attorney

          MICHAEL A. RATAJ, ESQ. Attorney for Defendant JAMES DESHAWN WILLIAMS, Defendant

          STIPULATED PRELIMINARY ORDER OF FORFEITURE

          HONORABLE VICTORIA A. ROBERTS UNITED STATES DISTRICT JUDGE.

         The United States of America, by and through its attorneys, Matthew Schneider, United States Attorney for the Eastern District of Michigan, and Shankar Ramamurthy, Assistant United States Attorney, together with Defendant James Deshawn Williams (“Defendant”), individually and by and through his attorney, Michael A. Rataj, Esq., hereby submit this Stipulated Preliminary Order of Forfeiture:

         1. A First Superseding Indictment was filed and charged Defendant with Felon in Possession of a Firearm in violation of 18 U.S.C. § 922(g)(1) (Count One), with Possession/Discharge of a Firearm in Furtherance of a Drug Trafficking Offense in violation of 18 U.S.C. §§ 924(c) and 2 (Count Two) and Felon in Possession of a Firearm in violation of 18 U.S.C. § 922(g)(1) (Count Three) and sought criminal forfeiture pursuant to 18 U.S.C. § 924(d)(1).

         2. The United States filed a First Forfeiture Bill of Particulars on February 4, 2019, which set forth the government's notice and intent to forfeit seized firearm(s) and ammunition upon Defendant's conviction for the charged offenses. (Dkt. No. 37).

         3. On or about February 5, 2019, Defendant entered into a Rule 11 Plea Agreement (“Plea Agreement”) and pled guilty to violating 18 U.S.C. § 922, as alleged in Count One of the First Superseding Indictment. (Dkt. No. 38).

         4. Defendant agrees, pursuant to 18 U.S.C. § 924(d), to the forfeiture of the following “Subject Property” as being involved in Defendant's violations of 18 U.S.C. § 922(g):

a. One (1) Smith & Wesson, SW40VE, .40 caliber handgun, Serial No. PDY4558;

b. Two (2) Glock .40 caliber magazines;

c. One (1) American Tactical extended 7.62x39 caliber magazine;

d. One (1) 7.62x39 caliber magazine;

e. One (1) .40 caliber magazine;

f. One (1) 7.62x39 caliber drum ...