United States District Court, E.D. Michigan, Southern Division
MATTHEW SCHNEIDER United States Attorney SHANKAR RAMAMURTHY
Assistant U.S. Attorney
MICHAEL A. RATAJ, ESQ. Attorney for Defendant JAMES DESHAWN
STIPULATED PRELIMINARY ORDER OF FORFEITURE
HONORABLE VICTORIA A. ROBERTS UNITED STATES DISTRICT JUDGE.
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:
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. §
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.
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).
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.
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
d. One (1) 7.62x39 caliber magazine;
e. One (1) .40 caliber magazine;
f. One (1) 7.62x39 caliber drum ...