IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND

Transcription

1 ADC/JAC/SR: USAO 2009R00541 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND UNITED STATES OF AMERICA * * v. * * CRIMINAL NO. RICHARD DELABRER, * AMRIK SINGH MELHI, * (Conspiracy to Interfere with RAVINDER KAUR MELHI, * Commerce by Extortion, 18 U.S.C. AMIR MILIJKOVIC, * 1951(a); Forfeiture, 28 U.S.C. 2461, CHONG CHIN KIM, * 18 U.S.C. 981, 21 U.S.C. 853) CHUN CHEN, * a/k/a Eddy Chen, and * JOSE MORENO, * * Defendants * * ******* INDICTMENT COUNT ONE (Hobbs Act Conspiracy) The Grand Jury for the District of Maryland charges that: At all times relevant to this Indictment: A. The Defendants Introduction 1. Defendant RICHARD DELABRER, a resident of Maryland, was an active duty Sergeant with the Prince George s County Police Department ( PGCPD ). 2. Defendants AMRIK SINGH MELHI and RAVINDER KAUR MELHI, residents of Maryland, had ownership interests in numerous liquor stores in Maryland. 3. Defendant AMIR MILIJKOVIC, a resident of Maryland, owned an auto glass store located in College Park, Maryland.

2 4. Defendant CHONG CHIN KIM, a resident of Maryland, was an active duty Corporal with the PGCPD. 5. Defendants CHUN CHEN, a/k/a Eddy Chen, and JOSE MORENO were residents of Maryland. B. State and Federal Taxes Governing the Sale of Cigarettes and Alcohol 6. Maryland and Virginia imposed state taxes on the sale of cigarettes and alcohol. Maryland imposed a $2.00 sales tax on each pack of cigarettes and a sales tax of $1.50 per gallon of liquor. Virginia imposed a $0.30 sales tax on each pack of cigarettes. Virginia state government directly controlled the sale of liquor in Virginia. The United States Department of the Treasury imposed a federal excise tax of $1.01 on the sale of each pack of cigarettes. 7. Each pack of cigarettes sold in Maryland and Virginia was required to contain state tax stamps indicating that state taxes had been paid. The Conspiracy 8. From at least in or about July 2009 and continuing through at least in or about January 2010, in the District of Maryland and elsewhere, the defendants, RICHARD DELABRER, AMRIK SINGH MELHI, RAVINDER KAUR MELHI, AMIR MILIJKOVIC, CHONG CHIN KIM, CHUN CHEN, a/k/a Eddy Chen, and JOSE MORENO, did knowingly, willfully, and unlawfully combine, conspire, confederate and agree with each other, others, and public officials known and unknown to the Grand Jury to obstruct, delay, and affect commerce, and the movement of articles and commodities in commerce, by extortion in 2

3 the form of public officials obtaining, under color of official right, the property of others with their consent and not due to the officials and their offices, to wit: by agreeing that defendant AMRIK SINGH MELHI and others would provide things of value, including money, to public officials, including defendant RICHARD DELABRER, in return for using their official authority and influence to ensure the safe transport and distribution of untaxed cigarettes and alcohol in Maryland and Virginia and official acts involving the enforcement of state and federal laws by the PGCPD. 18 U.S.C. 1951(a) 3

4 FORFEITURE ALLEGATION The Grand Jury for the District of Maryland further charges: 1. Pursuant to Rule 32.2, Fed. R. Crim. P., notice is hereby given to the defendants that the United States will seek forfeiture as part of any sentence in accordance with Title 28, United States Code, Section 2461(c), and Title 18, United States Code, Section 981(a)(1)(C), in the event of the defendants convictions under Count One of this Indictment. 2. As a result of the offense charged in Count One, the defendants, RICHARD DELABRER, AMRIK SINGH MELHI, RAVINDER KAUR MELHI, AMIR MILIJKOVIC, CHONG CHIN KIM, CHUN CHEN, a/k/a Eddy Chen, and JOSE MORENO, shall forfeit to the United States (1) any and all property obtained directly or indirectly as a result of any such violation, and (2) any and all property used, or intended to be used, in any manner or part to commit and to facilitate the commission of any such violation charged in this indictment, including the following: a. $3,500,000 in United States currency and all interest and proceeds traceable thereto; b. 401 Baltimore Pike, Bel Air, Maryland; c University Boulevard, Hyattsville, Maryland; d North Point Boulevard, Baltimore, Maryland; e Narrow Leaf Court, Clarksville, Maryland; f Dobbin Road, Columbia Maryland; 4

5 g Annapolis Road, Lanham, Maryland; h Berry Road, Waldorf, Maryland; i Riggs Road, Adelphi, Maryland; j Energy Parkway, Baltimore, Maryland; k Richie Highway, Pasadena, Maryland; l. 617 Solomons Island Road, Prince Frederick, Maryland; m Hamilton Street, Hyattsville, Maryland; n Walmart Way, Midlothian, Virginia; o Annapolis Road, New Carrollton, Maryland; p Greenbelt Road, Suite J, Greenbelt, Maryland; q Old Keene Mill Court, Springfield, Virginia; r. 508 Digiulian Boulevard, Glen Burnie, Maryland; s. 725 Gouldman Lane, Great Falls, Virginia; t New Hampshire Avenue, Takoma Park, Maryland; u Edwards Way, Unit 605C, Adelphia, Maryland; v Coralberry Court, Aberdeen, Maryland; w Sandy Creek, Clarksville, Maryland; x Ashcroft Drive, Laurel, Maryland; y Shawmont Lane, Bowie, Maryland; z Black Walnut Way, Bowie, Maryland; aa. bb Ford E313 Van, VIN # 1FBNE31L74HB21119; 2005 Dodge Grand Caravan, VIN # 2D4GP44L75R125678; 5

6 cc. dd. ee. ff. gg. hh. ii. jj. kk. ll. mm. nn Toyota Scion, VIN # JTKDE ; 2005 Volkswagen Beetle, VIN # 3VWCK31CX5M415698; 2008 Mercedes Benz, VIN # WDBUF87XX8B279862; 2005 Acura TK, VIN # 2HNYD18925H535229; 2008 Lexus, VIN # WP1AA29P56LA27276; 2007 Toyota Scion, VIN # JTKDE ; 2002 Chevrolet Corvette, VIN # 1G1YY22G ; 2010 Cadillac SRX, VIN # 3GYFNAEY0AS518503; 2009 Honda Sport Utility Vehicle, VIN # 3CZRE38339G702647; 2000 Mercedes Benz sedan, VIN # WDBJF70J5YA968796; 2007 Harley Davidson, VIN # 1HD4CP2177K403350; all funds contained in Capital One Bank (formerly Chevy Chase Bank) accounts bearing the following numbers: , , , , , , , , ; oo. all funds contained in Bank of America accounts bearing the following numbers: , , , , , , , , , , , , , , , , , , , , , , , , 6

7 , , , , , , , , , , , , , , , , , , , , , , , , , , ; pp. all funds contained in Branch Banking and Trust Company accounts bearing the following numbers: , , , , , , , , , , , , , , , , , , , ; and qq. all funds contained in Sandy Spring Bank accounts bearing the following numbers: , , , Substitute Assets 3. If, as a result of any act or omission of the defendants, any proceeds subject to forfeiture: 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 of the court; 7

8 d. has been substantially diminished in value; or e. has been commingled with other property that cannot be subdivided without difficulty; it is the intent of the United States, pursuant to Title 18, United States Code, Sections 982, to seek forfeiture of any other property of said defendants up to but not exceeding $3,500, U.S.C. 2461(c) 18 U.S.C. 981(a)(1)(C) 21 U.S.C. 853(p) A TRUE BILL: Rod J. Rosenstein United States Attorney Foreperson Date: October,