Richard Delabrer Information
Richard Delabrer Information
Richard Delabrer Information
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COUNT ONE
(Hobbs Act Conspiracy)
The United States Attorney for the District of Maryland charges that:
Introduction
2. Amrik Singh Melhi and Ravinder Kaur Melhi, residents of Maryland, had
4. Chong Chin Kim, a resident of Maryland, was an active duty Corporal with the
PGCPD.
Case 8:10-cr-00637-PJM Document 143 Filed 05/24/11 Page 2 of 4
5. 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 and its state government
directly controlled the sale of liquor in Virginia. The United States Department of the Treasury
imposed a federal excise tax of $1.0 1 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
RICHARD DELABRER,
did knowingly, willfully, and unlawfully combine, conspire, confederate and agree with Amrik
Singh Melhi, Ravinder Kaur Melhi, Amir Miljkovic, Chong Chin Kim, Chun Chen, a/k/a
Eddy Chen, Jose Moreno, and others known and unknown to the United States, to obstruct,
delay, and affect commerce, and the movement of articles and commodities in commerce, by
extortion in 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
Amrik Simgh Melhi and others would provide things of value, including money, to public
officials, including defendant RICHARD DELABRER, in return for using his official authority
and influence to ensure the safe transport and distribution of untaxed cigarettes and alcohol in
2
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Case 8:10-cr-00637-PJM Document 143 Filed 05/24/11 Page 3 of 4
Maryland and Virginia and official acts involving the enforcement of state and federal laws by
the PGCPD.
18 U.S.C. S 1951(a)
3
Case 8:10-cr-00637-PJM Document 143 Filed 05/24/11 Page 4 of 4
COUNT TWO
(Possession of a Firearm in Furtherance of a Crime of Violence)
The United States Attorney for the District of Maryland further charges:
defendant,
RICHARD DELABRER,
did knowingly possess a firearm, to wit, a Smith and Wesson .40 caliber semi-automatic handgun,
in furtherance of a crime of violence for which he may be prosecuted in a court of the United States,
to wit, conspiracy to commit extortion under color of official right, in violation of Title 18, United
States Code, Section 1951, as set forth in Count One of this Superseding Information and
incorporated here.
18 U.S.c. S 924(c)