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COUNT 1
(Interference with Interstate Commerce by Robbery)
1. At all times material to this Indictment, the Dollar Tree store located at 1646
Sycamore Street, Iowa City, Iowa, was engaged in the retail sale of consumer goods in interstate
2. On or about October 12, 2010, in the Southern District of Iowa, the defendant,
ANTHONY RENARD MARTIN, did unlawfully obstruct, delay and affect, and attempt to
obstruct, delay and affect, commerce as that term is defined in Title 18, United States Code,
Section 1951, and the movement of articles and commodities in such commerce, by robbery as
that term is defined in Title 18, United States Code, Section 1951, in that the defendant
ANTHONY RENARD MARTIN did unlawfully take and obtain personal property consisting of
over $1000 in United States currency from the person of and in the presence of another person,
against her will by means of actual and threatened force, violence, and fear of injury, immediate
and future, to her person and the persons of other employees of the Dollar Tree store.
Case 3:10-cr-00108-JEG -TJS Document 2 Filed 12/15/10 Page 2 of 3
COUNT 2
(Possession of a Firearm in Furtherance of a Crime of Violence)
ANTHONY RENARD MARTIN, did use and carry a firearm during and in relation to a crime of
violence which was a felony prosecutable in a court of the United States, that is, a violation of
Title 18, United States Code, Section 1951(a), as set forth in Count 1 of this Indictment, and did
possess a firearm in furtherance of said crime of violence, and, in the course of using, carrying
COUNT 3
(Felon in Possession of a Firearm and Ammunition)
for a term exceeding one year, did knowingly possess a firearm and ammunition, that is:
This is a violation of Title 18, United States Code, Sections 922(g)(l) and 924(e).
NOTICE OF FORFEITURE
realleged and incorporated by reference for the purpose of alleging forfeitures, pursuant to the
2. That upon conviction for the offense alleged in Counts 1, 2, and 3 of this
Indictment, the defendant, ANTHONY RENARD MARTIN, shall forfeit to the United States,
pursuant to Title 18, United States Code, Section 924(d), and Title 28, United States Code,
Section 2461(c), all firearms, magazines, and ammunition involved in the commission of said
offense, including, but not limited to, the firearm and ammunition identified in Count 3 of this
Indictment.
A TRUE BILL.
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FOREPERSON
Nicholas A. Klinefeldt
By: ,--"Is,---I _
John D. Keller