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Case 3:10-cr-00108-JEG -TJS Document 2 Filed 12/15/10 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF lOWA

Ul'JITED STATES OF AMERICA, )


) Criminal No. 3:10-cr-108
Plaintiff, )
) INDICTMENT
v. ) T. 18 U.S.C. § 1951(a)
) T. 18 U.S.C. § 924(c)(1)(A)
ANTHONY RENARD MARTIN, ) T. 18 U.S.C. § 924(e)
) T. 18 U.S.C. § 922(g)(l)
Defendant. ) T. 18 U.S.c. § 924(d)
) T. 28 U.S.C. § 2461(c)

THE GRAND JURY CHARGES:

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

commerce, and was engaged in an industry which affects interstate commerce.

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

This is a violation of Title 18, United States Code, Section 1951.

COUNT 2
(Possession of a Firearm in Furtherance of a Crime of Violence)

On or about October 12,2010, in the Southern District ofIowa, the defendant,

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

and possessing the firearm, the defendant brandished the firearm.

This is a violation of Title 18, United States Code, Section 924(c)(l)(A).

COUNT 3
(Felon in Possession of a Firearm and Ammunition)

On or about October 12,2010, in the Southern District ofIowa, the defendant,

ANTHONY RENARD MARTIN, having been convicted of a crime punishable by imprisonment

for a term exceeding one year, did knowingly possess a firearm and ammunition, that is:

(a) a Silver Rossi .38 Special revolver; and

(b) five .38 caliber bullets and cartridges,

said firearm and ammunition possessed in and affecting commerce.

This is a violation of Title 18, United States Code, Sections 922(g)(l) and 924(e).

Case 3:10-cr-00108-JEG -TJS Document 2 Filed 12/15/10 Page 3 of 3

NOTICE OF FORFEITURE

1. The allegations contained in Counts 1, 2 and 3 of this Indictment are hereby

realleged and incorporated by reference for the purpose of alleging forfeitures, pursuant to the

provisions of Title 18, United States Code, Section 924(d).

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.

lsi
FOREPERSON

Nicholas A. Klinefeldt

United States Attorney

By: ,--"Is,---I _

John D. Keller

Assistant United States Attorney

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