EA L E DTED STATES DISTRICT COURT 

ESTERN DISTRICT OF TEXAS 

SAN ANTONIO DIVISION 

UNITED STATES OF AMERICA, § 

§ 

Plaintiff, § § VS. § 

§ 

OMAR RICHARDSON, § 

§ 

Defendant. § 

§ 

§ 

CRIMINAL NO.: 

zIit1 

MAR 0 4 O2U 

CLERU DISTRICT COURT 

WES11 DISTRICT OF TEXAS 

DEPUTY CLEf 

INDICTMENT 

Ct 1: 21 U.S.C. § 841(a)(1) & (b)(l)(D) 

Possession with Intent to Distribute 

Marihuana 

Ct 2: 18 U.S.C. § 922(g)(1) 

Felon in Possession of a Firearm 

Ct 3: 18 U.S.C. § 924(c) 

Possession of a Firearm in Furtherance of a 

Drug Trafficking Crime 

THE GRANDJURYCHARGES: SA2 0 CR0125 FB 

COUNT ONE 

121 U.S.C. § 841(a)(1) & (b)(1)(D)] 

On or about August 29, 2019, in the Western District of Texas, Defendant, 

OMAR RICHARDSON, 

did knowingly, intentionally, and unlawfully, possess with intent to distribute a controlled 

substance, which offense involved less than 50 kilograms of marihuana, contrary to Title 21, 

United States Code, Sections 841(a)(l) & (b)(1)(D). 

COUNT TWO 

[18 U.S.C. § 922(g)(1)] 

On or about August 29, 2019, in the Western District of Texas, Defendant, 

OMAR RICHARDSON, 

knowing he had previously been convicted of a crime punishable by imprisonment for a term 

exceeding one year, knowingly possessed a firearm, to wit: a Norinco, model AK47S, 7.62 caliber 

rifle, serial number 6907, and said firearm had been shipped and transported in interstate and 

foreign commerce, in violation of Title 18, United States Code, Sections 922(g)(1) and 924(a)(2). 

Case 5:20-cr-00125-FB Document 3 Filed 03/04/20 Page 1 of 3
COUNT THREE 

[18 U.S.C. § 924(c)] 

On or about August 29, 2019, in the Western District of Texas, Defendant, 

OMAR RICHARDSON, 

did knowingly use and carry a firearm, to wit: a Norinco, model AK47S, 7.62 caliber rifle, serial 

number 6907, during and in relation to, and did possess said firearm in furtherance of, a drug 

trafficking crime that may be prosecuted in a court of the United States, that is Possession with 

Intent to Distribute Marihuana, in violation of Title 21, United States Code, Sections 841(a)(1) & 

(b)(1)(D), as further described in Count One, in violation of Title 18, United States Code, Section 

924(c). 

NOTICE OF UNITED STATES OF AMERICA'S DEMAND FOR FORFEITURE 

[See Fed. R. Crim. P. 32.21 

This Notice of Demand for Forfeiture includes, but is not limited to, the property listed in 

Paragraph III below. 

I. 

Drug Violations and Forfeiture Statutes 

[Title 21 U.S.C. § 841(a)(1) and (b)(1)(D) subject to forfeiture 

pursuant to Title 21 U.S.C. § 853(a)(1) and (2)] 

As a result of the criminal violations set forth in Count One the United States of America 

gives notice to defendant of its intent to seek the forfeiture of the property described below upon 

conviction pursuant to FED. R. CRIM. P. 32.2 and 21 U.S.C. § 853(a)(1) and (2), which states: 

Title 21 U.S.C. § 853. Criminal forfeitures 

(a) Property subject to criminal forfeitures. 

Any person convicted of a violation of this subchapter or subchapter II of this 

chapter punishable by imprisonment for more than one year shall forfeit to the 

United States, irrespective of any provision of State law.-- 

(1) any property constituting, or derived from, any proceeds the person 

obtained, directly or indirectly, as the result of such violation; 

Case 5:20-cr-00125-FB Document 3 Filed 03/04/20 Page 2 of 3
(2) any of the person's property used, or intended to be used, in any 

manner or part, to commit, or to facilitate the commission of, such 

violation;... 

II. 

Firearm Violations and Forfeiture Statutes 

[Title 18 U.S.C. § 922(g)(1) and 924(c), subject to forfeiture pursuant to Title 18 U.S.C. § 924(d)(1), made applicable to criminal forfeiture by Title 28 U.S.C. § 24611 

As a result of the criminal violations set forth in Counts Two and Three, the United States 

of America gives notice to the defendant of its intent to seek the forfeiture of the below described 

properties upon conviction and pursuant to Fed. R. Crim. P. 32.2 and Title 18 U.S.C. § 924(d)(l), 

made applicable to criminal forfeiture by Title 28 U.S.C. § 2461, which states: 

Title 18 U.S.C. § 924. Penalties 

(d)(l) Any firearm or ammunition involved in or used in any knowing 

violation of subsection. . . (g) . . . of section 922, or. . . section 924 

shall be subject to seizure and forfeiture . . . under the provisions of this 

chapter.... 

III. 

Properties 

1. Norinco, model AK47S, 7.62 caliber rifle, serial number 6907; and 

2. Any related ammunition and firearm accessories. 

A TRUE BILL 

FOIEPERSON OF THE AND JURY 

JOHN F. BASH 

UNITED STATES ATTORNEY 

BY: 

BRIAN NOWINSKI 

Assistant United States Aftorney 

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