IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

JUN 1 5 2023

CLERK, U.S. DIST ICT COU T

EASTERN DIST ICT OF TEXAS

UNITED STATES OF AMERICA §

v. §

§

§

TERRY O NEIL WILLIAMS, JR. §

No. 4:23-CRJudse

INDICTMENT

The United States Grand Jury Charges:

COUNT ONE

Violation: 18 U.S.C. § 922(a)(1)(A)

(Engaging in the Business Without

a License (Firearms))

Beginning in and around 2020 and continuing through May of 2023, in the Eastern

District of Texas and elsewhere, the defendant, TERRY O NEIL WILLIAMS, JR., not

being a licensed dealer of firearms within the meaning of Chapter 44, Title 18, United

States Code, did willfully engage in the business of dealing in firearms, in violation of 18

U.S.C. §§ 922(a)(1)(A), 923(a), and 924(a)(1)(D).

COUNT TWO

Violation: 18 U.S.C. § 922(a)(6)

(Acquire a Firearm from a Licensed

Dealer by False or Fictitious Statement)

On or about April 28, 2022, in the Eastern District of Texas, TERRY O’NEIL

WILLIAMS. JR., defendant, in connection with the acquisition of a firearm, to wit: a

Palmetto State Armory Dagger Compact, 9mm pistol bearing serial number FG05151

Case 4:23-cr-00149-SDJ-AGD Document 11 Filed 06/15/23 Page 1 of 5 PageID #: 33
and Glock Inc. Model 42, .380 caliber pistol bearing serial numberAGNV711, from

Mister Guns, a licensed dealer within the meaning of Chapter 44, Title 18, United States

Code, knowingly made a false and fictitious written statement that was intended and

likely to deceive Mister Guns as to a fact material to the lawfulness of such sale of the

said firearm to the defendant.

In violation of 18 U.S.C. §§ 922(a)(6) and 924(a)(2).

COUNT THREE

Violation: 18 U.S.C. § 922(g)(3)

(Possession of a Firearm by a

User of a Controlled Substance)

On or about March 13, 2023, in the Eastern District of Texas, TERRY O NEIE

WILLIAMS, JR. defendant, knowing that he was an unlawful user of a controlled

substance as defined in Title 21 United States Code, Section 802, did knowingly possess

a firearm, that is, a Glock Inc., Model 44, .22 caliber pistol, bearing serial number

ADUV508, said firearm having been shipped and transported in interstate and foreign

commerce.

In violation of 18 U.S.C. § 922(g)(3) and 924(a)(8).

NOTICE OF INTENTION TO SEEK CRIMINAL FORFEITURE

Criminal Forfeiture Pursuant to 18 U.S.C. § 924(d) and 28 U.S.C. § 2461(c).

As a result of committing the felony offense alleged in Count One of this

Indictment, defendant, TERRY O NEIL WILLIAMS, JR., shall forfeit to the United

Case 4:23-cr-00149-SDJ-AGD Document 11 Filed 06/15/23 Page 2 of 5 PageID #: 34
States, pursuant to 18 U.S.C. § 924(d), and 28 U.S.C § 2461(c), all firearms and

ammunition involved in the offense, including but not limited to the following:

1. a Maverick Arms, Model 88, 12-gauge shotgun bearing serial number

MV0925067

2. a Glock GMBH, Model 23, .40 caliber pistol bearing serial number BWWN484

3. a ROMARM/CUGIR, Model Micro Draco, ,762x 39 caliber pistol bearing

serial number 22PG-7210

4. a Taurus., Model PT111G2A, 9mm caliber pistol bearing serial number

ADA878834

5. a Glock GHMB, Model 19GEN5, 9mm caliber pistol bearing serial number

BNTZX718

6. a Glock GHMB, Model 30GEN4, 9mm caliber pistol bearing serial number

BPMF125

7. a Glock Inc., Model 23C, .40 caliber pistol bearing serial number ABKK664

8. an Aero Precision., Model XI5, .5.5 caliber rifle bearing serial number

X188771

9. a Glock GHMB, Model 23GEN5, .40 caliber pistol bearing serial number

BTEU143

10. a Glock GHMB, Model 43X, 9mm caliber pistol bearing serial number

BNAW278

11. a Smith & Wesson, Model M&P, 9mm caliber pistol bearing serial number

DWZ1333

Case 4:23-cr-00149-SDJ-AGD Document 11 Filed 06/15/23 Page 3 of 5 PageID #: 35
12. a Smith & Wesson, Model SD$0VE, .40 caliber pistol bearing serial number

FXB4506

DAMIEN M. DIGGS

UNITED STATES ATTORNEY

AL

MAUREEN SMITH

Assistant United States Attorney

Respectfully Submitted,

A TRUE BILL

GRAND JURY FOREPERSON

Date: < //5 J 

Case 4:23-cr-00149-SDJ-AGD Document 11 Filed 06/15/23 Page 4 of 5 PageID #: 36
IN THE UNITED STATES OF AMERICA

EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

UNITED STATES OF AMERICA §

v. §

§

§

TERRY O NEIE WILLIAMS, JR. §

No. 4:23-CR- W

Judge

NOTICE OF PENALTY

Count One

Violation: 18 U.S.C. § 922(a)(1)(A)

Penalty: Imprisonment of not more than five years, a fine not to

exceed $250,000, or both; a term of supervised release of not

more than three years.

Special Assessment: $ 100.00

Count Two

Violation: 18 U.S.C. §§ 922(a)(6) & 2

Penalty: Imprisonment of not more than ten (10) years, a fine not to

exceed $250,000, or both. A term of supervised release of

not more than three (3)

years.

Special Assessment: $100.00

Count Three

Violation: 18 U.S.C. § 922(g)(3)

Penalty: Imprisonment for not more than 10 years, a fine not to exceed

$250,000, or both, and a term of supervised release of not

more than three (3) years.

Special Assessment: $100.00

Case 4:23-cr-00149-SDJ-AGD Document 11 Filed 06/15/23 Page 5 of 5 PageID #: 37