Case 8:10-cr-00637-PJM Document 143 Filed 05/24/11 Page 1 of 4

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IN THE UNITED STATES DISTRICT CO~~T

FOR THE DISTRICT OF MARYLAND~li,1 ~AY2'-1 P 3: it b

UNITED STATES OF AMERICA *

*
v. * CRIMINAL NO. PJM~37 .
*
RICHARD DELABRER, * (Conspiracy to Interfere with
* Commerce by Extortion Under Color of
Defendant * Official Right, 18 U.S.c. ~ 1951(a);
* Possession of a Firearm in Furtherance
* of a Crime of Violence, 18 U.S.c. 924( c»
*
*******
SUPERSEDING INFORMATION SOLELY AS TO
DEFENDANT RICHARD DELABRER

COUNT ONE
(Hobbs Act Conspiracy)

The United States Attorney for the District of Maryland charges that:

Introduction

At all times relevant to this Information:

A. The Defendant and His Coconspirators

1. Defendant RICHARD DELABRER, a resident of Maryland, was an active duty

Sergeant with the Prince George's County Police Department ("PGCPD").

2. Amrik Singh Melhi and Ravinder Kaur Melhi, residents of Maryland, had

ownership interests in numerous liquor stores in Maryland.

3. Amir Miljkovic, a resident of Maryland, owned an auto glass store located in

College Park, Maryland.

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

January 2010, in the District of Maryland and elsewhere, the defendant,

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:

1. Paragraphs 1 through 7 of Count One are incorporated here.

2. On or about September 6, 2009, in the District of Maryland and elsewhere, the

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)

Date: May _' 2011