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Criminal Indictment — United States v. Dion Marquise Hayes (N.D. Ga., Dkt. 4, filed 03/10/20)

Summary

Criminal indictment in the Northern District of Georgia, Atlanta Division, against Dion Marquise Hayes. Count One charges that on or about November 8, 2019, the defendant, knowing of a previous conviction for at least one of the listed offenses (carjacking and felony firearms possession in Wayne County, Michigan, in or about 2011), each punishable by imprisonment for a term exceeding one year, knowingly possessed a Glock model 19x 9mm pistol in and affecting interstate and foreign commerce. The forfeiture provision states that the defendant shall forfeit to the United States all firearms and ammunition involved in and used in the commission of the offense.

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“Criminal Indictment — United States v. Dion Marquise Hayes (N.D. Ga., Dkt. 4, filed 03/10/20).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-20-cr-00123-dkt-4-n-d-ga-50e1e341bb/, SHA-256 3a810df42beec75f1440260073cb89f7fe8f3856cf3cf84d18cad123496a9238.

Full text

               Case 1:20-cr-00123-WMR-LTW Document 4 Filed 03/10/20 Page 1 of 3
‘~.   q\ C                                                                      FILED IN CHAMBERS
                                                                                  U.5.D.C. Atlanta


                                                                                 MAR 1 0 2020
                                                                          JAMES N. HATTEN Clerk
                           IN THE UNITED STATES DISTRICT COURTB~.
                          FOR THE NORTHERN DISTRICT OF GEORGIA
                                    ATLANTA DIVISION



             UNITED STATES OF AMERICA
                                                          Criminal Indictment

             DION MARQUISE HAYES                          No.   1.      a cP
                                                                           —           —         12
        THE GRAND JURY CHARGES THAT:

                                             Count One

             On or about November 8, 2019, in the Northern District of Georgia, the
        defendant, DION MARQUISE HAYES, knowing that he had been previously
        convicted of at least one of the following offenses, that is:

             1. Carjacking in the State of Michigan, Third Judicial Circuit, Wayne County,
                Michigan, in or about 2011; and
             2. Felony Firearms Possession in the State of Michigan, Third Judicial Circuit,

                Wayne County, Michigan, in or about 2011,
        each of which was a crime punishable by imprisonment for a term exceeding one
        year, did knowingly possess a firearm, that is, a Glock model 19x 9mm pistol,

        said possession being in and affecting interstate and foreign commerce, all in
        violation of Title 18, United States Code, Section 922(g)(l).

                                        Forfeiture Provision
             Upon conviction of the offense alleged in this Indictment, the defendant,
        DION MARQUISE HAYES, shall forfeit to the United States, pursuant to Title 18,
      Case 1:20-cr-00123-WMR-LTW Document 4 Filed 03/10/20 Page 2 of 3




United States Code, Section 924(d), and Title 28, United States Code, Section
2461, all firearms and ammunition involved in and used in the commission of the
offense.

   If, as a result of any act or omission of the defendant, any property subject to
forfeiture:
       a. cannot be located upon the exercise of due diligence;

       b. has been transferred or sold to, or deposited with, a third person;
       c. has been placed beyond the jurisdiction of the Court;
       d. has been substantially diminished in value; or

       e. has been commingled with other property which cannot be subdivided
           without undue complexity or difficulty;

the United States intends, pursuant to Title 21, United States Code, Section

853(p), as incorporated by Title 28, United States Code, Section 2461(c), to seek




                                          2
     Case 1:20-cr-00123-WMR-LTW Document 4 Filed 03/10/20 Page 3 of 3




forfeiture of any other property of said defendant up to the value of the above
forfeitable property
                                         A                                  BILL

                                                  _________             £
                                                    FOREPERSON
BYUNG    J. PAK
  United States Attorney




                HA NA N
  Assistant United States Attorney
Georgia Bar No. 623388


600 U.S. Courthouse
75 Ted Turner Drive, SW
Atlanta, GA 30303
404-581-6000; Fax: 404-581-6181

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