Stipulation of Facts — No. 1:24-cr-00179 (Dkt. 36-1, D. Md.)

Summary

A Stipulation of Facts, Document 36-1 in Case 1:24-cr-00179-GLR, filed April 30, 2025, naming the Defendant, Bohrer Harris, and stating that all events took place in the District of Maryland. The parties stipulate that, if the case had proceeded to trial, the Government's office would have proven the listed facts beyond a reasonable doubt. The stipulated facts describe Baltimore Police Department officers responding on February 1, 2024 to a call about a suspected breaking and entering, the Defendant's arrest for fourth degree burglary, and a handgun found on the Defendant. They also state a prior conviction for a crime punishable by imprisonment for a term exceeding one year and cite 18 U.S.C. § 921(a)(3) for the definition of a firearm.

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Case 1:24-cr-00179-GLR Document 36-1 Filed 04/30/25 Page1of2

STIPULATION OF FACTS
The undersigned parties stipulate and agree that if this case had proceeded to trial, this
Office would have proven the following facts beyond a reasonable doubt. The undersigned parties
also stipulate and agree that the following facts do not encompass all of the evidence that would
have been presented had this matter proceeded to trial.

On February 1, 2024. at around 12:52 p.m., Baltimore Police Department (“BPD”) officers
responded to a call for service at 3412 Esther Place in reference to a suspected breaking and
entering. Officers met with the owner upon arrival who explained that she received a call from a
concerned neighbor that there were squatters occupying the property. The owner noticed that the
basement window of the home had been shattered and boarded up with plywood from the inside.
The owner gave the officers the keys to her property and asked them to clear the home.

Officers announced themselves before using the owner’s keys to enter. One officer
stationed at the back of the house stopped the Defendant, Bohrer Harris, at the back door. While
securing the residence, officers found one other male suspect (Individual |) inside the home. The
Defendant and Individual | were placed under arrest for fourth degree burglary.

Officers searched the Defendant incident to arrest and found a black SCCY CPX-1 handgun
bearing serial number 096564 inside the Defendant's pant leg. The firearm was loaded with
approximately eleven rounds of 9mm ammunition.

The firearm was test-fired and found to be operable, thereby meeting the definition of a
firearm pursuant to 18 U.S.C. § 921(a)(3). The ammunition also meets the definition of
ammunition pursuant to 18 U.S.C. § 921(a)(17).

Prior to possessing the firearm on February |, 2024, Harris had been convicted of a crime
punishable by imprisonment for a term exceeding one year. his civil rights had not been restored,
and he had knowledge of this status when he possessed the firearm and ammunition. The
Defendant agrees that he knowingly possessed the firearm and ammunition.

The above-listed firearm and ammunition affected interstate commerce. as they were
manufactured outside of the State of Maryland.

All the above-described events took place in the District of Maryland.

Jacpb Gordin Wi
Special Assistant U.S. Attorney

SO STIPULATED:

Rev. August 2018
10


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