Indictment — No. 4:22-cr-00471 (Dkt. 2, E.D. Mo.)

Summary

An indictment filed August 24, 2022 as Doc. #2 in United States v. Gabriel J. Vamboi, No. 4:22-CR-00471-HEA/JMB (Case 4:22-cr-00471-HEA-JMB), in the U.S. District Court for the Eastern District of Missouri, Eastern Division. Count I charges possession with intent to distribute a mixture or substance containing fentanyl, a Schedule II controlled substance, on July 12, 2022. Count II charges possession of a firearm by a person previously convicted of a crime punishable by more than a year of imprisonment on the same date. A forfeiture allegation lists $1,970.00 in United States currency and a pistol seized on July 12, 2022.

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Case: 4:22-cr-00471-HEA-JMB Doc. #: 2 Filed: 08/24/22 Page: 1 of 3 PageID #: 6

                              UNITED STATES DISTRICT COURT                                     FILED
                              EASTERN DISTRICT OF MISSOURI
                                    EASTERN DIVISION                                         AUG 2 4 2022
                                                                                            U S OISiRICT COURT
                                                                                          EASTERN o1s1R1cr Or MO
UNITED STATES OF AMERICA,                      )                                                 ST. LOUIS
                                               )
                       Plaintiff,              )
                                               )
               V.                              )       No.
                                               )
GABRIEL J. V AMBOI,                            )          4:22-CR-00471-HEA/JMB
                                               )
                       Defendant.              )
                                               )

                                          INDICTMENT

       The Grand Jury charges that:

                                             COUNT!

       On July 12, 2022, in St. Louis County, State of Missouri, within the Eastern District of

Missouri, the defendant GABRIEL J. VAMBOI did knowingly and intentionally possess with

intent to distribute to another person a mixture or substance containing a detectable amount of

fentanyl, a Schedule II controlled substance, in violation of Title 21, United States Code, Section

841 (a)(l) and punishable under T_itle 21, United States Code, Section 841 (b )(1 )(C).

                                            COUNT II

       The Grand Jury further charges that:

       On July 12, 2022, in St. Louis County, State of Missouri in the Eastern District of Missouri,

GABRIEL J. VAMBOI, the defendant herein, knowing he had been convicted of a crime

punishable by imprisonment for a term exceeding one year, did knowingly possess a firearm, a FN

FNS-9 9mm semiautomatic pistol, which traveled in interstate or foreign commerce during or prior

to being in defendant's possession.
Case: 4:22-cr-00471-HEA-JMB Doc. #: 2 Filed: 08/24/22 Page: 2 of 3 PageID #: 7

          In violation of Title 18, United States Code, Section 922(g)(l ).

                                       FORFEITURE ALLEGATION

      The Grand Jury further finds· by probable cause that:

          1.        Pursuant to Title 21, United States Code, Section 853(a), upon conviction of an

offense in violation of Title 21 , United States Code, Sections 841(a)(l) as set forth in Count I of

this indictment, the defendants, GABRJ;EL J. VAMBOI, shall forfeit to the United States of

America any property, constituting, or derived from, any proceeds the defendants obtained,

directly or indirectly, as a result of such violation/sand any property used, or intended to be used,

in any manner or part to commit or to facilitate the commission of such violations.

     2.        Subject to forfeiture upon a conviction of Count I is a sum of money equal to the total

property constituting, or derived from, any proceeds obtained directly or indirectly as a result of

such violations.

     3.        The specific property subject to forfeiture includes, but is not limited to, the following:

               a.        bne thousand, nine-hundred and seventy dollars ($1,970.00) in United States

Currency located and seized by law enforcement from GABRIEL J. VAMBOI on July 12, 2022.

               b.        A FN FNS-9 9mm semi-automatic pistol, seral number GKU0114997, located

and seized by law enforcement from GABRIEL J. VAMBOI on July 12, 2022.

     4.        If any of the property described above, as a result of any act or omission of the

defendant:

                    a.        cannot be located upon the exercise of due diligence;

                    b.       has been transferred or sold to, or deposited with, a third party;

                    c.       has been placed beyond the jurisdiction of the court;

                    d.       has been substantially diminished in value; or
 Case: 4:22-cr-00471-HEA-JMB Doc. #: 2 Filed: 08/24/22 Page: 3 of 3 PageID #: 8

               e.      has been commingled with other property which cannot be divided without

                       difficulty,

the United States of America will be entitled to the forfeiture of substitute property pursuant to 21

U.S .C. § 853(p).

                                                      A TRUE BILL.




                                                      FOREPERSON

SAYLER A. FLEMING
United States Attorney




JOHN R. MANTOV ANI #50867MO
Assistant United States Attorney


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