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Case 4:12-cr-00155-RAS-DDB Document 40 Filed 06/03/13 Page 1 of 3 PageID #: 219

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS

SHERMAN DIVISION

UNITED STATES OF AMERICA

v.

ANSON CHI

§
§
§
§
§

NO. 4:12CR155
Judge Schell

ELEMENTS OF THE OFFENSE

Count One

26 U.S.C. § 5861(d) makes it a crime for anyone to knowingly possess certain kinds

of unregistered firearms such as destructive devices manufactured through the use of

chemicals and a combination of parts intended for use in converting a readily assembled

explosive. For the defendant to be found guilty of this crime, the government must prove

each of the following elements beyond a reasonable doubt:

First: That the defendant knowingly possessed a firearm.

Second: That the firearm was a destructive device manufactured through the use of
chemicals and a combination of parts intended for use in converting a readily
assembled explosive.

Third: That the defendant knew of the characteristics of the firearm, that is, that it
was a destructive device manufactured through the use of chemicals and a
combination of parts intended for use in converting a readily assembled explosive.

Fourth: That the firearm was and could readily have been put in operating
condition.

Fifth: That the firearm was not registered to the defendant in the National Firearms
Registration and Transfer Record. It does not matter whether the defendant knew
that the firearm was not registered or had to be registered.

ELEMENTS OF THE OFFENSE

Case 4:12-cr-00155-RAS-DDB Document 40 Filed 06/03/13 Page 2 of 3 PageID #: 220

Count Two

18 U.S.C. § 844(i) makes it a crime for anyone to attempt to maliciously damage

or destroy by fire or explosive any building, vehicle, or any other real or personal property

used in interstate or foreign commerce or affecting interstate or foreign commerce. For

the defendant to be found guilty of this crime, the government must prove each of the

following elements beyond a reasonable doubt:

First: That the defendant maliciously attempted to damage or destroy an Atmos
natural gas pipeline, described in the indictment, by means of an explosive;

Second: That the defendant acted intentionally or with deliberate disregard of the
likelihood that damage or injury would result from his acts; and

Third: That the Atmos natural gas pipeline that the defendant attempted to damage
or destroy was used in activity affecting foreign or interstate commerce.

Respectfully submitted,

JOHN M. BALES
United States Attorney

/s/
M. Andrew Stover
Assistant United States Attorney
Texas Bar No. 19349300
101 East Park Boulevard, Suite 500
Plano, Texas 75074
Tel: (972) 509-1201
Fax: (972) 509-1209
[email protected]

ELEMENTS OF THE OFFENSE

Case 4:12-cr-00155-RAS-DDB Document 40 Filed 06/03/13 Page 3 of 3 PageID #: 221

Certificate of Service



I hereby certify a true and correct copy of the foregoing was served by electronic

filing by CM/ECF to Robert Arrambide, on this the 3rd day of June, 2013.

/s/
M. Andrew Stover