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ELECTRONICALLY FILED - 2024 May 06 2:19 PM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002372
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
COUNTY OF CHARLESTON ) FOR THE NINTH JUDICIAL CIRCUIT
SOLICITOR, ) CASE NO.: 2024-CP-10-
NINTH JUDICIAL CIRCUIT, )
Plaintiff, )
vs. )
)
1.29 grams of Cocaine Base, 2.7 grams ) SUMMONS FOR FORFEITURE
of Marijuana, one Apple iPhone, One ) NON-JURY
Thousand Five Hundred Ninety-Five )
Dollars Zero Cents ($1,595.00) in US )
Currency, )
)
Defendant. )
)
)
)
)
ELECTRONICALLY FILED - 2024 May 06 2:19 PM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002372
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
COUNTY OF CHARLESTON ) FOR THE NINTH JUDICIAL CIRCUIT
SOLICITOR, ) CASE NO.: 2024-CP-10-
NINTH JUDICIAL CIRCUIT, )
Plaintiff, )
vs. )
)
1.29 grams of Cocaine Base, 2.7 grams ) SUMMONS FOR FORFEITURE
of Marijuana, one Apple iPhone, One ) NON-JURY
Thousand Five Hundred Ninety-Five )
Dollars Zero Cents ($1,595.00) in US )
Currency, )
)
Defendant. )
)
)
)
)
TO: Deshaun L. Williams
78 Ashley Hall Plantation Rd. Apt. F-36
Charleston, SC 29407
YOU ARE HEREBY SUMMONED and required to answer the Complaint
for Forfeiture in this proceeding, a copy of which is hereby served upon you, and
to serve a copy of your filed Answer to the Complaint for Forfeiture on the
undersigned attorney at 180 Lockwood Blvd., Charleston, South Carolina, within
thirty (30) days after service hereof, exclusive of the date of such service, and, if
you fail to Answer the Complaint for Forfeiture within the time aforesaid,
judgment by default will be entered against you for the relief demanded in the
Complaint and Forfeiture of the subject property will be ordered.
Electronically signed on 5/6/2024
/s Steve Ruemelin, Esquire
Charleston Police Department
180 Lockwood Blvd.
Charleston, SC 29403
(843) 720-3787
Attorney for Plaintiff
Charleston, South Carolina
ELECTRONICALLY FILED - 2024 May 06 2:19 PM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002372
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
COUNTY OF CHARLESTON ) FOR THE NINTH JUDICIAL CIRCUIT
SOLICITOR, ) CASE NO.: 2024-CP-10-
NINTH JUDICIAL CIRCUIT, )
Plaintiff, )
vs. )
)
1.29 grams of Cocaine Base, 2.7 grams of ) COMPLAINT FOR FORFEITURE
Marijuana, one Apple iPhone, One ) NON-JURY
Thousand Five Hundred Ninety-Five )
Dollars Zero Cents ($1,595.00) in US )
Currency, )
)
Defendant. )
)
)
)
)
Plaintiff would respectfully show the Court:
I.
Plaintiff is the Circuit Solicitor of the Ninth Judicial Circuit of the State of
South Carolina and is hereby authorized pursuant to South Carolina Code Ann.
§44-53-520 et seq. to initiate this Complaint for the Forfeiture of Defendant
property. Your undersigned counsel has been designated to pursue civil
forfeiture actions pursuant to §44-53-520 et seq which involve the City of
Charleston Police Department.
II.
Defendant property is approximately 1.29 grams of Cocaine Base, 2.7
grams of Marijuana, one Apple iPhone, One Thousand Five Hundred Ninety-Five
Dollars Zero Cents ($1,595.00) in US Currency.
ELECTRONICALLY FILED - 2024 May 06 2:19 PM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002372
III.
Defendant property was seized on or about 5/1/2024 at approximately
1410 hours, when CPD Officers Bunch and Fiedler were assisting CPD Special
Investigations Unit in reference to ongoing complaints and violations for narcotics
at Aiken St. & Columbus St. (Mall Park) in the city of Charleston. During the
course of the investigation officers observed Mr. Deshaun Williams conduct a
hand-to-hand transaction with an individual and conducted a person stop on him.
Officers located and seized the following items from Mr Williams: 1.29 grams of
Cocaine Base, 2.7 grams of Marijuana, one Apple iPhone, One Thousand Five
Hundred Ninety-Five Dollars Zero Cents ($1,595.00) in US Currency. Mr.
Williams was placed under arrest and charged with Possession with Intent to
Distribute Cocaine Base and PWID Cocaine base in Close Proximity to a School/
Park. Mr. Deshaun Williams has numerous documented law enforcement
encounters in the CPD Records Management System while at Mall Park, which
shows his knowledge of Mall Park being a public park. There are also several
signs on the fence surrounding the park labeled, "Philip Simmons Park at Mall
Playground", and "Welcome to Mall Park".
IV.
Defendant property falls into one or more of the following categories:
(1) all controlled substances which have been
manufactured, distributed, dispensed, or acquired in
violation of this article;
(2) all raw materials, products, and equipment of any kind
which are used, or which have been positioned for
ELECTRONICALLY FILED - 2024 May 06 2:19 PM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002372
use, in manufacturing, producing, compounding,
processing, delivering, importing, or exporting any
controlled substance in violation of this article;
(3) all property which is used, or which has been
positioned for use, as a container for property
described in items (1) or (2);
(4) all property, both real and personal , which in any
manner is knowingly used to facilitate production,
manufacturing, distribution, sale, importation,
exportation, or trafficking in various controlled
substances as defined in this article;
(5) all books, records, and research products and
materials, including formulas, microfilm, tapes, and
data which are used, or which have been positioned
for use, in violation of this article;
(6) all conveyances including, but not limited to, trailers,
aircraft, motor vehicles, and water going vessels
which are used or intended for use unlawfully to
conceal, contain, or transport or facilitate the unlawful
concealment, possession, containment, manufacture,
or transportation of controlled substances and their
compounds, except as otherwise provided, must be
forfeited to the State. No motor vehicle may be
forfeited to the State under this item unless it is used,
intended for use, or in any manner facilitates a
violation of Section 44-53-370(a), involving at least
one pound or more of marijuana, one pound or more
of hashish, more than four grains of opium, more than
two grains of heroin, more than four grains of
morphine, more than ten grains of cocaine, more than
fifty micrograms of lysergic acid diethylamide (LSD) or
its compounds, more than ten grains of crack, or more
than one gram of ice or crank, as defined in Section
44-53-110, or unless it is used, intended for use, or in
any manner facilitates a violation of Section 44-53-
370(e);
(7) all property including, but not limited to, monies,
negotiable instruments, securities, or other things of
value furnished or intended to be furnished by any
person in exchange for a controlled substance, and all
ELECTRONICALLY FILED - 2024 May 06 2:19 PM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002372
proceeds including, but not limited to, monies, and
real and personal property traceable to any exchange;
(8) all monies seized in close proximity to forfeitable
controlled substances, drug manufacturing, or
distributing paraphernalia, or in close proximity to
forfeitable records of the importation, manufacturing,
or distribution of controlled substances and all monies
seized at the time of arrest or search involving
violation of this article. If the person from whom the
monies where taken can establish to the satisfaction
of a court of competent jurisdiction that the monies
seized are not products of illegal acts, the monies
must be returned pursuant to court order.
V.
At the date of filing this Complaint for Forfeiture, no other persons are
known to the Plaintiff to have interest in the Defendant property.
WHEREFORE, Plaintiff prays that the Defendant property be declared forfeited
to the State of South Carolina pursuant to S.C. Code Ann. §44-53-520, et seq.
and that it be distributed as provided in that article.
Electronically signed on 5/6/2024
s/Steve Ruemelin, Esquire
Charleston Police Department
180 Lockwood Blvd.
Charleston, SC 29403
(843) 720-3787
Attorney for Plaintiff
Charleston,
South Carolina
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ELECTRONICALLY FILED - 2024 May 06 2:19 PM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002372 STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS COUNTY OF CHARLESTON ) FOR THE NINTH JUDICIAL CIRCUIT SOLICITOR, ) CASE NO.: 2024-CP-10- NINTH JUDICIAL CIRCUIT, ) Plaintiff, ) vs. ) ) 1.29 grams of Cocaine Base, 2.7 grams ) SUMMONS FOR FORFEITURE of Marijuana, one Apple iPhone, One ) NON-JURY Thousand Five Hundred Ninety-Five ) Dollars Zero Cents ($1,595.00) in US ) Currency, ) ) Defendant. ) ) ) ) ) ELECTRONICALLY FILED - 2024 May 06 2:19 PM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002372 STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS COUNTY OF CHARLESTON ) FOR THE NINTH JUDICIAL CIRCUIT SOLICITOR, ) CASE NO.: 2024-CP-10- NINTH JUDICIAL CIRCUIT, ) Plaintiff, ) vs. ) ) 1.29 grams of Cocaine Base, 2.7 grams ) SUMMONS FOR FORFEITURE of Marijuana, one Apple iPhone, One ) NON-JURY Thousand Five Hundred Ninety-Five ) Dollars Zero Cents ($1,595.00) in US ) Currency, ) ) Defendant. ) ) ) ) ) TO: Deshaun L. Williams 78 Ashley Hall Plantation Rd. Apt. F-36 Charleston, SC 29407 YOU ARE HEREBY SUMMONED and required to answer the Complaint for Forfeiture in this proceeding, a copy of which is hereby served upon you, and to serve a copy of your filed Answer to the Complaint for Forfeiture on the undersigned attorney at 180 Lockwood Blvd., Charleston, South Carolina, within thirty (30) days after service hereof, exclusive of the date of such service, and, if you fail to Answer the Complaint for Forfeiture within the time aforesaid, judgment by default will be entered against you for the relief demanded in the Complaint and Forfeiture of the subject property will be ordered. Electronically signed on 5/6/2024 /s Steve Ruemelin, Esquire Charleston Police Department 180 Lockwood Blvd. Charleston, SC 29403 (843) 720-3787 Attorney for Plaintiff Charleston, South Carolina ELECTRONICALLY FILED - 2024 May 06 2:19 PM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002372 STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS COUNTY OF CHARLESTON ) FOR THE NINTH JUDICIAL CIRCUIT SOLICITOR, ) CASE NO.: 2024-CP-10- NINTH JUDICIAL CIRCUIT, ) Plaintiff, ) vs. ) ) 1.29 grams of Cocaine Base, 2.7 grams of ) COMPLAINT FOR FORFEITURE Marijuana, one Apple iPhone, One ) NON-JURY Thousand Five Hundred Ninety-Five ) Dollars Zero Cents ($1,595.00) in US ) Currency, ) ) Defendant. ) ) ) ) ) Plaintiff would respectfully show the Court: I. Plaintiff is the Circuit Solicitor of the Ninth Judicial Circuit of the State of South Carolina and is hereby authorized pursuant to South Carolina Code Ann. §44-53-520 et seq. to initiate this Complaint for the Forfeiture of Defendant property. Your undersigned counsel has been designated to pursue civil forfeiture actions pursuant to §44-53-520 et seq which involve the City of Charleston Police Department. II. Defendant property is approximately 1.29 grams of Cocaine Base, 2.7 grams of Marijuana, one Apple iPhone, One Thousand Five Hundred Ninety-Five Dollars Zero Cents ($1,595.00) in US Currency. ELECTRONICALLY FILED - 2024 May 06 2:19 PM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002372 III. Defendant property was seized on or about 5/1/2024 at approximately 1410 hours, when CPD Officers Bunch and Fiedler were assisting CPD Special Investigations Unit in reference to ongoing complaints and violations for narcotics at Aiken St. & Columbus St. (Mall Park) in the city of Charleston. During the course of the investigation officers observed Mr. Deshaun Williams conduct a hand-to-hand transaction with an individual and conducted a person stop on him. Officers located and seized the following items from Mr Williams: 1.29 grams of Cocaine Base, 2.7 grams of Marijuana, one Apple iPhone, One Thousand Five Hundred Ninety-Five Dollars Zero Cents ($1,595.00) in US Currency. Mr. Williams was placed under arrest and charged with Possession with Intent to Distribute Cocaine Base and PWID Cocaine base in Close Proximity to a School/ Park. Mr. Deshaun Williams has numerous documented law enforcement encounters in the CPD Records Management System while at Mall Park, which shows his knowledge of Mall Park being a public park. There are also several signs on the fence surrounding the park labeled, "Philip Simmons Park at Mall Playground", and "Welcome to Mall Park". IV. Defendant property falls into one or more of the following categories: (1) all controlled substances which have been manufactured, distributed, dispensed, or acquired in violation of this article; (2) all raw materials, products, and equipment of any kind which are used, or which have been positioned for ELECTRONICALLY FILED - 2024 May 06 2:19 PM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002372 use, in manufacturing, producing, compounding, processing, delivering, importing, or exporting any controlled substance in violation of this article; (3) all property which is used, or which has been positioned for use, as a container for property described in items (1) or (2); (4) all property, both real and personal , which in any manner is knowingly used to facilitate production, manufacturing, distribution, sale, importation, exportation, or trafficking in various controlled substances as defined in this article; (5) all books, records, and research products and materials, including formulas, microfilm, tapes, and data which are used, or which have been positioned for use, in violation of this article; (6) all conveyances including, but not limited to, trailers, aircraft, motor vehicles, and water going vessels which are used or intended for use unlawfully to conceal, contain, or transport or facilitate the unlawful concealment, possession, containment, manufacture, or transportation of controlled substances and their compounds, except as otherwise provided, must be forfeited to the State. No motor vehicle may be forfeited to the State under this item unless it is used, intended for use, or in any manner facilitates a violation of Section 44-53-370(a), involving at least one pound or more of marijuana, one pound or more of hashish, more than four grains of opium, more than two grains of heroin, more than four grains of morphine, more than ten grains of cocaine, more than fifty micrograms of lysergic acid diethylamide (LSD) or its compounds, more than ten grains of crack, or more than one gram of ice or crank, as defined in Section 44-53-110, or unless it is used, intended for use, or in any manner facilitates a violation of Section 44-53- 370(e); (7) all property including, but not limited to, monies, negotiable instruments, securities, or other things of value furnished or intended to be furnished by any person in exchange for a controlled substance, and all ELECTRONICALLY FILED - 2024 May 06 2:19 PM - CHARLESTON - COMMON PLEAS - CASE#2024CP1002372 proceeds including, but not limited to, monies, and real and personal property traceable to any exchange; (8) all monies seized in close proximity to forfeitable controlled substances, drug manufacturing, or distributing paraphernalia, or in close proximity to forfeitable records of the importation, manufacturing, or distribution of controlled substances and all monies seized at the time of arrest or search involving violation of this article. If the person from whom the monies where taken can establish to the satisfaction of a court of competent jurisdiction that the monies seized are not products of illegal acts, the monies must be returned pursuant to court order. V. At the date of filing this Complaint for Forfeiture, no other persons are known to the Plaintiff to have interest in the Defendant property. WHEREFORE, Plaintiff prays that the Defendant property be declared forfeited to the State of South Carolina pursuant to S.C. Code Ann. §44-53-520, et seq. and that it be distributed as provided in that article. Electronically signed on 5/6/2024 s/Steve Ruemelin, Esquire Charleston Police Department 180 Lockwood Blvd. Charleston, SC 29403 (843) 720-3787 Attorney for Plaintiff Charleston, South Carolina