The Indictment (PDF) - WUSA9.com

Case 1:11-cr-00188-CMH Document 26 Filed 06/30/11 Page 1 of 7 PageID# 47 

FIIEO 

IN OPFN COURT 

IN THE UNITED STATES DISTRICT COURT FORfTHp JJ§j) 3 

2Q|{ 

EASTERN DISTRICT OF VIRGINIA 

Alexandria Division 

CURK. U.S. DISIRICI COURT 

AlFXAfinRIA. VIRGINIA 

UNITED STATES OF AMERICA 

Criminal Case No. 1:11-cr-188 

v. 

DELANTE T. COOK, 

Defendant. 

Count 1: 18U.S.C. § 1951(a) 

(Conspiracy to commit Hobbs Act robbery) 

Count 2: 18 U.S.C. §§ 1951(a), 2 

(Attempt to commit Hobbs Act robbery) 

Count 3: 18 U.S.C. § 924(c) 

(Carry and use a firearm in relation to a 

crime ofviolence) 

JUNE 2011 TERM - AT ALEXANDRIA, VIRGINIA 

SUPERSEDING INDICTMENT 

Count One 

THE GRAND JURY CHARGES THAT: 

In and around the Autumn of2008, the exact dates being unknown to the Grand Jury, in 

the Eastern District of Virginia and elsewhere, the defendant, DELANTE T. COOK, did 

unlawfully, knowingly, and intentionally combine, conspire, confederate, and agree together 

with Jelani Slayand other persons known and unknown to the Grand Jury to obstruct, delay, and 

affect commerce and the movement of articles and commodities in commerce, by robbery and 

acts ofphysical violence, in violationofTitle 18,United States Code, Section 1951(a).


WAYS. MANNER. AND MEANS TO ACCOMPLISH THE CONSPIRACY 

The primary purpose of the conspiracy was to obtain as much money and drugs as 

possible through robbery. The ways, manner, and means by which this purpose was carried out 

included, but were not limited to, the following: 

1. It was part of the conspiracy that the conspirators played different roles, took 

upon themselves different tasks, and participated in the affairs ofthe conspiracy through various 

criminal acts. 

2. It was further part of the conspiracy that the conspirators made themselves and 

their services available at various times throughout the conspiracy. 

3. It was further part of the conspiracy that the conspirators targeted individuals to 

rob who lived and were engaged in marijuana trafficking in Fairfax County, Virginia, within the 

Eastern District ofVirginia. 

4. It was further part ofthe conspiracy that, in preparing to commit the robbery, the 

conspirators conducted physical surveillance of the residence where those individuals lived and 

were engaged in marijuana trafficking in Fairfax County, Virginia, within the Eastern District of 

Virginia. 

5. It was further part of the conspiracy that, in preparing to commit the robbery, the 

conspirators obtained clothing adorned with law enforcement-related lettering and insignia, 

which clothing they intended to wear during the robbery to gain entry into the residence where 

those individuals lived and were engaged in marijuana trafficking in Fairfax County, Virginia, 

within the Eastern District ofVirginia. 

6. It was further part of the conspiracy that, in preparing to commit the robbery, the 

conspirators obtained weapons, including knives and firearms. 

2


7. It was further part ofthe conspiracy that the conspirators used cellular telephones 

to maintain contact and facilitate the conspiracy. 

OVERT ACTS 

In furtherance of the conspiracy and to affect the objects thereof, the defendant, 

DELANTE T. COOK, and his co-conspirators committed overt acts, in the Eastern District of 

Virginia and elsewhere, including, but not limited to, the following: 

1. On or about November 17,2008, the defendant, DELANTE T. COOK, traveled to 

Fairfax County, Virginia, within the Eastern District ofVirginia, to conduct physical surveillance 

of the residence of Ryan Strope and Terence Strope, individuals engaged in marijuana 

trafficking. 

2. On or about November 18,2008, the defendant, DELANTE T. COOK, traveled to 

Fairfax County, Virginia, within the Eastern District ofVirginia, to conduct physical surveillance 

ofthe residence ofRyan Strope and Terence Strope. 

3. On or about November 18, 2008, members ofthe conspiracy, to include, but not 

limited to, the defendant, DELANTE T. COOK, and Jelani Slay, conducted physical surveillance 

of the residence of Ryan Strope and Terence Strope in Fairfax County, Virginia, within the 

Eastern District ofVirginia. 

4. On or about November 19, 2008, members of the conspiracy, to include, but not 

limited to, the defendant, DELANTE T. COOK, and Jelani Slay, dressed themselves in clothing 

adorned with law enforcement-related lettering and insignia. 


limited to, the defendant, DELANTE T. COOK, and Jelani Slay, armed themselves with 

weapons, to include, but not limited to, knives and firearms. 

3



limited to, the defendant, DELANTE T. COOK, and Jelani Slay, traveled to Fairfax County, 

Virginia, within the Eastern District of Virginia, to the immediate vicinity of the residence of 

Ryan Strope and Terence Strope. 

7. On or about November 19, 2008, in Fairfax County, Virginia, within the Eastern 

District of Virginia, members of the conspiracy, to include, but not limited to, the defendant, 

DELANTE T. COOK, and Jelani Slay, while dressed in clothing adorned with law enforcementrelated 

lettering and insignia, and armed with weapons, to include, but not limited to, knives and 

firearms, entered the residence of Ryan Strope and Terence Strope with the intent to commit 

robbery and acts ofphysical violence. 


District of Virginia, members of the conspiracy pistol whipped Terence Strope with a firearm 

during the course ofthe robbery. 


District of Virginia, members of the conspiracy murdered Ryan Strope by stabbing him during 

the course ofthe robbery. 


District of Virginia, members of theconspiracy murdered Terence Strope bystabbing himduring 

the course ofthe robbery. 


District of Virginia, members of the conspiracy murdered Andres Yelicie by stabbing him during 

the course ofthe robbery.



District ofVirginia, members ofthe conspiracy took personal property from inside the residence 

of Ryan Strope and Terence Strope to include, but not limited to, a cellular telephone and two 

laptop computers, and did so against the will ofRyan Strope, Terence Strope, and Andres Yelicie 

by means ofactual and threatened force, violence, and fear ofinjury, immediate and future. 

(All in violation ofTitle 18, United States Code, Section 1951(a).)


Count Two 

THE GRAND JURY FURTHER CHARGES THAT: 

On or about November 19, 2008, in Fairfax County, Virginia, within the Eastern District 

of Virginia, the defendant, DELANTE T. COOK, did attempt to unlawfully, knowingly, and 

intentionally obstruct, delay, and affect interstate commerce and the movement of articles and 

commodities in commerce, by robbery and acts of physical violence, in that the defendant 

attempted to take and obtain personal property consisting of marijuana and proceeds from the 

sale of marijuana from Ryan Strope and Terence Strope, against their will by means of actual 

and threatened force, violence, and fear of injury, immediate and future, while Ryan Strope and 

Terence Strope were engaged in commercial activities, namely the distribution of marijuana, 

which affects interstate commerce. 

(In violation ofTitle 18, United States Code, Sections 1951(a) and 2.)


Count Three 

THE GRAND JURY FURTHER CHARGES THAT: 

On or about November 19, 2008, in Fairfax County, Virginia, within the Eastern District 

of Virginia, the defendant, DELANTE T. COOK, did unlawfully, knowingly, and intentionally 

use and carry a firearm, to wit a handgun, during and in relation to a crime ofviolence for which 

he may be prosecuted in a court of the United States, specifically, conspiracy to commit Hobbs 

Act robbery, in violation of 18 U.S.C. § 1951, and attempt to commit Hobbs Act robbery, in 

violation of 18 U.S.C. §§ 1951 and 2, as set forth and charged respectively in Counts One and 

Two ofthis indictment. 

(All in violation ofTitle 18, United States Code, Sections 924(c)(1) and 2) 

A TRUE BILL 

Foreperson 

Pur»ttn» tothe F«Govemn>»nt Act, 

the original ofthis page has been t\\ei. 

undersealisU» Cle&lCfiita 

Neil H. MacBride 

UnitedJS&tfesAttorney 

By: 

Jonathan LfFahey 

Assistant United States Attorney 

By: 

Sean P.Tonolli 

Assistant United States Attorney 

^

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