Case 5:21-cr-00316-EGS Document 1 Filed 08/12/21 Page 1 of 5

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA CRIMINAL NO.

v. DATE FILED:

DOMINIC ESCALERA VIOLATIONS:

18 U.S.C. $ 1958(a) (use of interstate
commerce facilities in the commission
of murder-for-hire - 2 counts)
18 U.S.C. S 922(gXl) (possession
of a firearm by a felon - I count)
Notice of forfeiture

INDICTMENT
COUNT ONE

THE GRAND JURY CHARGES THAT:

From at least as early as on or about January 28,2021 to on or about February 17,

2021, in the Eastem District of Pennsylvania and elsewhere, defendant,

DOMINIC ESCALERA

used and caused another to use a facility of interstate commerce, that is, a cellular telephone, and

traveled in interstate commerce from Newark, in the state of New Jersey, to Allentown, in the

Commonwealth of Pennsylvania, with intent that the murder of M.R., a person known to the

grand jury, be committed in violation of the laws of the Commonwealth of Pennsylvania, that is,

Title 18, Pennsylvania Consolidated Statutes Annotated, Sections2502 and 306, as consideration

for a promise and agreement to pay, things of pecuniary value, that is, controlled substances and

United States currency.

In violation of Title 18, United States Code, Section 1958(a).

 Case 5:21-cr-00316-EGS Document 1 Filed 08/12/21 Page 2 of 5

COUNT TWO

THE GRAND JURY FURTHER CHARGES THAT:

From at least as early as on or about January 28, 2021 to on or about February 1 7,

2O2l,in the Eastern District of Pennsylvania and elsewhere, the defendant,

DOMINIC ESCALERA

used and caused another to use a facility of interstate commerce, that is, a cellular telephone, and

traveled in interstate commerce from Newark, in the state of New Jersey, to Allentown, in the

Commonwealth of Pennsylvania, with intent that the murder of A.R., a person known to the

grand jury, be committed in violation of the laws of the Commonwealth of Pennsylvania, that is,

Title 18, Pennsylvania Consolidated Statutes Annotated, Sections 2502 and 306, as consideration

for a promise and agreement to pay, things of pecuniary value, that is, controlled substances and

United States currency.

In violation of Title 18, United States Code, Section 1958(a).

 Case 5:21-cr-00316-EGS Document 1 Filed 08/12/21 Page 3 of 5

COUNT THREE

THE GRAND JURY FURTHER CHARGES THAT:

On or about February 17,2021, in Allentown, in the Eastern District of

Pennsylvania, defendant

DOMINIC ESCALERA,

knowing he had previously been convicted in a court of the Commonwealth of Pennsylvania of a

crime punishable by imprisonment for a term exceeding one year, knowingly possessed a

firearm, that is, a Ruger, Model Redhawk, double-action .44 caliber Magnum revolver, bearing

serial number 501-75073, loaded with four live rounds of ammunition, and the firearm was in

and affecting interstate commerce.

In violation of Title 18, United States Code, Section 922(9(1).

 Case 5:21-cr-00316-EGS Document 1 Filed 08/12/21 Page 4 of 5

NOTICE OF FORFEITURE

THE GRAND JURY FURTHER CHARGES THAT:

As a result of the violation of Title I 8, United States Code, Section 922(g)(l), set

forth in this indictment, defendant

DOMINIC ESCALERA

shall forfeit to the United States of America all firearms and ammunition involved in the

commission of such offense, including, but not limited to:

1) a Ruger, Model Redhawk, double-action .44 caliber Magnum revolver,

bearing serial number 501-75073, and

2) thirty-three live rounds of .44 caliber ammunition.

All pursuant to Title 28, United States Code, Section 2ail@) and Title 18, United

States Code, Section 924(d).

A TRUE BILL:

FORE,PERSON

JENNIFEBIARBITTIER W
Acting United States Attorney
 Case 5:21-cr-00316-EGS Document 1 Filed 08/12/21 Page 5 of 5

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 Case 5:21-cr-00316-EGS Document 1-1 Filed 08/12/21 Page 1 of 1

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

INDICTMENT

DESIGNATION FORM to be used by counsel to indicate the category of the case for the
purpose of assignment to appropriate calendar.
Address of Plaintiff: 615 Chestnut Street, Suite 1250, Philadelphia, PA 19106-4476

Post Office: Philadelphia County: Philadelphia

City and State of Defendant: Allentown, PA

County: Lehigh Register number: N/A

Place of accident, incident, or transaction: Eastern District of Pennsylvania

Post Office: Lehigh County: Lehigh

RELATED CASE, IF ANY:

Criminal cases are deemed related when the answer to the following question is Ayes@.

Does this case involve a defendant or defendants alleged to have participated in the same
action or transaction, or in the same series of acts or transactions, constituting an offense
or offenses?

YES/NO: No

Case Number: N/A Judge: N/A

CRIMINAL: (Criminal Category - FOR USE BY U.S. ATTORNEY ONLY)
1. Antitrust
2. Income Tax and other Tax Prosecutions
3. Commercial Mail Fraud
4. Controlled Substances
5. Violations of 18 U.S.C. Chapters 95 and 96 (Sections 1951-55 and 1961-68)
and Mail Fraud other than commercial
6. General Criminal
(U.S. ATTORNEY WILL PLEASE DESIGNATE PARTICULAR CRIME AND
STATUTE CHARGED TO BE VIOLATED AND STATE ANY PREVIOUS
CRIMINAL NUMBER FOR SPEEDY TRIAL ACT TRACKING PURPOSES)
18 U.S.C. § 1958(a) (use of interstate commerce facilities in the commission of murder
for-hire – 2 counts)
18 U.S.C. § 922(g)(1) (possession of a firearm by a felon – 1 count)
Notice of forfeiture

DATE: 08/12/2021 /s/ Thomas M. Zaleski

THOMAS M. ZALESKI
Assistant United States Attorney

File No. 2021R00081

U.S. v. DOMINIC ESCALERA