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·- - --FILED
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UNITED STATES DISTRICT C
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SOUTHERN DISTRICT OF CALI
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UNITED STATES OF AMERICA,
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Magistrate '
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COMPLAINT FOR VIOLATION
v.
Title 18 U.S.C. Sec. 922(a)(l )(A)
Engaging in the Business of Dealing
Firearms Without a License (Felony);
Title 18, U.S.C. § 922(a)(3)Unlicensed Transportation of Firearms
(Felony)
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JAIME CASILLAS (1),
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APR_ l 5 2015 -]
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Plaintiff,
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ANDREW REYES (2),
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The undersigned Complainant, being duly sworn, states:
Count One
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On or about and between August 14, 2014, and March 16, 2015, within the
Southern District of California, the defendants, Jaime CASILLAS and Andrew
REYES, not being licensed dealers of firearms, within the meaning of Chapter 44,
Title 18, United States Code, did willfully engage in the business of dealing in
firearms, in violation of Title 18, United States Code, Sections 922(a)(l)(A) and
924(a) (l)(D).
Count Two
On or about and between December 1, 2014, and March 15, 2015, within the
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Southern District of California, Andrew REYES, a person not having a valid Federal
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A\·~a\\6
Firearm License, did knowingly purchase in the State of Texas and then intentionally
transport into the State of California, firearms, to wit: a multi-caliber Diamondback
AR15 rifle, model DB-15, bearing serial number DB-1801557; a multi-caliber E3
Arms AR15 rifle, model Omega-15, bearing serial number A04752; aDPMS, model
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A-15, 5.56mm rifle, serial number F142558; a Century Arms, model 59/66 Yugo,
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7.62 caliber rifle, serial number 657903; and an Anderson Manufacturing Model AM-
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15 multi-caliber rifle, bearing serial number 14154217; in violation of 18, United
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States Code, Section 922 (a) (3).
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And the complainant states that this complaint is based on the attached
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Statement of Facts incorporated herein by reference.
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J~
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Special Agent, ATF
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HONORABLE MITC LL D. DEMBIN
UNITED STATES MAGISTRATE JUDGE
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STATEMENT OF FACTS
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In August 2014, a Drug Enforcement Administration Task Force Officer was
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acting in an undercover capacity ("UCA") within the Southern District of California.
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The UCA had a meeting with an individual, later identified as Jaime CASILLAS.
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During the meeting, CASILLAS told the UCA that he had the ability to acquire
firearms and ammunition for sale. At the time of this meeting, CASILLAS was toldand appeared to believe - that the UCA was a member of a Mexico-based drugtrafficking-organization ("DTO") who had been tasked to acquire firearms and
ammunition for the DTO. CASILLAS told the UCA that he was a U.S. Army
Reservist and added that he and a fellow reservist, "Sgt. Reyes" (later identified as
Andrew REYES) had the ability to acquire firearms, ammunition, and body armor for
the UCA.
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During this initial meeting, CASILLAS offered to sell the UCA a .40 caliber
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pistol, an AK-47 rifle, and 1,600 rounds of .223 caliber ammunition. During a
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subsequent undercover meeting, CASILLAS sold the UCA 1,600 rounds of .223
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caliber ammunition for $700.00. The ammunition was later identified as U.S.
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military inventory.
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On August 14, 2014, the UCA traveled to Melody Mobile Home Estates
located at 1313 E. Main Street in El Cajon, California, and purchased a .40 caliber
pistol from CASILLAS for $800.00. During the transaction, CASILLAS claimed
that the pistol had been used to "do a job" in Tijuana, Mexico.
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On September 3, 2014, the UCA met with REYES and purchased the AK-47
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rifle (originally offered by CASILLAS) for $1,700. Record checks revealed that
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REYES resides at 5831 Christa Court #B, La Mesa, California, 91942. On October
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10,2014, CASILLAS contacted the UCA on his cell phone and claimed that he had
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an AR15 assault-style rifle for sale for $1 ,200.00. Ultimately, the two agreed to meet
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on October 17, 2014, in order for the UCA to purchase the rifle from CASILLAS.
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On October 17, 2014, CASILLAS arrived at a pre-designated location.
CASILLAS arrived in a white Nissan SUV, bearing California license plate number
6DF A520 -which was registered to CASILLAS' girlfriend (who also resides at the
Melody Mobile Home Estates, mentioned above). Upon his arrival, CASILLAS
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entered the UCA's vehicle and sold him the previously-negotiated AR15 rifle for
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$1 ,200.00. During the transaction, CASILLAS also advised the UCA that the serial
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number on the rifle was fake and had only been placed on the rifle to make it appear
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legitimate in the event law enforcement inspected it during a traffic stop. During the
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same conversation, theUCA advised CASILLAS that the assault-rifle was destined
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for Mexico.
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On November29, 2014, REYES contacted the UCA via text. REYES advised
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the UCA that his out-of-state firearm source had two AR15 rifles available for
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$2,700.00. REYES then forwarded the UCA pictures of the AR15 rifles that,
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according to REYES, had been sent to him via text from his firearm source. REYES
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advised the UCA that his firearm source would require a down payment of$2,000.00
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to secure the rifles and that he (REYES) planned to travel to Texas to acquire them.
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REYES then offered to sell the UCA twenty Small Arms Protective Inserts
(SAPI) plates for $2,000.00 and one hundred AR15 rifle ammunition magazines for
$800.00. REYES indicated that both the SAPI plates and ammunition magazines
were from U:S military inventory. SXPis are ceramic trauma plates placeoTnsiOeof - --
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ballistic vests that provide the user protection from high velocity ammunition. SAPIs
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are primarily utilized by law enforcement and U.S. military combat personnel.
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REYES indicated that if the UCA was interested in either or both items, he would use
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the proceeds as the down payment to his firearm source for the AR15 rifles.
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two agreed to meet on December 1, 2014, for the SAPI plate transaction.
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On December 1, 2014, during an undercover meeting, the UCA purchased
twenty SAPI plates from REYES for $2,000.00. During this meeting, REYES
advised the UCA that he planned to depart San Diego later that day. He intended to
travel to Texas in order to acquire the two previously negotiated AR15 rifles.
REYES claimed that he would have the rifles for the UCA to purchase on December
3, 2014. REYES further claimed that the drive to Texas would take approximately
nine hours.
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Later that day, REYES left San Diego and traveled to Texas. He returned to
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San Diego at approximately 11 :00 pm on December 2, 2014. Unbeknownst to
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REYES, his vehicle contained a tracking device- previously authorized by a federal
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magistrate judge. See 14-MC-1402.
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On December 3, 2014, during an undercover meeting, the UCA purchased two
AR15 rifles and four, high-capacity .223 caliber rifle magazines from REYES for
$2, 700.00. The rifles were later-identified as a multi-caliber Diamondback AR15
rifle, model DB-15, bearing serial number DB-1801557 and a multi-caliber E3 Arms
AR15 rifle, model Omega-15, bearing serial number A04752.
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During the transaction, REYES told the UCA that the rifles were unregistered
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and "clean". The UCA advised REYES that he planned on taking the rifles south
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(referring to Mexico) later in the day.
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On January 22, 2015, REYES contacted the UCA via text and advised him that
his out-of-state firearm source had two rifles available for $2,400.00. REYES
described the rifles as a 7.62 caliber SKS rifle and a .223 caliber AR15 rifle. REYES
then forwarded pictures of the firearms to the UCA. REYES further advised the
UCA that he would travel to Texas to acquire the rifles. He also requested a down
payment of$1,700.00 to secure the rifles. REYES then offered to sell the UCA one
hundred and fifty, .223 caliber, thirty-round rifle magazines for $1,500.00, which he
would use as a down payment to his source to secure the rifles.
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On January 23, 2015, REYES arrived at a pre-designated location. During this
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meeting, REYES sold the UCA one hundred and fifty, .223 caliber, thirty-round rifle
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magazines for $1,500.00. REYES then told the UCA that he planned to travel to
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Texas in order to acquire the previously negotiated rifles later that day. REYES
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added that he planned to return to San Diego on Sunday, January 25,2015. The two
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agreed to meet on Monday, January 26,2015, in order for the UCA to purchase the
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rifles from REYES.
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REYES actually left San Diego at approximately 2:00am on January 24,
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2015. After stopping in Texas, he returned to San Diego at approximately 11:50 pm
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on January 25, 2015.
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REYES' vehicle contained a new tracking device- authorized by a federal magistrate
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judge. See 15-MC-033.
The details of his movements are known, in part, because
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On January 26, 20 15, REYES arrived at a pre-designated location and met with
the UCA. REYES sold the UCA two rifles, a 7.62 caliber SKS rifle and a .223
caliber AR15 rifle, for $1,900.00. The firearms were later identified as a DPMS,
model A-15, 5.56mmrifle, serial number F142558 and a Century Arms, model59/66
- yugo, 7.62 caliber rifle, serial number 6579
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The UCA advised REYES that both rifles were to be transported to Mexico
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later that same day along with additional firearms that he (UCA) had obtained from
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other firearm sources.
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On March 10, 2015, REYES contacted the UCA via text. He advised the UCA
that his out-of-state firearm source had anAR15 with amounted scope for $2,150.00.
REYES then forwarded pictures ofthe AR15 to the UCA. REYES then advised the
UCA that his source would require a down payment to secure the rifle. REYES then
offered to sell the UCA two ballistic vests with SAPI plates, and over a dozen high-
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capacity rifle magazines for $800.00. REYES stated that he would use the proceeds
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to secure the AR15 from his firearm source. The two agreed to meet on March 12,
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2015, for the purchase of the vests and magazines.
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On March 12, 2015, at approximately I 1:50am, REYES arrived at a pre-
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designated meet location. REYES then sold the UCA the pre-negotiated vests, SAPis
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and rifle magazines for $800.00. During the meet, REYES stated that he planned to
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travel to Texas the following day to acquire the AR15. The two agreed to meet on
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Monday, March 16, 2015. The UCA told REYES that once he acquired the AR15 he
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would be taking it south (referring to Mexico). REYES acknowledged the plan and
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told the UCA that he was confident he (UCA) would like the rifle.
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On March 15, 2015, at approximately 6:12pm, REYES contacted the UCA via
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text and advised he was two hours away from San Diego. The two then exchanged
several text messages regarding the AR15 . During the text message exchange the two
confirmed their meeting for 11:00 am the following day. In addition to coordinating
their meeting, REYES texted the UCA a short video. The video depicted REYES
firing an AR15 with a mounted scope at what appeared to be an outdoor shooting
hat he had fireo the A1t15 in order to make silre ir
range.
"fired smoothly" because it was "j"t,Ist built."
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On March 16, 2015, the UCA traveled to a pre-designated meet location in
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order to purchase the above-referenced AR15 rifle. CASILLAS and REYES showed
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up together for the meeting, in a vehicle being driven by CASILLAS. REYES was
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wearing U.S. Army physical training gear (work-out clothing). CASILLAS was
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dressed in a U.S. Army camouflage uniform. Upon the UCA's arrival, CASILLAS
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and REYES transferred an AR15 rifle and rifle case to UCA's vehicle. UCA then
handed REYES $2, 150.00. The UCA advised both CASILLAS and REYES that the
rifle was destined for Mexico. The UCA then asked both CASILLAS and REYES if
there would "be any issues" in the event the rifle was recovered by law enforcement
in Mexico. In response, REYES claimed that the rifle was unregistered. CASILLAS
then suggested that the UCA obliterate the serial number once in Mexico. The rifle
was later identified as an Anderson Manufacturing Model AM-15 multi-caliber rifle,
bearing serial number 14154217.
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During the same conversation, CASILLAS then told the UCA that he had a .45
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caliber pistol for sale. CASILLAS described the firearm as being "hot" (a slang term
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typically used to describe an item that is either stolen or was used in a crime). The
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UCA told CASILLAS that he was not concerned about the firearm being "hot"
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because he would be taking it to Mexico. The two then agreed to discuss the pistol
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purchase at a later time.
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Subsequent to the meeting- but still on March 16, 2015 -REYES sent a text
message to the UCA indicating that he had a .50 caliber rifle available for $15,000.
REYES then forwarded photos of the rifle to the UCA. To date, that sale was never
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On April15, 2015, law enforcement executed search warrants at the residences
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of CASILLAS and REYES. The .50 caliber rifle was not found. Both individuals
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were arrested. CASILLAS was advised of his Miranda rights and elected to answer
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questions and to make a statement without the presence of an attorney. In sum,
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CASILLAS admitted that he had sold firearms and ammunition to an undercover
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agent who he believed was bringing the items into Mexico. CASILLAS further
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claimed that he was coordinating the various sales for REYES and did not personally
profit from the transactions.
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Record checks confirmed that neither CASILLAS nor REYES have a Federal
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Firearms License that would allow them to sell firearms; or to purchase firearms
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outside their state of residency and then transport those same firearms back into
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California.
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