UNITED STATES OF AMERICA, Magistrate ' oepun Plaintiff, The undersigned Complainant, being duly sworn, states: Count One

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1 - v. ---FILED j - UNITED STATES DISTRICT C URf APR_ l 0 -] SOUTHERN DISTRICT OF CALI ~f'\.. p ~- ~... L t" ~ c. ~ ~ :,r - -,;, R-: SOU. irle~~n (J;S T r~ C u;: _:.:.t,.. ~()R : \ : ~ UNITED STATES OF AMERICA, Magistrate ' oepun Plaintiff, JAIME CASILLAS (), ANDREW REYES (), Defendants ~----- COMPLAINT FOR VIOLATION Title U.S.C. Sec. (a)(l )(A) Engaging in the Business of Dealing Firearms Without a License (Felony); Title, U.S.C. (a)() Unlicensed Transportation of Firearms (Felony) 0 The undersigned Complainant, being duly sworn, states: Count One On or about and between August, 0, and March, 0, within the Southern District of California, the defendants, Jaime CASILLAS and Andrew REYES, not being licensed dealers of firearms, within the meaning of Chapter, Title, United States Code, did willfully engage in the business of dealing in firearms, in violation of Title, United States Code, Sections (a)(l)(a) and (a) (l)(d). Count Two On or about and between December, 0, and March, 0, within the Southern District of California, Andrew REYES, a person not having a valid Federal 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 AR rifle, model DB-, bearing serial number DB-; a multi-caliber E Arms AR rifle, model Omega-, bearing serial number A0; adpms, model A\ ~a\\

2 A-,.mm rifle, serial number F; a Century Arms, model / Yugo, multi-caliber rifle, bearing serial number ; in violation of, United States Code, Section (a) (). And the complainant states that this complaint is based on the attached Statement of Facts incorporated herein by reference. J~ Special Agent, ATF. caliber rifle, serial number 0; and an Anderson Manufacturing Model AM- ;:- --swom-to--m-e-ami~subscrib-ed in my-pres enceihis~=f?-day-of-a-pril;--0-i-~ HONORABLE MITC LL D. DEMBIN UNITED STATES MAGISTRATE JUDGE STATEMENT OF FACTS In August 0, a Drug Enforcement Administration Task Force Officer was acting in an undercover capacity ("UCA") within the Southern District of California. The UCA had a meeting with an individual, later identified as Jaime CASILLAS. 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.

3 During this initial meeting, CASILLAS offered to sell the UCA a.0 caliber pistol, an AK- rifle, and,00 rounds of. caliber ammunition. During a subsequent undercover meeting, CASILLAS sold the UCA,00 rounds of. caliber ammunition for $ The ammunition was later identified as U.S. military inventory. On August, 0, the UCA traveled to Melody Mobile Home Estates located at E. Main Street in El Cajon, California, and purchased a.0 caliber pistol from CASILLAS for $ During the transaction, CASILLAS claimed that the pistol had been used to "do a job" in Tijuana, Mexico. On September, 0, the UCA met with REYES and purchased the AK- rifle (originally offered by CASILLAS) for $,00. Record checks revealed that REYES resides at Christa Court #B, La Mesa, California,. On October,0, CASILLAS contacted the UCA on his cell phone and claimed that he had an AR assault-style rifle for sale for $, Ultimately, the two agreed to meet on October, 0, in order for the UCA to purchase the rifle from CASILLAS. On October, 0, CASILLAS arrived at a pre-designated location. CASILLAS arrived in a white Nissan SUV, bearing California license plate number DF A0 -which was registered to CASILLAS' girlfriend (who also resides at the Melody Mobile Home Estates, mentioned above). Upon his arrival, CASILLAS entered the UCA's vehicle and sold him the previously-negotiated AR rifle for $, During the transaction, CASILLAS also advised the UCA that the serial number on the rifle was fake and had only been placed on the rifle to make it appear legitimate in the event law enforcement inspected it during a traffic stop. During the same conversation, theuca advised CASILLAS that the assault-rifle was destined for Mexico.

4 On November, 0, REYES contacted the UCA via text. REYES advised the UCA that his out-of-state firearm source had two AR rifles available for $, REYES then forwarded the UCA pictures of the AR rifles that, according to REYES, had been sent to him via text from his firearm source. REYES advised the UCA that his firearm source would require a down payment of$, to secure the rifles and that he (REYES) planned to travel to Texas to acquire them. REYES then offered to sell the UCA twenty Small Arms Protective Inserts (SAPI) plates for $, and one hundred AR rifle ammunition magazines for $ REYES indicated that both the SAPI plates and ammunition magazines were from U:S military inventory. SXPis are ceramic trauma plates placeotnsioeof - -- ballistic vests that provide the user protection from high velocity ammunition. SAP Is are primarily utilized by law enforcement and U.S. military combat personnel. REYES indicated that if the UCA was interested in either or both items, he would use the proceeds as the down payment to his firearm source for the AR rifles. The two agreed to meet on December, 0, for the SAPI plate transaction. 0 On December, 0, during an undercover meeting, the UCA purchased twenty SAPI plates from REYES for $, 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 AR rifles. REYES claimed that he would have the rifles for the UCA to purchase on December, 0. REYES further claimed that the drive to Texas would take approximately nine hours. Later that day, REYES left San Diego and traveled to Texas. He returned to San Diego at approximately :00 pm on December, 0. Unbeknownst to REYES, his vehicle contained a tracking device- previously authorized by a federal

5 0 magistrate judge. See -MC-. On December, 0, during an undercover meeting, the UCA purchased two AR rifles and four, high-capacity. caliber rifle magazines from REYES for $, The rifles were later-identified as a multi-caliber Diamondback AR rifle, model DB-, bearing serial number DB- and a multi-caliber E Arms AR rifle, model Omega-, bearing serial number A0. During the transaction, REYES told the UCA that the rifles were unregistered and "clean". The UCA advised REYES that he planned on taking the rifles south (referring to Mexico) later in the day. On January, 0, REYES contacted the UCA via text and advised him that his out-of-state firearm source had two rifles available for $, REYES described the rifles as a. caliber SKS rifle and a. caliber AR rifle. REYES then forwarded pictures of the firearms to the UCA. REYES further advised the UCA that he would travel to Texas to acquire the rifles. He also requested a down payment of$,00.00 to secure the rifles. REYES then offered to sell the UCA one hundred and fifty,. caliber, thirty-round rifle magazines for $,00.00, which he would use as a down payment to his source to secure the rifles. On January, 0, REYES arrived at a pre-designated location. During this meeting, REYES sold the UCA one hundred and fifty,. caliber, thirty-round rifle magazines for $, REYES then told the UCA that he planned to travel to Texas in order to acquire the previously negotiated rifles later that day. REYES added that he planned to return to San Diego on Sunday, January,0. The two agreed to meet on Monday, January,0, in order for the UCA to purchase the rifles from REYES.

6 0 REYES actually left San Diego at approximately :00am on January, 0. After stopping in Texas, he returned to San Diego at approximately :0 pm on January, 0. The details of his movements are known, in part, because REYES' vehicle contained a new tracking device-authorized by a federal magistrate judge. See -MC-0. On January, 0, REYES arrived at a pre-designated location and met with the UCA. REYES sold the UCA two rifles, a. caliber SKS rifle and a. caliber AR rifle, for $, The firearms were later identified as a DPMS, model A-,.mmrifle, serial number F and a Century Arms, model/ -yugo,. caliber rifle, serial number. The UCA advised REYES that both rifles were to be transported to Mexico later that same day along with additional firearms that he (UCA) had obtained from other firearm sources. On March, 0, REYES contacted the UCA via text. He advised the UCA that his out-of-state firearm source had anar with amounted scope for $,.00. REYES then forwarded pictures ofthe AR 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 highcapacity rifle magazines for $ REYES stated that he would use the proceeds to secure the AR from his firearm source. The two agreed to meet on March, 0, for the purchase of the vests and magazines. On March, 0, at approximately I :0am, REYES arrived at a predesignated meet location. REYES then sold the UCA the pre-negotiated vests, SAPis and rifle magazines for $ During the meet, REYES stated that he planned to travel to Texas the following day to acquire the AR. The two agreed to meet on

7 0 Monday, March, 0. The UCA told REYES that once he acquired the AR he would be taking it south (referring to Mexico). REYES acknowledged the plan and told the UCA that he was confident he (UCA) would like the rifle. On March, 0, at approximately :pm, REYES contacted the UCA via text and advised he was two hours away from San Diego. The two then exchanged several text messages regarding the AR. During the text message exchange the two confirmed their meeting for :00 am the following day. In addition to coordinating their meeting, REYES texted the UCA a short video. The video depicted REYES firing an AR with a mounted scope at what appeared to be an outdoor shooting range. hat he had fireo the At in order to make silre ir "fired smoothly" because it was "j"t,ist built." On March, 0, the UCA traveled to a pre-designated meet location in order to purchase the above-referenced AR rifle. CASILLAS and REYES showed up together for the meeting, in a vehicle being driven by CASILLAS. REYES was wearing U.S. Army physical training gear (work-out clothing). CASILLAS was dressed in a U.S. Army camouflage uniform. Upon the UCA's arrival, CASILLAS and REYES transferred an AR rifle and rifle case to UCA's vehicle. UCA then handed REYES $,.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- multi-caliber rifle, bearing serial number.

8 I... 0 During the same conversation, CASILLAS then told the UCA that he had a. caliber pistol for sale. CASILLAS described the firearm as being "hot" (a slang term typically used to describe an item that is either stolen or was used in a crime). The UCA told CASILLAS that he was not concerned about the firearm being "hot" because he would be taking it to Mexico. The two then agreed to discuss the pistol purchase at a later time. Subsequent to the meeting- but still on March, 0 -REYES sent a text message to the UCA indicating that he had a.0 caliber rifle available for $,000. REYES then forwarded photos of the rifle to the UCA. To date, that sale was never On April, 0, law enforcement executed search warrants at the residences of CASILLAS and REYES. The.0 caliber rifle was not found. Both individuals were arrested. CASILLAS was advised of his Miranda rights and elected to answer questions and to make a statement without the presence of an attorney. In sum, CASILLAS admitted that he had sold firearms and ammunition to an undercover agent who he believed was bringing the items into Mexico. CASILLAS further claimed that he was coordinating the various sales for REYES and did not personally profit from the transactions. Record checks confirmed that neither CASILLAS nor REYES have a Federal Firearms License that would allow them to sell firearms; or to purchase firearms outside their state of residency and then transport those same firearms back into California.