Case Document 42 Filed 04/14/16 Page 1 of 17

FILED

BENJAMIN B. WAGNER
United States Attorney

 

JUSTIN L. LEE  
MATTHEW M. YELOVICH APR 1 1; I311:6?an

RK. U.S. DIS 
 
Sacramento, CA 95814 37 DEPUTYCLERA 

Telephone: (916) 554?2700

Attorneys for Plaintiff
United States of America

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA,
Plaintiff,

CASE NO. TLN
PLEA AGREEMENT

V- DATE: April 14, 2016

DANIEL ALBERT CROWNINSHIELD, 'Ir?oy Nunley

Defendant.

 

 

I. INTRODUCTION

 

A. Scone of Agreement

The indictment in this case charges the defendant with violations of 18 U.S.C.

922(a)(1)(A) Unlawful Manufacturing and Dealing in Firearms (Count One); 18 U.S.C.

922(g)(9) and 924(a)(2) Possession of a Firearm by a Prohibited Person (Count Two);
18 U.S.C. 922(0) Unlawful Possession of a Machinegun (Count Three); and 26 U.S.C.

5861(d) Possession of an Unregistered Firearm (Counts Four through Six). This
document contains the complete plea agreement between the United States Attorney?s
Office for the Eastern District of California (the ?government?) and the defendant
regarding this case. This plea agreement is limited to the United States Attorney?s Office

for the Eastern District of California and cannot bind any other federal, state, or local

prosecuting, administrative, or regulatory authorities.

PLEA AGREEMENT 1

 






 

 

Case Document 42 Filed 04/14/16 Page 2 of 17

B. Court Not a Partv

The Court is not a party to this plea agreement. Sentencing is a matter solely
within the discretion of the Court, and the Court may take into consideration any and all
facts and circumstances concerning the criminal activities of defendant, including
activities that may not have been charged in the indictment. The Court is under no
obligation to accept any recommendations made by the government, and the Court may in
its discretion impose any sentence it deems appropriate up to and including the statutory
maximum stated in this plea agreement.

If the Court should impose any sentence up to the maximum established by the
statute, the defendant cannot, for that reason alone, withdraw his guilty plea, and he will
remain bound to ful?ll all of the obligations under this plea agreement. The defendant
understands that neither the prosecutor, defense counsel, nor the Court can make a

binding prediction or promise regarding the sentence he will receive.
II. OBLIGATIONS

A. Guilty Plea
The defendant will plead guilty to Counts One and Six of the indictment. The

defendant agrees that he is in fact guilty of these charges and that the facts set forth in
the Factual Basis for Plea attached hereto as Exhibit A are accurate.

The defendant agrees that this plea agreement will be filed with the Court and
become a part of the record of the case. The defendant understands and agrees that he
will not be allowed to withdraw his plea should the Court not follow the government?s
sentencing recommendations.

The defendant agrees that the statements made by him in signing this Agreement,
including the factual admissions set forth in the factual basis, shall be admissible and
useable against the defendant by the United States in any subsequent criminal or civil
proceedings, even if the defendant fails to enter a guilty plea pursuant to this Agreement.
The defendant waives any rights under Rule 11(f) of the Federal Rules of Criminal

Procedure and Rule 410 of the Federal Rules of Evidence, to the extent that these rules

PLEA AGREEMENT

 

 

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Case Document 42 Filed 04/14/16 Page 3 of 17

are inconsistent with this paragraph or with this Agreement generally.

B. Sentencing Recommendation

The defendant and his counsel may recommend whatever sentence they deem
appropriate.

C. Special Assessment

 

The defendant agrees to pay a special assessment of $200 at the time of sentencing
by delivering a check or money order payable to the United States District Court to the
United States Probation Of?ce immediately before the sentencing hearing. If the
defendant is unable to pay the special assessment at the time of sentencing, he agrees to
earn the money to pay the assessment, if necessary by participating in the Inmate
Financial Responsibility Program.

D. Defendant?s Violation of Plea Agreement or Withdrawal of Plea

If the defendant, violates this plea agreement in any way, withdraws his plea, or
tries to withdraw his plea, this plea agreement is voidable at the option of the government.
The government will no longer be bound by its representations to the defendant
concerning the limits on criminal prosecution and sentencing as set forth herein. One way
a defendant violates the plea agreement is to commit any crime or provide any statement
or testimony which proves to be knowingly false, misleading, or materially incomplete.
Any post-plea conduct by a defendant constituting obstruction of justice will also be a
violation of the agreement. The determination whether the defendant has violated the
plea agreement shall be decided under a probable cause standard.

If the defendant violates the plea agreement, withdraws his plea, or tries to
withdraw his plea, the government shall have the right: (1) to prosecute the defendant on
any of the counts to which he pleaded guilty; (2) to reinstate any counts that may be
dismissed pursuant to this plea agreement; and (3) to file any new charges that would
otherwise be barred by this plea agreement. The defendant shall thereafter be subject to
prosecution for any federal criminal violation of which the government has knowledge,

including perjury, false statements, and obstruction of justice. The decision to pursue any

PLEA AGREEMENT

 




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Case Document 42 Filed 04/14/16 Page 4 of 17

or all of these options is solely in the discretion of the United States Attorney?s Office.

By signing this plea agreement, the defendant agrees to waive any objections,
motions, and defenses that the defendant might have to the government?s decision to
exercise the options stated in the previous paragraph. Any prosecutions that are not time-
barred by the. applicable statute of limitations as of the date of this plea agreement may be
commenced in accordance with this paragraph, notwithstanding the expiration of the
statute of limitations between the signing of this plea agreement and the commencement
of any such prosecutions. The defendant agrees not to raise any objections based on the I
passage of time with respect to such counts including, but not limited to, any statutes of
limitation or any objections based on the Spe'edy Trial Act or the Speedy Trial Clause of .
the Sixth Amendment to any counts that were not time-barred as of the date of this plea
agreement.

In addition: (1) all statements made by the defendant to the government or other
designated law enforcement agents, or any testimony given by the defendant before a
grand jury or other tribunal, whether before or after this plea agreement, shall be
admissible in evidence in any criminal, civil, or administrative proceedings hereafter
brought against the defendant; and (2) the defendant shall assert no claim under the
United States Constitution, any statute,iRu1e 11(f) of the Federal Rules of Criminal
Procedure, Rule 410 of the Federal Rules of Evidence, or any other federal rule, that
statements. made by the defendant before or after this plea agreement, or any leads
derived therefrom, should be suppressed. By signing this plea agreement, the defendant

waives any and all rights in the foregoing respects.

E. Forfeiture

The defendant agrees to forfeit to the United States voluntarily and immediately all
of his right title and interest to any and all assets subject to forfeiture pursuant to 18
U.S.C. 924(d)(1), 26 U.S.C. 5872, 28 U.S.C. 2461(c), and 49 U.S.C. 80303. Those
assets include, but are not limited to, the following:
1) Unknown Manufacturer Unknown Receiver/Frame, caliber: unknown (14-

PLEA AGREEMENT 4

 




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Case Document 42 Filed 04/14/16 Page50f 17

93),

2) Unknown Manufacturer Unknown Receiver/Frame, caliber:

98),

3) Unknown Manufacturer Unknown Receiver/Frame, caliber:



4) Unknown Manufacturer Unknown Receiver/Frame, caliber:



5) Unknown Manufacturer Unknown Receiver/Frame, caliber:

ATF-000801),

6) Unknown Manufacturer Unknown Receiver/Frame, caliber:

ATF-000803),

7) Unknown Manufacturer Unknown Receiver/Frame, caliber:

ATF-000804),

8) Unknown Manufacturer Unknown Ri?e, caliber:

ATF-000813),

9) Unknown Manufacturer Unknown Ri?e, caliber:

ATF-000816),

10) Unknown Manufacturer Unknown Ri?e, caliber:



11)Unknown Manufacturer Unknown Ri?e, caliber:

ATP-000824),

12) Unknown Manufacturer Unknown Ri?e, caliber:

ATP-000825),

13) Unknown Manufacturer Unknown Ri?e, caliber:



unknown, 

unknown, 
unknown, 
unknown, 

unknown, 8/ N:

unknown, 

unknown (14-
unknown (lil-
unknown (14-
unknown (14-
unknown (14-

unknown (14-

none (14-

none (14-

000 (14-

none (14-

none (14-

none (14-

14) Unknown Manufacturer Unknown Receiver/Frame, caliber: unknown (14-

ATF-000827),

15)Unknown Manufacturer Unknown Ri?e, caliber: unknown, SIN: AE3243 (14-

PLEA AGREEMENT

 

 






 

 

Case Document 42 Filed 04/14/16 Page 6 of 17

ATF-000830),

16) 18750 Rounds of Assorted Ammunition, caliber: unknown, (14-ATF-000847),

17)Unknown Manufacturer Unknown Ri?e Receiver/Frame, SIN: none (14-ATF-
000850),

18)Unknown Manufacturer Unknown Ri?e Receiver/Frame, SIN: none 
000854),

19) Unknown Manufacturer Unknown Ri?e Receiver/Frame, SIN: none (14-ATF-
000858),

20)Unknown Manufacturer Unknown Ri?e, caliber: unknown, SIN: 294727 (14-
ATF-00087 3),

21)Unknown Manufacturer Unknown Ri?e, caliber: unknown, SIN: 000 (14-ATF-
000881),

22)Unknown Manufacturer Unknown Ri?e, caliber: unknown, SIN: none (14-
ATF-000889),

23) Unknown Manufacturer Unknown Ri?e, caliber: unknown, SIN: unknown
(14-ATF-000891),

24)Unknown Manufacturer Unknown Ri?e, caliber: unknown, SIN: none (14-
ATF-000892),

25)Unknown Manufacturer Unknown Ri?e, caliber: unknown, SIN: none (14-
ATF-000893),

26)Unknown Manufacturer Unknown Ri?e, caliber: unknown, SIN: none (14-
ATF-000895),

27) 809 Rounds of Assorted Ammunition, caliber: unknown (14-ATF-000897),

28)3125 Rounds of Assorted Ammunition, caliber: unknown (14-ATFI-000898),

29) Unknown Manufacturer Unknown Ri?e, caliber: unknown, SIN:
1292989527-1 (14-ATF-0-00899),

30)Unknown Manufacturer Unknown Ri?e, caliber: unknown, SIN: none (14-

ATF-000900),

PLEA AGREEMENT

 






 

 

Case Document 42 Filed 04/14/16 Page 7 of 17

31)Unknown Manufacturer Unknown Ri?e, caliber: unknown, none (14-
ATF-000901),

32) Unknown Manufacturer Unknown Ri?e Receiver/Frame, SIN: none (14-ATF-
001941)

33)6 Rounds of Assorted Ammunition, caliber: 12 (14-ATF-001099),

34) 180 Rounds of Assorted Ammunition, caliber: unknown (14-ATF-001221),

35) 650 Rounds of Assorted Ammunition, caliber: unknown (14-ATF-001226),

36) 140 Rounds of Assorted Ammunition, caliber: unknown (14-ATF-001228),

37) 2000 Component Assorted Ammunition, caliber: unknown (14-ATF-001231),

38)908 Rounds of Assorted Ammunition, caliber: unknown (14-ATF-001232),

39) 1985 Rounds of Assorted Ammunition,- caliber: 22 (14-ATF-001234),

40) 80 Rounds of Assorted Ammunition, caliber: 81 (14-ATF-001235),

Rounds of Assorted Ammunition, caliber: unknown (14-ATF-001238),

42)624 Rounds of Assorted Ammunition, caliber: unknown (14-ATF-001239),

43) 1558 Rounds of Assorted Ammunition, caliber: unknown (14-ATF-001241),

44) 5000 Component Assorted Ammunition, caliber: unknown (14-ATF-001242),

45) 966 Rounds of Assorted Ammunition, caliber: unknown (14-ATF-001243),

46) 190 Rounds of Assorted Ammunition, caliber: 223 (14-ATF-001245),

47) 1359 Rounds of Assorted Ammunition, caliber: unknown (14-ATF-001247),

48)8 Rounds of Assorted Ammunition, caliber: 9 (14-ATF-001248),

49)6 Rounds of Assorted Ammunition, caliber: 12 (14-ATF-001250),

50)350 Rounds of Assorted Ammunition, caliber: 9 (14-ATF-001251),

51)5 Component Assorted Ammunition, caliber: unknown (14-ATF-001252),

52) 1990 Matsura Machine, Model: MC-510V, Serial Number: 900208118,

53) 1985 Matsura Machine, Model: MC-510V2, Serial Number: 85065087,

54)Heavy Machinery Rockwell Delta 15-665, Serial Number: 1421443, and

55)Heavy Machinery Bridgeport Series 1, Serial Number: 7 4340-2.

The defendant agrees that the listed assets above constitute property involved in or

PLEA AGREEMENT

 






 

 

Case Document 42 Filed 04/14/16 Page 8 of 17

used in the commission of the offenses to which he is pleading guilty and subject to
forfeiture as alleged in the indictment.

The defendant agrees to fully assist the government in the forfeiture of the listed
assets and to take whatever steps are necessary to pass clear title to the United States.
The defendant shall not sell, transfer, convey, or otherwise dispose of any of his assets,
including but not limited to, the above-listed assets.

The defendant agrees not to file a claim to any of the listed property in any civil
proceeding, administrative or judicial, which may be initiated. The defendant agrees to
waive his right to notice of any forfeiture proceeding involving this property, and agrees to
not file a claim or assist others in ?ling a claim in that forfeiture proceeding.

The defendant knowingly and voluntarily waives his right to a jury trial on the
forfeiture of assets. The defendant knowingly and voluntarily waives all constitutional,
legal and equitable defenses to the forfeiture of these assets in any proceeding. The
defendant agrees to waive any jeopardy defense, and agrees to waive any claim or defense
under the Eighth Amendment to the United States Constitution, including any claim of
excessive ?ne, to the forfeiture of the assets by the United States, the State of California
or its subdivisions.

The defendant waives oral pronouncement of forfeiture at the time of sentencing,

and any defenses or defects that may pertain to the forfeiture.

THE OBLIGATIONS
A. Recomme ndations

1. Incarceration Range

The government will recommend that the defendant be sentenced to a term of
imprisonment within the Guidelines range for his offenses, as determined by the Court.
The government may recommend whatever it deems appropriate as to all other aspects of
sentencing.

2. Acceptance of Resnonsibilitv

The government will recommend a two-level reduction in the computation of

PLEA AGREEMENT

 






 

 

Case Document 42 Filed 04/14/16 Page 9 of 17

defendant?s offense level if he clearly demonstrates acceptance of responsibility for his
conduct as defined in U.S.S.G. 3E1.1. This includes the defendant meeting with and
assisting the probation officer in the preparation of the pre-sentence report, being truthful
and candid with the probation of?cer, and not otherwise engaging in conduct that
constitutes obstruction of justice within the meaning of U.S.S.G 3C1.1, either in the
preparation of the pre-sentence report or during the sentencing proceeding.

Because the government has already engaged in extensive trial preparation due to
the proximity of the trial date to the entry of this plea agreement, the government will not
move for the additional one-level reduction pursuant to U.S.S.G. 3E 

B. Use of Information for Sentencing

The government is free to provide full and accurate information to the Court and
the United States Probation Of?ce (?Probation?), including answering any inquiries made 7
by the Court andlor Probation, and rebutting any inaccurate statements or arguments by
the defendant, his attorney, Probation, or the Court. The defendant also understands and
agrees that nothing in this Plea Agreement bars the government from defending on appeal
or collateral review any sentence that the Court may impose. -

ELEMENTS OF THE OFFENSE

At a trial, the government would have to prove beyond a reasonable doubt the

IV.

following elements of the offenses to which the defendant is pleading guilty:
As to Count One, unlawful dealing in firearms in violation of 18 U.S.C.
922(a)(1)(A)2
1. First, the defendant was willfully engaged in the business of dealing in
and manufacturing ?rearms within the dates speci?ed in the
indictment; and
2. Second, the defendant did not then have a license as a ?rearms dealer
or manufacturer.

As to Count Six, possession of an unregistered ?rearm in violation of 26 U.S.C.

5861(d):

PLEA AGREEMENT

 

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case2:14-cr-00164-TLN Document 42 Filed 04/14/16 Page 10 of 17

1. First, the defendant knowingly possessed the firearm (AK-47) listed in
the indictment for Count Six;

2. Second, the defendant was aware that this ?rearm had speci?c
features that brought it within the scope of the National Firearms Act,
specifically, the firearm was capable of expelling multiple rounds of
ammunition with a single trigger pull; and

3. Third, the defendant had not registered this ?rearms with the
National Firearms Registration and Transfer Record.

The defendant fully understands. the nature and elements of the crimes charged in
the indictment to which he is pleading guilty, together with the possible defenses thereto,

and has discussed them with his attorney.

V. MAXIMUM SENTENCE

 

A. Maximum penalty

The maximum sentences that the Court can impose are: for Count One, ?ve years
of incarceration, a ?ne of 250,000, a 3 year period of supervised release, and a special
assessment of $100; for Count Six, ten years of incarceration, a fine of up to $10,000, a 3
year period of supervised release, and a special assessment of $100. In addition, the
defendant may be ineligible for certain federal and/or state assistance and/or benefits,
pursuant to 21 U.S.C. 862.

B. Violations of Supervised Release

The defendant understands that if he violates a condition of supervised release at
any time during the term of supervised release, the Court may revoke the term of
supervised release and require the defendant to serve up to 2 years of additional

imprisonment.

VI. SENTENCING DETERMINATION

A. Statutory Authority

The defendant understands that the Court must consult the Federal Sentencing

Guidelines and must take them into account when determining a final sentence. The

10

PLEA AGREEMENT

 

 






 

 

Case Document 42 Filed 04/14/16 Page 11 of 17

defendant understands that the Court will determine a non-binding and advisory
guideline sentencing range for this case pursuant to the Sentencing Guidelines and must
take them into account when determining a ?nal sentence. The defendant further
understands that the Court will consider whether there is a basis for departure from the
guideline sentencing range (either above or below the guideline sentencing range) because
there exists an aggravating or mitigating circumstance of a kind, or to a degree, not
adequately taken into consideration by the Sentencing Commission in formulating the
Guidelines. The defendant further understands that the Court, after consultation and
consideration of the Sentencing Guidelines, must impose a sentence that is reasonable in

light of the factors set forth in 18 U.S.C. 3553(a).

VII. WAIVERS

A. Waiver of Constitutional Rights
The defendant understands that by pleading guilty he is waiving the following

constitutional rights: to plead not guilty and to persist, in that plea if already made; 
to be tried by a jury; to be assisted at trial by an attorney, who would be appointed if
necessary; to subpoena witnesses to testify on his behalf; to confront and cross-
examine witnesses against him; and not to be compelled to incriminate himself.

B. Waiver of Appeal and Collateral Attack

The defendant understands that the law gives the defendant a right to appeal his
guilty plea, conviction, and sentence. The defendant agrees as part of his plea/pleas,
however, to give up the right to appeal the guilty plea, conviction, and the sentence
imposed in this case as long as the sentence does not exceed the statutory maximum as to
each count. The defendant speci?cally gives up the right to appeal any order of restitution
the Court may impose.

Notwithstanding the defendant?s waiver of appeal, the defendant will retain the
right to appeal if one of the following circumstances occurs: (1) the sentence imposed by
the District Court exceeds the statutory maximum; andjor (2) the government appeals the

sentence in the case. The defendant understands that thesercircumstances occur

PLEA AGREEMENT 1 1

 

 






 

 

Case Document 42 Filed 04/14/16 Page 12 of 17

infrequently and that in almost all cases this Agreement constitutes a complete waiver of
all appellate rights.

In addition, regardless of the sentence the defendant receives, the defendant also
gives up any right to bring a collateral attack, including a motion under 28 U.S.C. 2255
or 2241, challenging any aspect of the guilty plea, conviction, or sentence, except for non-
waivable claims. A ?collateral attack? in this circumstance means filing a motion in this
Court, or any other court challenging any aspect of his guilty plea, his conviction, or his
sentence. Therefore, the defendant cannot later decide that he is unhappy with his plea,
conviction, or sentence and seek to amend, alter, or overturn it.

If the defendant ever attempts to vacate his plea, dismiss the underlying charges, or
modify or set aside his sentence on any of the counts to which he is pleading guilty, the
government Shall have the rights set forth in paragraph II.D (Defendant?s Violation of

Plea Agreement) herein.

ENTIRE PLEA AGREEMENT

Other than this plea agreement, no agreement, understanding, promise, or
condition between the government and the defendant exists, nor will such agreement,
understanding, promise, or condition exist unless it is committed to writing and signed by
the defendant, counsel for the defendant, and counsel for the United States.












PLEA AGREEMENT 1 2

 






 

 

Case Document 42 Filed 04/14/16 Page 13 of 17

IX. APPROVALS AND SIGNATURES

A. Defense Counsel

I have read this plea agreement and have discussed it fully with my client. The

plea agreement accurately and completely sets forth the entirety of the agreement. I

concur in my client?s decision to plead guilty as set forth ijhis plea agreement.
Dated: 

Lam-11 DA g,


for Defenda

 

 

B. Defendant

I have read this plea agreement and carefully reviewed every part of it with my
attorney. I understand it, and I voluntarily agree to it. Further, I have consulted with my
attorney and fully understand my rights with respect to the provisions of the Sentencing
Guidelines that may apply to my case. No other promises or inducements have been made
to me, other than those contained in this plea agreement. In addition, no one has

threatened or forced me in any way to enter into this plea agreement. Finally, I am

Dated: 4'I4'f?

 

 

I efendant .

C. Attorney for the United States

I accept and agree to this plea agreement on behalf of the

Dated:  H, 

  
   

 

   

JUSTI . LEE
MAT M. YELOVICH
Assi nt United States Attorneys

13

PLEA AGREEMENT

 

WOOKJON

Case Document 42 Filed 04/14/16 Page 14 of 17

EXHIBIT A
Factual Basis for Plea

If this matter proceeded to trial, the United States would establish the following
facts beyond a reasonable doubt:

Daniel Crowninshield owned and operated Tool, a machine shop in
Sacramento, California, where members of the general public could pay for the
manufacture of AR-15-style firearms. This manufacturing would use AR-15 ?blanks,?
which are small partially-machined metal items that were not firearms but could be
transformed using machine tools into AR-15 lower receivers, which are regulated ?rearms
pursuant to 18 U.S.C. 

Generally, the manufacturing would proceed as follows: prospective gun buyers
would purchase an AR-15 blank and take it to Tool where a skilled machinist would
?nish the AR-15 blank into a completed AR- 15 lower receiver, which is a regulated
?rearm. In order to create the pretext that the individual in such a scenario was building
his or her own firearm, the skilled machinist would often have the individual press a
button or put his or her hands on a piece of machinery so that the individual could claim
that the individual, rather than the machinist, made the ?rearm.

On May 3, 2013, an undercover agent from the California Department of
Justice conducted an undercover purchase at Tool, which was audio and video
recorded, that con?rmed these manufacturing means and method. The UC met with
Crowninshield and arranged to convert an AR-15 blank that the UC had brought with him
into an AR-15 lower receiver. (The UC brought two AR-15 blanks with him that he had
previously purchased from a different machine shop in Sacramento.) Crowninshield took
one of the blanks and assembled a jig around the blank. Crowninshield then directed the
UC to place the blank into a CNC machinel, owned by Crowninshield at Tool and

used to mill out machine parts. Crowninshield then directed the UC to close the safety

 

1 A computer numerical control machine is an automated, programmable piece of metal-working
equipment. 

PLEA AGREEMENT A'l

 






 

 

Case Document 42 Filed 04/14/16 Page 15 of 17

door on the CNC machine and to hit a specific button to start the machine.

During this time, the UC observed another customer that appeared to be doing the
same thing at another machine. The UC overhead Crowninshield and another employee
discussing a customer purchasing blanks. These blanks were known colloquially as
blanks because they purportedly constituted of a completed ?rearm and could
be milled out at machine shops into completed firearms. The UC inquired if
Crowninshield sold such blanks. Crowninshield showed the UC an inventory of such
blanks for sale. The UC purchased an blank for $260, a gray blank for $180,
and an aluminum blank for $160, all from Crowninshield.

Crowninshield then assisted the UC in converting each of these three blanks into
?nished lower receivers (regulated ?rearms). Crowninshield provided step-by-step
directions. that the UC followed: where to place the blank in the CNC machine, when to
close the door, when to push the button to activate the CNC machine, how to clean out the

CNC machine with an air compressor, and how to operate a drill press to complete the

1 lower receiver. While the UC was in the process of converting the three blanks into lower

receivers, Crowninshield commented that the UC had quite a production going. The UC
joked that Crowninshield could call him ?Colt? (the manufacturer of commercial AR-15s).
Crowninshield jokingly responded by asking the UC if he was building a personal army.

In total, the UC paid Crowninshield $920 for the cost of purchasing the blanks and
milling out four blanks into lower receivers (regulated ?rearms). At no point did
Crowninshield require the UC to fill out any firearm purchase paperwork, conduct a
background check, or stamp the ?rearms with a serial number or manufacturer marking.

Law enforcement interviews of Tool employees confirmed that individuals
would indeed manufacture lower receivers (regulated ?rearms) with the aid and
knowledge of Tool employees, including Crowninshield.

Crowninshield advertised such services on at least one online ?rearm enthusiast
forum. This website mainly consists of forums where people ask and answer questions

related to ?rearms. Crowninshield, using the moniker ?Dr-Death? was a proli?c poster on

PLEA AGREEMENT A'z

 






 

 

Case Document 42 Filed 04/14/16 Page 16 of 17

the website. Additionally, other membersfrequently posted about Dr-Death, including
review of service provided and recommending that other users visit his shop. For
example, on September 5, 2013, Dr-Death posted about opening a new shop in San Joseadvertised the ?Lowest Price Builds Lowers,?
and stated that customers could ?Save Up to $40-$60 per lower on your 80% ar builds.?
On September 7, 2013, Dr-Death posted a special deal for the ?rst ten customers, offering
your CNC Instructions On October 2, 2013, another user posted the
following: have done several 80s 10/22, ar15?s an ar 10?s With Dr. Death. He is not in
west sac. He?s off Northgate by Fry?s. Great guy and great work. You will not be
disappointed.?

On October 9, 2013, ATF executed a federal search warrant at Tool. In
Crowninshield?s of?ce at Tool, agents seized an ri?e (later determined to be a
fully-automatic machinegun). In total, agents seized eight firearms from Crowninshield
during execution of the search warrant.

That same day, Crowninshield was contacted by ATF as they executed the search
warrant at Tool. Crowninshield declined to answer questions and immediately left
the shop when he was advised that he was not under arrest. At 1:33 Dr-Death
posted on the website the following: ?Contact your local ATF or DOJ for any local builds
contact guns or dw machine for your needs.?2 Law enforcement learned that Dr-Death
was immediately engaged in deleting past posts on the forum. At 1:56 another
member of the ?rearms forum posted, ?unfortunately Dr-Death got shut down.?

At Tool, Crowninshield had one of his tool chests labeled, On
Crowninshield?s desk, during execution of the search warrant, agents found an email
addressed to Dr. Death and requesting assistance with firearms parts.

Crowninshield was not licensed by ATF to manufacture or deal ?rearms.

Crowninshield did not register any ?rearms in the National Firearms Registration and

 

2 ?lcg guns? and ?dw machine? are other machine shops in Sacramento that engaged in manufacturing
5 style ?rearms built from blanks. 

PLEA AGREEMENT 

 






 

 

Case Document 42 Filed 04/14/16 Page 17 of 17

Transfer Record.
1, DANIEL A. CROWNINSHIELD, have read the Factual Basis for Plea and agree

to the facts and stipulations contained therein.

 

-
- . OWNINSHIEL
Defendant

Dated:

H4 11/! 

PLEA AGREEMENT