LnCase Document 1 Filed 07/16/15 Page 1 of 3

 

BENJAMIN R. WAGNER
United States Attorney

KAREN A. ESCOBAR
Assistant United States Attorney
2500 'I?ulare Street, Suite 4401
Fresno, CA 93221

Telephone: (559) 497-4000
Facsimile: (559)492?4099




JULTB

CLERK. U.S. DIST

Attorneys for Plaintiff
United States of America

IN THE UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF 

UNITED STATES OF AMERICA,
Plainti?',



2015

RICT COURT

EASTERN DISTRICTOF CA -IFOFINIA

 

caseno. l: 1 ca 00190 HO sate

VIOLATIONS: 13 U.S.C. 39A Aiming a Laser

v. Pointer at an Aireralt; 26 U.S.C. 5341, 5361(d),

PABLO CESAR SAHAGUN,
use. 5372, and 23 use ?2461(

Defendant. Forfeiture.

 

 



COUNT ONE: [18 USC. 39A - Aimng a Laser Pointer at an Aircraft]
The Grand Jury charges: A 

PABLO CESAR SAHAGUN,

and 58?] A Possession of 7' Unregistered Destructive
Devices; l8 981(a)( I 26

c) Criminal

detendantherein, on or about February 26, 2015, in the Countyr of Kern, State and Eastern District of

Calitiornia, did knowineg aim the beam ol'a laser pointer at an aircraft, namely, Air-1, a Kern County

Sheri ff?s Of?ce helicopter. in the special airera?jurisdietion ol? the United States, andl'or at the ?ight

path of said airera ft, in violation of Title 18, United States Code, Section 39A.
if!
If!
If!



 

Case Document 1 Filed 07/16/15 Page 2 of 3

COUNT TWO: 584 . 536! and Possession of? Unregistered

Destructive Devices'l
The Grand Jury charges: A 
PABLO CESAR 
defendantherein. on or about February 26, 20] 5, in the County of Kern, State and Eastern District of
California, did knowingly possess seven firearms. as defined in Title 26, United States Code, Section
58450). to wit: seven destructive devices, known as C02 cartridge or Cricket bombs, not registered to
him in the National Firearm Registration and Transfer Record, in violation of Title 26, United States

Code, Sections 584] 586] and 587].

 

FORFEITURE ALLEGATION: [18 U.S.C. 26 U.S.C. 5872, and
28 U.S.C. 2461(e) - Criminal Forfeiture]
1. Upon conviction of the offense alleged in Count One of this Indictment, defendant

PABLO CESAR SAHAGUN shall forfeit to the United States, pursuant to 18 U.S.C. 
and 28 U.S.C. 2461(c), all property, real or personal, which constitutes or is derived
from proceeds traceable to such violation. or is property derived from, involved in, or used or intended
to be used to commit the alleged offense. including, but not limited to:

a. one black key-activated laser pointer emitting a green laser beam and bearing the
words, ?Laser 301" and containing a blue, black and silver danger warning.

2, Upon conviction of the olfensc alleged in Count Two of this Indictment, defendant
PABLO CESAR SAHAGUN shall forfeit to the United States, pursuant to 26 U.S.C. 5372 and 23
U.S.C. 2461(e), any ?rearm or destructive device involved in the alleged offense, including but not
limited to the following:

a. seven firearms, consisting of seven destructive devices, known as C02 cartridge
or Cricket bombs.

3. If any property subject to forfeiture as a result of the offenses alleged in Counts One and
Two of this Indictment, for which defendant is convicted:

a. cannot be located upon the exercise ofdue diligence;

2

 

Case Document 1 Filed 07/16/15 Page 3 of 3

b. has been transferred or sold to, or deposited with, a
third party;

C. has been placed beyond the jurisdiction of the court;

d. has been substantially diminished in value; or

e. has beeu oontntingled with other preperty which cannot be divided without
dif?culty;

it is the intent of the United States, pursuant to 23 U.S.C. 246 incorporating 21 U.S.C. 853(p), to

seek forfeiture of any other property ofsaid defendant, up to the value of the property subject to

 

forfeiture.
A TRUE BILL.
mum
FOREPERSON
BENJAMIN B. WAGNER

United States Attorney

Ma?t E. Bullets

 

 

 

By MARK E. CULLERS
Assistant United States Attorney
Chief, Fresno Office

INDICTMENT