Case 7:17-cr-00690 Document 1 Filed in TXSD on 05/04/17 Page 1 of 3 95.524 ?Willem A091 (Rev. 02/09) Criminal Complaint Wmd?! UNITED STATES DISTRICT COURT MAY 04 2017 for the Southern District of Texas . United States of America V- l9 80 8' Lombardo BAZAN-Barrera Case No. YOB: 1985 Defendant CRIMINAL COMPLAINT I, the complainant in this case, state that the following is true to the best of my knowledge and belief. On or about the date of 01/08/2015 in the county of Hidalgo in the Southern District of Texas the defendant violated offense described as follows: in that the defendant Lombardo BAZAN did conspire to knowingly makes any false statement or representation with respect to the information required by this chapter to be kept in the records of a person licensed under this chapter or in applying for any license or exemption or relief from disability under the provisions of this chapter. This criminal complaint is based on these facts: SEE ATTACHMENT A if Continued on the attached sheet. 9a.] 6 am ?3 Complainant? signature . . A +9 David B. Weiss - ATF Special Agent A14 5A Printed name and title Sworn to before me and signed in my presence. Judge ?3 signature Date; (95/04/2017 City and state: McAllen, Texas Dorina Ramos, U.S. Magistrate Judge Printed name and title Case 7:17-cr-00690 Document 1 Filed in TXSD on 05/04/17 Page 2 of 3 A0 91 (Rev 02:09) Criminal Complaint ATTACHMENT A 1, Special Agent David Weiss, af?ant, do hereby depose and state the following: I am a Special Agent of the United States Department of Justice, Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). I have been a law enforcement of?cer since April 2007. 1. My duties include the investigation of violations of the Federal firearms laws. I know it to be unlawful for any person in connection with the acquisition or attempted acquisition of any ?rearm(s) from a licensed dealer, knowingly to make any false or ?ctitious oral or written statement or to furnish or exhibit any false, ?ctitious, or misrepresented identi?cation, intended or likely to deceive such dealer with respect to any fact material to the lawfulness of the sale of such ?rearm(s). Furthermore, it is a violation of the Federal ?rearms laws for a person to knowingly make any false statement or representation with respect to the information required to be kept in the records of a licensed Federal ?rearms dealer (FFL). 2. On January 10, 2016, in Hidalgo, Texas, US. Customs and Border Protection Of?cers arrested Joseph GONZALEZ at the Hidalgo Port-of-Entry for attempting to illegally export defense articles. A subsequent secondary inspection and search of vehicle yielded 16 ?rearms. A subsequent trace of the 16 ?rearms showed four of the recovered ?rearms, Make: Glock, Model: 42, Caliber: 9mm, Serial Numbers: ABHF281, ABHH797, ABAY766, and AAXAO39, were purchased by Lombardo BAZAN. Case 7:17-cr-00690 Document 1 Filed in TXSD on 05/04/17 Page 3 of 3 A0 91 (Rev. 02/09) Criminal Complaint 1 ATTACHMENT A 3. On September 13, 2016, Lombardo BAZAN was interviewed. During the interview, BAZAN admitted purchasing the four ?rearms in January 2016. BAZAN stated he traded those four ?rearms for a 1993 Ford F-150 pick-up truck. Record checks of the Ford F-150 title and registration revealed that the pick-up was sold for $800 dollars on May 19, 2016. A subsequent interview ofthe previous Ford F-150 owner con?rmed that the vehicle was purchased for money and that no trade involving four ?rearms occurred. 4. During the summer of 2016, ATF Special Agents interviewed two co-conspirators in reference to their ?rearms purchases. Both co?conspirators stated that they had purchased ?rearms for BAZAN. These individuals explained that they were recruited by BAZAN to purchase ?rearms and that they were paid by BAZAN after completing the purchases. The co-conspirators told Agents that BAZAN would supply them with money to purchase the ?rearms and that BAZAN would instruct them on which ?rearms they should purchase. 5. The co-conspirators told Agents that BAZAN traveled with them to the FF Ls to purchase ?rearms on certain occasions. The co?conspirators stated that BAZAN often sent them to purchase ?rearms at FFLs in Hidalgo County without accompanying them and that BAZAN would take possession of the illegally straw purchased ?rearms after they were purchased. 6. Based upon the above information, it is alleged that BAZAN violated the Federal Firearms Laws by illegally straw purchasing ?rearms, and by conspiring and recruiting multiple individuals to illegally straw purchase ?rearms. BAZAN is in violation of Title (18) United States Code, Sections 924(a)(1)(A) and 371.