Case 7:17-cr-00913 Document 1 Filed in TXSD on 06/05/17 Page 1 of 3

A0 91 (Rev. 032'09) Criminal Complaint

 

 

b?niieo States District 00an

UNITED STATES DISTRICT COURT 
for the i r- .
. ?it? a (in?
Southern District of Texas
David J- Braden Clerk

 

United States of America 
V. 
Erika Vereniz RODRIGUEZ Case No. AL i7~0?77? 
so, DOB: 1984 3

Def?ndant(s)
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(the county of Hidaigo in the
Southern District of Texas the defendant(s) violated;
Code Section O?ense Description,
18 USC 922(g)(1) possession of a firearm or ammunition, which has affected
interstate commerce, by an individual having been convicted of a
felony

This criminal complaint is based on these facts:

See Attachment A

at Continued on the attached sheet.

  

 

ompiainant signature

57 vaa? 

?571/? Steven Medrano - ATF SpeCiai Agent

Printed name and title

Sworn to before me and signed in my presence.

Date: 33' do?. ?fM

Judge ?3 signature

 

City and state: McAllen, Texas US. Maoistrate Peter E. 

Printed name and title

Case 7:17-cr-00913 Document 1 Filed in TXSD on 06/05/17 Page 2 of 3

A0 9i (Rev. 02/09) Criminal Complaint

ATTACHMENT A

I, Special Agent Steven Medrano, af?ant, do hereby depose and state the
following: i
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 May 2010.

1. My duties include the investigation of violations of Federal ?rearms laws. I
- know it to be unlawful for any person who has been convicted of a crime
punishable by more than'one year in prison to possess a ?rearm.

2. On Saturday, June 3, 2017, a Texas Department of Public Safety Trooper
conducted a traf?c stop on a dark in color 2011 Ford Taurus displaying Texas
license plate on US. 281 Southbound in San Manuel, Texas for a traf?c
violation. Erika Vereniz RODRIGUEZ was the driver of the vehicle and was
traveling with one passenger. During the traf?c stop, the DPS trooper conducted a
criminal history check on RODRIGUEZ and discovered RODRIGUEZ was a
convicted felon. During the stop, RODRIGUEZ advised the trooper that she had
?rearms in the vehicle and granted the trooper consent to search the vehicle. Upon
searching the vehicle, the DPS trooper discovered seven (7) style ri?es, one
(1) AK-47 style pistol, and one (1) 50 caliber ri?e in the trunk of the vehicle. The
serial numbers to all nine (9) ?rearms were obliterated. The DPS trooper contacted
ATF agents and advised them of the traf?c stop resulting in the discovery cf nine
?rearms with obliterated serial numbers located in the trunk of the vehicle driven
by Erika Vereniz RODRIGUEZ.

3. During a post-Miranda interview, RODRIGUEZ stated all nine (9) ?rearms
belonged to her and informed ATF agents the passenger who was with her had no
knowledge of the ?rearms in the vehicle.

Case 7:17-cr-00913 Document 1 Filed in TXSD on 06/05/17 Page 3 of 3

50 91 (Rev. 2109) Criminal Complaint

 

ATTACHMENT A

4. The ?rearms were found to be manufactured outside of Texas and affects
interstate or foreign commerce. The ?rearms are involved in a violation of 18 USC
The ?rearms are subject to forfeiture under 18 USC 924(d).

5. In 2015, RODRIGUEZ, was convicted of Possession of Marijuana a 2nd degree
felony in the 155th District Court of Fayette County,Texas. RODRIGUEZ was
sentenced to six (6) months to the custody of the Texas Department of Criminal
Justice and ten (10) years probation. RODRIGUEZ is prohibited from possessing a
firearm having been convicted of a criminal offense with a punishment greater than
one year.

 

Steven Medrano ATF Special Agent

Sworn to before me and subscribed in my presence,

 

 

U.S. Magistrate Peter E. Date