Case 7:19-cr-00865 Document 1 Filed on 05/03/19 in Page. 1 of 2 
United States District Court

A0 91 (Rev. 08/09) Criminal Complaint Southern District 2:35

UNITED STATES DISTRICT COURT MAY 3 2019 

 

 

for the
Southern District of Texas . . Dav'd J- Bradley, Clerk
4 United States of America I
V. 
Alberto De Leon Case No. (0 Lg 
YOB: 1993, 
(USC) . 

Defendant{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(s) of April 29, 2019 in the county of Cameron in the
Southern District of -'Texas the defendant(s) violated:
Code Section O?ense Description

18 U.S.C. 
De Leon, a felon having been convicted of a crime punishable by imprisonment for a

term exceeding one year, possessed a ?rearm in and affecting interstate commerce.

This criminal complaint is based on these facts:

See Attached Probable Cause Af?davit

Continued on the attached sheet.

 

 

Complainant signature

 

?4 VJJO . I i - ATF Special Aqent Steven Medrano
7 Q, (V Que/rm Printed name and title

Sworn to before me and signed in my me .

Date: 05/03/2019 7 
. Judge ?3 signature . I
City and state: McAllen, Texas J. S, ott Hacker, US Magistrate Judge

 

Printed name and title

Case 7:19-cr-00865 Document 1 Filed on 05/03/19 in TXSD Page 2 of 2

A0 91 (Rev. 2/09) Criminal Complaint

 

 

ATTACHMENT A

PROBABLE CAUSE AFFIDAVIT

On April 29, 2019, ATP Special Agents observed a female, later identi?ed as REYNAGA, at a Federal
Firearms Licensee (FFL) Dannys Pawn Shop in McAllen, Texas. Agents observed REYNAGA pay for a
?rearm with cash, later identi?ed as a FN pistol, model: ?ve- -seven, Serial Number (SN): 386363913, for
approximately 500 00. After REYNAGA purchased this ?rearm, she carried the ?rearm out in a brown

paper bag and entered her vehicle.

Agents conducted mobile surveillance on REYNAGA and followed her as she drove to a nearby Popeye's
restaurant. Agents observed a male, later identi?ed as Alberto DE LEON, enter .the front passenger side of
vehicle. Agents continued to maintain surveillance on REYNAGA and DE LEON as they

traVeled from McAllen, Texas to 2804 Elena Street in .Brownsville, Texas.

Upon arrival at 2804 Elena Street, REYNAGA and DE LEON exited the vehicle. The agents observed DE
LEON carrying the brown? paper bag containing the FN pistol. Agents approached DE LEON and identi?ed
themselves. DE LEON walked over to agents, still carrying the brown paper bag. 
DE LEON admitted to the agents that he was a convicted felon who was prohibited from possessing ?rearms.

A records check revealed that DE LEON was convicted on November 26, 2012, in the 197th Judicial District 1n
the State of Texas, for Possession of a'Controlled Substance which was punishable by imprisonment for a term

exceeding one year.

DE LEON admitted to knowing he was carrying the ?rearm but claimed that he was not the owner..DE LEON
stated that REYNAGA was the owner of the ?rearm but that he was merely carrying it for her.

When agents observed the bag, the ?rearm was no longer in the box but was loose inside the brown paper bag.
Agents questioned REYNAGAfseparately and she admitted that after she purchased the ?rearm that DE LEON

had removed the ?rearm from the box and was handling it while they drove to Brownsville.

An ATP interstate nexus expert has determined that this ?rearm was not manufactured in the state of Texas,
and therefore has affected interstate commerce.

 

 

WEI Agent Steven Me'drano

Sworn to before me a subscribed in my presence,

05/03/2019.

 

/Sc tt Hacker, US Magistrate Judge - Date