Case 7:194mj-02459 Document 1 Filed on 10/10/19 in szo? Page'l of 2

A0 91 (Rev 02/09) Criminal Complaint 
United assesses 
5??themFI LED UNITED STATES DISTRICT COURT .
20i9 . . 

Southern District of Texas.
David J. Bradley,- Clerk

 

United States of America .)
7V. 
- OlOscarAntonio YOB: 1983 use .. Case No. 101- ?l 501 -- 
-oZJose Ventura DE LEON- FUENTES . (-
Mexican National - . 
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 10/09/2019 in the county of Hidalgo in the Southern District of

Texas the defendant violated . Title 18 U. S. C. 924(a)(1)(A) and 2(8)
an Offense described. as follows: 

Whoever knowingly makes any false statement or representation With respebt to the information required to be kept In
the records of a federal rearms licensee.

Whoever commits an offense against the United States or aids, abets, counsels, commands, induces or precures its
commission, is punishable as a principal. .

This, criminal complaint is based 'on these facts:

SEE ATTACHMENT A

if Continued on the attached sheet.
Complain-(Tm ?sls?gnature

Michael Cardenas, ATF Senior Special Agent

Approved by WSA I Am areal/1?04??" loll pl"! - Printed name and title

 

Sworn to before me and signed in my presence. -

 

. Date; 10/10/2019 - (57.525;? 4.

 

 

Judge ?3 signature
City and state: . McAllen, TX Juan Alanis, U.S. Magistrate Judge

Printed name and title

Case 7:19-mj-02459 Document 1 Filed on 10/10/19 in TXSD Page 2 of 2

A0 91 (Rev. 02/09) Criminal Complaint

ATTACHMENT A

This af?davit is in support of a criminal complaint charging Oscar Antonio (hereina?er
referred to as and Jose Ventura DE LEON-FUENTES (hereinafter referred to as 
with the criminal violation set forth in Attachment A. The evidence available to me
demonstrates that there is probable cause that DE aided and abetted FLORES-ARRIAGA in
violating Title 18 U.S.C. Section 924(a)(1)(A) whichprovides as follows: Whoever, knowingly makes any
false statement or representation with respect to the information required to be kept in the records of a federal

?rearms licensee (FF L).

Further, the Af?ant states as follows:

On or about October 9, 2019, ATP Agents, to include your af?ant, and HSI Agents were conducting
surveillance in the area of a Federal Firearms Licensee (FF L) located in Hidalgo County, Texas when agents
observed LORBS-ARRIAGA and DE LEON-FUENTES exit the FFL. Agents observed

LORES-ARRIAGA walking out of the FFL with a brown paper bagand one ri?e cardboard box. Agents
observed DE LEON-FUENTES enter the driver's seat and FLORES-ARRIAGA enter the front passenger seat
of a Mexican plated vehicle. -

agents maintained surveillance once DE and LORES-ARRJAGA departed from
the FF L. Agents made Consensual contact with FLORES-ARRIAGA and DE when, the 
vehicle'driven by DE LEON-FUENTES parked at a residence in Mission, TX. Agents asked
and DE if they would be willing to consensually speak to Agents at
the Mc?Allen? HSI Of?ce to which both agreed;

Post Miranda interview of revealed that FLORES-ARRIAGA was recruited by DE
LEON-FUENTES to purchase a Browning .380 pistol and one Browning .270 caliber bolt action ri?e forDE
LEON-FUENTES. PEBEON-FUENTES provided him with the money to
purchase both the ?rearms. mail-ES stated he was paid approximately $200, for the purchase of
both ?rearms, for his pro?t. FLORES-ARRIAGA admitted to making a false statement on ATF Form 4473
when he indicated that he was the actual purchaser when in fact, he was purchasing the ?rearms for DE
LEON-FUENTES. 

Post-Miranda interview of DE LEON-FUENTES revealed that DE provided
FLORES-ARRIAGA with the money to purchase both ?rearms. DE LEON-FUENTES stated that he provided
- FLORES-ARMAGA with the money to purchase the ?rearms so both DE LEON-FUENTES and .
FLORES-AERIAGA could go hunting at a later date. DE LEON-FUENTES stated he knew he could not
purchase'the ?rearms because he was a Mexican National and could not purchase ?rearms from an FFL.