USA v. Ruben Ramirez et al_firearm charges

8/7/2019 USA v. Ruben Ramirez et al_firearm charges

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Case 4:11-cr-00053-A Document 1 Filed 03/10/11 Page 1 of 9 PageID 1

ORIG\NAlUNITED STATES DISTRICT b O U R 1 { ~ " ,NORTHERN DISTRICT OF JfEXAS{ M ~ I 0 20/1 I

FORT WORTH DIVISIQN ! ~ " _ , II,-1

UNITED STATES OF AMERICAv.

RUBEN RAMIREZ (1)ROMEO RAMIREZ (2)ERNESTO MANZANAREZ (3)

( '; . COI.iliT

CASE NO. 4: Il-MJ-O , 9

CRIMINAL COMPLAINT

Complainant Joshua Yoder, being duly sworn, state the following is true andcorrect to the best ofmy knowledge and belief:

Alien Unlawfully in the United Statesin Possession of a Firearm in Commerceand Aiding and Abetting

On or about March 9, 2011, in the Fort Worth Division of the NorthernDistrict ofTexas, the defendant, Romeo Ramirez, then being an alien,unlawfully and illegally in the United States, did knowingly and unlawfullypossess in and affecting interstate commerce a firearm, to wit, a A. CenturyArms, Model GP WASR 10, 7.62x39mm, rifle, Serial Number 1985SBJ4385;B. Century Arms, Model GP WASR 10, 7.62x39mm, rifle, Serial Number1971CB3451; C. Century Arms, Model GP WASR 10, 7.62x39mm, rifle,Serial Number 1972CB4595; and D. DPMS, Model Panther LR-308, .308caliber rifle, Serial Number 65970; and the defendants, Ruben Ramirez andErnesto Manzanarez did aid, abet, counsel, command, induce and procure thecommission of the above offense.

In violation of 18 U.S.C. 922(g)(5), 924(a)(2) and 2.

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I am a Special Agent assigned to the Fort Worth office of the Bureau ofAlcohol, Tobacco, Firearms and Explosives (ATF). The information set out hereinis based on my own investigation and statements and reports of the withinnamed law enforcment officers.

1. Complainant, Joshua Yoder, is currently assigned as a Special Agentwith the Bureau ofAlcohol, Tobacco, Firearms and Explosives (ATF).Complainant is assigned to the Fort Worth, Texas Field Office of the Bureau ofAlcohol, Tobacco, Firearms and Explosives (ATF). Complainant has been aSpecial Agent for the ATF for the past nine years.

2. This complaint is based upon the Complainant's interviews ofwitnessesand review ofphysical evidence, and other information related to Complainant bySpecial Agents with the Bureau ofAlcohol, Tobacco, Firearms, and Explosives(ATF) and Special Agents with the Department ofHomeland Security (ICE).

3. OnMarch 9, 2011, ATF Special Agent Josh Yoder was informed ofapossible "straw purchase" that would occur that afternoon at Cheaper Than Dirt,2522 NE Loop 820 Service Road South Fort Worth, TX, a federally licensed firearmsdealer in Fort Worth, Texas.

4. OnMarch 9,2011, ATF and ICE agents established surveillance insideand around the firearms dealer in Fort Worth. At approximately 2:30PM twovehicles entered the store parking lot, an orange Hummer, bearing TX Licenseplate BP7 K893, occupied by four males and a blue Grand Am, bearing TXu.s. v. Ramirez, Et AI.Cause No. 4:11-MJ-O Page 2


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License plate, 866XNJ, occupied by two males. The driver of the Grand Amentered the store and purchased four (4) rifles with cash. The Hummer wasobserved driving in and around the area of the store and stopped and parked in aparking lot south of the store. After purchasing the rifles, the individual exited thestore with a store employee who helped load the rifles into the blue Grand Am.

5. ATF and ICE agents, with the assistance of Fort Worth Police, followedthe blue Grand Am as it drove south on the service road and entered south-bound1-35 as did the orange Hummer. The vehicles drove to the east side ofFort Worthwhere the Grand Am stopped in the street in front of a convenience store on thecomer ofMiller and Rosedale and the Hummer stopped in the convenience storeparking lot. Agents observed two individuals get out of the Hummer as the twooccupants of the blue Grand Am got out of it. The two individuals that exited theHummer got into the Grand Am and drove away with the firearms. The twoindividuals that exited the Grand Am, to include the actual purchaser of thefirearms, got into the back seat of the Hummer and the Hummer drove away.

6. Agents with ICE continued surveillance of the blue Grand Am andobserved it pull into the driveway of 1021 S. Sergeant, Fort Worth, TX. ICE agentsconducted a stop of the vehicle where the driver of the Grand Am was identified asRomeo RAMIREZ (WIM 01/21/86). The passenger of the Grand Am was identified asEmesto MANZANAREZ (WIM 10/06/86). The four rifles were found in the back seat ofthe Grand Am.u.s. v. Ramirez, Et AI.Cause No. 4:11-MJ-O Page 3


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7. Agents with ATF followed the orange Hummer where Fort Worth Policeconducted a vehicle stop in a commercial parking lot off of Felix at 1-35 in FortWorth, TX. The driver of the Hummer was later identified as Ruben RAMIREZ (W/M07/23/83), the front seat passenger was identified as Ramon SALINAS (W/M OS/26/86),the rear seat passenger side occupantwas identified as a juvenile A. O. (W/M 05/15/93).The rear seat driver's side occupant was identified as the straw purchaser of the firearms,Josh Cisneroz (W/M 08/24/90).

8. All six individuals were taken to a Fort Worth Police Departmentsubstation and advised of their rights per Miranda.

9. ATF Special Agent Gus Benavides advised Ramon Salinas of hisMiranda rights. Salinas advised that he understood his rights and was willing toanswer questions and make statements at that time without an attorney present.Salinas stated that he was here illegally and had been living with Ruben Ramirezfor the past two weeks. Salinas advised that he was getting a ride to Fort Worthwith Ruben so he could meet a friend that was going to take him to OklahomaCity, OK. Salinas stated that they met with the individuals in the Grand Am at agas station and Ernesto (Manzanarez) got out of the Hummer and into the GrandAm. Salinas advised that when Ernesto got back in the Hummer someone askedhim howmuch money he gave them and Ernesto stated that he gave him a lot ofcash plus $40.00 for gasoline. Salinas advised that Ernesto said they were buying"Toys" with the money. Salinas advised that everyone knew that "Toys" meantu.s. v. Ramirez, Et AI.Cause No. 4:1l-MJ-O Page 4


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guns. Salinas stated that they didn't discuss how many guns were being bought orwhere the guns were going but he assumed they were headed to Mexico.

10. ATF Task Force Officer Dallas Seals advised Ernesto Manzanarezofhis Miranda rights. Manzanarez advised that the understood his rights and waswilling to answer questions and make statement at that time without an attorneypresent. Initially Manzanarez stated he and his friends were driving fromComanche to Fort Worth to go shopping at the mall. Manzanarez advised thenames of his friends were Alfredo, Romeo and Ramon, but that he did not knowany of their last names. Manzanarez was very upset and repeatedly said he was infear for his family's life. Manzanarez said he did not know anything about theguns until Alfredo went to the gun store. TFO Seals advised Manzanarez he wasnot being truthful because agents knew Alfredo was not the nameof the driver ofthe Hummer. Manzanarez then advised he was contacted by Ruben Ramirez onMarch 5, 2011. Ruben Ramirez told Manzanarez that he was going to bring

C.N\ ...... ~ money to him in.ceffltlche, Texas. Ruben Ramirez told Manzanarez that ifhe didnot transport the money, Manzanarez's family would be killed. Manzanarezagreed to bring the money to Ruben Ramirez because he feared for his family inDel Rio, Texas and Mexico. On Sunday March 6, 2011 Manzanarez met RubenRamirez in Senora Texas and got Ramirez's Hummer to drive the money toComanche. On Tuesday March 8, 2011, Manzanarez was contacted by anunknown Hispanic male who met him and gave him $10,000 US currency to takeu.s. v. Ramirez, Et AI.Cause No. 4:11-MJ-O Page 5


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to Ruben Ramirez. Manzanarez stated he immediately drove to Comanche, Texasand gave the money and the Hummer to Ruben Ramirez. Manzanarez advisedRuben Ramirez told him the money was to buy guns to send to Mexico for theZetas to fight the war. Manzanarez stated he rode in the Hummer with RubenRamirez to the gun store. Manzanarez stated they waited in the Hummer while the"white kid" bought the guns for Ruben. Manzanarez advised they drove awayfrom the store together and were going to get the guns from the "white kid" at adifferent location. Manzanarez advised Ruben stopped at a store and told him andRomeo Ramirez to get in the "white kid's" car and they did. Manzanarez advisedthey drove around the comer and then were arrested. Manzanarez had $1857dollars in his pocket and he advised it was Ruben Ramirez's money that Rubentold him to hold when he got outof the Hummer.

11. ATF Special Agent Gus Benavides advised Romeo Ramirezof hisMiranda rights. Romeo Ramirez advised that he understood his rights and waswilling to answer questions and make statements at that time without an attorneypresent. Romeo Ramirez advised that he was a native and citizenofMexico hereillegally and had been living in Minnesota with his girlfriend. Romeo Ramirezdidn't want to answer any questions about the firearms or his knowledgeof them.

12. ICE agent Lina Gilderson advised Ruben Ramirez, who initially statedhis name was Alfredo Beltran, of his Miranda rights. Ruben Ramirez advised thathe understood his rights and was willing to answer questions and make a statementu.s. v. Ramirez, Et AI.Cause No. 4:11-MJ-O Page 6


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at that t ime without an attorney present. Ruben Ramirez stated that he was born inSonorra, Sonorra, Mexico. Ruben Ramirez admitted that he had last entered the UnitedStates(U.S.) in approximately January 2007 without inspection or authorization andfurther admitted that he was illegally present in the U.S. Ruben Ramirez stated that hewas employed through a company named Lakeside foods as a seasonal employee and hadtraveled to Minnesota and NewMexico as well as Proctor, Texas working in the fieldspicking com, watermelons, etc...

13. Ruben stated that he was approached by an unknown male at a gas station in

Comanche, Texas and offered $500.00 to pick up approximately two (2) or three (3)persons in the Fort Worth area. Ruben initially stated that he did not own a vehicle andborrowed the orange Hummer owned by a friend named Ruben Ramirez. Later Rubenadmitted that he was in fact Ruben Ramirez and the orange Hummer was his vehicle.Ruben also stated that he was to follow a vehicle, which he identified as a blue PontiacGrand Am with loud mufflers, out of a business parking lot located within some brownbuildings offIH 35 North and Hwy 820 in Fort Worth, Texas. Ruben stated that hefollowed the Grand Am to a gas station that was closed, observed two (2) men exit theGrand AM and enter his orange Hummer. Ruben stated that he was to take the two (2)men, a white male and a Hispanic male, to a Walmart parking lot in Stephenville anddrop the men of f there in exchange for the money. Ruben stated that he gave the

unknown male his cell phone number 254-979-2567 so that the unknown male couldcommunicate with him. Ruben did not have the unknown males phone number. Rubenfurther stated that he observed the white male throw a handful of cash onto the cupholder

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in his vehicle. He placed the cash in the center console of his vehicle. (Agents foundapproximately $4880.00 in the console of Ruben Ramirez's vehicle.)

14. ATF agents contacted representatives ofCheaper Than Dirt regardingthe firearms purchased on March 9, 2011 by Josh Cisneroz. The followingfirearms were purchased for $3063.35 by Cisneroz at that time:

A. Century Arms, Model GP WASR 10, 7.62x39mm, rifle, Serial Number1985SBJ4385;B. Century Arms, Model GP WASR 10, 7.62x39mm, rifle, Serial Number1971CB3451;C. Century Arms, Model GP WASR 10, 7.62x39mm, rifle, Serial Number1972CB4595; andD. DPMS, Model Panther LR-308, .308 caliber rifle, Serial Number 65970.

These firearms were found in the blue Grand Am driven by Romeo Ramirez whenICE stopped the vehicle on March 9, 2011.

15. OnMarch 10,2011, an ATF Interstate Nexus expert informedComplainant that the aforementioned firearms were each manufactured outside theState ofTexas and traveled in interstate or foreign commerce prior to Manzanarezpossessing them.

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16. I have not listed all the facts known to me regarding this case. I have onlylisted those facts I believe necessary to establish probable cause to believe that thedefendants committed the crimes listed above.

Sworn to before me, and subscribed in my presenceMarch 10,2011, at Z \9 a . m . ~Date and Time Issued

U. S. Magistrate Judge Jeffrey L. CuretonName and Title of Judicial Officer

u.s. v. Ramirez, Et AI.Cause No. 4:1l-MJ-O

at Fort Worth Texas

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USA v. Ruben Ramirez et al_firearm charges