0 t - Guns.com · the actual tr=sferee/buyer of the firearm; and si> the form in the box entitled...
Transcript of 0 t - Guns.com · the actual tr=sferee/buyer of the firearm; and si> the form in the box entitled...
(
*4
UNITED STATES DISTm CT COURTSOUTHERN DISTW CT OF FLORIDA
CASE NO. IS-I8OO8-CR-M ARTINED SNOW t:)
18 U.S.C. j 371jg uxsoc. j kzz(b)(1)18 U.S.C. j 922(b)(t)
18 U.S.C. j 922(b)(5)18 U.S.C. j 922(4)(1)18 U.S.C. j 924(a)(1)(D)18 U.S.C. j 924(d)(1)26 U.S.C. j 5861(d)26 U.S.C. j 5872(a)
p/zeoUNITED STATES OF AMERICA â
0 t,7
vs. #d# ,ar - ? 2n3cettyz/,F'zf/i t4JARVIS NELSON OSORIO
, 4. g>h). , pjyyyv' THOMAS JOSEPH WILLI, and %.k)1. - y)j ( y, ) y
yOUTBQEAK ORDNANCE, LLC,
Defendants./
SUPERSEDING INDICTM ENT
n e Orand Jury charges that:I
GENERAL ALLEGATIONS
At al1 times relevant to this Superseding Indictment:I
Federal Firearm s Licensees
1. n e Bureau of Alcohol, Tobacco, Fireanns and Explosives (%1ATF''), an agency ofI
the United States Department of Justict. administered and enforced laws and regulations
pertaining to the acquisition and disposition of firearms and the licensing K d operation ofI
lirearms dealers.
2. A person or business who desired to engage in the business of dealing in sreannsI
was required to obtain a federal lirearms license from ATF.if
'
I ti i
l ll l
f !I
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 1 of 32
Defendant OUTBREAK ORDNANCL LLC was a limited liability company
incorporated on January 1 1 , 201 3, and located at 1 1 County Road, Big Pine Key, Monroe
County, Floridw 33043.
4. Defendants JARVIS NELSON OSORIO and THOMAS JOSEPH W ILLI
owned and operated OUTBREAK ORDNANCE, LLC and sold flrearms and ammunhion at its
rttail stort in M omoe Coumy, Flodda.
OUTBREAK ORDNANCE, LLC was a federally Iicensed firearms dtaler as of
September l2, 2013, and was assigned federal flrearms Iicense number 1 5923297 by ATF.
6. A federally licensed firearms dealer was prohibittd from selling or transferring
firearms to a person if the dealer knew or had reasonable caus: to believe that said person was a
convicted felon, that is, the person had bven convicted in a court of a crime punishable by a term
of imprisonment exceeding one year.
A convicted felon was prohibited from purch%ing or possessing firearms.
8. A federally licensed Iirearms dealer was required to initiate a criminal history
background check on a prospective srearm buyer through the National Instant Criminal
Background Check System (GN1CS''), prior to the sale or transfer of a firearm to any person.
9. If the buyer or transferee had a prior felony conviction, the federally licensed
fireanns dealer would receive a ççdenied'' responst from the NICS check, and would be
prohibited from proceeding whh the sale or transfer of the firearm to the buyer or transferee with
the criminal history.
10. A federally licensed firearms dealer was prohibited from selling or delivering any
firearm or ammunition to any individual who the licensee knew or had reasonable cause to
believe was less than eightcen years of age, and, if the firearm, or nmmunition, wms other than a
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 2 of 32
.*
shotgun or ritle, or ammllnition for a shotgun or rifle, to any individual who the licensee knew or
had rea onable cause to believe was less than twenty-one years of age.
ATF Form 4473
l 1. Before a federally licensed firearms dealer tould sell or transfer a firearm to any
p N rson, the federally Iicensed firearms dealer and tht buyer or transferee were required to
complete ATF Form 4473.
12. By completing the ATF Form 4473, the federally licensed firearm s dealer was
rtquired to;i
1 a. dttermine thx the person signing his or her name in the box entitledl çê-l-mnsferee's/Buyer's Sir aturt'' was the actual transferee or buyer of the flrearm;
b. verify the transferee or buyer's true identity by inspecting a driver's liccnse or
other form of photographic identiication displaying the name, address, and date of birth of the
transferee/buyer;
c. verify the transferee or buyer's answers to a11 questions on the form to ensure that
the transferee/buyer of the Grearm was not a prohibited person; I
d. describe the type of firearm, manufacturer and/or importer, model, serial number,
and calibtr or gauge of the firearm being sold or transferred on the form; I
e. transmit the transferee or buytr's identifying information for a NICS check l fore
transferring the firearm to the transferee or buyer; j
f. transfer the firearm to the transferee or buyer only aRer receiving a ttprocecd''
rnotice from the NICS check;I
g. document the information from the NICS check on the form;
1
(.I
3
I
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 3 of 32
h. docllment the federal lirrarms dealer's name, address, and license number on the
ATF 4473 form;
certify that th: federally licensed firearms dealer believed that it was not unlawful
to sell, deliver, transport, or otherwise dispose of a srearm to the ptrson identified in the form as
the actual tr=sferee/buyer of the firearm; and
si> the form in the box entitled StTransferor's/stller's Signature.''
13. Once ATF Form 4473 was completed and the firesrm was transferrtd or sold, the
federally licensed firearms dealer was required to maintain the form on the business premises for
at least twenty (20) years.
14. n e federally licensed firearms dealer was also required to record the acquisition
and disposition of every firearm in an Acquisition and Disposition record C$A & D book''),
which the dealqr was required to keep on the business premises. Upon disposition of a firearm,
tht licensed dealer was required to record the date of disposition, the transferee's nnme, and the
transferee's address or federal Grearms license number.
A federally licensed llrearms dealer was prohibited from knowingly causing to be
made or making a false entry in, failing to make an entry in, or failing to properly maintain any
record which he was required to keep pursllnnt to fedtral law or regulations ptrtaining to the salt
or transfer of firearms.
16. Proper recordkeeping and documentalion as mandated by federal 1aw was
essential when an insm ction or examination of those documents wms required for determ ining
the disposition of one or more srearms in the course of a bona fide criminal investigation.
4
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 4 of 32
National Firearms Act-
17. n e National Firearms Act C%FA'') was a comprehensive taxing scheme that
: regulated the manufacture, sale, and transfer of certain specially dangerous and concealable
weam ns, including short-barreled shotguns, short-barreled ritles. any weapon or dcvice capable
of being concealed on the person from which a shot can be discharged through the energy of an
! explosive, machineguns, silencers, and destructive devices.
l 8. Under the NFA, a manufactmer, importer. or dealer of a covertd firearm was
required to register with ATF, pay an occupational excise tax, and register each covered ûrearm
with ATF in the Naîional Firearms Registration and Transfer Record (CtNFRTRM). n e maker or
subsequent transferor of a covered fsrearm was permitted to transfer the wcapon only pursuant to
the NFA, which rtquired that the m aker or transferor identify itself, the Erearm, and thv
% nsferee, and apply for and receive approval from ATF.
19. The makvr or transferor of a covered firearm was required to pay a transftr tax for
each firearm transferred.
I
20. Under the NFA, it was unlawful f0r any person to receive or possess a firearm
which was not registered to him in the NFRTR.I
Floridags M andatoa Three-Dav W aitinz Period for Haadeuns
21 . Section 790.0655 of the Florida Statutes required a mandatory three-day waiting j
period between the date on which a handgun was purchased and the date on which the handgun
was delivered to the buyer by the retailtr. The statuk made it unlawful for any retailer, or any I
employee or agent of a retailer, to deliver a handgun before the expiration of the three-day
waiting period. I
I
l (5 l l
I I
I .1l l
I
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 5 of 32
22. Section 790.0655 of the Florida Statutes deGned çlpmchase'' as the transfer of
money or other valuable consideration to the retailer.
23. Section 790.0655 of 1he Florida Statutes defined Sshandgun'' as a firearm capable
of bting tarried and used by one hand, such as a pistol or revolver.
24. Section 790.0655 of the Florida Statutes includes in the delinition of itretailer''1i .
every person engaged in the business of making sales at retail.
COUNT 1Conspiracy
(18 U.S.C. j 371)
1 . Paragraphs 1 through 24 of the General Allegations of this Superseding
Indictment are realleged and incomorated by reference ms though fully set forth herein.
2. Beginning at ltast as early as September 12, 2013, and continuing through thc
datc of this Superseding Indic% ent, in M onroe County, in the Southem District of Florida, and
elsrwhere, the defendnnts,
JARW S NELSON OSORIO,THOMAS JOSEPH W ILLI. andOUTBREAK OO NANCE, LLC,
did willfully, lhat is, with the intent to further the objects of tht conspiracy, and knowingly
combine, conspire, confederate, and agree with each othvr and others known and unknown to thcI
Orand Jury to commit ctrtain offenses against the United States, that is;
(a) to knowingly sell or othtrwise dispose of a firearm and arnmunition to a person,I
è knowing and having rtasonable cause te believe that such person had been
previously convicted in any court of a crime punishable by imprisonment for a
term exceeding one year, in violation of Title 1 8, United States Code, Sections l
922(d)(1) and 924(a)(2);
I
6
I
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 6 of 32
, (b) being licensed dealers of srearms, within the meaning of Chapttr 44, Title 18,
United States Code, to willfully sell a tirearm and nmmtmition other than a
shotgun and riflt, and nmmunition for a shotgun and rifle, to an individual that the
' defendants knew and had reasonable cause to believe was a person less than
twenty-one years of age, in violation of Title l 8, United States Code. Sections
922(b)(1) and 924(a)(1)(D);
(c) being licensed dealers of ûrearms, within the meaning of Chapter 44, Title 18,
United States Code, to willfully sell and deliver a tsrearm, in the State of Florida,
where the purchase and possession of such frearm would be in violation of State
law then applicablt at the place of sale, that is, Section 790,0655 of the Florida
Stamtes, in violation of Title 18, United States Code, Sections 922(b)(2) and
; 924(a)(1)(D);'
tè )
'
@' (d) to knowingly receive and possess a firearm, that is, a weapon or device capable of;.)t being concealed on the person from which a shot can be discharged through the
Jenergy of an explosive, as defined in Title 26, United States Code. Section('
i 5845(a)(5) and (e), not registered to them in the National Firearms Regiseation l
tj '
'
and Transfer Record, as required by Title 26, United States Code, Section 5841,
. in violation of Title 26, United States Code, Sections 5841, 5861 (d), and 5871 ;
I(t) being licensed dealers of firearms, within the meaning of Chapter 44, Title 18,
l
' ' United Statts Code, to willfully sell and deliver a firearm to a purchaser, withouti
noting in the defendants' records required to be kept by law pursuant to Title l 8,L
) I(t Unitet States Code, Section 923(g)(1)(A), the nnme of said purchaser, in violationt;
i of Title 18, United States Code, Sections 922(b)(5) and 924(a)(1)(D); andf
I7
)
I
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 7 of 32
(9 to knowingly make any false statement and representation with respect to the
information required by Chapter 44 of Title 18, Unittd States Code, to be kept in'
?
the records of a person licensed under this chapter, in violation of Title 1 8, United
'
States Code. Section 924(a)(l )(A).
PURPOSE OFTHE CONSPIM CY
3. It was the pvrpose of the conspiracy to enrich the defendants and their co-
conspirators by illegally selling firearms in exchange for U,S. currency.
MANNER AND M EANS OF THE CONSPIRACY
The manner and means by which the defendants and their co-conspirators sought to
accomplish the objects and pupose of the conspiracy included, among other things, the
following:
l 4. Dming the conspiracy ptriod, OUTBREAK ORDNANCE, LLC, throught
('
l JARVIS NELSON OSOm O and THOM AS JOSEPH W ILLI, sold and Y sferred lirearms. q
'
from the OUTBREAK ORDNANCE, LLC retail stort to individuals who wert prohibited from'
(purchasing and possessing tiresrms.
'
j( 5. JARW S NELSON OSORIO and THOMAS JOSEPH W ILLI sold firearmst
!
from the OUTBREAK ORDNANCE, LLC retail store without requiring the acmal((
transftrees/buycrs to complete ATF Form 4473. j
6. JARVIS NELSON OSOm O and THOMAS JOSEPH W ILLI maintained
incomplete, misleading, and false records of flrearms sales by allowing persons other than the
t actual transferees/buyers of the firenrms to complete ATF Form 4473 for purchases of tirearms.
l(
'
)
p I
. s l' j. è'. l' j
I
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 8 of 32
JARW S NELSON OSORIO and THOMAS JOSEPH W ILLI made false
statements and representations by falsely certifying on ATF Forms 4473 that they believed that
the unlawful firearm transftrs and sales to certain prohibited buyers were lawful.
8. JARVIS NELSON OSORIO and THOMAS JOSEPH W ILLI delivered
fireœms, speciscally, handguns, to firearms buyers at the OUTBREAK ORDNANCE, LLC
retail store before the expiration of Florida's mandatory three-day waiting period.
9. JARVIS NELSON OSOR1O and THOM AS JOSEPH W ILLI sold srearms,
speciGcally, handguns, and handgun ammunition, to çT .P.,'' a person less than twenty-one years
of age, at the OUTBREAK ORDNANCE, LLC retail store.
10. JARVIS NELSON OSORIO and THOM AS JOSEPH W ILLI receivcd and
possessed National Firearms Act firearms,that is, weapons or devices capablv of being
concealed on the person from which a shot can be discharged through the energy of an explosive,
which firearms were not registered to them in the National Firearms Registration and Transfer
Record.
JARVIS NELSON OSORlO and THOM AS JOSEPH W ILLI advertised and
sold National Firearms Act flrearms, which tirearms were not registered to them in the National
Firearms Registration and Tm nsfer Record,
12. JARVIS NELSON OSORIO, THOM AS JOSEPH W ILLI, and OUTBREAK
ORDNANCE, LLC receivcd thousR ds of dollars through tht illegal sale of firearms at the
OUTBREAK ORDNANCE, LLC retail store.
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 9 of 32
OVERT ACTS
In furtbtrance of the conspiracy and to achieve the objetts thereof, at least one of the co-
conspirators committed and caused to be committed, in Monroe County, in the Southern District
of Florida, and elsewhere, at least one pf the following overt acts, among others;
1. On or about September 3. 2014, THOM AS JOSEPH W ILLI provided ATF
Fonn 4473 to a cooperating source (hereinaher, $:CS2''), who listed himself as the actual
transferee/buyer of one (1) Remington brand. 700 model, .308 caliber rifle.
On or about September 3, 2014, THOM AS JOSEPH W ILLI accepted $750.00
as payment for the Remington ritle from a different cooperating source (hereinaher, $'CS1''),
who was a convicted felon and was not listed on ATF Form 4473 as the actual transferee/buyer
of the Remington rifle.
3. On or about September 3, 2014, THOM AS JOSEPH W ILLI transferred the
Remington ritle to CS1 upon the completion of the sale transaction.
4. On or about September 4, 2014, JARW S NELSON OSORlO provided A'I'F
Form 4473 to CS2, who listed himself as the actual transferee/buyer of one (1) Smith & Wesson
brand, M&P15 model, .223 caliber rille and one (l) CCMO. lnc. brand, MK-4 model, 5.56mm
rifle.
5. On or about September 4, 2014, JARW S NELSON OSORIO accepted
$1650.09 as payment for the Smith & W esson rifle and the CCM O ritle from CS1 , who was a
convicted fclon and was not listed on ATF Fonn 4473 as the actual transferee/buytr of thc Smith
& W esson rifle and the CCM G ritle.
10
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 10 of 32
6, On or about September 4, 2014, JARW S NELSON OSORIO transferred the
Smith & Wesson rifle and the CCMG rifle to CS1 and CS2 upon the completion of the sale
transaction.
On or abom September 23, 2014, JARVIS NELSON OSORIO and THOM AS
JOSEPH W ILLI provided ATF Fonn 4473 to CS2, who listed himstlf as the actual
transferee/buyer of one (1) Glock brand, 41 model, .45 caliber pistol bee ng strial number
WMA675 and one (1) Olock brand, 41 model, .45 caliber pistol bearing serial number
W M A678.
8. On or about September 23, 2014, JARVIS NELSON OSOR1O and THOM AS
JOSEPH W ILLI acçcpted $1600.00 as pam ent for the Glock pistols from CSI, who was a
convicted felon and was not Iisted on ATF Fonn 4473 as tht acmal tmnsferee/buyer of the Olock
pistols.
On or about September 23, 2014, JARVIS NELSON OSOm O and THOM AS
JOSEPH W ILLI transferred the Glock pistols to CS1 and CS2 upon completion of the sale
transaction.
10. On or about September 23, 2014, JARVIS NELSON OSORIO and THOMAS
JOSEPH W ILLI transferred the Glock pistols to CSl and CS2 before the expiralion of the
tltree-day waiting period, which was mr dated by Florida law.
On or about February 19, 2015, JARVIS NELSON OSORlO and THOMAS
JOSEPH W ILLI provided ATF Form 4473 to CSI, alkr CS1 told OSORIO and W ILLI that
he was a convicted felon interested in purchasing a Iirearm.
12. On or about February 19, 2015, JARVIS NELSON OSOm O and THOMAS
JOSEPH W ILLI conducted a NICS check on CS1 and received a t'denied'' response.
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 11 of 32
l3. On or about February 19, 2015, JARW S NELSON OSORlO and THOMAS
JOSEPH WILLI accepted $600.00 from CS1 as paymtnt for one (1) Springfield Armory brand,
XD-45 model, .45 caliber pistol.
14. On or about February 25, 2015, JARVIS NELSON OSOm O and THOMAS
JOSEPH W ILLI accepted $800.00 as payment for one (l) Spike's Tactical, LLC brand, SLl5
model, .223 caliber ritle from CSI.
15. On or about February 25, 2015, JARW S NELSON OSORIO and THOMAS
JOSEPH W ILLI transferred the Springfield pistol and the Spikt's rifle to CS1 upon completion
of the sale transaction.
16. On or about April 1, 2015, JARVIS NELSON OSORIO and THOMAS
JOSEFH W ILLI receivtd a Reminglon brand, 870 model,
number A8095765M .
12 gauge shotgun beaHng seHal
On or about April 1,2015, JARVIS NELSON OSORIO and THOMAS
JOSEPH W ILLI received an AFT Inc. brand,
01 l 7CG.
38 caliber lçcane gun'' bearing serial number
18. On or about April 1, 2015, JARVIS NELSON OSORIO and THOM AS
JOSEPH W ILLI received a .380 caliber çmashlight gun'' bearing serial number 030.
19. On or about April 1, 2015, JARVIS NELSON OSORIO and THOMAS
JOSEPH W ILLI received an es Defense brand, .410 bore tlflmshlight gun'' bearing serial
number .R'/oooG V?? J e20. On or about April 1, 2015, JARVIS NELSON OSORIO and THOM AS
JOSEPH W ILLI received a G.R.A.D. brand, .22 caliber lsknife gun'' bearing serial number
D0552.
12
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 12 of 32
21. On or aboqt April 1,2015, JARW S NELSON 9SORIO and THOMAS
JOSEPH W ILLI received a G.R.A.D. brand, .22 caliber Gknife gun'' bearing serial number
GR3229AD.
22. On or about April 1,2015, JARVIS NELSON OSOR1O and THOMAS
JOSEPH W ILLI received a G.R.A.D. brand, .22 caliber ttknife gun'' bearing serial number
M F0502.
23. On or aboutApril 1, 2015, JARVIS NELSON OSORlO and THOMAS
JOSEPH W ILLI received a Harrison & Richardson brand, .410 bore Sçhandy-gun'' bearing
serial number 13503.
24. On or about Apxil 1,2015, JARVIS NELSON OSORIO and THOMAS
JOSEPH W ILLI received a .410 bore t'handy-gun'' bearing serial number 32417.
25, On or aboqt April 1, 2015. JARVIS NELSON OSORIO and THOMAS
JOSEPH W ILLI rectived a .410 bore Sthandy-gun'' N aring serial number 45709.
26, On or about April 1, 2015, JARVIS NELSON OSOm O and THOMAS
JOSEPH W ILLI received a .22 caliber ç#pen gun'' bearing serial number l PG#7.
27. On or about April 1, 2015, JARVIS NELSON OSOm O and THOM AS
JOSEPH W ILLI received a John Vittie brand, .22 caliber sipen gun'' bearing serial number 00l .
28. On or about April 1, 201 5, JARVIS NELSON OSORIO and THOMAS
JOSEPH W ILLI received an AFT Inc. brand, .25 caliber tspen gun'' bearing serial number
0007PG.
29. On or about April 1, 2015, JARVIS NELSON OSOY O and THOMAS
JOSEPH W ILLI received a Quicksilver brand, .22 caliber ttpen gun'' bearing serial number
QSM 109.
13
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 13 of 32
30. On or about April l , 2015, JARW S NELSON OSORIO and THOM AS
JOSEPH W ILLI received a .22 calibtr 'çknifv gun'' bearing serial number 020013 1 .
31. On or about April 7. 2015, JARW S NELSON OS9m O and THOM AS
JOSEPH W ILLI accepttd $1560.00 as payment for ont (1) AFT Inc. brud, .25 caliber ççpen
gun'' bearing serial number 0007PO and one (1) Quicksilver brand, .22 caliber Sspen gun'' bearing
serial number QSM 109.
32. On or about April 14, 2015, JARW S NELSON 9SORIO and THOMAS
JOSEPH W ILLI accepted $370.00 as pam ent for one (l) Heckler & Koch brrd, VP modtl, 9
millimeter pistol Y aring serial number 224-039142 from $T.P.,'' a person less than twenty-one
years of age, at the OUTBREAK ORDNANCE, LLC retail store.
33. On or about July l4, 2015, JARVIS NELSON OSORIO and THOMAS
JOSEPH W ILLI accepttd $420.00 as payment for one (1) Glock brand, 42 model, .380 calibvr
pistol bearing serial number ABET6I 8 from $çT.P.,'' a N rson less than twenty-one years of age,
at the OUTBQEAK ORDNANC:, LLC retail store.
34. On or about July 5.2015, JARVIS NELSON OSORIO and THOM AS
JOSEPH W ILLI pnsted an advertisement on OUTBREAK ORDNANCE, LLC'S Facebook
page, which advertisement stated: StW TS: G.R.A.D. REVOLVER KNIFE Gtm SET.
ORIGINAL Circa l990s, new in tht box ntver betn fired. Class 3 NFA AOW . n ese are the
original 6 shot 221r made by Olobal Research M d Development, Not the imitation Arsenal
knives. n e Millenium (sic) Gold Knife comes in the factory Presidential Presentaion Isicl hard
wood case. PM for price. Serious inquiries only''.
All in violation of Title 18, United States Code, Section 371 .
14
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 14 of 32
COUNT 2S le of a Firearm to a Prohibited Persona
(18 U.S.C. j 922(d)(1))
On or about February 19, 2015, in Monroc County, in tht Southem District of Florida,
the defendants,
JARVIS NELSON osom o,
THOM AS JOSEPH W 1LLI.andOUTBREAK ORDNANCE, LLC,
did knowingly sell and otherwise dispose of a firearm, that is, one (1 ) Springfield Armory brand,
XD-45 model, .45 caliber pistol, to a person, knowing and having reasonable cause to Y lieve
that such person had been previously convicted in any court of a crime punishable by
imprisonment for a term exceeding one year, in violation of Title 18, United States Code,
Sections 922(d)(l ), 924(a)(2), and 2.
CO UNT 3Sale of a Firearm to a Prohibited Person
(18 U.S.C. j 922(d)(1))
On or about February 25, 2015, in Monroe County, in the Southem District of Florida,
the defendants,
Ju vls N>x soN osom o,THOM AS JOSEPH W ILLI, andOUTBREAK ORDNANCE, LLC,
did knowingly sell and othelwise dispose of a flrearm, that is, one (1) Spike's Tactical, LLC
brand, SL15 model, .223 caliber rifle, to a person, knowing and having rtasonable cause to
bdieve that such person had been previously convicted in any court of a crime punishable by
imprisonment for a term exceeding one year, in violation of Title 18, United States Code,
Sections 922(d)(1), 924(a)(2), and 2.
15
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 15 of 32
COUNT 4Sale of a Firearm to a Person under Twenty-one Years of Age
(18 U.S.C. j 922(b)(1))
On or about April 14, 2015, in Monroe County, in the Southem District of Floridw the
7defendcts,
JARW S NELSON OSORIO,THOMAS JOSEPH W ILLI. andOUTBREAK ORDNANCE, LLC,
being licensed dealers of firem s, within the meaning of Chapter 44, Title 18, United States
Code, did willfully sell a firearm other than a shotgun and rifle, that is, one (1) Heckler & Koch
brand, VP model, 9 millimeter pistol bearing serial number 224-039142, to an individual that the
defendants knew and had reasonable cause to believe was less than twenty-one years of age, that
is, ç1T.P.,'' in violation of Title 18, United States Codt, Sections 922(b)(1), 924(a)(1)(D), and 2.
COUNT -SSale of a Firearm to a Person under Twentp one Years of Age
(18 U.S.C. j 922(b)(1))
On or about luly 14, 20l 5. in Monroe Cpunty, in the Southern District of Florida, the
defendants,
JARVIS NELSON OSOm O,
THOM AS JOSEPH W ILLI, andOUTBREAK ORDNANCE, LLC.
being licensed dealers of llrearms, within the meaning of Chapter 44, Title 18, United States
Code, did willfully sell a fire= other than a shotgun and rille, and nmmunition other than for a
shotgun and rifle, that is, one (1) Glock brand, 42 model, .380 caliber pistol bearing serial
number ABET6I 8, and .380 caliber nmmunition, to an individual that the defendants knew and
had reasonable cause to believe wms less than twenty-one years of age, that is, GT.P.,'' in I
violation of Title 18, United States Code, Stdions 922(b)(1), 924(a)(1)(D), and 2.
l 6 I
1
I
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 16 of 32
COUNT 6Illegal Sale by Federally Licensed Dealer in Violation of State Law
(18 U.S.C. j 922(b)(2))
On or about September 23s 2014, in Monroe County, in the Southem District of Flcrida,
the defendants,
Ju vls NELSON osoltlo,
THOMAS JOSEPH W ILLI, andOUTBREAK ORDNANCE, LLc,
being licensed dealers of fireaM s, within the meaning of Chapter 44, Title 18, United States
Code, did willfully sell and deliver a firearm, in the State of Floridw where the purchase and
possession of such srearm would be in violation of State law then applicable at the place of sale,
that is, Section 790.0655 of the Florida Statutes, in violation of Title 18. United States Code,
Sections 922(b)(2), 924(a)(1)(D), and 2.
It is further allegtd that the firearms are:
(a) one (1) Glock brand, 41 model, .45 caliber pistol bearing serial numbtr
W M A675; and
(b) one (1) Olock
W M A678,
brand, 41 model, .45 caliber pistol bearing serial number
COUNTS 7-21Receipt and Possession of an Unregistered Firearm
(26 U.S.C. j 5861(d))
On or about April 1, 2015, in Monrie County, in the Southem Distritt of Floida, and
elsewhere, the defendants,
17
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 17 of 32
1 l ;
JARW S NELSON OSORIO.THOM AS JOSEPH W ILLI, andOUTBREAK ORDNANCE, LLC,
did knowingly receive and possess a fsresrm, that is, a weapon or deviçe capable of being
concealed on the N rson from which a shot can be discharged through the energy of an explosive,
as delined in Title 26, United States Code, Section 5845(a)(5) and (e), which Grearm was not
registered to the defendants in the National Firearms Rrgistration and Transfer Record as
required by Title 26, United States Cede, Section 5841, as described further below:
i Count Firearm Type Calie r Serial Number
): 7 Cane Gtm .38 01 1 7CG
.
j') g Flashlight Gun
,3g0 030
# 9 Flashlight Gun .410 Borei .
g pgooo. s gvzéet 10 Knife Oun .22 D0552è
'
t 11 Knife Gun .22 GR3229AD)'
):) 12 Knife Gun .22 MF0502'
tt'
î. 13 Handy-oun .410 nore 13503t
)' 14 Handy-oun .410 Bore 32h17)
.
# It', 15 Handy-oun .410 Bore 45709Et .l 16 pen Gun
.22 11v 87
è 17 pen Gun .22 ooI
è
'
18 Pen Gun .25 0Q07PG)-1,(q. I) 19 P
en Gun .22 QSM l09.'.t
t 20 Knife Gun .22 02001 31. t) ë .)T ' 2 1 Shotgun 12 Oauge A8095765M
()
. q
'
) l a I
i!' d
, 1. .!t
E : : : f . ' : ' - ' : '. ! t '.r ' : . - '
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 18 of 32
ln violation of Title 26, United States Code, Sections 5841 , 5861(d), and 5871, and Title
l 8, United States Code, Section 2.
COUNTS 22- -26Failure by Federally Licensed Dealer to Keep Proper Reeords
(18 U.S.C. j 922(b)(5))
On or about !he dates speciôed as lo each counl belom in Monroe County, in the
Southern District of Florida, the defendants,
JARVIS NELSON OSORIO,
THOMAS JOSEPH W ILLI, andOUTBREAK ORDNANCE, LLC,
being licenxd dealers of irearms, within the me= ing of Chapttr 44, Title 18, United States
Code, did willfully sell K d deliver a tlrearm to a pumhaser, without noting in the defendants'
records required to be kept by 1aw pursllqnt to Title 1 8, United States Code, Section 923, the
nsme of said purchaser:
Count Approximate Date Reeorded Purcbaser Aetual Purehaser
22 September 3. 2014 CS2 CS1
23 September 4, 2014 CS2 CS1
24 September 23, 2014 CS2 CS1
25 /ebruary 19, 2014 CS2 CS1
26 February 25, 2015 CS2 CS1
ln violation of Title 18, United States Code, Sections 922(b)(5), 924(a)(1)(D), and 2,
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 19 of 32
! l
COUNT 27False Statement in Connedion with Sale of a Firearm
(18 U.S.C. j 924(a)(1)(A))
On or abom September 3, 2014, in Monroe County, in the Southem District of Florida,
the defendant,
THOM AS JOSEPH W ILLI,
- )did knowingly make a false statement and representation with resptct to the information required
by Chapter 44 Qf Title 18, United States Code, to be kept in the records of a person licensed
tmder this chapter, that is, in connection with the purchase of Remington brand, 700 model, .308
L
t caliber rifle by CS2 from OUTBREAK ORDNANCE, LLC, a federally licensed firearms dealer,. j; '
'
l the defendant stated and represented on an ATF Form 4473 that it was his belief that it was not
è unlawful to sell, deliver, transporq or otherwise dispose of the atbrementioned firearm to CS2,)
' '
?)7 hen in truth and in fact
, and as the defendant then and there well knew, it was unlawful to sell,î W ,y
'
'
TL deliver, transm rt, or otherwisc dispose of the aforementioned firearms to CS2, in that CS2 was
$(i not the actual transferee/buyer of the aforementioned firearm.)è
'
11 In violation of Title 18, United States Code, Sections 924(a)(1)(A) and 2.E :
COUNT 28
False Statement in Connection with Sale of a Firearm I(18 r.s.c. j 9z4(a)(1)(A))
J On Qr aboul Seplember 4, 2014, in Monroe County, in the Southern District of Florida,
): the defendant
,( .
'
) JARVIS NELSON OSORIO, I
) did knowingly make a false statement and representation with respect to the information required
)! by Chapter 44 of Title 1 8, United States Code, to be kept in the records of a person licensed
, under this chapter, that is, in comwction with the purchue of one (1 ) Smith & Wesson brand,
p IE.'
. '
20
''
jj(
'
I(
'
'
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 20 of 32
M&P15 modtl, .223 caliber rifle and one (1) CCMO, Inc. brand, MK-4 model, 5.56mm rifle by
CS2 from OUTBREAK ORDNANCE, LLC, a federally licensed firearms dealer, the defendant
stated and represented on an ATF Fonn 4473 that it was his belief that it was not unlawful to
sell, deliver, transport, or othtrwise dispose of the aforementioned tirearms to CS2, when, in
truth and in fact, and as the defendant then and there well knew, it waN unlawful to sell, deliver,
transpod, or otherwise dispose of the aforementioned irearms to CS2 in that CS2 was not the
actqal transferee/buyer of the aforementioned firearms.
In violation of Title 18, United States Code. Sections 924(a)(1)(A) and 2.
COUNT 29False Statement in Conneetion with Sale of a Firearm
(18 U.S.C. j 924(a)(1)(A))
On Qr about September 23, 2014, in Monroe County, in thç Somhern District of Florida,
the defendant,
THOM AS JOSEPH W ILLI,
did knowingly make a false statement and representation with respect to the infonnation required
by Chapter 44 of Title l 8, United States Code, to be kept in the records of a person licensed
under this chapter. that is, in connection with the purch%e of one (1) Glock brand, 41 model, .45
calilr pistol bearing serial number WMA675 and one (l) Glock brand. 41 model, .45 caliber
pistol bearing serial number W MA678 by CS2 from OUTBREAK ORDNANCE, LLC, a
federally licensed ûrearms dealer, the defendant stated and represented on an ATF Form 4473
that it was his belief that it was not unlawful to stll, deliver, transporq or otherwise dispose of
the aforementioned srearms to CS2, when, in truth and in fact and as the defendant then and
there well knew, it was unlawful to sell, deliver, transporq or otherwise dispose of the
aforementioned firearms to CS2, in that CS2 was not the actual kansferee/buyer of the
21
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 21 of 32
2
aforementioned firearms and that the defcndant had not complied with Section 790.0655 of the
i Florida statutes, which required a mandatory tkee-day waiting period betwecn the date on1
which a handgun was purchased and the date on which the handgun was delivered to the buyer
by the retailers prior to transferring the afortmentioned tirearms to CS2, as required by, and in
violation of Section 790.0655 of the Florida Statutes.
In violation of Title 18, United Slates Code, Sections 924(a)(1)(A) and 2.
COUNT 30False Statement in Connection with Sale of a Firearm
(18 U.S.C. j 924(a)(1)(A)).E .C bout Februav 25
, 2015, in M onroe county, in the soutlwrn District of Florida,E on or a) .(.
t rt the defendant,. è
'
) THOMAS JOSEPH W ILLI,:q )(. t; did knowingly make a false statement and representation with respect to the information required
' by Chapter 44 of Thle 18, United States Code, to be kept in the records of a person licensed' (
'
'
; under this chapter, that is, in connection with the pmchase of one (1 ) Springfield Armory brand,.11è XD
-45 model, .45 caliber pistol and one (1 ) Spike's Tactical, LLC brand, SLl 5 model, .223i .
I, caliber rifle by CS2 from OUTBREAK ORDNANCE, LLC, a federally licensed firearms dealer, !
; the defendant stated and represented on an ATF Form 4473 that it was his belief that it was not! , .
)ik tmlawful to sell, deliver, transport, or otherwise dispose of the aforementioned firearms to CS2,
: I: when, in truth and in fact, and as the defendant then and there well knew, it wis unlawful to sell,)
) deliver, transport, or otherwise dispose of the aforementioned firearms to CS2, in that CS2 wasE .
)q
) not the actual transferee/buyer of the aforementioned firearms and that the defvndant knew and(( I$ had reasonable cause to know that the actual transtkree/buyer was a person who had been)
j '
) j) #
'
t i
'
@. ir. I
22
.
. l .i .
I:
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 22 of 32
previously convicted in any court of a crime punishable by imprisonment for a term exceeding
one year, in violation of Title 18, United States Code, Section 922(d)(1).
ln violation of Title 18, United States Code, Sections 924(a)(1)(A) and 2.
FORFEITURE ALLEGATIONS
n e allegations of this Superseding lndictment are re-alleged and by this1.
rvference fully incoporated herein for the purpose of alleging forfeiture to the United States of
America of certain property in which one or more of the defendants, JARW S NELSON
OSORI9, THOM AS JOSEPH W ILLI, and OUTBREAK ORDNANCE, LLC, has an
interest.
Upon conviction of any violation of Title 18, United States Code, Section 922,
Title 26, United States Code, Section 5861(d), or any violation of any other criminal 1aw of the
United States, as alleged in this Superseding Indictment, the defendants, JARW S NELSON
OSORIO, THOMAS JOSEPH W ILLI, and OUTBQFAK ORDNANCE, LLG shall fofeit
to the United States any firearm and ammunition involved or used in the commission of said
violation. Such property includes, but is not limited to:
(i) One (1) Remington brand, 700 model, .308 caliber rine;(ii) Ont (1) Smith & Wesson brand, M&P15 model, .223 caliber rifle;(iii) One (l) CCMG, lnc, brand, MK-4 model, 5.56mm rifle;(iv) One (1) Olock brrd, 41 model, .45 caliber pistol Garing serial nllmber
W M A675;
One (1) Glock brand, 41 model, .45 caliber pistol bearing serial numberW M A678;
(vi) One (1) Springield Armory brand, XD-45 model, .45 caliber pistol;(vii) One (1) Spike's Tactical, LLC brand, SLI 5 model, .223 calibtr rifle;(viii) One (1) Remington brand, 870 model, 12 gauge shotgtm btaring serial
number A8095765M ;
(ix) One (1) AFT Inc. brand, .38 caliber çscane gun'' bearing serial number01 17CO;
(x) One (1) .380 caliber S<flashlight gun'' beming serial mlmber 030;(xi) One (1) Ares Dtftnse brsnd, .410 gauge Sçflashlight gun'' bearing serial
number D4006797428;
23
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 23 of 32
(xii) 0ne (1) a G.R.A.D. brand, .22 caliber ttknife gun'' bearing serial numberD0552;
(xiii) Ont (1) G.R.A.D. brand, .22 caliber S%knife gun'' bearing serial numberGR3229AD;
(xiv) One (1) O.R.A.D. brand, .22 caliber Rknife gun'' bearing serial numberMF0502;
(xv) One (1) Harrison & Richardson brand, .410 gauge l'handy-gun'' bearing serialnumber 13503;
(Jvi) One (1) .410 gauge lshandy-gun'' bearing serial number 32417;(xvii) One (1) .410 gauge Rhandy-gun'' bearing serial numbtr 45709;(xviii) One (1) .22 caliber Gpen gun'' bearing serial mxmber 1PG87;(xix) One (1) .22 caliber ttpen gun'' bearing serial nllmber 0019(xx) One (1) .25 caliber çspen gun'' bearing serial number 0007PG;(xxi) One (1) Quicksilver brand, .22 caliber ççpcn gun'' btaring serial number
QSMl09;(xxii) One (1) .27 caliber çtknife gun'' bearing serial number 0200131 ;(xxiii) one (1) Glock brand, 42 model, .380 caliber pistol bearing serial number
ABET618; and
(xxiv) one (1) Heçkler & Koch brand, VP model, 9 millimeter pistol btaring serialnumber 224-039142.
If any of the proptly described above, as a result of any act or omission of tht
defendants:
a. cnnnot bt located upon the exercise of due diligence;
b. has been transferred or sold to, or dem sited with, a third party;
c. has been placed beyond the jurisdiction of the court;
d, has been substantially diminished in value; or
e. hms been commingled with other property which cannot be divided without
dim culty,
the United States of America shall be entitled to forfeiture of substimte property pmsuant to Title
21. United States Code, Section 8571), as incomorated by Title 28. United Slales Code. Section
2461(c).
24
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 24 of 32
All pursllsmt to Thle 18, United States Code, Section 924(d)(1), Title 26, United States
Code, Section 5872(a), and the procedmes sd forth in Title 21, United States Code, Section 853,
all made criminally applicable by Title 28, United States Code, Section 2461 (c).
A TRUE BILL
tW I DQ A, FERRERUNITED STATES ATTORNEY
>
PIX STOPHER B. Bkdn EASSISTANT UNITED STATES ATTORNEY
25
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 25 of 32
UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDA
UNITED STATES OF AMERICA
V*.
JARVIS NELSON OSORIO,THOMAS JOSEPH W ILLIand OUTBREAK ORDNAMCE, LLC, I
Defendantl.
Coud Dlvislon: (seled one)
Miami Ke W est ..M-w(u FzpFTL
I do hereby certi: that:
1. l have carefully considered the allegations pf the indictmqnt the number of defendants, the numberofrobable witnesses and the legal complexlties of the Indlctyenylnformation attached hereto.P
3.
4.
5.
I am aware that !h: information su plied Qq this ?tqtemeqt wil! be relied upon by the Judges of thisJschedullng cnmlna, tnals under tbe mandate of tbe speedy Trialcourt in setting thelr cayndars anAct, Title 28 u.s.c. sectfon 3161.
lqterpreter: (Yes Qr Nj NoLlst Ianguage and/or dlalec
This case will take 6-10 days for the parties to try.
Please check appropriate category and type of oKense Iisted below:
(Ce k lnly @f1e)
CASE NO. ISWX O -WIMARTINEPSNOWI#) - - - -
CERTIFICATE OF TRIAL AU ORNEY*
Supeaedlng Cale Informatlon:
New Defendanqs) YesNumber of New DefendantsTotal number of covnts
No X- U
6.
(Cœ : (mly (oe)
l 0 to 5 days11 6 to IQ dayslII 1 1 to 20 daysIV 21 to 60 daysV 61 days and over
Has this case been previously filed in this District Court? (Yes Qr No) Yeslf yes: Judge Jose E. MadinezJqdge: Case No. IS-IOX 8-Cr-MARTINEZ/SNOW
Attach Cepy Vf dispositive vrdeq)has a complant been filed In thls matter? (Yes or No) NOIf yeq:Magdstrate Case No. - - - - - - -Related Misc#llaneous num- rs: NfADefendantts) ln federal custody as of Q7/16/2015Defendanqs) ln state custody as ofRule 20 from the - Disthct of -
Is lhis a potentia! death penalty case? (Yes or No) --I--N
P#ttyMlnorMlsdem.Felony
XU -
Dpes this case or ci inate from a maqer pending in the Northern Region of the U,S. Attorney's OfficeC4, 2003? - - - Yes X Noprlor to october
Dpes this case originate from a matter pending in the Central Region of the U.S. Attorney's Officeprlor to September 1, 20077 Yes X No
CHRISTOPHER BU-BROW NEASSISTANT UNITED STATES AU ORNEYBar No. 91337
*penalty Sheeqs) attached Rw4/8/:ô
8.
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 26 of 32
UNITED STATES DISTRICT COURT
SOUTHERN PISTRICT OF FLOW DA
PENALTY SHEET
Defendant's Name: JARVIS NELSON OSOm O
Case No: IS-IOOM8-CR-MARTINEDSNOW IS)
Count #: 1
Cpns.piracy to Commit Firesrms Tramcking Violations
Til).ç 18, United Stateq- Cpde, Section 371
*M ax. Penalty: 5 Years' Imprisonment
Counts #: 2-3
Sale of a Firearm to a Prohibited Person
Title 18, United States Code, Section 922(d)(1)
*Max. Penalty: 10 Years' Imprisonment -
Counts #: 4-5
Sale of a Firearm to a Person under Twenty-one Years of Age
Title 1 8, Unhed States Code, Section 922(b)(1) - - - - -- - - --
*M ax. Penalty: 5 Years' Imprisonment
Count #: 6
llle-gal Sale by Federally Licensed Dealer in Violation of State Law
Title 18, United States Code, Section 922(b)(2)
wM axr Penalty: 5 Years' Imprisomnent
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 27 of 32
Counts #: 7-21
Receipî and Possession of an Unregistered Firtarm
Title 26, -u-n-it-ed
- -s-tates
. C. p de, Section 586 1 (d)
*.M.>x. Pepplty: 10 Years' Imprisonment
Counts #: 22-26
Failurt by -lrt-dtrally Licensed Dealer to Keep Proper- Records
Title l8,-united States Code, Section 922(b)(5)
*M axp Penalty: 5 Years' Imprisonment
Count #: 28
False Statement in Connection with Sale of Firearm
T.i!14-1 8, United States Code. Section 924(a)(1)(A)
*M ax. PfI?>I4y: 5 Years' Imprisonment
*Refen only to possible term of intarceration, does nof include possible nnes, restitution,speeial assessm ents, parole terms, er forfeitvres tbat may bt applitable.
1.î
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 28 of 32
UNITED STATES DISTRICT COURTSOUTHERN DISTRIW OF FLORIDA
PENALTY SHEETj ' .
j 'Defendant s Name: THOMAS JOSEPH W ILLI
Case No: IS-IeOO8-CR-MARTINED SNOW IS) '
Count #; 1
Con-spir-acy to Commit Firearms Tram cking Violations
l Title 18, U- nited Stat-es- C- ode, Stction 37 1!
-- - -- -
. *M ax. Penalty: 5 Years' Imprisonment
Counts #: 2-3
Sale of a Firearm to a Prohibited Person
Title l 8, United States Code, Section 922(d)(1)
*Max. Penalty: 10 Years' Imprisonment i'
)Counts #: 4-5
Sale of a Firearm to a Persen under Twenty-one Yev s of Age
ITitle I 8. United States Code, Section 922(b)(1) - - - --
*Max. Penally: 5 Years' Imyrisonmtnt
l # 6 'Count : j jIllcgal Sale by Feder
-ally Licensed Dealer in Violation of State Law
l Title l 8, United States Code, Section 922(b)(2)j - - - --
.
: I' *M ax. Penalty: 5 Years' lmprisonment
i
!l I
I
J r 7 : t n r .i 'l. .
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 29 of 32
Counts #: 7-2 1
Receipt and Possession of an Unregistered Firearm
Titlç 26, United States Code, Section 5861(d)
*M ax. Penalty: 10 Years' Imprisonment -
Counts #: 22-26
Failure by Federally Licensed Dealer to Keep Proper Records
Title 18, United States Code, Section 922(b)(5)
*M..>x,-Pena!+: 5 Years' Imprisonment
Counts #: 27, 29, and 30
False Statement in Cormection with Sale of Firearm
Title 18, United States Code, Section 924(a)(1)(A) -
*M ax. Penalty: 5 Years' Imprisonment
ARefers only to possible term of inearceration, does not intlude possible snes, restitution,special assessm ents, parole term s, or forfeitures that may be applicable.
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 30 of 32
UNIT'D STATES DISTW CT COURT1 SOUTHERN DISTRICT OF FLORIDAl
PENALTY SH E-ET
pefendant's Name: OUTBQYAK ORDNANCE, LLC
Case N@: IS-IOBO8-CR-MARTINEDSNOWIS)! . .. ... . .
! count #: 1
Conspiracy to Commit Firearms Tramcking Violationsj ' . .î Title 18
, United States Code. Section 37 1)$
'
*M ax. P-ena
-lty
-: $250.000 Fine
Counts #: 2-3
Sale of a Firearm to a Prohibited Person
Title 18, United States Code, Section 922(d)(1) - - -
*M ax. P-ena
-lty: $250,000 Fine
Counts #: 4-5
Sale of a Firearm to a Person under Twenty-onc Years of Age
Thle 1 8, United States Code, Section 922(b)(1). . .
WMax. Penalty: $250,000
Count #: 6
llleg-al Sale by Federally Licqnstd Dealer in Violation of State Law
T-itl
-e 1 8
-, United States Code, Section 922(b)(2)' . .. - - * *
. . -
*M ax. Penalty: $250,000 Fine
))
.j'
)7
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 31 of 32
Counts #: 7-21
Feçeipt and Possession of an Unregistered Firearm
Title 26, United States Code, Section 5861(d)
*Max. Penalty: $250,000 Fine
Counts #: 22-26
Failure by Federally Licensed Dealer to Keep Proper Records
Title l 8, U- nited States Code, Section 922(b)(5)
*Max. Pqnalty: $250,000 Fine
Case 4:15-cr-10008-JEM Document 102 Entered on FLSD Docket 03/03/2016 Page 32 of 32