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

ORIG\NAl
UNITED STATES DISTRICT bOUR1{~" ,
NORTHERN DISTRICT OF JfEXAS { M~R I 0 20/1 I
FORT WORTH DIVISIQN !~"_, I
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UNITED STATES OF AMERICA §

§
v. § CASE NO. 4: Il-MJ-O , 9
§
RUBEN RAMIREZ (1) §
ROMEO RAMIREZ (2) §
ERNESTO MANZANAREZ (3) §

CRIMINAL COMPLAINT

Complainant Joshua Yoder, being duly sworn, state the following is true and

correct to the best of my knowledge and belief:

Alien Unlawfully in the United States

in Possession of a Firearm in Commerce
and Aiding and Abetting

On or about March 9, 2011, in the Fort Worth Division of the Northern

District of Texas, the defendant, Romeo Ramirez, then being an alien,
unlawfully and illegally in the United States, did knowingly and unlawfully
possess in and affecting interstate commerce a firearm, to wit, a A. Century
Arms, Model GP WASR 10, 7.62x39mm, rifle, Serial Number 1985SBJ4385;
B. Century Arms, Model GP WASR 10, 7.62x39mm, rifle, Serial Number
1971CB3451; C. Century Arms, Model GP WASR 10, 7.62x39mm, rifle,
Serial Number 1972CB4595; and D. DPMS, Model Panther LR-308, .308
caliber rifle, Serial Number 65970; and the defendants, Ruben Ramirez and
Ernesto Manzanarez did aid, abet, counsel, command, induce and procure the
commission of the above offense.

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

u.s. v. Ramirez, Et AI.

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I am a Special Agent assigned to the Fort Worth office of the Bureau of

Alcohol, Tobacco, Firearms and Explosives (ATF). The information set out herein

is based on my own investigation and statements and reports of the within

named law enforcment officers.

1. Complainant, Joshua Yoder, is currently assigned as a Special Agent

with the Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF).

Complainant is assigned to the Fort Worth, Texas Field Office of the Bureau of

Alcohol, Tobacco, Firearms and Explosives (ATF). Complainant has been a

Special Agent for the ATF for the past nine years.

2. This complaint is based upon the Complainant's interviews of witnesses

and review of physical evidence, and other information related to Complainant by

Special Agents with the Bureau of Alcohol, Tobacco, Firearms, and Explosives

(ATF) and Special Agents with the Department of Homeland Security (ICE).

3. On March 9, 2011, ATF Special Agent Josh Yoder was informed ofa

possible "straw purchase" that would occur that afternoon at Cheaper Than Dirt,

2522 NE Loop 820 Service Road South Fort Worth, TX, a federally licensed firearms

dealer in Fort Worth, Texas.

4. On March 9,2011, ATF and ICE agents established surveillance inside

and around the firearms dealer in Fort Worth. At approximately 2:30PM two

vehicles entered the store parking lot, an orange Hummer, bearing TX License

plate BP7 K893, occupied by four males and a blue Grand Am, bearing TX
u.s. v. Ramirez, Et AI.
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License plate, 866XNJ, occupied by two males. The driver of the Grand Am

entered the store and purchased four (4) rifles with cash. The Hummer was

observed driving in and around the area of the store and stopped and parked in a

parking lot south of the store. After purchasing the rifles, the individual exited the

store 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, followed

the blue Grand Am as it drove south on the service road and entered south-bound

1-35 as did the orange Hummer. The vehicles drove to the east side of Fort Worth

where the Grand Am stopped in the street in front of a convenience store on the

comer of Miller and Rosedale and the Hummer stopped in the convenience store

parking lot. Agents observed two individuals get out of the Hummer as the two

occupants of the blue Grand Am got out of it. The two individuals that exited the

Hummer got into the Grand Am and drove away with the firearms. The two

individuals that exited the Grand Am, to include the actual purchaser of the

firearms, got into the back seat of the Hummer and the Hummer drove away.

6. Agents with ICE continued surveillance of the blue Grand Am and

observed it pull into the driveway of 1021 S. Sergeant, Fort Worth, TX. ICE agents

conducted a stop of the vehicle where the driver of the Grand Am was identified as

Romeo RAMIREZ (WIM 01/21/86). The passenger of the Grand Am was identified as

Emesto MANZANAREZ (WIM 10/06/86). The four rifles were found in the back seat of

the Grand Am.

u.s. v. Ramirez, Et AI.

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7. Agents with ATF followed the orange Hummer where Fort Worth Police

conducted a vehicle stop in a commercial parking lot off of Felix at 1-35 in Fort

Worth, TX. The driver of the Hummer was later identified as Ruben RAMIREZ (W/M

07/23/83), the front seat passenger was identified as Ramon SALINAS (W/M OS/26/86),

the rear seat passenger side occupant was 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 Department

substation and advised of their rights per Miranda.

9. ATF Special Agent Gus Benavides advised Ramon Salinas of his

Miranda rights. Salinas advised that he understood his rights and was willing to

answer questions and make statements at that time without an attorney present.

Salinas stated that he was here illegally and had been living with Ruben Ramirez

for the past two weeks. Salinas advised that he was getting a ride to Fort Worth

with Ruben so he could meet a friend that was going to take him to Oklahoma

City, OK. Salinas stated that they met with the individuals in the Grand Am at a

gas station and Ernesto (Manzanarez) got out of the Hummer and into the Grand

Am. Salinas advised that when Ernesto got back in the Hummer someone asked

him how much money he gave them and Ernesto stated that he gave him a lot of

cash plus $40.00 for gasoline. Salinas advised that Ernesto said they were buying

"Toys" with the money. Salinas advised that everyone knew that "Toys" meant

u.s. v. Ramirez, Et AI.

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guns. Salinas stated that they didn't discuss how many guns were being bought or

where the guns were going but he assumed they were headed to Mexico.

10. ATF Task Force Officer Dallas Seals advised Ernesto Manzanarez of

his Miranda rights. Manzanarez advised that the understood his rights and was

willing to answer questions and make statement at that time without an attorney

present. Initially Manzanarez stated he and his friends were driving from

Comanche to Fort Worth to go shopping at the mall. Manzanarez advised the

names of his friends were Alfredo, Romeo and Ramon, but that he did not know

any of their last names. Manzanarez was very upset and repeatedly said he was in

fear for his family's life. Manzanarez said he did not know anything about the

guns until Alfredo went to the gun store. TFO Seals advised Manzanarez he was

not being truthful because agents knew Alfredo was not the name of the driver of

the Hummer. Manzanarez then advised he was contacted by Ruben Ramirez on

March 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 did

not transport the money, Manzanarez's family would be killed. Manzanarez

agreed to bring the money to Ruben Ramirez because he feared for his family in

Del Rio, Texas and Mexico. On Sunday March 6, 2011 Manzanarez met Ruben

Ramirez in Senora Texas and got Ramirez's Hummer to drive the money to

Comanche. On Tuesday March 8, 2011, Manzanarez was contacted by an

unknown Hispanic male who met him and gave him $10,000 US currency to take
u.s. v. Ramirez, Et AI.
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to Ruben Ramirez. Manzanarez stated he immediately drove to Comanche, Texas

and gave the money and the Hummer to Ruben Ramirez. Manzanarez advised

Ruben Ramirez told him the money was to buy guns to send to Mexico for the

Zetas to fight the war. Manzanarez stated he rode in the Hummer with Ruben

Ramirez to the gun store. Manzanarez stated they waited in the Hummer while the

"white kid" bought the guns for Ruben. Manzanarez advised they drove away

from the store together and were going to get the guns from the "white kid" at a

different location. Manzanarez advised Ruben stopped at a store and told him and

Romeo Ramirez to get in the "white kid's" car and they did. Manzanarez advised

they drove around the comer and then were arrested. Manzanarez had $1857

dollars in his pocket and he advised it was Ruben Ramirez's money that Ruben

told him to hold when he got out of the Hummer.

11. ATF Special Agent Gus Benavides advised Romeo Ramirez of his

Miranda rights. Romeo Ramirez advised that he understood his rights and was

willing to answer questions and make statements at that time without an attorney

present. Romeo Ramirez advised that he was a native and citizen of Mexico here

illegally and had been living in Minnesota with his girlfriend. Romeo Ramirez

didn't want to answer any questions about the firearms or his knowledge of them.

12. ICE agent Lina Gilderson advised Ruben Ramirez, who initially stated

his name was Alfredo Beltran, of his Miranda rights. Ruben Ramirez advised that

he understood his rights and was willing to answer questions and make a statement
u.s. v. Ramirez, Et AI.
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at that time without an attorney present. Ruben Ramirez stated that he was born in

Sonorra, Sonorra, Mexico. Ruben Ramirez admitted that he had last entered the United

States(U.S.) in approximately January 2007 without inspection or authorization and

further admitted that he was illegally present in the U.S. Ruben Ramirez stated that he

was employed through a company named Lakeside foods as a seasonal employee and had

traveled to Minnesota and New Mexico as well as Proctor, Texas working in the fields

picking 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 and

borrowed the orange Hummer owned by a friend named Ruben Ramirez. Later Ruben

admitted 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 Pontiac

Grand Am with loud mufflers, out of a business parking lot located within some brown

buildings offIH 35 North and Hwy 820 in Fort Worth, Texas. Ruben stated that he

followed the Grand Am to a gas station that was closed, observed two (2) men exit the

Grand 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 and

drop the men off 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 could

communicate with him. Ruben did not have the unknown males phone number. Ruben

further stated that he observed the white male throw a handful of cash onto the cupholder

u.s. v. Ramirez, Et AI.

Cause No. 4: ll-MJ-O Page 7
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in his vehicle. He placed the cash in the center console of his vehicle. (Agents found

approximately $4880.00 in the console of Ruben Ramirez's vehicle.)

14. ATF agents contacted representatives of Cheaper Than Dirt regarding

the firearms purchased on March 9, 2011 by Josh Cisneroz. The following

firearms were purchased for $3063.35 by Cisneroz at that time:

A. Century Arms, Model GP WASR 10, 7.62x39mm, rifle, Serial Number

1985SBJ4385;
B. Century Arms, Model GP WASR 10, 7.62x39mm, rifle, Serial Number
1971CB3451;
C. Century Arms, Model GP WASR 10, 7.62x39mm, rifle, Serial Number
1972CB4595; and
D. DPMS, Model Panther LR-308, .308 caliber rifle, Serial Number 65970.

These firearms were found in the blue Grand Am driven by Romeo Ramirez when

ICE stopped the vehicle on March 9, 2011.

15. On March 10,2011, an ATF Interstate Nexus expert informed

Complainant that the aforementioned firearms were each manufactured outside the

State of Texas and traveled in interstate or foreign commerce prior to Manzanarez

possessing them.

u.s. v. Ramirez, Et AI.

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16. I have not listed all the facts known to me regarding this case. I have only

listed those facts I believe necessary to establish probable cause to believe that the

defendants committed the crimes listed above.

Sworn to before me, and subscribed in my presence

March 10,2011, at Z ~ \9 a.m.~ at Fort Worth Texas

Date and Time Issued

U. S. Magistrate Judge Jeffrey L. Cureton

Name and Title of Judicial Officer

u.s. v. Ramirez, Et AI.

Cause No. 4:1l-MJ-O Page 9