IN TUE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

EL PASO DIVISION 

UNITED STATES OF AMERICA, 

Plaintiff, 

V. U 

and 

ISAAC RODRIGUEZ (2) 

Defendant. 

THE GRAND JURY CHARGES: 

FILED 

282FE25 AP11f:37 

CLERc. U.S. DIrRf COURT NESTERH TEXAS CRIMINAL NO. EP193348FM(4L 

1W P UT V 

SEALED 

SUPERSEDING INDICTMENT 

CT 1: 18 U.S.C. § 2 and 922(a)(6) - Aiding and 

Abetting False Statement During Purchase of a 

Firearm; 

CT 2: 18 U.S.C. § 2 and 922(a)(6) - Aiding and 

Abetting False Statement During Purchase of a 

Firearm; 

CT 3: 18 U.S.C. § 922(g)(5), 924(a)(2) 

- Alien in Possession of Firearm; and 

CT 4: 18 U.S.C. § 922(g)(5), 924(a)(2) 

Alien in Possession of Ammunition 

Notice of Government's L)emand for Forfeiture 

COUNT ONE 

(18 U.S.C. § 2 and 922(a)(6)) 

On or about June 19, 2019, within the Western District of Texas, Defendants, 

and 

ISAAC RODRIGUEZ (2) 

in connection with the acquisition of a firearm, to wit: DPMS Panther, Model A15, 5.56 caliber 

rifle, purchased from Federal Firearms Licensee #1 (FFL #1), a licensed firearms dealer within the 

meaning of Chapter 44, Title 18, United States Code, Defendant, 

, did knowingly aid, abet and counsel Defendant, ISAAC RODRIGUEZ (2), to knowingly 

Case 3:19-cr-03348-FM Document 33 Filed 02/26/20 Page 1 of 5
make a false and fictitious written statement intended and likely to deceive said dealer as to a fact 

material to the lawfulness of the acquisition and sale of said firearm to Defendant, ISAAC 

RODRIGUEZ (2), in that Defendant, ISAAC RODRIGUEZ (2) stated and represented on a 

Bureau of Alcohol, Tobacco and Firearms Form 4473 the answer "yes" in response to the question, 

"Are you the actual transferee/buyer of the firearm(s) listed on this form?" when in fact Defendant, 

ISAAC RODRIGUEZ (2), well knew he was in fact purchasing the firearm for Defendant, 

Code, Sections 2 and 922(a)(6). 

and not for himself, in violation of Title 18, United States 

COUNT TWO 

(18 U.S.C. § 2 and 922(a)(6)) 

On or about July 3, 2019, within the Western District of Texas, Defendants, 

and 

ISAAC RODRIGUEZ (2) 

in connection with the acquisition of a firearm, to wit: Glock, Model 19X, 9mm pistol, purchased 

from Federal Firearms Licensee #1 (FFL #1), a licensed firearms dealer within the meaning of 

Chapter 44, Title 18, United States Code, Defendant, did 

knowingly aid, abet and counsel Defendant, ISAAC RODRIGUEZ (2), to knowingly make a 

false and fictitious written statement intended and likely to deceive said dealer as to a fact material 

to the lawfulness of the acquisition and sale of said firearm to Defendant, ISAAC RODRIGUEZ 

(2), in that Defendant, ISAAC RODRIGUEZ (2) stated and represented on a Bureau of Alcohol, 

Tobacco and Firearms Form 4473 the answer "yes" in response, to the question, "Are you the actual 

transferee/buyer of the firearm(s) listed on this form?" when in fact Defendant, ISAAC 

RODRIGUEZ (2), well knew he was in fact purchasing the flreann for Defendant, 

Case 3:19-cr-03348-FM Document 33 Filed 02/26/20 Page 2 of 5
SectIons 2 and 922(a)(6). 

and not for himself, in violation of Title 18, United States Code, 

COUNT TIIRIEE 

(18 U.S.C. § 922(g)(5) & 924(a)(2)) 

That on or about July 7, 2019, in the Western District of Texas, Defendant, 

knowing he was an alien who had been admitted to the United States under a nonimmi grant visa, 

as that term is defined in section 10l(a)(26) of the Tmrnigration and Nationality Act, 8 U.S.C. § 

1101 (a)(26), knowingly possessed a firearm to wit: Glock, Model 1 9X, 9mm pistol; said firearm 

having been shipped and transported in interstate commerce, in violation of Title 18, United States 

Code, Sections 922(g)(1) and 924(a)(2). 

COUNT FOUR 

(18 U.S.C. § 922(g)(5) & 924(a)(2)) 

That on or about July 22, 2019 through July 24, 2019, in the Western District of Texas, 

Defendant, 

knowing he was an alien who had been admitted to the United States under a nonimmigrant visa, 

as that term is defined in section 101(a)(26) of the Immigration and Nationality Act, 8 U.S.C. § 

1 101(a)(26), knowingly possessed ammunition to wit, approximately 6,000 rounds of assorted 

ammunition; said ammunition having been shipped and transported in interstate commerce, in 

violation of Title 18, United States Code, Sections 922(g)(1) and 924(a)(2). 

Case 3:19-cr-03348-FM Document 33 Filed 02/26/20 Page 3 of 5
NOTICE OF GOVERIMENT'S DEMAND FOR FOR VE1TEIRE 

[See Fed. R Crim. 32.2] 

I. Firearm Violations and Forfeiture Statutes 

[Title 18 U.S.C. § 922(a)(6) & (g)(5) and 924(a)(2), subject 

to forfeiture pursuant to Title 18 U.S.C. § 924(d)(1), as made 

applicable to criminal forfeiture by 28 U.S.C. § 2461(c)J 

As a result of the foregoing criminal violation set forth above, the United States of America 

gives notice to the Defendant and ISAAC RODRIGUEZ 

(2) of its intent to seek the forfeiture of the properties described below upon conviction pursuant 

to FED. R. Ciu:rvi. P. 32.2 and Title 18 U.S.C. § 924(d)(1), as made applicable to criminal forfeiture 

by Title 28 U.S.C. § 246 1(c). Section 924 states, in pertinent part, the following: 

18 U.S.C. § 924. 

(d)(1) Any firearm or ammunition involved in or used in any knowing violation of 

subsection. . . of section 922. . . or knowing violation of section 924. . . shall be 

subject to seizure and forfeiture. . . under the provisions of this chapter. 

This Notice of Demand for Forfeiture includes but is not limited to the properties described 

below in Paragraph II and III. 

H. 

Personal Property 

1. Approximately 6,000 rounds of assorted ammunition; and 

2. Any and all firearms, ammunition, and/or accessories involved in or used in the 

commission of the criminal offense. 

Money Judgment 

Money Judgment: A sum of money that represents the value of the properties involved in 

the violations set forth in Counts One and Two of the Indictment for which Defendants 

and ISAAC RODRIGUEZ (2), are individually 

liable. 

Case 3:19-cr-03348-FM Document 33 Filed 02/26/20 Page 4 of 5
Substitute Assets 

If any of the property described above as being subject to forfeiture for the violations set 

forth above, as a result of any act or omission of the Defendants: 

a. cannot be located upon the exercise of due diligence; 

b. has been transferred or sold to, or deposited with, a third party; 

c. has been placed beyond the jurisdiction of the court; 

d. has been substantially diminished in value; or 

e. has been commingled with other property which cannot be divided without 

difficulty; 

it is the intent of the United States of America to seek forfeiture of any other property of the 

Defendants, up to the value of the money judgment, as substitute assets pursuant to Title 21 U.s.c. 

853(p) and Fed. R. Crim. P. 32.2(e)(l). 

A 

JIAL SIGNATURE 

REDACTED PURSUANTTO FORBY 

JOHN F. BASH 

IJMTED STATES ATTORNEY 

BY: 

Assistant United tes Attorney 

Case 3:19-cr-03348-FM Document 33 Filed 02/26/20 Page 5 of 5