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IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

FORT WORTH DIVISION

UNITED STATES OF AMERICA

v. No. 4:22-MJJOSE CARLOS RIVAS-CHAIREZ (01)

ANA DOMINGO-FRANCISCO (02)

CRIMINAL COMPLAINT

I, the undersigned complainant, being duly sworn, state the following is true and correct 

to the best of my knowledge and belief:

Alleged Offense:

On or about July 29, 2022, in the Fort Worth Division of the Northern District of 

Texas, the defendants, Jose Carlos Rivas-Chairez and Ana Domingo-Francisco, 

aiding and abetting each other and knowing that they were aliens illegally and 

unlawfully present in the United States, did knowingly and unlawfully possess in 

and affecting interstate or foreign commerce the following firearms: a Remington, 

model 1911 R1, .45 caliber pistol, bearing serial number RHE0078; and a Glock, 

model 19x, 9mm caliber pistol, bearing serial number BWZW084, in violation of 

18 U.S.C. § 922(g)(5)(A) and § 924(a)(8) and § 2.

Probable Cause:

1. I, Kyle Medvetz (affiant), being duly sworn, depose and swear the following information is

true and correct to the best of my knowledge and belief. I am a Special Agent with the Bureau

of Alcohol, Tobacco, Firearms and Explosives (ATF) and have been so employed since March

2020. I am currently assigned to the Dallas Field Division office. I have prior experience

working interstate trafficking investigations. Through those investigations, I have learned

trends that indicate firearms trafficking or straw purchasing.

2. As an ATF Special Agent, my primary responsibilities are enforcing federal firearms laws as

set forth in the United States Code, including the following violations pertaining to this

investigation: 18 U.S.C. § 922(a)(6), False Statement to a Federal Firearms Licensee (straw

purchase); and 18 U.S.C. § 922(g)(5)(A), Possession of a Firearm by an Alien Illegally and

Unlawfully Present in the United States. I have conducted numerous federal investigations of

criminal activity and have testified in federal court numerous times concerning a wide variety

587

FILED

KAREN MITCHELL

CLERK, U.S. DISTRICT 

COURT July 29, 2022

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of federal criminal violations including the aforementioned violations. I have conducted 

numerous debriefings of defendants, witnesses, informants, and other persons concerning the 

aforementioned and related violations.

3. As a result of training and experience as a Special Agent, I am familiar with the federal 

firearms laws and know it is unlawful for a person to possess a firearm as an alien illegally and 

unlawfully in the United States. I also know it is unlawful for someone to “straw purchase” a 

firearm. A straw purchase is committed when the individual purchasing the firearm is not the 

intended buyer. This typically occurs when an individual prohibited from purchasing and 

possessing firearms recruits an individual to acquire the firearm on their behalf.

4. This affidavit is based on my personal knowledge and on information provided to me by other 

law enforcement officers who participated in this investigation. Since this affidavit is being 

submitted for the limited purpose of supporting a criminal complaint, I have not included each 

and every fact known to me concerning this investigation.

5. In July of 2022, your affiant and an ATF SA were made aware of purchases of two FN, model 

Scar 17s, .308 caliber rifles by Jerusha Francisco on June 3 and June 6, 2022 from Range USA, 

a Federal Firearms Licensee (FFL), located at on S Cooper St in Arlington, Texas 76017. 

Francisco purchased each rifle for $4,005.24, for a combined total of $8,010.48.

6. A Texas Workforce Commission report showed Francisco earned $891.63 in 2022. In the 

fourth quarter of 2021, Francisco earned $10,052.97. Based on training and experience, your 

affiant knew that Francisco’s lack of a discernable income and the amount of money spent on 

the purchase of two (2) similar firearms of the same caliber during a short period of time, was 

indicative of firearms trafficking and straw purchasing.

7. On or about July 27, 2022, your affiant and another ATF SA conducted an audio recorded noncustodial interview of Francisco at her residence. Francisco admitted to purchasing the 

aforementioned FN SCAR rifles at the direction of her sister, Ana Domingo-Francisco

(Domingo), for Domingo’s boyfriend, Jose Carlos Rivas-Chairez (Rivas). Francisco showed 

ATF SAs text message communication between herself and Domingo. The communication 

showed Domingo was directing Francisco to purchase the two rifles from Range USA for 

Rivas. The text messages also showed Domingo stated her address was 310 Mahogany Drive 

Arlington, Texas 76018. Francisco told your affiant Domingo resides at 310 Mahogany with 

her boyfriend, Rivas. Francisco told your affiant that Rivas was driving a black SUV. 

8. On or about July 27, 2022, your affiant and another ATF SA went to Range USA. There, your 

affiant spoke with a Range USA employee who stated they remembered the two purchases 

Francisco made. A Range USA employee provided your affiant with surveillance footage from 

June 3, 2022, and June 6, 2022. Your affiant reviewed the footage, and on June 3, 2022,

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observed Rivas, Domingo, and Francisco inside of Range USA. Rivas pointed at a wall where 

the FN SCAR rifles were located and walked to the counter in front of the rifles. Francisco

walked next to Rivas. While Rivas and Francisco stood next to each other, Rivas looked at 

Francisco, then looked toward the wall where the FN SCAR rifles were hanging. Rivas did

this multiple times. Rivas walked away, and Francisco began talking to the Range USA 

employee and Francisco handled the FN SCAR rifle. After completing the ATF Form 4473, 

Francisco left the store with the FN Scar Rifle

9. On or about July 27, 2022, the Range USA employee told your affiant of a purchase of an FN, 

model SCAR 20S, 7.62x51mm NATO rifle, bearing serial number PR15071 by a Mario Lara. 

During this transaction, Lara overpaid for the firearm by $100. A Range USA employee 

contacted Lara, advised him of the overpayment, and Lara returned to retrieve the $100. When 

the Range USA employee left work that night, the employee reported a black SUV followed 

the employee.

10. On or about July 27, 2022, your affiant contacted a Department of Homeland Security Special 

Agent to verify the immigration status of Domingo and Rivas. The HSI SA advised your 

affiant both Domingo and Rivas are not United States citizens and are currently in the United 

States illegally.

11. On or about July 29, 2022, you affiant and additional ATF SAs went to 310 Mahogany Drive 

Arlington, Texas 76018 in an attempt to interview Domingo and Rivas. The initial attempt to 

contact the residents at 310 Mahogany Drive was unsuccessful, and no one answered the door. 

Your affiant and another ATF SA attempted to contact Domingo via telephone. Eventually, 

Domingo called your affiant, and told your affiant she was currently at a doctor’s appointment 

at the Med-City Arlington Hospital. Your affiant asked Domingo if your affiant could meet 

her at the hospital, and Domingo agreed. 

12. Your affiant and additional ATF SAs responded to Med-City Arlington while additional ATF 

SAs remained at 310 Mahogany Drive. Once at Med-City Arlington, your affiant contacted 

Domingo via telephone to inquire about her current location. Domingo told your affiant she 

was currently on her way home because she forgot her driver’s license.

13. As your affiant returned to 310 Mahogany Drive, another ATF SA observed an induvial exit 

the front of 310 Mahogany Drive. The ATF SA met with the individual, and determined this 

individual was a relative of Rivas. Moments later, Domingo exited the front of the residence,

and an ATF SA began to talk with her.

14. During the interview, Domingo admitted to directing Francisco to purchase two FN SCAR 

rifles for Rivas. Domingo also showed ATF SAs the communication between her and 

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Francisco where she directed Francisco regarding the purchases. At that time, Domingo told 

ATF SAs that she was a citizen of Mexico.

15. While Domingo was being interviewed, your affiant asked the relative of Rivas to call Rivas

and ask him to come outside. The call was completed, and Rivas exited the front door of 310

Mahogany Drive and began talking to your affiant.

16. During an audio recorded non-custodial interview between ATF SAs, your affiant, and Rivas,

Rivas admitted to directing multiple individuals, including Francisco and Mario Lara, to

purchase firearms on Rivas’s behalf. Rivas told your affiant there were multiple firearms

currently inside of the residence. Your affiant asked Jose Rivas-Chairez if he would provide

written consent for your affiant and ATF SAs to search the house for the firearms, ammunition,

and other illicit items. Rivas agreed, as long as he was present during the search. Your affiant,

another ATF SA, and Rivas read aloud from an ATF Consent to Search form. Rivas agreed

to provide consent and signed the ATF Consent to Search form.

17. Once consent to search 310 Mahogany Drive was obtained, ATF SAs conducted a protective

sweep of the interior of the residence. It was determined no other persons were inside of the

residence, and ATF SAs began the search of 310 Mahogany Drive.

18. Your affiant, another ATF SA, and Rivas then walked through each room of 310 Mahogany

Drive, and Rivas identified every place firearms, ammunition, firearm related items, and illicit

narcotics were stored. In the master bedroom of 310 Mahogany Drive, Rivas showed your

affiant where a Remington, model 1911 R1, .45 caliber pistol bearing serial number RHE0078

was stored in a dresser drawer, loaded with eight (8) rounds of .45 caliber ammunition. Rivas

also showed your affiant where a Glock, model 19x, 9mm caliber pistol bearing serial number

BWZW084 was stored tucked into the south side of the master bed and loaded with seventeen

(17) rounds of 9mm caliber ammunition. Leaning against the wall, in the northwest corner of

the master bedroom, was an Aero Precision, model TX, multi caliber rifle, with serial number

TXM4-06723. A drum magazine was inserted into the firearm, and approximately 62 rounds

of .223/5.56 caliber ammunition was found inside. In the master bedroom closet, where female

clothing belonging to Domingo was stored, a large cardboard box, standing approximately

four feet tall, was propped up. Inside of the box was an FN, model Scar 20S, 7.62X51mm

caliber rifle, with serial number PR19567. In addition, while searching the master bedroom,

items belonging to Domingo were located. Rivas also told your affiant he occupied the room

with Domingo and their two children. Moreover, during your affiant’s interview with Rivas,

your affiant confirmed Rivas and Domingo were in a domestic, boyfriend-girlfriend

relationship, and Domingo is pregnant with their child.

19. Throughout the residence, numerous empty firearm boxes were located. Rivas stated the

firearms that were once in those boxes were no longer present in the house. Of note were four

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empty boxes with identifying markings to the following firearms: an FN, model SCAR 17S, 

7.62x51mm NATO rifle, bearing serial number H1C11871; an FN, model SCAR 20S, 

7.62x51mm NATO rifle, bearing serial number PR22565; and an FN, model SCAR 17S, 

7.62x51mm NATO rifle, bearing serial number H1C12232; an FN, model SCAR 17S, 7.62x51 

NATO rifle, bearing serial number H0C27133. Two of the firearms once in the boxes were 

purchased by Francisco, and two of the firearms once in the boxes were purchased by another 

individual known by your affiant to have purchased them from an FFL.

20. In a downstairs room of 310 Mahogany Drive, ATF SAs located a white substance suspected 

to be methamphetamine. In this same room was a device to remove a tire from a rim, and a 

rim attached to a tire. Rivas stated the tire once contained kilograms of methamphetamine 

which he sold prior to your affiant’s arrival at 310 Mahogany Drive. Rivas directed ATF SAs 

to additional trash bags stored on the side of 310 Mahogany Drive where numerous empty bags 

with a white residue were located. Rivas stated these empty bags once contained kilograms of 

methamphetamine and were previously stored in a separate tire.

21. Rivas directed ATF SAs to two duffel bags sitting on the living room floor. Inside of those 

bags, ATF SAs located two (2) disassembled FN SCAR 17S rifles, one (1) disassembled FN 

SCAR 20S rifle, one (1) suspected suppressor (silencer), nine (9) Glock handguns, and one 

(1), Colt handgun. The firearms and suspected suppressor were wrapped in towels, which were 

then wrapped in cellophane. An ATF SA questioned Rivas about the suppressor, and Rivas

stated the suppressor makes the firing of a firearm quieter.

22. In total, in excess of one hundred and fifty-one (151) firearm boxes were observed throughout

Rivas and Domingo’s residence.

23. Through an interview of Rivas and Domingo on July 29, 2022, and upon further search of 

their immigration records by an immigration officer, it was confirmed that Rivas and Domingo 

are not citizens or nationals of the United States and are aliens illegally and unlawfully present 

in the United States. A review of automated immigration systems indicated that Rivas was a 

citizen of Mexico who entered the United States on a B-2 visitor visa on July 3, 2004, with 

authorization to remain in the United States until January 1, 2005. Since the expiration of his

visa, Rivas overstayed his visa and unlawfully remained in the United States without 

permission from the United States Attorney General or the Secretary of the Department of the 

Homeland Security. A review of automated immigration systems indicated Domingo was a 

citizen of Guatemala who entered the United States unlawfully and without inspection on or 

about October 19, 2017, and was found by immigration officials near San Luis, Arizona, and 

subsequently placed into immigration removal proceedings. Thus, at the time Rivas and 

Domingo possessed the above-described firearms, they were both illegally and unlawfully 

present in the United States. Further, in interviewing them, they admitted they were illegally 

present in the United States and that they knew of this illegal status. 

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24. An A TF certified Firearms Interstate Nexus Expert determined that the Remington, model 

1911 R 1, .45 caliber pistol, bearing serial number RHE0078, and Glock, model l 9x, 9mm 

caliber pistol, bearing serial number BWZW084 were not manufactured in the state of Texas. 

Therefore, at the time that Rivas and Domingo possessed the two firearms in their home in 

Fort Worth, Texas, they would have previously traveled in interstate and/or foreign commerce 

at some time prior to being possessed by Rivas and Domingo. 

Based upon the above facts and circumstances, I submit that there is probable cause to 

believe that Jose Carlos Rivas-Chairez and Ana Domingo-Francisco, aiding and abetting each 

other and knowing that they were aliens illegally and unlawfully present in the United States, did 

knowingly and unlawfully possess, in and affecting interstate or foreign commerce, the following 

firearms: an Remington, model 1911 RI, .45 caliber pistol, bearing serial number RHE0078; and 

a Glock, model 19x, 9mm caliber pistol bearing serial number BWZW084, in violation of 18 

U.S.C. § 922(g)(5)(A), and § 924(a)(8), and § 2. 

A TF Special Agent 

Sworn to me, over the telephone or other electronic means, and signed by me 

pursuant to Fed. R. Crim. P. 4.1 on this ____ day of July 2022 at ___ p.m., 

in Fort Worth, Texas. 

HAL R. RAY, JR. 

UNITED STATES MAGISTRATE JUDGE 

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29th 7:33

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