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UNITED STATES DISTRICT COURT 

UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

LEON RAMON IRELAND, 

JON ANDREW MEYER, 

VICTORIA INDIA KOHOUT, 

Defendants. 

DISTRICT OF OREGON 

MEDFORD DIVISION 

1:15-CR- C0t15·W\~ 

INDICTMENT 

18 U.S.C. § 2 

18 U.S.C. § 371 

18 U.S.C. § 922(a)(6) 

UNDER SEAL 

THE GRAND JURY CHARGES: 

COUNTl 

CONSPIRACY TO FALSIFY FIREARMS APPLICATION 

On or about April2011 to April2013, in the District of Oregon, the defendants, LEON 

RAMON IRELAND, JON ANDREW MEYER, and VICTORIA INDIA KOHOUT, did 

unlawfully and knowingly conspire and agree with each other to commit the following offense: 

in connection with the acquisition of firearms from a licensed dealer, to knowingly and 

I 

intentionally make a false oral or written statement intended or likely to deceive the dealer, as to 

/ 

' 

a fact material to the .lawfulness of such acquisition of the firearms, to wit: falsely representing 

the identity of the actual buyer of the firearms, in violation of Title 18, United States Cooe, 

Sections 371 and 922(a)(6). The grand jury further alleges overt acts as described in Counts 2 

through 10 below. 

Case 1:15-cr-00175-MC Document 1 Filed 05/08/15 Page 1 of 7
COUNT2 

FALSE STATEMENT ON FIREARMS APPLICATION 

On or about June 9, 2012, in the District of Oregon, the defendants, JON ANDREW 

MEYER and LEON RAMON IRELAND, in connection with the acquisition of a firearm, 

including: 

Smith & Wesson SW9VE 9mm semi-automatic pistol,# DYK2939 

Smith & Wesson SW9VE 9mm semi-automatic pistol,# DYK2807 

Smith & Wesson SW9VE 9mm semi-automatic pistol,# DYK2928 

from Tyrholm Big R, Inc., a licensed federal firearms dealer in White City, Oregon, did 

knowingly and intentionally make a false oral or written statement intended or likely to deceive 

the dealer, as to a fact material to the lawfulness of such acquisition of the said firearm, in that 

JON ANDREW MEYER represented that he resided at 420 Fish Hatchery Road, Grants Pass, 

Oregon, when in fact he did not reside there, and that he was the actual buyer of the firearms 

when in fact he was acquiring the firearms on behalf of another person, LEON RAMON 

IRELAND, in violation of 18 U.S.C. § 922(a)(6) and§ 2. 

COUNT3 

FALSE STATEMENT ON FIREARMS APPLICATION 

On or about July 2, 2012, in the District of Oregon, the defendants JON ANDREW 

MEYER and LEON RAMON IRELAND, in connection with the acquisition of a firearm, 

including: 

Glock 19, 9mm semi-automatic pistol, #TBW317 

Glock 21, .45 caliber semi-automatic pistol, #GPM064 

Glock 26, 9mm semi-automatic pistol, #TDGOOO 

Glock 21, .45 caliber pistol, #SDG245 (recovered San Francisco, CA 3/29/14) 

Glock 19, 9mm pistol, #HA W283 (recovered Oakland, CA 8/15/13) 

from Cash Connection, a licensed federal firearms dealer in Grants Pass, Oregon, did knowingly 

and intentionally make a false oral or written statement intended or likely to deceive the dealer, 

2- INDICTMENT 

Case 1:15-cr-00175-MC Document 1 Filed 05/08/15 Page 2 of 7
as to a fact material to the lawfulness of such acquisition of the said firearm, in that JON 

ANDREW MEYER represented that he resided at 420 Fish Hatchery Road, Grants Pass, Oregon, 

when in fact he did not reside there, and that he was the actual buyer of the firearms when in fact 

he was acquiring the firearms on behalf of another person, LEON RAMON IRELAND, in 

violation of 18 U.S.C. § 922(a)(6) and§ 2. 

COUNT4 

FALSE STATEMENT ON FIREARMS APPLICATION 

On or about July 6, 2012, in the District of Oregon, the defendants, JON ANDREW 

MEYER and LEON RAMON IRELAND, in connection with the acquisition of a firearm, 

including: 

Smith & Wesson 9mm pistol, #DYK4335 

Smith & Wesson .40 caliber pistol, #DYK6567 

from Tyrholm Big R, Inc., a licensed federal firearms dealer in White, Oregon, did knowingly 

and intentionally make a false oral or written statement intended or likely to deceive the dealer, 

as to a fact material to the lawfulness of such acquisition of the said firearm, in that JON 

ANDREW MEYER represented that he resided at 420 Fish Hatchery Road, Grants Pass, Oregon, 

when in fact he did not reside there, and that he was the actual buyer of the firearms when in fact 

he was acquiring the firearms on behalf of another person, LEON RAMON IRELAND, in 

violation of 18 U.S.C. § 922(a)(6) and§ 2. 

COUNTS 

FALSE STATEMENT ON FIREARMS APPLICATION 

On or about July 7, 2012, in the District of Oregon, the defendants, VICTORIA INDIA 

KOHOUT, JON ANDREW MEYER, and LEON RAMON IRELAND, in connection with the 

acquisition of a firearm, including: 

3 -INDICTMENT 

Case 1:15-cr-00175-MC Document 1 Filed 05/08/15 Page 3 of 7
Smith & Wesson SW9VE, 9mm pistol, #DYK4320 (recovered Ontario, CA 9/15/13) 

Smith & Wesson SW9VE, 9mm semi-automatic pistol, #DYK4391 

Smith & Wesson SW40VE, .40 cal pistol, #DYK6554 (recovered Oakland, 04/24/13). 

from Tyrholm Big R, Inc., a licensed federal firearms dealer in White, Oregon, did knowingly 

and intentionally make a false oral or written statement intended or likely to deceive the dealer, 

as to a fact material to the lawfulness of such acquisition of the said firearm, in that VICTORIA 

INDIA KOHOUT represented that she was the actual buyer of the firearms when in fact she was 

acquiring the firearms on behalf of another person, JON ANDREW MEYER and/or LEON 

RAMON IRELAND, in violation of 18 U.S.C. § 922(a)(6) and§ 2. 

COUNT6 

FALSE STATEMENT ON FIREARMS APPLICATION 

On or about October 2, 2012, in the District of Oregon, the defendants JON ANDREW 

MEYER and LEON RAMON IRELAND, in connection with the acquisition of a firearm, 

including: 

Glock 26, 9mm pistol, #RFU709 

Glock 21, .45-caliber pistol, #RTK489 

from Cash Connection, a licensed federal firearms dealer in Grants Pass, Oregon, did knowingly 

and intentionally make a false oral or written statement intended or likely to deceive the dealer, 

as to a fact material to the lawfulness of such acquisition of the said firearm, in that JON 

ANDREW MEYER represented that he resided at 420 Fish Hatchery Road, Grants Pass, Oregon, 

when in fact he did not reside there, and that he was the actual buyer of the firearms when in fact 

he· was acquiring the firearms on behalf of another person, LEON RAMON IRELAND, in 

violation of 18 U.S.C. § 922(a)(6) and§ 2. 

4- INDICTMENT 

Case 1:15-cr-00175-MC Document 1 Filed 05/08/15 Page 4 of 7
COUNT? 

FALSE STATEMENT ON FIREARMS APPLICATION 

On or about October 2, 2012, in the District of Oregon, the defendants JON ANDREW 

MEYER and LEON RAMON IRELAND, in connection with the acquisition of a firearm, 

including: 

Glock 26, 9mrn pistol, #CCB483 

Glock 22, .40-caliber pistol, #SHG880 (recovered Hayward, CA 1 0/22112) 

from Fox Firearms, a licensed federal firearms dealer in Grants Pass, Oregon, did knowingly and 

intentionally make a false oral or written statement intended or likely to deceive the dealer, as to 

a fact material to the lawfulness of such acquisition of the said firearm, in that JON ANDREW 

MEYER represented that he resided at 420 Fish Hatchery Road, Grants Pass, Oregon, when in 

fact he did not reside there, and that he was the actual buyer of the firearms when in fact he was 

acquiring the firearms on behalf of another person, LEON RAMON IRELAND, in violation of 

18 U.S.C. § 922(a)(6) and§ 2. 

COUNTS 

FALSE STATEMENT ON FIREARMS APPLICATION 

On or about November 3, 2012, in the District of Oregon, the defendants JON ANDREW 

MEYER and LEON RAMON IRELAND, in connection with the acquisition of a firearm, 

including: 

Glock 19, 9mm pistol, #SYM437 

Glock 19, 9mm pistol, #SYM435 (recovered Alameda, CA 08/11/2013) 

Glock 26, 9mm pistol, # SZU445 

from Fox Firearms, a licensed federal firearms dealer in Grants Pass, Oregon, did knowingly and 

intentionally make a false oral or written statement intended or likely to deceive the dealer, as to 

a fact material to the lawfulness of such acquisition of the said firearm, in that JON ANDREW 

5- INDICTMENT 

Case 1:15-cr-00175-MC Document 1 Filed 05/08/15 Page 5 of 7
MEYER represented that he resided at 420 Fish Hatchery Road, Grants Pass, Oregon, when in 

fact he did not reside there, and that he was the actual buyer of the firearms when in fact he was 

acquiring the firearms on behalf of another person, LEON RAMON IRELAND, in violation of 

18 U.S.C. § 922(a)(6) and§ 2. 

COUNT9 

FALSE STATEMENT ON FIREARMS APPLICATION 

On or about November 3, 2012, in the District of Oregon, the defendants VICTORIA 

INDIA KOHOUT, JON ANDREW MEYER, and LEON RAMON IRELAND, in connection 

with the acquisition of a firearm; including: 

Glock 30, .45-caliber pistol, #FLS536 

Glock 23, 40-caliber pistol, #SWW181 

from Cash Connection, a licensed federal firearms dealer in Grants Pass, Oregon, did knowingly 

and intentionally make a false oral or written statement intended or likely to deceive the dealer, 

as to a fact material to the lawfulness of such acquisition of the said firearm, in that VICTORIA 

INDIA KOHOUTS represented that she was the actual buyer of the firearms when in fact she 

was acquiring the firearms on behalf of another person, JON ANDREW MEYER and/or LEON 

RAMON IRELAND, in violation of 18 U.S.C. § 922(a)(6) and§ 2. 

COUNT 10 

FALSE STATEMENT ON FIREARMS APPLICATION 

On or about April 10, 2013, in the District of Oregon, the defendants JON ANDREW 

MEYER and LEON RAMON IRELAND, in connection with the acquisition of a firearm, 

including: 

Glock 19, 9mm pistol, #UNE639 

Glock 35, .40 caliber pistol, #UGB799 

6- INDICTMENT 

Case 1:15-cr-00175-MC Document 1 Filed 05/08/15 Page 6 of 7
from Good Guys Guns, a licensed federal firearms dealer in Medford, Oregon, did knowingly 

and intentionally make a false oral or written statement intended or likely to deceive the dealer, 

as to a fact material to the lawfulness of such acquisition of the said firearm, in that JON 

ANDREW MEYER represented that he resided at 420 Fish Hatchery Road, Grants Pass, Oregon, 

when in fact he did not reside there, and that he was the actual buyer of the firearms when in fact 

he was acquiring the firearms on behalf of another person, LEON RAMON IRELAND, in 

violation of 18 U.S.C. § 922(a)(6) and§ 2. 

Dated this 7th day of May, 2015. 

PRESENTED BY: 

S. AMANDA MARSHALL, OSB #953473 \ 

United States Attorney 1 

DOUGLkf-G,OSB#8421. & w~ ' 

Assistant U.S. Attorney 

7- INDICTMENT 

Case 1:15-cr-00175-MC Document 1 Filed 05/08/15 Page 7 of 7