AO 91 (Rev. 11/11) Criminal Complaint AUSA Matthew J. McCrobie (312) 353-5356 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

EASTERN DIVISION

UNITED STATES OF AMERICA 

v. 

BRANDON PEGUES 

CASE NUMBER: 

CRIMINAL COMPLAINT 

I, the complainant in this case, state that the following is true to the best of my knowledge and belief. 

On or about May 31, 2020, at Chicago, in the Northern District of Illinois, Eastern Division, the defendant(s) 

violated:

Code Section Offense Description 

Title 18, United States Code, Section 

922(g)(1) 

knowing that he had previously been convicted of a 

crime punishable by a term of imprisonment 

exceeding one year, did knowingly possess, in and 

affecting interstate and foreign commerce, a firearm, 

namely, a loaded Glock model 19 9mm semiautomatic 

pistol bearing serial number SHA485, which firearm 

had traveled in interstate and foreign commerce prior 

to defendant’s possession of the firearm 

This criminal complaint is based upon these facts: 

 X Continued on the attached sheet. 

 

CINDY M. BERND 

Special Agent, Bureau of Alcohol, Tobacco, 

Firearms & Explosives (ATF) 

Pursuant to Fed. R. Crim. P. 4.1, this complaint is presented by reliable electronic means. The above-named 

agent provided a sworn statement attesting to the truth of the foregoing affidavit by telephone. 

Date: June 1, 2020 

Judge’s signature 

City and state: Chicago, Illinois Rebecca R. Pallmeyer, U.S. CHIEF DISTRICT JUDGE 

Printed name and title 

CINDY BERNDDigitally signed by CINDY BERND

Date: 2020.06.01 15:27:07 -05'00'

regoing affidavit by telephone

Judge’s signature 

&5

FILED 6/1/2020

THOMAS G. BRUTON CLERK, U.S. DISTRICT COURT

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UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

AFFIDAVIT

I, CINDY M. BERND, being duly sworn, state as follows: 

1. I am a Special Agent with the Bureau of Alcohol, Tobacco, Firearms &

Explosives (ATF), and have been so employed for approximately 18 years. My current 

responsibilities include the investigation of firearms crimes, including, among others, 

the unlawful possession of firearms. 

2. This affidavit is submitted in support of a criminal complaint alleging

that Brandon Pegues has violated Title 18, United States Code, Section 922(g)(1). 

Because this affidavit is being submitted for the limited purpose of establishing 

probable cause in support of a criminal complaint charging PEGUES with unlawful 

possession of a firearm by a felon, I have not included each and every fact known to 

me concerning this investigation. I have set forth only the facts that I believe are 

necessary to establish probable cause to believe that the defendant committed the 

offense alleged in the complaint. 

3. This affidavit is based on my personal observations, my training and

experience, and information provided to me by other law enforcement agents. 

I. FACTS SUPPORTING PROBABLE CAUSE

A. Pegues Possession of a Firearm

4. On May 30, 2020, the Mayor of Chicago instituted a curfew of 9:00 p.m.

for the city. 

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5. According to law enforcement reporting, at approximately 12:38 a.m. on

May 31, 2020, during the curfew, Chicago Police Department (CPD) officers were in 

the vicinity of 801 South Financial Place in Chicago, in response to mass crowds and 

multiple reported ongoing crimes, including criminal damage to property. 

6. Officers observed four men running southbound on South Financial

Place, some of whom were carrying hammers. 

7. Officers relocated to 801 South Financial Place to investigate further.

Officers observed an individual, later identified as PEGUES, look at them, adjust the 

right side of his waistband, and then flee southbound on South Financial Place. 

8. CPD officers pursued PEGUES on foot. As he ran, PEGUES stumbled

and fell while reaching in his waistband. Officers observed a firearm fall to the 

ground, and further observed PEGUES push the firearm along the ground under a 

vehicle. 

9. CPD officers apprehended PEGUES. A CPD officer recovered the

firearm from underneath the vehicle. The firearm was determined to be a Glock 

model 19, 9mm semi-automatic pistol, bearing serial number SHA485. The firearm was 

loaded. 

B. Pegues’s Criminal History

10. Based on my review of his criminal history records, I know that on or

about January 14, 2010, PEGUES was convicted of residential burglary, a felony, in 

the Circuit Court of Cook County, case number 09C66065402, for which he was 

sentenced to 30 months’ probation. 

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C. Interstate Nexus

11. On or about June 1, 2020, I spoke to ATF Special Agent Ryan McBride,

who advised the following: 

a. Special Agent McBride is a certified interstate nexus expert for

firearms and ammunition who has previously testified in federal court as an 

interstate nexus expert. 

b. Special Agent McBride was informed of the make and model of

the firearm recovered from where PEGUES had pushed it beneath the vehicle. 

c. Based upon his training and experience and the research he

conducted, Special Agent McBride determined that this Glock model 19 9mm pistol 

was manufactured outside the state of Illinois. Therefore, in order for the foregoing 

firearm to have been recovered in Illinois, it had to have moved in interstate or foreign 

commerce. 

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CONCLUSION

12. For all the reasons described above, there is probable cause to believe

that PEGUES has committed a violation of Title 18, United States Code, Section 

922(g)(1) (unlawful possession of a firearm by a felon). 

FURTHER AFFIANT SAYETH NOT. 

 

CINDY M. BERND 

Special Agent, Bureau of Alcohol, Tobacco, 

Firearms & Explosives 

SUBSCRIBED AND SWORN to before me by telephone on June 1, 2020. 

Honorable Rebecca R. Pallmeyer 

United States Chief District Judge 

CINDY BERND

Digitally signed by CINDY 

BERND 

Date: 2020.06.01 15:27:51 

-05'00'

Honorable Rebecca R. Pallm

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