AO 91 (Rev.

11/11) Criminal Complaint AUSA Albert Berry III (312) 886-7855

UNITED STATES OF AMERICA

ROLAND JACKSON 18CR 64.6

I, the complainant in this case, state that the following is true to the best of my knowledge
and belief.
On or about September 30, 2018, at Midlothian, Illinois, in the Northern District of Illinois,
Eastern Division and elsewhere, the defendant violated:
Code Section Offense Description
Title 18, United States Code, Section having been convicted in any court of a crime
922(g)(l) punishable by imprisonment for a term exceeding
one year, unlawfully possessed in or affecting
interstate commerce, a firearm, namely: (1) a
Ruger, model LCP, caliber .380 pistol, bearing
serial number 372208945, (2) a Ruger, model
LCP, caliber .380 pistol, bearing serial number
372208928, and (3) a Ruger, model LCP, caliber
.380 pistol, bearing serial number 372207151.

This criminal complaint is based upon these facts:

SARGON MACKSUD
Special Agent, Bureau of Alcohol, Tobacco,

Sworn to before me and signed in my presence.

Date: October 1, 2018

City and state: Chicago, Illinois M . DAVID WEISMAN, U.S. Magistrate Judge
Print~cet: VED
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M DAVID WEIQrvk N
MAGISTRATE JUDGE
UNITED STATES DISTRICT COURT
 UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF ILLINOIS

AFFIDAVIT

I, SARGON MACKSUD, being duly sworn, state as follows:

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

. Explosives. I have been so employed since approximately January 2017. My current

responsibilities include the investigation of criminal violations relating to the federal

firearms laws,.including Title 18, United States Code, Sections 922 and 924.

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

that Roland JACKSON (JACKSON) has violated Title 18, United States Code,

Section 922(g)(l). Because this affidavit is being submitted for the limited purpose

of establishing probable cause in support of a criminal complaint charging JACKSON

with receipt, possession, concealment, and storing of a stolen firearm, 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 knowledge, and on information I

have received from other law enforcement personnel and from persons with

knowledge regarding relevant facts.

RUGER FIREARM UPS BURGLARY IN MEMPHIS, TENNESSEE

4. On September 28, 2018, the UPS distribution center in Memphis,

Tennessee received sixteen pallets of firearms from the Ruger factory in North
Carolina. On September 30, 2018, a semi-trailer carrying sixteen pallets of firearms

was scheduled to depart Memphis, Tennessee enroute to Dallas, Texas on September

30, 2018 at 8:00 a.m. At some time between 3:00 a.m. and 4:00 a.m., an alarm was

triggered as an unauthorized U-Haul van drove onto the lot of the UPS distribution

center. According to law enforcement, upon arrival at the distribution center, UPS

employees observed two male, African-American individuals pushing a pallet of boxes

across the lot. The individuals loaded the pallets into a U-Haul van, reversed and

sped off the lot.

5. According to UPS, there were three stolen pallets and further

investigation found that the contents of the three stolen · pallets, contained

approximately 367 firearms. The stolen items were .22 caliber and .380 caliber

firearms.

RECOVERY OF FIREARMS IN MIDLOTHIAN, ILLINOIS

6. On September 30, 2018, at approximately 3:09 p.m., law enforcement

received a call about suspicious activity at a store parking lot located in Midlothian,

Illinois. Upon arrival, law enforcement found a U-Haul van parked in the lot bearing

Arizona license plate AJ22258. The driver of the van identified himself as Roland

JACKSON and the passenger of the van identified himself as Individual A. After a

brief conversation, through the window of the van, law enforcement observed a white

box with a "Ruger" logo on it.

7. Law enforcement requested that Individual A and JACKSON exit the

van. Upon request; JACKSON opened the front, driver's side door and ran. Individual
A climbed into driver's seat, exited the van, and ran. After a brief chase, Individual A

and JACKSON eluded law enforcement.

8. Law enforcement ran Individual A's name through an investigative

database and identified Individual A as the passenger of the vehicle. Similarly, law

enforcement ran JACKSON's name through an investigative database and identified

JACKSON as the driver of the vehicle. After a search of the area, at approximately

6:54 p.m., law enforcement found and arrested Individual A and he was positively

identified as the passenger in the van.

9. Upon seizure of the U-Haul van, law enforcement recovered

approximately 364 Ruger .22 caliber and .380 caliber firearms. Among these

recovered Ruger firearms were: (1) a Ruger, model LCP, caliber .380 pistol, bearing

serial number 372208945, (2) a Ruger, model LCP, caliber .380 pistol, bearing serial

number 372208928, and (3) a Ruger, model LCP, caliber .380 pistol, bearing serial

number 372207151. A check with the UPS distribution center located in Memphis,

Tennessee found that the firearms recovered in the U-Haul van matched the firearms

stolen from the UPS distribution center.

CONFESSION OF INDIVIDUAL A

10. Following his arrest, law enforcement spoke with Individual A. After

waiving Miranda, Individual A stated, in sum and substance that he knew the

individual he was with in the U-Haul van had previously stolen items from train

shipments. Individual A denied participating in the theft but stated that he knew

the firearms were stolen and that he was helping JACKSON and his brother sell the
stolen firearms. Additionally, Individual A stated that he and JACKSON had sold at

least three of the stolen firearms for a total of $400.

INTERSTATE NEXUS OF THE FIREARMS

11. Based on information provided by UPS and my training and experience,

the (1) a Ruger, model LCP, caliber .380 pistol, bearing serial number 372208945, (2)

a Ruger, model LCP, caliber .380 pistol, bearing serial number 372208928, and (3) a

Ruger, model LCP, caliber .380 pistol, bearing serial number 372207151 all traveled

from North Carolina to Memphis, Tennessee, prior to JACKSON's possession of them

on September 30, 2018.

CRIMINAL HISTORY OF JACKSON

12. According to JACKSON's criminal history record, on October 4, 2013,

JACKSON was convicted in Cook County, Illinois, under case number 12 CR 1421602

of residential burglary. Residential burglary is a felony and is punishable by a term

of imprisonment exceeding one year.

13. Based upon the foregoing facts, I respectfully submit that there is

probable cause to believe that on or about September 30, 2018, defendant Roland

JACKSON, having been convicted in any court of a crime punishable by

imprisonment for a term exceeding one year, unlawfully possessed in or affecting

interstate commerce, a firearm, in violation of Title 18, United States Code, Section

922(g)(l).

FURTHER AFFIANT SAYETH NOT.

SARGON MACKSUD
Special Agent, Bureau of Alcohol, Tobacco,
Firearms, & Explosives (ATF)

SUBSCRI AND SWORN to before me on October 1, 2018.

~ ~/~~
M. DAVID WEISMAN
United States Magistrate Judge