AO 91 (Rev. O6/ase Srreini)-66360%N Document. Filed.04/28/16 Rage of8, PagelD 1 = - ROS a : ' ‘na QEALI United States District Court NORTHERN DISTRICT OF UNITED STATES OF AMERICA V. COMPLAINT JOSHUA WILLIAM JACKSON CASE NUMBER: 3-16-MJ-360-@"/ 1, the undersigned complainant being duly sworn state the following is true and correct to the best of my knowledge and belief. Between on or about September 11, 2014 through April 27, 2016, in the Dallas Division of the Northern District of Texas, Joshua William Jackson, who was then under indictment for a crime punishable by imprisonment for a term exceeding one year, to wit: Theft of Property ($1500-$20,000), did willfully receive firearms, namely a Springfield Armory XDS-45ACP, semi-automatic 45 ACP pistol and a Springtield Armory XDS-9 semi-automatic 9mm pistol said firearms having been shipped and transported in interstate commerce, in violation of Title 18 __, United States Code, Section(s) _922(n) I further state that I am a(n) Special Agent with the Bureau of Alcohol, Tobacco, Firearm: ; and Explosives (ATF) and that this complaint is based on the following facts: See attached Affidavit of Special Agent Matthew C. Belew which is incorporated and made a part hereof by reference. Continued on the attached sheet and made a part hereof: XX Yes No Signature of Complainant Matthew C. Belew Special Agent, DEA Swom to before me and subscribed in my presence, on this 28th Dallas, Tex: ae day of April , 2016, at DAVID L. HORAN Za _ UNITED STATES MAGISTRATE JUDGE 77% Name & Title of Judicial Officer Signature of Judicial OfficerCase 3:16-mj-00360-BN Document 1 Filed 04/28/16 Page 2of8 PagelD 2 AFFIDAVIT OF Special Agent Matthew C. Belew Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) 1, Matthew C. Belew, being duly sworn, depose and state that: I am an ATF Special Agent (SA) in the Dallas Field Division and have been employed as a Special Agent since 2007. Prior to becoming an ATF Agent, I was a Detective with the Sedgwick County Sheriff's Office in Wichita, Kansas. In 2003, I was assigned to the FBI Joint Terrorism Task Force (ITTF) investigating international and domestic terrorism, during this time I was also assigned as a Narcotics detective. In 2006, I was assigned full-time to the Narcotics section until separation of service in 2007. Presently, | investigate violent crime, including drug and firearm offenses, in specific high-crime areas. In my 18 years as a law enforcement officer, [ have been involved in both state and federal drug investigations, including making arrests and executing federal search warrants. As a result, I am familiar with federal firearms and narcotics laws. The information contained in this affidavit is based on my personal knowledge experience, and information provided by other law enforcement officers. This affidavit is being submitted for the purpose of securing an arrest warrant for Joshua Jackson, | have set forth facts that I believe are necessary to establish probable cause that JoshuaCase 3:16-mj-00360-BN Document1 Filed 04/28/16 Page 3of8 PagelD3 Jackson has violated Title 18, U.S.C. § 922(n), Illegal Receipt of a Firearm While Under Indictment. Factual Background On April 27, 2016, at approximately 8:15 a.m., officers from Wichita Falls Police Department (WFPD) conducted a tactical enforcement operation, together with agents from Homeland Security and ATF, at 2600 9" Street, Wichita Falls, Texas 76301, Northern District of Texas to apprehend Joshua William Jackson (DOB: 03/13/1988) for a state arrest warrant issued out of Harris County, Texas. In addition, officers and agents executed a federal search warrant obtained by Special Agents of the Department of Homeland Security (DHS), Homeland Security Investigations (HSI) at the location. WFPD swept and cleared the residence, located Jackson and apprehended him. Three additional female occupants were detained and identified for safety purposes, A search of Jackson's bedroom yielded a Springfield Armory XDS-45ACP, semi-automatic .45 ACP pistol, Serial Number (S/N): $3214072 and Springfield Armory XDS-9 semiautomatic 9mm pistol, S/N: $3949330. Both firearms were found next to the bed on the floor in close proximity to Jackson’s wallet, which contained his driver’s license and social security card. In addition, agents located numerous rounds of .45 ACP, 9mm and .380 caliber ammunition, among other items, in theCase 3:16-mj-00360-BN Document 1 Filed 04/28/16 Page 4of8 PagelD 4 living room of the home. Following his arrest, Jackson waived his Miranda rights, and agreed to be interviewed by DHS HSI Special Agent’s (SA’s) Allison M. Schaefer and Mark Adair, During the recorded interview, Jackson admitted he was currently on state felony probation, and while on probation, he got a friend to purchase several firearms for him. Jackson stated he was not able to purchase the firearms himself because he was on probation, He stated he obtained the following firearms while on probation: two .380 caliber pistols, a .45 ACP pistols and a 9mm pistol. Prior to executing the search warrant, on February 9, 2016, law enforcement officers assigned to the North Texas Trafficking Task Force (NTTTF) received information from the Tarrant County District Attorney’s Office that an adult female, later identified as V.N., was a potential victim of sex trafficking in the Dallas-Fort Worth Metropolitan area, Texas. The information further revealed that Joshua Jackson used force, fraud and coercion to cause V.N. to engage in commercial sex acts over an extended period time. During multiple interviews of V.N., she stated in September 2012, when she was 18 years old, she enrolled at and attended the University of North Texas (UNT) located in Denton, Texas. She lived in a UNT dorm room with her friend. In September 2012, V.N, and her roommate attended an anime convention located inCase 3:16-mj-00360-BN Document 1 Filed 04/28/16 Page 5of8 PagelD 5 downtown Dallas, Texas, and met Jackson, About a month later, in October 2012, Jackson came to visit V.N. from his residence in Houston, Texas, and began living at her dorm room on a permanent basis. From February 2013 through May 2013, Jackson used various methods to coerce and manipulate V.N. to engage in sex acts. In June 2013, Jackson determined the process that V.N. would charge clients and give him the proceeds for her commercial sex acts, and later, in January 2014, Jackson increased the amount she charged. When V.N, told Jackson she did not want to engage in commercial sex acts, he used various methods to coerce her into continuing. For example, in October or November of 2014, Jackson instructed V.N. to lay on the bed naked, and he-useda Taser-on/her stomach, chest, inside thighyand her vagina as punishment. Also, Jackson threatened V.N. with pistols in order to cause her to engage in commercial sex acts. In December 2015, Jackson pointed a pistol at V.N. and told her that he would kill her bloodline, specifically her mother, father, brother and nephew, and she had nowhere to run because he would find her and sell her, Jackson further threatened to pistol whip V.N. and said she was lucky that he did not kill her. V.N. reported Jackson threatened her with guns on approximately ten occasions. Between June 2013 and January 2016, Jackson caused V.N. engaged inCase 3:16-mj-00360-BN Document 1 Filed 04/28/16 Page 6 of 8 PagelD 6 commercial sex acts in various cities including: Denton, Irving, Dallas, Grapevine, Fort Worth, Arlington, San Antonio, Galveston, Corpus Christi, Austin and Tampa, Florida. He would often transport V.N. in his car to these locations, including locations in the Dallas Division of the Northern District of Texas, and he routinely took pistols with him on those trips. Finally, in late January of 2016, V.N. was able to get away from Jackson and report what happened to law enforcement. After learning that Jackson had weapons, HSI enlisted the help of ATF in its investigation into Jackson. Law enforcement later interviewed the former roommate of Jackson and V.N. During the interview, the former roommate indicated that he purchased a total of four firearms for Jackson because he could not purchase them himself. The roommate purchased two firearms for Jackson on or about September | 1, 2014, another one in December of 2014, and the last pistol in November of 2015. He further indicated, among other things, that Jackson moved out of the apartment on or about February 12, 2016, and Jackson took two guns with him, a Smith & Wesson Bodyguard .380 caliber pistol and a Springfield Armory XDS 9 mm caliber pistol A review of Jackson’s criminal record indicated on May 9, 2010, Jackson was arrested by Fort Bend County Sheriff's Office for Theft of Property more than $1,500.00 but less than $20,00.00, a state jail felony charge. Jackson pled guilty, andCase 3:16-mj-00360-BN Document 1 Filed 04/28/16 Page 7 of 8 PagelD7 was placed on five years of deferred adjudication on May 28, 2010. However, Jackson absconded supervision and failed to complete his probation. He is currently in custody for a probation violation through the State of Texas, and that arrest warrant was issued by the State of Texas on 04/12/2016. Federal law, namely Title 18 USC 922(n), prohibits people from receiving firearms while they are under indictment. Since Jackson obtained firearms during, 2014 and 2015 while he was under indictment for his felony theft charge during the term of his deferred adjudication probation, he was prohibited from receiving these firearms under federal law. Likewise, because he remains under probation, he is prohibited from possessing the two firearms found in his bedroom on April 27, 2016. Based on the description of the aforementioned Springfield Armory XDS- 45ACP, semi-automatic 45 ACP pistol, and Springfield Armory XDS-9 semiautomatic 9mm pistol, recovered during the search of 2600 9" Street, Wichita Falls, Texas 76301, Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) SA T. English, Interstate NEXUS Expert, determined the firearms were manufactured in the Country of Croatia. Therefore, for the firearms to be found in the State of Texas, it would have had to have been shipped or transported previously in interstate or foreign commerce, Based on the aforementioned facts herein, there is probable cause to believe thatCase 3:16-mj-00360-BN Document 1 Filed 04/28/16 Page 8 of 8 PagelD 8 between on or about September 11, 2014 through April 27, 2016, in the Dallas Division of the Northern District of Texas and elsewhere, Joshua William Jackson committed violations of the United States Criminal Law, to wit, Title 18 U.S.C. Section 922(n), Illegal Receipt ofa Firearm While Under Indictment. Satter C. Belew ATF Special Agent Subscribed and sworn to before me on this 28th day of April, 2016. Cav L. HORAN United States Magistrate Judge Northern District Of Texas