Beruflich Dokumente
Kultur Dokumente
V.
Introduction
President.
I
5. Defendant ANA BUNDY came to hold several administrative
facilities.
10. Fully automatic weapons and rifles with barrels less than
FFLs are permitted to have in their inventory such weapons and are
limited to two samples of any model machine gun and must register
same make and model even to a qualifying FFL, and even then, must
facility.
contracts.
its business.
automatic form, they are not subject to enhanced regulation and can
physical plant.
Count One
herein by reference.
HOWELL, RONALD SLEZAK, and ANA BUNDY, defendants herein, and others
that is:
section 5861(d) i
and conceal an obj ect with the intent to impair the obj ect' s
violation of Title 18, United States Code, Section 1512(b) (2) (B);
Section 1519.
both the M4s and the AK47s. The Sheriff's office provided blank
paid for the weapons. When the weapons arrived at the Sheriff's
the Sheriff's Office had no direct access. At the time the weapons
gain favor with the Government of the Kingdom of Jordan. When the
give the appearance that the weapons had been purchased by them as
individuals.
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4. Another means emanated from the defendant's desire to
contracts with the Government with short barrel rifles (SBRs). The
rifles and then had their own armorers install the short barrels on
what had been long barrel rifles. They did this without
the defendants detached the short barrels from the receivers they
However, the short barrels and their receivers were shipped at the
assembled.
facility. After moving them, and despite their knowledge that the
long barrels and returned only the long barrel guns to the location
initiated with an order directing that the SBRs be both moved and
altered. After this directive was issued and was carried out, the
have given the false impression that he, the new President, and not
weapons. The new President refused to sign the letter and directed
Overt Acts
SBRs.
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rifles.
rifles.
11
Blackwater/Xe.
12
and possess the Bushmaster automatic M4s under the pretense that
and possess the Romanian automatic AK47s under the pretense that
Despite the fact that the employee was then responsible for the
firearms, BUNDY told him it was none of his business what was in
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they well knew previously been gifted to the King of Jordan and/or
his entourage.
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Obstruction of Justice
rifles then being held at the Moyock facility was "not an option".
ANDREW HOWELL and ANA BUNDY, and with the objective of avoiding
facility.
the direction of defendants ANDREW HOWELL and ANA BUNDY, with the
dated, would have given the false impression that the President of
rifles.
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Count Two
firearms dealer, that is, they falsely completed an ATF Form 4473
serial #GGA645 which firearm, as they well knew, had actually been
gifted to the King of Jordan and/or his entourage, and did aid and
~ J~i3W
abet in aoing so, in violation of Title 18, United States Code,
1\
Section 924 (a) (1) (A) and 2.
Count Three
well knew, been gifted to the King of Jordan and/or his entourage,
~tln
and d 1' d al' d an d a b e ' J;l7,
uOlng~ .
so ln 'I
V10 '
atlon 0 f T'lt I e 18, Unlte
. d
1\
States Code, Sections 924(a) (1) (A) and 2.
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Count Four
knew, been gifted ~o the ~ng of Jordan and/or his entourage, and
~/gv~~
did aid and abet~in ~oing so, in .violation of Title 18, United
Count Five
well knew, been gifted to the King of Jordan and/or his entourage,
~.Js~~
and did aid and abet in doing SOl in violation of Title 18, United
)..
Count Six
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that is, they falsely completed an ATF Form 4473 which represented
been gifted to the King of Jordan and/or his entourage, and did aid
b ~jsd·t>~
and a et In
1\
olng so, , VlO
In ' 1 a t'lon 0 f T'tl
l e 18 ,Unlte
' d States Co d e,
Count Seven
and elsewhere defendant GARY JACKSON and others, both known and
behalf of Blackwater/Xe, and did aid and abet others in doing so,
in violation of Title 18, United States Code, Section 922(0) (1) and
2.
Count Eight
both known and unknown to the Grand Jury, did knowingly and
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so, in violation of Title 18, United States Code, Section 922 (0) (1)
and 2.
Count Nine
both known and unknown to the Grand Jury, did knowingly and
Bus~ter M4s held in the armory of Blackwater/Xe, and did aid and
, '~~c4i,ln
abet ln ~olng so,
, ,
violatlon of Tltle 18, United States Code,
"
Section 922(0) (1) and 2.
Count Ten
defendant GARY JACKSON, and others, both known and unknown to the
held in the armory of Blackwater/Xe, and did aid and abet in~oi~g
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so, in violation of Title 26, United States Code, Section 5861 (d)
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Count Eleven
both known and unknown to the Grand Jury, did knowingly and
Count Twelve
both known and unknown to the Grand Jury, did knowingly and
guns, held in the armory of Blackwater/Xe, and did aid and abet i~ ~
/j
doing so, in violation of Title 26, United States Code, Section
Count Thirteen
defendants GARY JACKSON and others, both known and unknown to the
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and abet in d~ing so, in violation of Title 26, United States Code,
,{
Section 5861(d) and Title 18, United States Code, Section 2.
Count Fourteen
Carolina and elsewhere, defendants ANDREW HOWELL and ANA BUNDY, did
do so, with the intent to cause and induce a person to alter and
conceal an obj ect for the purpose of impairing the obj ect' s
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Count Fifteen
falsely stated that the President had ordered the movement and
A, TRUJUlBcILl:..
rOREPtmsOzq---::
DATE: 1/),Zf;/l)
GEORGE E. B. HOLDING
United States Attorney
JO~L~·IkL../ ~
Assistant United States Attorney
Criminal Division
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