Jackson Complaint

AO 91 (Rev.
11/11) Criminal Complaint AUSA Albert Berry III (312) 886-7855

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
UNITED STATES OF AMERICA

CASE NUMBER:
V.
ROLAND JACKSON 18CR 64.6

CRIMINAL COMPLAINT MM.ISTllATE J-UOOE WEISMAN
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:

__x_ Continued on the attached sheet.
SARGON MACKSUD
Special Agent, Bureau of Alcohol, Tobacco,
Sworn to before me and signed in my presence.
Date: October 1, 2018

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Judge s signature
City and state: Chicago, Illinois M . DAVID WEISMAN, U.S. Magistrate Judge
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MAGISTRATE JUDGE
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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.

CONCLUSION
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

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AO 91 (Rev.

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

UNITED STATES OF AMERICA

ROLAND JACKSON 18CR 64.6

This criminal complaint is based upon these facts:

Sworn to before me and signed in my presence.

Date: October 1, 2018

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

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

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

that the defendant committed the offense alleged in the complaint.

3. This affidavit is based on my personal knowledge, and on information I

knowledge regarding relevant facts.

RUGER FIREARM UPS BURGLARY IN MEMPHIS, TENNESSEE

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

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

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

sped off the lot.

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

RECOVERY OF FIREARMS IN MIDLOTHIAN, ILLINOIS

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

box with a "Ruger" logo on it.

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

and JACKSON eluded law enforcement.

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

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

identified as the passenger in the van.

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

stolen from the UPS distribution center.

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,

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,

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

of imprisonment exceeding one year.

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

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

FURTHER AFFIANT SAYETH NOT.

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

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