Indictment — United States v. Billy Cao Cruz (Dkt. 1, May 7, 2025)

Summary

This Indictment in the United States District Court for the District of Guam, Case 1:25-cr-00004, charges Billy Cao Cruz. Count 1, Failure to Register an Aircraft, alleges that on or about February 1, 2025, Cruz knowingly and willfully operated a DJI Mavic Mini 4 Pro unmanned aerial vehicle, knowing that the aircraft was not registered. Count 2, Violation of National Defense Airspace, alleges that on or about February 1, 2025, Cruz operated the same aircraft in National Defense Airspace around Camp Blaz, United States Marine Corps Base, Guam. A Notice of Forfeiture applies to Count One and covers aircraft whose use relates to the offense.

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SHAWN N. ANDERSON 5
United States Attorney iF: Le Dd.
STEPHEN F. LEON GUERRERO DISTRICTGOURT OrS0"™
Assistant U.S. Attorney MAY 07 2025
Sirena Plaza, Suite 500

108 Hernan Cortez Avenue JEANNE G. QUINATA
Hagatfia, Guam 96910 CLERK OF COURT

PHONE: (671) 472-7332
FAX: (671) 472-7215

Attorneys for the United States of America
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF GUAM
UNITED STATES OF AMERICA, CRIMINAL CASE NO. 2 a ~ 0 0 0 0 4

INDICTMENT

Plaintiff, FAILURE TO REGISTER AN AIRCRAFT
[49 U.S.C. § 46306(b)(6)(A)]

(Count 1)

VS.
VIOLATION OF NATIONAL DEFENSE
AIRSPACE

BILLY CAO CRUZ, [49 U.S.C. §§ 46307 and 40103]

(Count 2)

NOTICE OF FORFEITURE
Defendant. [49 U.S.C. § 46306 & 28 U.S.C. § 2461(c)]

THE GRAND JURY CHARGES:

GENERAL ALLEGATIONS

At times material to this Indictment:

COUNT 1: FAILURE TO REGISTER AN AIRCRAFT

On or about February 1, 2025, in the District of Guam, the Defendant BILLY CAO CRUZ,
knowingly and willfully operated an aircraft eligible for registration with the Federal Aviation
Administration under Title 49, United States Code, Section 44102, namely, a DJI Mavic Mini 4

Pro unmanned aerial vehicle with serial number 1581F6Z9C239P00399UT, knowing that the
INDICTMENT - 1

Case 1:25-cr-00004 Document1 Filed 05/07/25 Page1of3

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aircraft was not registered under Title 49, United States Code, Section 44103.

COUNT 2: VIOLATION OF NATIONAL DEFENSE AIRSPACE

On or about February 1, 2025, in the District of Guam, the Defendant BILLY CAO CRUZ,

knowingly and willfully operated an aircraft, namely, a DJI Mavic Mini 4 Pro unmanned aerial

vehicle with serial number 1581F6Z9C239P00399UT, in National Defense Airspace around Camp
Blaz, United States Marine Corps Base, Guam, in violation of Title 49, United States Code,
Sections 46307 and 40103, and Title 14, Code of Federal Regulations, Section 99.7, a regulation
prescribed under Title 49, United States Code, Section 40103(b)(3).
NOTICE OF FORFEITURE
1, Pursuant to Rule 32.2 of the Federal Rules of Criminal Procedure, notice is hereby
given that the United States will seek forfeiture as part of any sentence, pursuant to Title 49, United
States Code, Section 46306(d) and Title 28, United States Code, Section 2461(c), in the event of
the Defendant’s conviction of the offense set forth in Count One of this Indictment.
2. The Defendant, if so convicted, shall forfeit to the United States the following:
(a) All right, title, and interest in any and all aircraft whose use relates to such offense;
(b) All right, title and interest in any and all aircraft, used, or intended to be used to aid
or facilitate the commission of any such offense; and
(c) To the extent such property is not available for forfeiture, a sum of money equal to
the total value of the property described in subparagraphs (a) and (b).
3. If any of the property described above, as a result of any act or omission of the
Defendant:
(a) cannot be located upon the exercise of due diligence;
(b) has been transferred, sold to, or deposited with a third party;

(c) has been placed beyond the jurisdiction of the court;
INDICTMENT - 2

Case 1:25-cr-00004_ Document1 Filed 05/07/25 Page 2 of 3
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(d) has been substantially diminished in value; or
(ce) has been commingled with other property that cannot be divided without difficulty,
the United States shall be entitled to forfeiture of substitute property pursuant to Title 21, United
States Code, Section 853(p), as incorporated by Title 28, United States Code, Section 2461(c).
All pursuant to Title 49, United States Code, Section 46306(d) and Title 28, United States
Code, Section 2461(c).
DATED this 7th day of May, 2025.

A TRUE BILL.

Redacted

SHAWN N. ANDERSON
United States Attorney
Districts of Guam and the NMI

By: Vo. _—

STEPHEN F. LEON GUERRERO
Assistant U.S. Attorney

INDICTMENT - 3

Case 1:25-cr-00004 Document1 Filed 05/07/25 Page 3of3


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