Indictment — United States v. Jessica Robinson, No. 3:24-cr-00004

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An Indictment (Six Counts) in United States of America v. Jessica Robinson, Case No. 3:24-cr-00004-DRL-MGG, Document 1, filed 01/10/24, in the Northern District of Indiana, South Bend Division. The counts allege that on or about January 9, 2021, January 31, 2021, and June 5, 2021, the defendant made false statements to Midwest Gun Exchange, a licensed firearms dealer, on a Form 4473 Firearms Transaction Record, including to the effect that the defendant was not an unlawful user of, or addicted to, marijuana or other controlled substances. They cite Title 18, United States Code, Section 922(a)(6) and Section 924(a)(1)(A). The forfeiture allegations cite Section 924(d)(1). It is dated January 10, 2024, and the approval block names Clifford D. Johnson, United States Attorney.

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USDC IN/ND case 3:24-cr-00004-DRL-MGG document 1 filed 01/10/24 page 1 of 7

UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF INDIANA . _RJLED- .
SOUTH BEND DIVISION ‘ 4

UNITED STATES OF AMERICA ) INDICTMENT NORTHERN SISTRICT OF INDIANA
) (Six Counts)
)

Vv. ) Case No.: 3:24-cr-4

)
) .
) 18 U.S.C. § 922(a)(6)

JESSICA ROBINSON ) 18 U.S.C. § 924(a)(1)(A)

THE GRAND JURY CHARGES:

COUNT 1

On or about January 9, 2021, in the Northern District of Indiana,
JESSICA ROBINSON,

defendant herein, in connection with the acquisition of a firearm from Midwest Gun
Exchange, a licensed firearms dealer, knowingly made a false and fictitious
statement to Midwest Gun Exchange that was intended and likely to deceive
Midwest Gun Exchange as to a fact material to the lawfulness of the acquisition of
the firearm, in that the defendant executed a Department of Justice Bureau of
Alcohol, Tobacco, Firearms and Explosives Form 4473 Firearms Transaction Record
to the effect that the defendant was not an unlawful user of, or addicted to,
marijuana or other controlled substances when in fact she was an unlawful user.

All in violation of Title 18, United States Code, Section 922(a)(6).
USDC IN/ND case 3:24-cr-00004-DRL-MGG document 1 filed 01/10/24 page 2 of 7

THE GRAND JURY FURTHER CHARGES:

COUNT 2

On or about January 9, 2021, in the Northern District of Indiana,
JESSICA ROBINSON,

defendant herein, knowingly made a false statement and representation to Midwest
Gun Exchange, a licensed firearms dealer, with respect to information required by
the provisions of Chapter 44 of Title 18, United States Code, to be kept in the
records of Midwest Gun Exchange, in that the defendant executed a Department of
Justice Bureau of Alcohol, Tobacco, Firearms and Explosives Form 4473 Firearms
Transaction Record to the effect that the defendant was not an unlawful user of, or
addicted to, marijuana or other controlled substances when in fact she was an
unlawful user.

All in violation of Title 18, United States Code, Section 924(a)(1)(A).
USDC IN/ND case 3:24-cr-00004-DRL-MGG document 1 filed 01/10/24 page 3 of 7

THE GRAND JURY FURTHER CHARGES:

COUNT 3

On or about January 31, 2021, in the Northern District of Indiana,
JESSICA ROBINSON,

defendant herein, in connection with the acquisition of a firearm from Midwest Gun
Exchange, a licensed firearms dealer, knowingly made a false and fictitious
statement to Midwest Gun Exchange that was intended and likely to deceive
Midwest Gun Exchange as to a fact material to the lawfulness of the acquisition of
the firearm, in that the defendant executed a Department of Justice Bureau of
Alcohol, Tobacco, Firearms and Explosives Form 4473 Firearms Transaction Record
to the effect that the defendant was not an unlawful user of, or addicted to,
marijuana or other controlled substances when in fact she was an unlawful user.

All in violation of Title 18, United States Code, Section 922(a)(6).
USDC IN/ND case 3:24-cr-00004-DRL-MGG document 1 filed 01/10/24 page 4 of 7

THE GRAND JURY FURTHER CHARGES:

COUNT 4

On or about January 31, 2021, in the Northern District of Indiana,
JESSICA ROBINSON,

defendant herein, knowingly made a false statement and representation to Midwest
Gun Exchange, a licensed firearms dealer, with respect to information required by
the provisions of Chapter 44 of Title 18, United States Code, to be kept in the
records of Midwest Gun Exchange, in that the defendant executed a Department of
Justice Bureau of Alcohol, Tobacco, Firearms and Explosives Form 4473 Firearms
Transaction Record to the effect that the defendant was not an unlawful user of, or
addicted to, marijuana or other controlled substances when in fact she was an
unlawful user.

All in violation of Title 18, United States Code, Section 924(a)(1)(A).
USDC IN/ND case 3:24-cr-00004-DRL-MGG document 1 filed 01/10/24 page 5 of 7

THE GRAND JURY FURTHER CHARGES:

COUNT 5

On or about June 5, 2021, in the Northern District of Indiana,
JESSICA ROBINSON,

defendant herein, in connection with the acquisition of a firearm from Midwest Gun
Exchange, a licensed firearms dealer, knowingly made a false and fictitious
statement to Midwest Gun Exchange that was intended and likely to deceive
Midwest Gun Exchange as to a fact material to the lawfulness of the acquisition of
the firearm, in that the defendant executed a Department of Justice Bureau of
Alcohol, Tobacco, Firearms and Explosives Form 4473 Firearms Transaction Record
to the effect that the defendant was the actual transferee/buyer of the firearm when
in fact she was not the actual transferee/buyer, and to the effect that the defendant
was not an unlawful user of, or addicted to, marijuana or other controlled
substances when in fact she was an unlawful user.

All in violation of Title 18, United States Code, Section 922(a)(6).
USDC IN/ND case 3:24-cr-00004-DRL-MGG document 1 filed 01/10/24 page 6 of 7

THE GRAND JURY FURTHER CHARGES:

COUNT 6

On or about June 5, 2021, in the Northern District of Indiana,
JESSICA ROBINSON,

defendant herein, knowingly made a false statement and representation to Midwest
Gun Exchange, a licensed firearms dealer, with respect to information required by
the provisions of Chapter 44 of Title 18, United States Code, to be kept in the
records of Midwest Gun Exchange, in that the defendant executed a Department of
Justice Bureau of Alcohol, Tobacco, Firearms and Explosives Form 4473 Firearms
Transaction Record to the effect that the defendant was the actual transferee/buyer
of the firearm when in fact she was not the actual transferee/buyer, and to the effect
that the defendant was not an unlawful user of, or addicted to, marijuana or other
controlled substances when in fact she was an unlawful user.

All in violation of Title 18, United States Code, Section 924(a)(1)(A).
USDC IN/ND case 3:24-cr-00004-DRL-MGG document 1 filed 01/10/24 page 7 of 7

FORFEITURE ALLEGATIONS

1. The allegations contained in Counts 1-6 of the Indictment are hereby
realleged and by this reference fully incorporated herein for the purpose of alleging
forfeiture to the United States of America pursuant to the provisions of Title 18,
United States Code, Section 924(d)(1), and Title 28, United States Code, Section
2461(c).

2. Upon conviction of any or all of Counts 1-6 of the Indictment, the
defendant, JESSICA ROBINSON, shall forfeit to the United States of America
pursuant to Title 18, United States Code, Section 924(d), and Title 28, United
States Code, Section 2461(c), any and all firearms, firearm magazines or clips, and

ammunition involved in the commission of the offense.

Dated: January 10, 2024

A TRUE BILL:

s/ Grand Jury Foreperson
Grand Jury Foreperson

APPROVED BY:

CLIFFORD D. JOHNSON
UNITED STATES ATTORNEY

By: _s/ Katelan McKenzie Doyle
Katelan McKenzie Doyle
Assistant United States Attorney


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