Criminal Complaint and Affidavit — United States v. Deandre Lamont McCarter, No. 5:25-cr-00236 (C.D. Cal.)

Summary

A Criminal Complaint by telephone, Document 1, filed 06/26/25, Case 5:25-cr-00236-JGB (complaint Case No. 5:25-mj-00446), United States of America v. Deandre Lamont McCarter, Central District of California. It charges a violation of 18 U.S.C. § 922(g)(1), Felon in Possession of a Firearm, on the basis of an attached affidavit by Special Agent Estevan Banuelos. The affidavit states that on June 26, 2025, officers executing search warrants at the defendant's residence found body armor, safes, firearms and ammunition, that the defendant said the safes belonged to a cousin, and that a Glock pistol was manufactured in Austria. It lists prior felony convictions, including robbery in 2002 and possessing a weapon in prison in 2006. The magistrate judge's signature block reads Sheri Pym.

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“Criminal Complaint and Affidavit — United States v. Deandre Lamont McCarter, No. 5:25-cr-00236 (C.D. Cal.).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-5-25-cr-00236-dkt-1-c-d-cal-d1beca9d52/, SHA-256 b753a1f9562932a0b143e132873e907803307b4c12a938cabbb140140ca064ef.

Full text

Case 5:25-cr-00236-JGB Document 1 Filed 06/26/25 Page 1 of 9 Page ID #:1
AO 91 (Rev. 11/11) Criminal Complaint (Rev. by USAO on 3/12/20) ‫ ܆‬Original ‫ ܆‬Duplicate Original

LODGED
CLERK, U.S. DISTRICT COURT
UNITED STATES DISTRICT COURT
06/26/2025 for the
CENTRAL DISTRICT OF CALIFORNIA
AP
BY: ____________BB______ DEPUTY

Central District of California 06/26/25
KC
United States of America

v.
Case No. 5:25-mj-00446
DEANDRE LAMONT MCCARTER,

Defendant(s)

CRIMINAL COMPLAINT BY TELEPHONE
OR OTHER RELIABLE ELECTRONIC MEANS
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.

On or about the date(s) of June 26, 2025 in the county of San Bernardino in the Central District of California,

the defendant violated:

Code Section Offense Description

18 U.S.C. § 922(g)(1) Felon in Possession of a Firearm

This criminal complaint is based on these facts:

Please see attached affidavit.

_ Continued on the attached sheet.

/s/ Estevan Banuelos
Complainant’s signature

Estevan Banuelos, Special Agent
Printed name and title
Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by telephone.

Date: June 26, 2025
Judge’s signature

City and state: Riverside, California Hon. Sheri Pym, U.S. Magistrate Judge
Printed name and title
Case 5:25-cr-00236-JGB Document 1 Filed 06/26/25 Page 2 of 9 Page ID #:2

AFFIDAVIT

I, Estevan Banuelos, being duly sworn, declare and state as

follows:

I. PURPOSE OF AFFIDAVIT

This affidavit is made in support of a criminal

complaint and arrest warrant against Deandre McCarter

(“MCCARTER”) for a violation of Title 18, U.S.C. § 922(g)(1):

Felon in Possession of a Firearm.

The facts set forth in this affidavit are based upon

my personal observations, my training and experience, and

information obtained from various law enforcement personnel and

witnesses. This affidavit is intended to show merely that there

is sufficient probable cause for the requested complaint, arrest

warrant, and search warrant, and does not purport to set forth

all of my knowledge of or investigation into this matter.

Unless specifically indicated otherwise, all conversations and

statements described in this affidavit are related in substance

and in part only.

II. BACKGROUND OF AFFIANT

I am a Special Agent with the Federal Bureau of

Investigation (“FBI”) and have been employed with the FBI since

October 2019. I have completed the FBI 18-week training

program, which includes instruction in investigating various

criminal offenses governed by federal law. I have received

training in the enforcement of the laws of the United States,

including training in the preparation, presentation, service,
Case 5:25-cr-00236-JGB Document 1 Filed 06/26/25 Page 3 of 9 Page ID #:3

and execution of criminal complaints and arrest and search

warrants.

I am currently assigned to the FBI Los Angeles Field

Office, Riverside Resident Agency, where I am on the Inland

Violent Crime Suppression Task Force (“IVCSTF”) with an emphasis

on violent offenses and fugitive apprehension. This task force

consists of experienced investigators from the FBI, Riverside

Police Department, Riverside County Sheriff’s Department,

Fontana Police Department, San Bernardino Police Department, and

the San Bernardino County Sheriff’s Department.

In connection with my employment with the FBI, I have

participated in multiple investigations in which I have used a

variety of investigative techniques, including interviewing

suspects and witnesses, speaking with law enforcement agents and

officers, conducting and reviewing electronic surveillance,

executing arrest and search warrants, analyzing telephone

records, and collecting and reviewing physical evidence.

III. SUMMARY OF PROBABLE CAUSE

On June 26, 2025, law enforcement officers executed

federal search warrants on the residence and person of MCCARTER

for evidence of MCCARTER and his co-conspirators’s participation

in an attempted murder of a witness using firearms. See Case

Nos. 25-MJ-3795-PVC (Sealed); 25-MJ-3796 (Sealed). Two of

MCCARTER’s co-conspirators, Toriano KNOX and Kenya JONES, were

charged in an indictment for participating in a massive COVID-19

tax fraud scheme with the fraud’s ringleader, Kristerpher

TURNER, and then causing the attempted murder of TURNER, in
Case 5:25-cr-00236-JGB Document 1 Filed 06/26/25 Page 4 of 9 Page ID #:4

violation of, among other things, 18 U.S.C. 1512(a)(1)(C)

(attempted murder of a witness), and 18 U.S.C.

§ 924(c)(1)(A)(iii) (discharge of a firearm in furtherance of a

crime of violence). See Case No. 25-CR-00462-CVD.

During the execution of the search on MCCARTER’s

residence on N. Duesenberg Drive, Ontario, officers discovered

inside of MCCARTER’s closet: a set of body armor and two safes

containing four firearms, including a Glock 43 X 9mm pistol,

bearing serial number BWVE486, a Palmetto 5.7 Rock handgun, two

high-capacity magazines, a Smith and Wesson .38 special

revolver, loaded with 5 rounds of .38 caliber ammunition, a

short barrel rifle with no serial number, and approximately 300

rounds of ammunition.

MCCARTER knew he was not allowed to possess ammunition

or firearms: he was a four-time convicted felon who served a 15-

year sentence for robbery, and who was also convicted of

possessing a weapon while in prison.

IV. STATEMENT OF PROBABLE CAUSE

Based on my review of law enforcement reports, videos,

conversations with other law enforcement agents, and my own

knowledge of the investigation, I am aware of the following:

A. MCCARTER IS INVOLVED IN AN ATTEMPTED MURDER PLOT

Based on my review of law enforcement reports,

conversations with FBI Special Agents assigned to the case, I

understand the following:

On June 11, 2025, a grand jury returned an indictment

against TURNER, KNOX, JONES, and JOYCE JOHNSON in case number
Case 5:25-cr-00236-JGB Document 1 Filed 06/26/25 Page 5 of 9 Page ID #:5

25-CR-00462-CVD. The indictment charges TURNER and JOHNSON with

conspiracy to commit mail fraud, in violation of 18 U.S.C.

§ 1349, mail fraud, in violation of 18 U.S.C. § 1341, and

conspiracy to defraud the government with respect to claims, in

violation of 18 U.S.C. § 286. KNOX and JONES are charged with

the same fraud offenses, as well as attempt to kill a witness,

in violation of 18 U.S.C. § 1512(a)(1)(C), and discharge of a

firearm in furtherance of a crime of violence, in violation of

18 U.S.C. § 924(c)(1)(A)(iii).

In connection to the attempted murder and fraud scheme

alleged in the indictment, the Honorable Pedro V. Castillo, U.S.

Magistrate Judge, authorized search warrants for MCCARTER’s

person and his residence, allowing officers to seize evidence of

18 U.S.C. § 1958(a) (murder for hire resulting in personal

injury, conspiracy), 18 U.S.C. § 1512(a)(1)(C) (attempted murder

of a witness), 18 U.S.C. § 924(c)(1)(A)(iii) (discharge of a

firearm in furtherance of a crime of violence). Based on the

search warrant affidavits, I understand that MCCARTER is

believed to have been on the phone with one of the masked

assailants that shot TURNER at the time of TURNER’s attempted

assassination on August 29, 2023.

B. MCCARTER POSSESSED FOUR FIREARMS, AMMUNITION, AND BODY
ARMOR IN HIS BEDROOM CLOSET

On the morning of June 26, 2025, I and other law

enforcement officers proceeded to execute the search warrant of

defendant’s residence, which was an apartment on N. Duesenberg

Drive, Ontario, CA 91764. We located MCCARTER on the balcony of
Case 5:25-cr-00236-JGB Document 1 Filed 06/26/25 Page 6 of 9 Page ID #:6

his apartment. MCCARTER’s girlfriend, M.P., was also present on

the scene.

Inside of the master bedroom closet used by MCCARTER

and M.P., officers found one VFT Gear black body armor shirt and

one black Abalone body armor vest, and three locked safes.

In the large locked safe, officers found:

a. A short barrel rifle, bearing no serial number,

otherwise known as a “ghost gun,”

b. 31 rounds of ammunition found inside a high-

capacity magazine bearing the headstamp “300 Blackout,”

c. 19 rounds of ammunition found inside a high

capacity magazine bearing the headstamp “WMA 21”,

d. An ammunition box filled with approximately 170

rounds of assorted ammunition, including 9mm, 5.56 caliber, and

300 Blackout ammunition.

e. A Palmetto State Armory 5.7 Rock handgun.

In a smaller, locked safe, 1 officers found:

a. A Glock 43 X 9mm pistol, bearing serial number

BWVE486;

b. A Smith and Wesson .38 caliber revolver, bearing

serial number CVK383;

c. Loaded into the Smith and Wesson revolver, five

rounds of .38 caliber ammunition bearing the heads stamp

“Federal 38 Special”;

d. MCCARTER’s passport,

1 Officers found the key to the smaller safe on the bed in
the master bedroom.
Case 5:25-cr-00236-JGB Document 1 Filed 06/26/25 Page 7 of 9 Page ID #:7

e. MCCARTER’s California Driver’s License,

f. And vehicle registration paperwork in MCCARTER’s

name.

Officers read MCCARTER his Miranda rights and MCCARTER

consented to an interview. During the interview, MCCARTER

claimed that the safes in the bedroom closet did not belong to

him. MCCARTER claimed that they belonged to his cousin and he

had no access to what was inside. When asked when the cousin

would have brought the safes to MCCARTER’s residence, MCCARTER

responded that it was a couple months prior. This statement was

contradicted by Mirandized statements from M.P., who stated that

the safes had been in the residence for about a year and no one

else had lived inside the apartment besides MCCARTER and M.P.

After officers opened the safes, I and FBI SA Steven

Kinsey had another conversation with MCCARTER in which we asked

if there would be any reason officers would find MCCARTER’s DNA

on the guns located in the safes, noting that his DNA would be

on file because MCCARTER is a convicted felon. MCCARTER

responded affirmatively, noting that he would go with his cousin

and take the guns to use at a shooting range and claimed that

was legal for him to go to the range and shoot.

C. MCCARTER’s Felony Criminal History

I have reviewed criminal history and documents for

MCCARTER and learned that MCCARTER has previously been convicted

of the following felony crimes punishable by a term of

imprisonment exceeding one year:
Case 5:25-cr-00236-JGB Document 1 Filed 06/26/25 Page 8 of 9 Page ID #:8

a. On or about April 25, 2002, MCCARTER was

convicted for a violation of California Penal Code Section 211,

Robbery, in the Superior Court for the State of California,

County of Los Angeles, Case Number VA063818;

b. On or about April 25, 2002, MCCARTER was

convicted for a violation of California Penal Code Section 211,

Robbery, in the Superior Court for the State of California,

County of Los Angeles, Case Number VA063818;

c. On or about April 25, 2002, MCCARTER was

convicted for a violation of California Penal Code Section 211,

Robbery, in the Superior Court for the State of California,

County of Los Angeles, Case Number VA063818; 2

d. On or about August 1, 2006, MCCARTER was

convicted for a violation of California Penal Code Section

4502(a), Possessing a Weapon in Prison, in the Superior Court

for the State of California, County of Imperial, Case Number

JCF15882.

D. Interstate Nexus

In January 2022, I completed the International

Firearms Specialist Academy certifying me as a gun nexus expert

and have testified as an expert on interstate nexus of firearms.

On June 26, 2025, I examined the Glock 43 X pistol

bearing serial number BWVE486 and confirmed that the handgun was

manufactured in Austria, outside of the State of California.

2 Based on my review of MCCARTER’s criminal history records,
there were three robbery convictions, for which he received
sentences of 15 years presentment, 52 months of prison, to run
consecutively, and 1 year of imprisonment.
Case 5:25-cr-00236-JGB Document 1 Filed 06/26/25 Page 9 of 9 Page ID #:9

Because the handgun was found in California, I believe that it

has traveled in and affected commerce.

V. CONCLUSION

For all of the reasons described above, there is

probable cause to believe that MCCARTER has committed a

violation of Title 18, U.S.C. § 922(g)(1): Felon in Possession

of a Firearm.

Attested to by the applicant in
accordance with the requirements
of Fed. R. Crim. P. 4.1 by
telephone on this 26 day of June,
2025.

THE HONORABLE Sheri Pym
UNITED STATES MAGISTRATE JUDGE

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