Affidavit for a Warrant to Search and Seize - Firearms Investigation

This affidavit, prepared by Investigator Fahaad Alzaabi, details the grounds for a search and seizure warrant related to the illegal possession and trading of high-caliber weapons and related accessories by Pete Tommy Gunne. The affidavit outlines the investigator's background, training, and experience, emphasizing the established facts and investigative techniques used to gather evidence. It presents information from a confidential informant (CA-1), detailing Gunne's communications regarding firearms, his interactions with other suspects, and financial transactions. The affidavit describes the investigation, including surveillance, communications analysis, and financial records, and presents evidence supporting the probable cause for the warrant, including Gunne's communications with an undercover agent, email exchanges detailing firearms purchases, and suspicious financial transactions. The document also includes details of an airport investigation involving Gunne's accomplice, Nathan Stone, and the retrieval of incriminating evidence from Stone's confiscated phone.

AFFIDAVIT FOR A WARRANT TO SEARCH AND SEIZE
Introduction and Agent Background
I, Fahaad Alzaabi, being duly sworn in, depose and state the following:
I am an investigator in the Criminal Investigators Division, United States (U.S.)
Department of State, Virginia since June 30th, 2009 and have served as a general
investigator and a narcotics investigator in the ATF and Virginia State Police Task
Forces. I have been doing Criminal investigations for the United States, Department of
State, since the commencement of my official duties. I have received comprehensive
training in different aspects of investigations that are of both criminal and civil in
nature from the Federal Law Enforcement Training Agency. I have a Masters in
Forensic Science from Walden University, which has provided me with the capacity
to apply the skills I have learnt in investigative analysis and cyber crime.
During my tenure as an investigative officer, I have met with a number of suspects
who have been with the possession of fire arms, ammunition and related accessories. I
have also interrogated a number of investigative officers, witnesses, informants and
defendants in relation to the possession of firearms and ammunition as part of my
investigative responsibilities.
The information listed out in this affidavit comes from the leads given by informants,
facts given by other investigative officers, my own observations about the miscreant
and my intuitions based on the experiences I had garnered over the years. Based on
my experience and training, I know the following facts about illegal arms possession
and felony:

1. It is fair and acceptable to believe that a person who is dealing with firearms
and ammunition could be storing them at their homes or surrounding premises.
2. Possession of firearms would normally be accompanied by fire arm accessories
such as bullets, magazines, parts of guns, other ammunition, cartridges,
magazines, receipts of the purchase or other documents related to similar
purchases.
3. There may be evidence of weapon possession in the form of digital evidences
such as email correspondence, chat messages, phone calls, digital images and
soft copies of ammunition possession documents.
4. Suspects who have already been convicted of fire arms and related cases may
hide weapons inside their homes itself, or within the periphery of their homes,
which may cover their backyard, garage, vehicles or other areas within the
vicinity of their homes.
5. That it is possible for suspects to take photographs of themselves with their
weapons or the weapons alone, or their friends photographs with weapons and
store them in their phones. And that they may decide to share these photos with
their immediate friends through photo sharing mediums. They may decide to
save these images in their own computers or external devices such as flash
drives or memory cards
The Virginia State Police are currently investigating the case of Pete Tommy Gunne,
DOB 12-09-1980, residing at 4400 University Dr, Fairfax, Virginia, 22030, ENG5358
in suspicion of illegal possession and trading of high calibre weapons and their related
accessories. The details of the case as per my knowledge have been listed below:

1. Based upon my investigation, expertise, education, judgement and information
exchanges with the confidential informant, who will hereby be referred to as
CA-1, I have gained sufficient personal information regarding the ongoing
investigation. It has been accepted by CA-1 that he has been in regular contact
with an individual name Pete Tommy Gunne, through a mutual contact, who
had been enquiring about the availability of a variety of high calibre firearms
through the internet.
2. It is highly important that CA-1’s identity has to be undisclosed and considered
anonymous throughout the investigation. If there are any risks of CA-1’s
identity being revealed at present or at a later stage during the ongoing
investigation, CA-1 or his immediate family members could be in danger that
could be even life threatening.
3. CA-1 has proved to be a legitimate and reliable informant at previous instances
as there have been occasions where the leads that were given by him had
resulted in the execution of search warrants and seizures of arms and
ammunition and seizure of drugs at a number of previous occasions.
4. This affiant had the opportunity to interact with CA-1 during the past six
months on a regular basis, to enquire about the whereabouts of Pete Tommy
Gunne, who had been residing at 44oo University Dr, Fairfax, Virginia, 22020,
ENG 5358.
5. It had been disclosed that Gunne was in touch with CA-1, on many occassions
through a mutual contact who has been CA-1’s accomplice for the past few
years. It is assumed that Gunne was under the presumption that CA-1 had a

number of contacts and secretive information about arms buyers from countries
like Venuzueal and Argentina in South America.
6. Gunne has also contacted CA-1 to have discussions about the different modes
of possible identity theft, which CA-1 doubts was for the purchase of high
calibre firearms that mandatorily requires a legitimate identification and
genuine credentials of the buyer.
7. It had been observed that Gunne was frequently visited in a black Toyota
Camry by two white males and a black male at his residence on many
occasions during the past six months. On checking the Registry of Motor
Vehicles it had been revealed that the Camry was registered under the name of
Reece Nielson, who was at a later stage, identified as one of the frequent
visitors to Gunn’s residence.
8. A detailed probation check of Reece Nielson revealed that he had a long
standing criminal history and served a time span of 3 years in James River
Correctional Centre, Virginia. The crimes that were registered in his name was
mainly for the possession of firearms without proper identification, felony and
drug trafficking.
9. The investigation team, on different occasions had been on a close trail with
Gunn’s movements since Februrary 2016. On the 23rd of June this year,
approximately by around 7:40 p.m, it came to the investigator’s notice who
were in the trail of Pete Gunn, that he had arranged a meeting a middle aged
white male at Villa Mozart, a restaurant at 4009 Chain Bridge Rd, Fairfax, VA
22030.

10. A check on the Registry for Motor Vehicles identification revealed that the
white Chevy the man rode was registered under the name Jackson Tay. An
identification check and a further probe on the individual revealed that Tay was
currently employed as a special agent in the Bureau of Alcohol, Tobacco,
Firearms and Explosives (ATF) at 1600 5th Street, Suite D, Charlottesville,
Virginia, 22902.
11. On closer inspection of Jackson Tay’s tasks at the Bureau, it had been
identified that he had been hacking the servers of the ATF with the aid of his
accessibility privileges and deleting the records of Peter Gunn’s fire arms
purchase clandestinely for the past 4 months.
12. The agents from the ATF passed on a clandestine phone number to CA-1 and
instructed him to provide the same number to Pete Gunne if he contacted CA-1
again. It was assumed, in all probability that Gunne would contact the
confidential informant, CA-1 for details of dealers or sellers of firearms,
ammunition and related accessories in Virginia or the surrounding peripheries.
The number that was given for Pete Gunn to contact was that of an undercover
investigative officer, who will hereby be referred to as the UC agent for safety
concerns.
13. On July 15th, by around 8:30 am, Gunne had made frequent calls to the UC
agent. The agent introduced himself as an arms dealer specialized in selling
machine guns, their bullets and all related accessories pertaining to high calibre
weapons. Gunne made an enquiry about the availability of specific high calibre
weapons to the UC agent and asked the time that the UC agent could deliver

them at the earliest. He asked the UC agent for his email id. A counterfeit email
id was created for the UC agent and the information was shared with Gunne for
garnering further leads into the case.
14. On July 17th by around 6:20 a.m, the UC agent received an email from Gunne
in which a list of high calibre weapons and their related accessories were
enquired. It was mentioned in the mail by Gunne that the number of guns
required and the ammo required for each of these weapons would be disclosed
at a later stage. The email contained the names of a number of high calibre
guns like the Adaptive Combat Rifle, Ak–12, Barret REC7, Colt CM901,
Excalibur Rifle, FB MSBS, HK433, Remington R5 RGP and Remington
Rimfire Magnum. Further, an enquiry was also made on bullets and cartridges
like the .22 Reed Express 7.62mm, .221 Remington Fireball, Tokarev, 7.65 mm
Parabellum, 7.65mm Mannlicher, 9mm Parabellum, 9mm Winchester
Magnum, .38 Long Colt, .41 Wildey Magnum, .458 Devastator, .500 S&W
Magnum, .500 Linebaugh Long and the .600 Nitro Express.
15. On August 5th 2016, the Virginia Police Department's Financial Crimes Unit
was assigned with the task of impending an investigation into the financial
activities of Pete Gunne. It was inferred that Gunne held an account with the
Feedorm Bank of Virginia, located at10555 Main Street #100, Fairfax, VA
22030, USA.
16. The investigators at the Financial Crimes Unit discovered that Gunne had
received numerous suspicious check transactions from an individual named
George Greene from December 2015 onwards. The amounts of the transactions

to green’s account ranged from $5000 to $9900 and were done on the months
of Feb, May and June.
17. From my past experience I have come to the conclusion that the amounts were
made just under $10000 to conceal the clandestine operations. It would have
also been made to bypass the state imposed federal reporting requirements for
any transaction above $10000.
18. The Financial Crimes Unit also found out that Gunn’s Paypal account had
received over $72000 from May 2014 onwards, the sources mainly being from
different locations in South America from countries like Venezuela, Argentina
and Chile.
19. On August 14th 2017, a passenger, Nathan Stone, had arrived at the Richmond
International Airport located at 1 Richard E Byrd Terminal Dr, Richmond, VA
23250, USA, was sent for secondary screening by the Airport security officials
for refusing to share the PIN and passwords of his Apple iphone 6s. The phone
was being carried by Nathan Stone along with a Motorola Ming A1200..
20. As the contents of the phone were being reviewed, it came to the notice of the
Special Agents that there were text messages being sent from the phone to the
number of Pete Gunne, which proved that the detained Nathan Stone and Pete
Gunne were long term accomplices.
21. A further search into the confiscated device revealed that other forms of
communication existed between the two in the form of emails, social media
chat messages like that of facebook and whatsapp messages as well. A review
into the contents of these conversations revealed that Nathan Stone was one of

the contacts of Pete Gunne who was allegedly from Venezuela, and had been
one of the sources through which the amounts were being transferred to Gunn’s
Paypal account since February 2016.
22. The detained phone was then confiscated by the special authorities at the
Department of the Under secretary for Enforcement, and kept as an evidence
for further scrutiny and retrieval of deleted or lost data. All associated
components of the phone, including the memory card was confiscated and
retained as seized property by the special authorities at the department.
23. The detained phone and the related accessories was then handed over to the
Virginia Department of Forensic Science at Biotech Seven, 700 N 5th St,
Richmond, VA 23219. The Forensic Administrative Specialists at the Central
Laboratory for firearms and tool marks, retrieved further information from the
phone revealing the previous cash transactions of Nathan Stone, that amounted
well over $60000. The cash transactions were made through different accounts
held at a Bank in Venezuela in South America, by the name Banco Occidental
de Descuento located at Avenida 4 de Mayo, C.C Galerías Fente, Porlamar,
Venezuela, Porlamar 6301, Nueva Esparta, Venezuela.
24. On August 28th, by around 2:00 a.m, it was noticed by a surveillance team on
the trail of Pete Gunn that he carried a bundle wrapped in plastic sheets to his
white Land Rover Range Rover Sport and moved the contents within the
plastic sheets to the trunk of his vehicle. The contents were then again shifted
from the trunk of the vehicle by around 4:00 am in the morning and carried
back to the house.

25. During the last conversation that Gunn had with the informant CA-1, .it was
casually mentioned by Gunne that his favourite firearm was a Ruger Super
Redhawk and he liked to carry it wherever he wished to. I conducted a firearms
identification check on Gunne to see if had a valid permit for the possession of
the revolver that he mentioned. It was observed that Pete Gunne did not possess
any legal permit that supported his claims for using a firearm.
26. Depending upon all the information from the variety of sources, the
surveillance teams reports and findings and the leads given by the informant
and other investigators, there is a reasonable cause to believe that there are
firearms in the possession of Pete Gunne residing at at 4400 University Dr,
Fairfax, Virginia, 22030, ENG5358. This is clearly in violation of 18 U.S. Code
§ 922 which states that no person can import manufacture or deal with firearms
or ammunition either within the country or outside the country. Provided any
individual partakes in any such clandestine operations involving firearms could
be punishable by the Court of Law.
27. There is also probable cause to believe that Pete Gunne is not only in
possession of firearms but also may be possessing ammunition in the form of
magazine, cartridges or other explosive objects used for firearms.
28. I also firmly believe that a thorough investigation of his house and associated
periphery around the house, which includes his vehicle, backyard or garage,
could reveal the presence of illegal possession of arms and ammunition.

29. The object that I seek to take acquisition of following the search warrant is a
grey .44 Magnum Ruger Super Redhawk and its associated ammunition. I
further suspect that the bundle wrapped in plastic sheets that were shifted from
Gunne’s vehicle contained high calibre weapons. I wish to check all the
enclosed and secretive places within Gunne’s residency during my search and
seize whatever evidences that could be gathered during the search.
30. Based on these facts I request the honourable District Court of Virginia to issue
a warrant for search the residency of Pete Tommy Gunne at at 4400 University
Dr, Fairfax, Virginia, 22030, ENG5358. Following the search if any property
or external items has been seized would be produced before the Virginia
District Court. The address at 4400 University Dr, Fairfax, Virginia, 22030,
ENG5358 is described as a residential dwelling with a single storey painted in
blue. The house is in a dilapidated neighbourhood with a large courtyard and
thick brushes outside. The driveway leads to the front of the house and the
earth has been burrowed at different locations. There is an artificially created
pond towards the left of the entrance, which has been drained and not
maintained.
31. As the search tries to recover firearms and ammunition, I request the
honourable court to grant me permission to conduct the search during the night
to catch Pete Gunne unexpected and to possibly avert an attempt to flee. I duly
request the court to search any other person within the premises of the house at
the time the search is being executed. I also request the honourable court to

give permission to investigate the periphery surrounding the house as well that
includes his garage, vehicle, front and back yards.
32. I also request the honourable court to grant me permission to search all
electronic devices including computers, cell phones, cameras or laptops that are
located within the periphery of the house. I also need permission to seize any
digital evidence in the form of images, email conversations, chat messages and
proof of bank transactions contained within these electronic devices. It is to be
brought to the notice of the honourable court that the digital evidences that
may be contained within any of these electronic devices may prove to be
crucial in the outcome of the case.
33. It is not only required to have access to the digital evidences, but also the
seizure of these electronic devices as a Forensic analysis on these electronic
devices could enumerate the usage details such as how, when and why the
device was used. The Forensic analysis could determine who the user was in a
particular time and what actions had been carried out. From my learning and
experience, I am able to deduce that the Forensic analysis of a device could be
used to retrieve vital information which may prove to be the turning point in
many criminal offences.
34. Unless stated otherwise, it is implied that the information that is contained
within this affidavit is based solely on my knowledge and information provided
by all possible means. I assure the honourable court that all the information
stated in this affidavit report is reliable in nature and could be possibly used to

avert impending hazardous crimes that may involve the use of unlicensed
weapons and ammunition.