Declaration of Dimitrios Karras, CEO Ares Armor

In regards to the events surrounding Ares Armor’s interaction with EP Armory’s products and the threats made towards Ares Armor by the Bureau of Alcohol, Tobacco, Firearms, and Explosives (BATFE.) The following declarations are true and correct to the best of my knowledge.

I, Dimitrios Karras, state:

1. During a meeting with the BATFE around the end of 2012 that was unrelated to EP Armory’s product, the Agent that was present very strongly requested that I turn over Ares Armor’s customer list. He intimidated me with the possibility of criminal charges if he was not satisfied. This was the first attempt the BATFE made to intimidate Ares Armor into turning over private customer information.

2. An 80% lower is an industry term for an unfinished receiver that is not considered to be a firearm.

3. EP Armory manufactures an 80% lower receiver made from polymer.

4. Ares Armor purchases and then resells many products one of which is the 80% Polymer Lowers that are made by EP Armory.

5. In the regular course of business I have seen many different 80% AR-15 receivers.

6. EP Armory’s product is no different than standard 80% receivers that are sold openly and that the BATFE has consistently determined to not be a firearm. EP Armory’s product is in compliance with previous BATFE Determinations and is not a firearm.

7. The BATFE has Raided EP Armory based on incorrect information about EP Armory’s manufacturing process. The determination letter written by the BATFE incorrectly classified the EP Armory product as a firearm based on faulty information. The BATFE was under the impression that EP Armory was making a firearm and then reverting back to the 80% stage by filling in the fire-control cavity. At no point during the manufacturing process by EP Armory is a weapon made and then reverted. The solid fire-control cavity is built first and the rest of the 80% casting is made around this “core” specifically so that their product at no time could be considered to be a firearm.

a. As can be seen in Exhibit 1-3. The BATFE has consistently determined that the machining operations that cannot be performed in order to not be considered a firearm are as follows:

1. Milling out of fire-control cavity.

2. Selector-lever hole drilled.

3. Cutting of trigger slot.

4. Drilling of trigger pin hole.

5. Drilling of hammer pin hole.

b. EP Armory’s product is consistent with the BATFE’s many previous determinations.
c. At no time during EP Armory’s manufacturing process are any of the aforementioned 5 operations in a state that could cause a reasonable person to believe that EP Armory’s product would be considered a firearm.
8. The BATFE has been appropriately informed of their mistake. However, even though they have no determination that is based on fact, they are knowingly using their fiction based determination to intimidate Ares Armor with threats in order to inappropriately gain access to information that is private and should be protected.

9. I received communication on or about 3/10/2014 from our legal counsel (Jason Davis) that the BATFE was in the process of obtaining a warrant against Ares Armor based on their incorrect determination of EP Armory’s Product. I was advised that the BATFE had offered to forego obtaining a warrant if Ares Armor was willing to:

a. Hand over all of EP Armory’s 80% Lowers.
b. Turn over Ares Armor customer’s private information to the BATFE.
In exchange for turning over our customer’s private information the BATFE said that they would not “raid” Ares Armor’s facilities and would not pursue “criminal” charges. This made me feel as if I was being extorted. I agreed to their terms in order to delay an impending and unjust raid against Ares Armor long enough to obtain legal protection under the law.

10. I have been unjustly threatened with raids and criminal charges in an attempt by the BATFE to obtain information that is private and protected. The BATFE has expressed interest in obtaining Ares Armor’s customer list in the past and is now attempting to strong-arm us with undue threats based on information they know to be incorrect.

11. I am now in constant fear for the safety of my employees, my customers and

Executed March 10, 2014 Oceanside, CA

I declare under penalty of perjury that the foregoing is true and correct.

Dimitrios Karras

 AlmightyWalrus wrote:
I'll wait with judgment until we've heard the whole story, but if this is a correct representation of events I'm starting to see why you guys (Americans) don't like your government...

 KalashnikovMarine wrote:
Right nothing illegal about making your own kit from scratch. The AR-15 I recently lost in a boating accident being a prime example. I miss my baby. Nothing illegal about serial number free 80% lowers either. That's ATF regulations right there. How can we trust them if they can't even read their own rules?

 KalashnikovMarine wrote:
It was terrible, it really was, we got capsized right there in the bay shortly after I moved here. Everything sank to the bottom of the Chesapeake.

 AlmightyWalrus wrote:
I'll wait with judgment until we've heard the whole story, but if this is a correct representation of events I'm starting to see why you guys (Americans) don't like your government...

 Goliath wrote:
ITT: People complaining about government bodies not following the rules, then talking about 'boating accidents'

 djones520 wrote:

 Goliath wrote:
ITT: People complaining about government bodies not following the rules, then talking about 'boating accidents'

Please explain?

I gather your saying there is hypocrisy occuring, but in what form?

 djones520 wrote:
Who is doing anything wrong.

If per chance anyone wanted to just simply "lose" a gun, they are allowed to. There is no form of registration where I live, there is no "tracking" of my firearms. I can do what I like with them, to include tragically losing them in a nearby lake.

 Goliath wrote:

 djones520 wrote:
Who is doing anything wrong.

If per chance anyone wanted to just simply "lose" a gun, they are allowed to. There is no form of registration where I live, there is no "tracking" of my firearms. I can do what I like with them, to include tragically losing them in a nearby lake.

Which is why, as I said, I'm not meaning it as a criticism. I'm perfectly fine with lost firearms; I'm sure it happens all the time.

I posted entirely because I found the fact it took about five posts before the tragic accidents came up amusing.

 Goliath wrote:

 djones520 wrote:

 Goliath wrote:
ITT: People complaining about government bodies not following the rules, then talking about 'boating accidents'

Please explain?

I gather your saying there is hypocrisy occuring, but in what form?

To be 100% honest I'm not sure, I just find it amusing that you guys are talking about how awful the events in the article are, what with the BATFE not obeying the law, and then within five or six posts talking about the tragic boating accidents you had.

I think it might be the "They do stuff wrong therefore I can too" mindset that appears to being exhibited.

To clarify, I'm not meaning it as a criticism. I'm sure the boating accidents were incredibly tragic, and the events in the OP are entirely ridiculous, I just find it a bit amusing

 cincydooley wrote:
I read about this yesterday, and it infuriated me, particularly because a California judge upheld the restraining order and the ATF basically said, "naw, feth you, we're coming anyway. We got our own judge to overturn it."

Gross abuse of power that really highlights why many gun owners are hesitant to put their names on a 'gun registration' list like many people have suggested we do (and which, in uncorrupted principle, I'm not that opposed to).

I'm sure the NRA (with whom I just renewed my membership) will have something to say by the end of the week.

 KalashnikovMarine wrote:
Nothing illegal about serial number free 80% lowers either. That's ATF regulations right there. How can we trust them if they can't even read their own rules?

 Kanluwen wrote:
No, many gun owners are "hesitant to put their names on a 'gun registration' list" because so many of you so utterly are convinced by the NRA that the government is gonna come and take your guns.

 Peregrine wrote:

 KalashnikovMarine wrote:
Nothing illegal about serial number free 80% lowers either. That's ATF regulations right there. How can we trust them if they can't even read their own rules?

See, you just have this backwards. The rules don't exist to tell you what you're allowed to do, they tell you some of the things that you can be thrown in prison for. Nobody ever promised you that your 80% part was going to be legal forever, they just told you that you will go to prison for doing the other 20% without all the paperwork. The rules can be changed at any time for any reason, especially if it would help meet this week's arrest quota.

 Kanluwen wrote:
No, many gun owners are "hesitant to put their names on a 'gun registration' list" because so many of you so utterly are convinced by the NRA that the government is gonna come and take your guns.

Sorry, but that's not exactly an unreasonable concern when you have s like the ones in the OP who seem to think that the law consists of whatever they feel like declaring it to be at any given moment. Gun owners are pretty justified in wanting to avoid being on a registration list when the police are willing to blatantly abuse their power like that. It's much better to just not become a target in the first place.

 SickSix wrote:
I sold all my firearms to another private citizen. But somehow I have misplaced the bill of sale.

 Kanluwen wrote:

No, many gun owners are "hesitant to put their names on a 'gun registration' list" because so many of you so utterly are convinced by the NRA that the government is gonna come and take your guns.

The NRA is just as bad as the ATF. They're both organizations with an agenda to push and simpletons wrapped around their fingers.

 cincydooley wrote:

 Kanluwen wrote:

No, many gun owners are "hesitant to put their names on a 'gun registration' list" because so many of you so utterly are convinced by the NRA that the government is gonna come and take your guns.

Please don't presume to speak for "many gun owners" or me. There's precedence that the government wants to outlaw firearms. It's not like these are baseless concerns.

The NRA is just as bad as the ATF. They're both organizations with an agenda to push and simpletons wrapped around their fingers.

Please, show me some instances of the NRA infringing upon the rights or other people and circumventing the courts to obtain sales records for legal purchases.

KalashnikovMarine wrote:A California judge granted the restraining order. Because facts and laws are supposed to trump in our society. The ATF however got an Ex parte hearing with their own judge, reversed the decision and raided Ares Armor with automatic weapons, forcibly seizing company documents and computers, as well as cracking their safe, violating a judge's legal order and the fourth amendment to the constitution, which theoretically protects against unreasonable search and seizure.

Peregrine wrote:See, you just have this backwards. The rules don't exist to tell you what you're allowed to do, they tell you some of the things that you can be thrown in prison for. Nobody ever promised you that your 80% part was going to be legal forever, they just told you that you will go to prison for doing the other 20% without all the paperwork.

 Ouze wrote:
There is no "paperwork" to be done. In the US you are legally allowed to manufacture your own firearms for personal use without any further registration, documentation or even a serial number.