The Complainant having reviewed the applicable reports believes the following facts to be true: that on November 14, 2025 at approximately 10:30 P.M. A Ramsey County sheriff deputy was in the vicinity of Highway 52 and Plato Boulevard in the City of Saint Paul, Ramsey County when they noticed a motor vehicle being driven which had an expired registration. They attempted to stop the vehicle, which was initially evasive but eventually pulled over. The deputy could see the driver making furtive movements inside the vehicle as if they were hiding something.
They approached and spoke to the driver, Zen Txujci SOUNG, [DOB REDACTED], Defendant herein. A black and white rifle was in plain view in the vehicle, strewn on the floorboard of the back seat. As the rifle was uncased and not stored in the trunk of the vehicle, Defendant was taken out of the vehicle and it was searched. Multiple firearms were found inside the vehicle - in addition to the rifle, one 'ghost gun' Glock-style pistol with no registration number was found underneath the driver's seat, and a second 'ghost gun' pistol with a partial registration number was found in a backpack in the trunk.
A record check revealed Defendant does not have a permit to carry a pistol in the state of Minnesota.