Complaint — United States v. Rhondu Brown (E.D.N.Y., Dkt. 1, October 13, 2022)

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A complaint filed 10/13/22 in United States v. Rhondu Brown, Case 1:22-cr-00503-DLI, Document 1 (Case No. 22-MJ-1105), in the U.S. District Court for the Eastern District of New York, citing Title 18, United States Code, Section 922(g)(1). Edward Martin, a Special Agent with the Bureau of Alcohol, Tobacco, Firearms and Explosives, states that on or about October 13, 2022 the defendant, knowing of a previous conviction punishable by more than one year of imprisonment, possessed a firearm and ammunition. The complaint states that agents executing a search warrant saw a bag and a jacket thrown from a window and a firearm in a jacket pocket, and that Brown stated, in substance and in part, that the firearm belonged to him. It also states that on or about December 13, 2012 Brown was convicted of three offenses.

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Case 1:22-cr-00503-DLI Document 1 Filed 10/13/22 Page 1 of 3 PagelD #: 1

AB:ADR

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA COMPLAINT
- against - (18 U.S.C. § 922(g)(1))
RHONDU BROWN, Case No. 22-MJ-1105
Defendant.

EASTERN DISTRICT OF NEW YORK, SS:

EDWARD MARTIN, being duly sworn, deposes and states that he is a Special
Agent with the Bureau of Alcohol, Tobacco, Firearms and Explosives (“ATF”) duly appointed
according to law and acting as such.

On or about October 13, 2022, within the Eastern District of New York and
elsewhere, the defendant RHONDU BROWN, knowing that he had been previously convicted in
a court of one or more crimes punishable by a term of imprisonment exceeding one year, did
knowingly and intentionally possess in and affecting interstate or foreign commerce a firearm, to
wit: a Ruger LC380 .380 caliber pistol with serial number 32484343, and ammunition.

(Title 18, United States Code, Section 922(g)(1))

The source of your deponent’s information and the grounds for his belief are as

follows:!

| Because the purpose of this Complaint is to set forth only those facts necessary to

establish probable cause to arrest, I have not described all the relevant facts and circumstances of
which I am aware.
Case 1:22-cr-00503-DLI Document1 Filed 10/13/22 Page 2 of 3 PagelD #: 2

1. Il am a Special Agent with the Bureau of Alcohol, Tobacco, Firearms and
Explosives (“ATF”) and have been involved in the investigation of numerous cases involving the
recovery of firearms and ammunition. | am familiar with the facts and circumstances set forth
below from my participation in the investigation; my review of the investigative file, including
the defendant’s criminal history record; and from reports of other law enforcement officers
involved in the investigation. Where I describe the statements of others, I am doing so only in
sum and substance and in part.

2. On or about October 13, 2022, at approximately 6:00 a.m., ATF agents
arrived at the defendant RHONDU BROWN’ residence at 428 Columbia Street, Apartment 2C,
in Brooklyn, New York to execute a search warrant signed on October 12, 2022 by the
Honorable Robert M. Levy, United States Magistrate Judge for the Eastern District of New York
(See 22-MJ-1091).

3. As law enforcement agents knocked on RHONDU BROWN ’s door and
announced themselves, other agents outside the building observed BROWN throw a clear plastic
bag and a jacket out the back window of his apartment, which is located on the second floor of
the building. The bag landed on a scaffolding structure beside the building, and agents observed
several plastic vials of what appeared to be crack cocaine on the scaffolding in and immediately
around the bag. The jacket landed on the ground, and agents observed a partially exposed
firearm protruding from one of its pockets. The firearm was determined to be a Ruger LC380
.380 caliber pistol with serial number 32484343. It was loaded with five rounds of ammunition

in the magazine and an additional round in the chamber.

4. The defendant RHONDU BROWN was arrested and was read his Miranda

rights. He agreed to waive those rights and to be interviewed by ATF agents. BROWN stated,
Case 1:22-cr-00503-DLI Document 1 Filed 10/13/22 Page 3 of 3 PagelD #: 3

in substance and in part, that the plastic vials belonged to him and contained crack cocaine, and
that the firearm also belonged to him.

5. I have reviewed the defendant’s criminal history, which revealed, among
other felony convictions, that on or about December 13, 2012, RHONDU BROWN was
convicted of three offenses stemming from three separate arrests: Robbery in the Second Degree,
Gang Assault in the First Degree and Robbery in the Third Degree in Kings County Supreme
Court. For these three convictions, BROWN was sentenced to five years’ imprisonment on
January 9, 2013.

6. I have conferred with an interstate nexus expert at ATF, who has informed
me, in substance and in part, that the firearm recovered was manufactured outside the state of
New York.

WHEREFORE, your deponent respectfully requests that the defendant RHONDU

Special nt
Bureau*ef’Alcohol, Tobacco and Firearms

BROWN be dealt with according to law.

Sworn to before me this
[BP rkay of October, 2022
UO

\ \TE JUDGE
If V YORK


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