Criminal Complaint — United States v. Arthur S. Jordan (W.D.N.Y., Dkt. 1, August 15, 2023)
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A Criminal Complaint with supporting affidavit, Document 1 in United States v. Arthur S. Jordan, Case 1:23-cr-00131-JLS (Case No. 23-mj-1108), in the U.S. District Court for the Western District of New York, filed August 15, 2023. The complaint states that on or about May 16, 2023, the defendant knowingly possessed a firearm and ammunition after a prior conviction, in violation of Title 18, United States Code, Section 922(g)(1) and 924(a)(2). In the affidavit, Special Agent Husen Ali of the Federal Bureau of Investigation states that Buffalo Police Department officers stopped a vehicle on May 16, 2023, felt a firearm during a pat down, and recovered a handgun and ammunition. The complaint was sworn telephonically on August 15, 2023, before the Honorable Jeremiah J. McCarthy.
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“Criminal Complaint — United States v. Arthur S. Jordan (W.D.N.Y., Dkt. 1, August 15, 2023).”
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Case 1:23-cr-00131-JLS Document 1 Filed 08/15/23 Page 1 of 6
AO 91 (Rev. 02/09) Criminal Complaint
United States District Court
for the
Western District of New York
United States of America
Case No. 23-mj-1108
v.
Arthur S. Jordan
Defendant
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about May 16, 2023, in the Western District of New York, the defendant ARTHUR
JORDAN, knowing that he had previously been convicted on or about May 3, 2018, in County Court, Erie
County, New York, of a crime punishable by imprisonment for a term exceeding one year, did knowingly
possess, in and affecting interstate commerce, a firearm, namely, one (1) Beretta Model 92FS 9mm handgun,
serial number BER327140Z, and ammunition, that is, sixteen (16) 9mm caliber rounds of ammunition; all
in violation of Title 18, United States Code, Section 922(g)(1) and 924(a)(2).
This Criminal Complaint is based on these facts:
ց Continued on the attached sheet. Digitally signed by HUSEN
HUSEN ALI ALI
Date: 2023.08.15 11:16:49
-04'00'
Complainant’s signature
HUSEN ALI
Special Agent
Federal Bureau of Investigation
Printed name and title
Sworn to and subscribed telephonically
Date: August 15, 2023
Judge’s signature
HONORABLE JEREMIAH J. MCCARTHY
City and State: Buffalo, New York UNITED STATES MAGISTRATE JUDGE
Printed name and title
Case 1:23-cr-00131-JLS Document 1 Filed 08/15/23 Page 2 of 6
AFFIDAVIT
STATE OF NEW YORK )
COUNTY OF ERIE ) SS:
CITY OF BUFFALO )
I. INTRODUCTION
I, Husen Ali, Special Agent of the Federal Bureau of Investigation, United States
Department of Justice, having been duly sworn, states as follows:
1. I am a Special Agent of the Federal Bureau of Investigation (“FBI”) of the
United States Department of Justice. As such, I am an “investigative or law enforcement
officer of the United States” within the meaning of 18 U.S.C. § 2510(7), that is, an officer of
the United States who is empowered by law to conduct investigations of and to make arrests
for offenses enumerated in 18 U.S.C. § 2516.
2. I have served as an FBI Special Agent since January of 2021. During that time,
I have participated in investigations involving drug trafficking, gun possession, and organized
crime matters. In addition, I have had the opportunity to work with several other FBI agents
and other law enforcement agents and officers of varying experience levels, who have also
investigated firearms possession and drug trafficking networks, with regard to the manner in
which controlled substances are obtained, diluted, packaged, distributed, sold and used within
the framework of drug trafficking in the Western District of New York. As a result of my
experience, I am familiar with how controlled substances are obtained, diluted, packaged,
Case 1:23-cr-00131-JLS Document 1 Filed 08/15/23 Page 3 of 6
distributed, sold, and used in the framework of drug trafficking in the Western District of New
York and how drug traffickers utilize wire communications to facilitate their illegal activities.
My investigative experience detailed herein, and the experiences of other law enforcement
agents, who are participating in this investigation, serve as the basis for the opinions and
conclusions set forth herein.
3. Your Affiant states that this investigation was conducted by Special Agents of
the FBI and other law enforcement personnel assigned to the FBI Buffalo Division – Safe
Streets Task Force (FBI-SSTF). 1 Your Affiant is fully familiar with the facts and
circumstances of this investigation, such familiarity having been gained through: your
Affiant’s personal knowledge based upon your Affiant’s participation in this investigation;
statements by and/or reports provided to your Affiant by law enforcement personnel of the
FBI-SSTF, Buffalo Police Department (BPD), information provided by confidential sources;
consensual recordings, controlled evidence purchases of illegal drugs, controlled evidence
purchases of firearms, physical surveillances, records checks of various public and law
enforcement data bases, and other investigative techniques.
4. This affidavit is made in support of a criminal complaint charging ARTHUR
S. JORDAN with a violation of Title 18, United States Code, Sections 922(g)(1) and 924(a)(2)
(felon in possession of a firearm).
1
The SSTF is comprised of Agents and Investigators from the Immigration and Customs
Enforcement, Erie County Sheriff's Office, Lackawanna Police Department, Niagara Frontier
Transportation Authority Police Department, and the Buffalo Police Department.
2
Case 1:23-cr-00131-JLS Document 1 Filed 08/15/23 Page 4 of 6
5. The information contained in this affidavit is based upon reports and
information received from other law enforcement officers and agencies. This affidavit is
provided for the limited purposes of establishing probable cause to support the attached
application for a Criminal Complaint, and therefore does not contain each and every detail
of the investigation.
II. PROBABLE CAUSE
6. On May 16, 2023, at approximately 9:17 p.m., while on routine patrol, Buffalo
Police Department (BPD) officers conducted a traffic stop of a tan GMC Terrain bearing New
York registration KTV2024 in the vicinity of Leroy Avenue and Marigold Avenue, Buffalo,
New York. After approaching the vehicle, officers encountered four males in the GMC
Terrain, including the rear driver side passenger ARTHUR S. JORDAN. Despite it being
mid-May, JORDAN was wearing a garment on his head that appeared to be a ski hood. As
officers attempted to identify the occupants, they learned that the driver did not have a valid
driver’s license. Furthermore, officers observed an open alcohol bottle. The occupants
were asked by the officers, one at a time, to exit the vehicle. When JORDAN was asked to
exit, he refused.
7. After finally exiting the vehicle, officers attempted to pat down JORDAN.
During the pat down of JORDAN, an officer felt a firearm in JORDAN’s front jacket pocket.
JORDAN told officers it was his cellphone, which was not true. Officers recovered a Beretta
Model 92FS 9mm handgun, serial number BER327140Z, with fifteen rounds of ammunition
in the magazine and one round of ammunition in the chamber from JORDAN’s pocket.
3
Case 1:23-cr-00131-JLS Document 1 Filed 08/15/23 Page 5 of 6
8. Officers later recovered Seventeen (17) plastic corner baggies containing crack
cocaine. Subsequent analysis by the CPS laboratory confirmed the narcotics were crack
cocaine.
9. A review of JORDAN’s criminal history indicates that on May 3, 2018,
JORDAN was convicted of Criminal Possession of a Weapon in the 2nd Degree (Loaded
Firearm), a felony in the state of New York. JORDAN was sentenced to a term of 30 months
Post Release Supervision time. Of special note, on May 18, 2018, Arthur pled guilty to
violating 18 U.S.C. § 875(c) (Interstate Threats). On August 9, 2018, the Court sentenced
Arthur to two months of imprisonment to run concurrently with the New York State sentence.
10. According to Special Agent William Farnham of the Bureau of Alcohol,
Tobacco, Firearms, and Explosives, the firearm and the 16 rounds of ammunition were not
manufactured in New York State and would have traveled in and affected interstate
commerce prior to it being possessed by JORDAN.
4
Case 1:23-cr-00131-JLS Document 1 Filed 08/15/23 Page 6 of 6
13. WHEREFORE, based upon the foregoing, I respectfully submit that there is
probable cause to believe that ARTHUR JORDAN did knowingly, willfully, and unlawfully
violate Title 18, United States Code, Section 922(g)(1) and 924(a)(2) (felon in possession of a
firearm).
Digitally signed by
HUSEN ALI
HUSEN ALI Date: 2023.08.15
11:17:52 -04'00'
HUSEN ALI
Special Agent
Federal Bureau of Investigation
Sworn to and subscribed telephonically
this 15th day of August 2023.
HONORABLE JEREMIAH J. MCCARTHY
UNITED STATES MAGISTRATE JUDGE
5
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