Complaint — United States v. Robert Adams and Demetrius Frazier, No. 1:23-mj-01174

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A Complaint, Document 1 in Case 1:23-mj-01174-UA, filed February 14, 2023, before United States Magistrate Judge Stewart D. Aaron, Southern District of New York, against Robert Adams and Demetrius Frazier. Leigh Messett, a Postal Inspector with the United States Postal Inspection Service, swears to Count One (Theft and Receipt of Mail Matter) under Title 18, United States Code, Sections 1708 and 2, and Count Two (Theft of Postal Keys) under Sections 1704 and 2. The affidavit states that on or about February 13, 2023, New York Police Department officers stopped a vehicle and found a black bag filled with articles of mail and a United States Postal Service "arrow key." It asks that the defendants be imprisoned or bailed.

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Case 1:23-mj-01174-UA Document1 Filed 02/14/23 Page1of3

kie Delligatti
ssistant United States Attorney

Before: THE HONORABLE STEWART D. AARON 23 MAG 1 174
United States Magistrate Judge
Southern District of New York

COMPLAINT
UNITED STATES OF AMERICA
Violations of
-V.- 18 U.S.C. §§ 1708, 1704,
, and 2
ROBERT ADAMS and ;
DEMETRIUS FRAZIER, COUNTY OF OFFENSE:
‘ NEW YORK
Defendants.
SOUTHERN DISTRICT OF NEW YORK, ss.: a Octet eee

LEIGH MESSETT, being duly sworn, deposes and says that she is a Postal
Inspector with the United States Postal Inspection Service (“USPIS”), and charges as follows:

COUNT ONE
(Theft and Receipt of Mail Matter)

1, On or about February 13, 2023, in the Southern District of New York and
elsewhere, ROBERT ADAMS and DEMETRIUS FRAZIER, the defendants, did knowingly steal,
take, abstract, and by fraud and deception did obtain, and attempt so to obtain, from and out of
mail, post offices, stations thereof, letter boxes, mail receptacles, mail routes, other authorized
depositories for mail matter, and from letter and mail carriers, letters, postal cards, packages, bags,
and mail, and did abstract and remove from such letters, packages, bags, and mail, articles and
things contained therein, and did secrete, embezzle, and destroy such letters, postal cards,
packages, bags, and mail, and articles and things contained therein, and did steal, take, and abstract,
and by fraud and deception did obtain, letters, postal cards, packages, bags, and mail, and articles
and things contained therein, to wit, ADAMS and FRAZIER stole and received mail matter out
of a United States Postal Service mail receptacle in Manhattan, New York.

(Title 18, United States Code, Sections 1708 and 2.)
Case 1:23-mj-01174-UA Document1 Filed 02/14/23 Page 2of3

COUNT TWO
(Theft of Postal Keys)

2. On or about February 13, 2023, in the Southern District of New York and
elsewhere, ROBERT ADAMS and DEMETRIUS FRAZIER, the defendants, willfully and
knowingly did steal, purloin, embezzle, and obtain by false pretense keys suited to a lock adopted
by the Post Office Department and the Postal Service and in use on the mails and bags thereof, and
a key to a lock box, lock drawer, and other authorized receptacle for the deposit and delivery of
mail matter, and knowingly and unlawfully made, forged, and counterfeited such key, and
possessed such mail lock and key with the intent unlawfully and improperly to use, sell and
otherwise dispose of the same, and to cause the same to be unlawfully and improperly used, sold,
and otherwise disposed of, to wit, ROBERT ADAMS and DEMETRIUS FRAZIER, the
defendants, unlawfully obtained and then used arrow keys belonging to the United States Postal
Service to take mail matter without permission.

(Title 18, United States Code, Sections 1704 and 2.)
The bases for my knowledge and for the foregoing charges are, in part, as follows:

3. Iam a United States Postal Inspector and I have been personally involved in the
investigation of this matter. I base this affidavit on that experience, on my conversations with
other law enforcement officials, and on my examination of various reports and records. Because
this affidavit is being submitted for the limited purpose of demonstrating probable cause, it does
not include all the facts I have learned during the course of my investigation. Where the contents
of documents and the actions, statements, and conversations of others are reported herein, they are
reported in substance and in part, except where otherwise indicated.

4, Based on my conversations with other law enforcement officers involved in this
investigation, as well as my review of relevant reports and records, I know, among other things,
the following:

a, On or about February 13, 2023, at approximately 2:13 a.m., an individual
(“Witness-1”) called in a complaint to the New York Police Department (“NYPD”) stating, in
substance and in part, that Witness-1 had just observed two individuals who were not dressed as
U.S, Postal Service employees appearing to remove mail and materials from a U.S. Postal Service
collection box in the vicinity of East 65" Street and Second Avenue in Manhattan. Witness-1 gave
a general description of the two individuals, and also reported that he witnessed the two individuals
drive away from the scene in an older model white Lexus with duct tape attached to the rear bumper
(the “Subject Vehicle”).

b. Upon receiving the information from Witness-1, NYPD officers were
dispatched to the area in an effort to locate the Subject Vehicle and the individuals. Soon
thereafter, NYPD officers observed a vehicle that fit the description of the Subject Vehicle in the
vicinity of 70 Street between Second and Third Avenue in Manhattan.
Case 1:23-mj-01174-UA Document1 Filed 02/14/23 Page 3of3

c. NYPD officers stopped the Subject Vehicle and observed two individuals
inside. The officers questioned the individuals, and the driver of the Subject Vehicle identified
himself as ROBERT ADAMS, the defendant. Upon looking into the Subject Vehicle, NYPD
officers observed in plain view a pile of mail in ADAMS’s lap. The individual in the front
passenger seat of the Subject Vehicle identified himself as DEMETRIUS FRAZIER, the
defendant.

d. ADAMS and FRAZIER were subsequently arrested by NYPD officers and
brought back to the 19" Precinct. Upon arrival at the 19'" Precinct, at approximately 7:00 a.m.,
NYPD officers conducted an inventory search of the Subject Vehicle. During the search, the
officers found in the back seat a black bag that was filled with a large number of articles of mail.
NYPD officers also found in the driver’s-side door panel a United States Postal Service “arrow
key,” that is, a key that is used by U.S. Postal Service employees to access locked mail receptacles,
The officers also located in the driver’s-side door several other keys that, based on my training and
experience, I believe to be keys used by U.S. Postal Service employees to access locked mailboxes
in different residential buildings.

e. Upon arrival at the Precinct, FRAZIER indicated that he wished to use the
bathroom, An NYPD Lieutenant (“Licutenant-1”) led FRAZIER to a bathroom located within the
Precinct. While FRAZIER was in the bathroom, Lieutenant-1 heard a clanking sound, as if
FRAZIER had dropped an object into the toilet. After FRAZIER left the bathroom, “Lieutenant-
1” entered and observed another arrow key in the toilet. Licutenant-1 then retrieved the arrow key
from the toilet.

WHEREFORE, I respectfully request that ROBERT ADAMS and DEMETRIUS
FRAZIER, the defendants, be imprisoned or bailed, as the case may be.

KIGH MESSETT
Inspect
United States Postal Inspection Service

Sworn to me through the transmission of
this Complaint by reliable electronic
means (telephone), this 14" day of February, 2023.

‘THE HONORABLE STEWART D. AARON
United States Magistrate Judge
Southern District of New York


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