Complaint — United States v. Michael Jones, No. 24-MJ-324

Summary

A Complaint, Document 1 in Case 1:24-cr-00235-NRM (24-MJ-324), filed April 25, 2024, in the U.S. District Court for the Eastern District of New York, against Michael Jones under 18 U.S.C. § 922(g)(1). Amanda Van Houten, a Special Agent with the Federal Bureau of Investigation, swears that on or about April 13, 2024, the defendant, knowing of a prior conviction for a crime punishable by imprisonment for a term exceeding one year, possessed ammunition. The affidavit describes a ShotSpotter activation, a 9mm shell casing, surveillance footage, an identification by an NYPD officer, and an interview in which Jones said the firearm was an airsoft pistol. It also states that an expert with the Bureau of Alcohol, Tobacco, Firearms and Explosives indicated the ammunition was manufactured outside New York.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Text recognized from a scanned document; may contain errors.

Case 1:24-cr-00235-NRM Document1 Filed 04/25/24 Page 1 of 6 PagelD #: 1

NEM:AS

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA COMPLAINT
- against - (18 U.S.C. § 922(g)(1))
MICHAEL JONES, 24-MJ-324
Defendant.

EASTERN DISTRICT OF NEW YORK, SS:

AMANDA VAN HOUTEN, being duly sworn, deposes and states that she is a
Special Agent with the Federal Bureau of Investigation, duly appointed according to law and
acting as such.

On or about April 13, 2024, within the Eastern District of New York and
elsewhere, the defendant MICHAEL JONES, knowing that he had previously been convicted in
a court of a crime punishable by imprisonment for a term exceeding one year, did knowingly and
intentionally possess in and affecting interstate or foreign commerce 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:!

1, I am a Special Agent with the Federal Bureau of Investigation (“FBI”) and

have been a Special Agent since 2022. Prior to that, ] was a Police Officer with the

| Because the purpose of this Complaint is to set forth only those facts necessary to
establish probable cause to arrest, | have not described all the relevant facts and circumstances of
which I am aware.
Case 1:24-cr-00235-NRM Document1 Filed 04/25/24 Page 2 of 6 PagelD #: 2

N

Lackawanna Police Department in New York for five years. I have been involved in the
investigation of numerous cases involving the possession and use 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.

2. On or about April 13, 2024, New York City Police Department (“NYPD”)
officers responded to a ShotSpotter activation indicating a shot fired at 554 Madison Street in
Brooklyn, New York. One 9mm bullet shell casing was recovered in front of this location.
Surveillance footage from the vicinity of 554 Madison Street from April 13, 2024, at
approximately the time of the ShotSpotter activation, shows a Black man wearing light pants and
a dark jacket firing a gun into the air. The surveillance footage also shows that the defendant’s

dark jacket has lighter-colored patches on his left sleeve.

Figure |
Case 1:24-cr-00235-NRM Document1 Filed 04/25/24 Page 3 of 6 PagelD #: 3

Figure 2

33 Additional surveillance footage from the minutes after the shot was fired
shows the same individual around the corner from the location of the shooting. This footage,
which is in color, shows the individual wearing light colored pants and a black jacket with
Chicago Bulls insignia on the chest and light-colored patches on the sleeves. The individual’s
height and build also match the height and build of the individual seen on camera shooting the
gun. Within days, the NYPD circulated a Wanted Flyer, No. 91790579, seeking further

information regarding this individual.
Case 1:24-cr-00235-NRM Documenti1 Filed 04/25/24 Page 4 of 6 PagelD #: 4

POLICE DEPARTMENT| DETECTIVE BUREAU POLICE DEPARTMENT ©
CITY OF NEW YORK | Wanted Flyer#91790579 | CITYOFNEWYORK =~

INFORMATION NEEDED
FOR RECKLESS
ENDANGERMENT

FIELD INFORMATION NEEDED - PERSON

/ MALE / BLACK

The 81 PDU is endeavoring to identify the above pictured individual in
regard to reckless endangerment. The above individual discharged a
firearm in the air in the vicinity of 554 Madison Street.

Figure 3

4. On or about April 16, 2024, an NYPD Officer from the 81st Precinct
identified the individual in the Wanted Flyer, No. 91790579, as MICHAEL JONES, whom the
NYPD Officer has arrested previously and seen numerous times, including on March 13, 2024,
at the 81st Precinct when JONES was arrested for an unrelated incident.

5. On or about April 23, 2024, MICHAEL JONES arrived at the 81st
Precinct to turn himself in as the individual in Wanted Flyer, No. 91790579. JONES stated to
NYPD that he was the person in Wanted Flyer, No. 91790579. When JONES turned himself in,

he was wearing the same black jacket with Chicago Bulls insignia and light-colored patches on
Case 1:24-cr-00235-NRM Document1 Filed 04/25/24 Page 5 of 6 PagelD #: 5

the sleeves. JONES waived his Miranda rights and agreed to be interviewed. During an

interview, an NYPD Detective questioned JONES and showed JONES the surveillance footage
of JONES shooting the firearm (the video from which Figure 1 was taken). JONES confirmed
that he was the individual in the video shooting the gun but claimed that the firearm was an
airsoft pistol.

6. Through the training that 1 have received, as well as my experience as an
FBI Special Agent and Police Officer, I am familiar with firearms, the sounds that firearms make
when being shot, and the muzzle flash that occurs when firearms are shot. Based on my
previous experience as a Police Officer with the Lackawanna Police Department, I am also
familiar with airsoft pistols, which shoot only spherical pellets or “BBs.” Based on my review
of the surveillance footage of JONES shooting the firearm, including the audible sound of the
gun being fired and the observable muzzle flash, and my training and experience, | believe that
JONES fired a gun, not an airsoft pistol. Additionally, the retrieved 9mm bullet shell casing
corroborates that JONES fired a gun, not an airsoft pistol, as airsoft pistols fire only “BBs.”

7. I have reviewed JONES’s criminal history. On or about February 24,
2014, JONES pleaded guilty to Robbery in the First Degree: Displaying What Appears to Be a
Firearm, in violation of New York Penal Law Section 160.15(4), a felony punishable by more
than one year in prison. The criminal history report also indicates that on or about March 6,
2014, JONES was sentenced to seven years’ imprisonment and five years’ post-release
supervision for this crime.

8. I have conferred with an interstate nexus expert with the Bureau of
Alcohol, Tobacco, Firearms and Explosives, who has informed me, in substance and in part, that

the recovered ammunition was manufactured outside the state of New York.
Case 1:24-cr-00235-NRM Document1 Filed 04/25/24 Page 6 of 6 PagelD #: 6

WHEREFORE, your deponent respectfully requests that the defendant

MICHAEL JONES be dealt with according to law.

AMANDA VAN HOUTEN
Special Agent
Federal Bureau of Investigation

Sworn to before me this
25th day of April, 2024

THE HONORABLE ROBERTM. LEVY
UNITED STATES MAGISTRATE JUDGE

EASTERN DISTRICT OF NEW YORK


File and source

File

1.pdf

Size

848,106 bytes

SHA-256

30db6e0b13b36a9091aa3b8b71688c546ea8d089bf96a293fc99823938674bcc

Our copy

1.pdf

Original

No public link identified.