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Criminal Complaint and Affidavit — United States v. Anthony Williams, No. 6:25-cr-06064 (W.D.N.Y.)

Summary

A Criminal Complaint with affidavit, Document 1, filed 04/12/24, Case 6:25-cr-06064-FPG (complaint No. 24-MJ-537), United States of America v. Anthony Williams, Western District of New York. It charges violations of Title 18, United States Code, Section 922(a)(5) and Section 922(o)(1) (Transfer of A Machine Gun), beginning on or about December 14, 2023, through December 18, 2023. Special Agent Andrew J. Farnham of the Bureau of Alcohol, Tobacco, Firearms and Explosives states that a confidential source arranged by text to buy firearms for $4,000, that a parcel was mailed from St. Louis, Missouri, and intercepted at Rochester, and that a search warrant on December 26, 2023, found a pistol with a machine gun conversion device. Attested before Mark W. Pedersen, United States Magistrate Judge.

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“Criminal Complaint and Affidavit — United States v. Anthony Williams, No. 6:25-cr-06064 (W.D.N.Y.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-6-25-cr-06064-dkt-1-w-d-n-y-1171d9b066/, SHA-256 d94caf6302650a6930974655e37be94560b7180b5af0402929cf4b7cce144fa8.

Full text

                    Case 6:25-cr-06064-FPG                Document 1    Filed 04/12/24      Page 1 of 8
AO 91 (Rev. 02/09) Criminal Complaint




              United States District Court
                                                              for the
                                                    Western District of New York


                          United States of America
                                                                                   Case No. 24-MJ- 537
                                           v.

                            ANTHONY WILLIAMS,

                                        Defendant



                                                      CRIMINAL COMPLAINT

         I, the complainant in this case, state that the following is true to the best of my knowledge and belief.

         Beginning on or about December 14, 2023 through and including on or about December 18, 2023, in the
Western District of New York and elsewhere, the defendant committed violations of Title 18, United States Code,
Section 922(a)(5) (Transfer of a Firearm from a Non-Licensee to a Non-Licensee Resident of Another State; and Title
18 United States Code, Section 922(o)(1) (Transfer of A Machine Gun).

         This Criminal Complaint is based on these facts:

         ☒ Continued on the attached sheet.

                                                                                      Complainant’s signature

                                                                     Special Agent Andrew J. Farnham
                                                                     Bureau of Alcohol, Tobacco, Firearms and
                                                                     Explosives
                                                                                      Printed name and title
Application submitted electronically by email in .pdf
Format. Oath administered, and contents and signature
Attested to me and before me as true and accurate by telephone
Pursuant to Fed.R.Crim.P. 4.1 and 4(d) on:

                                                                                      Judge’s signature
Date: April        12       , 2024                                   HONORABLE MARK W. PEDERSEN
                                                                     UNITED STATES MAGISTRATE JUDGE
City and State: Rochester, New York
                                                                                      Printed name and title
    Case 6:25-cr-06064-FPG          Document 1       Filed 04/12/24      Page 2 of 8




IN THE UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF NEW YORK


UNITED STATES OF AMERICA

               -v-
                                                                    24-MJ- 537
ANTHONY WILLIAMS,

                              Defendant


STATE OF NEW YORK )
COUNTY OF MONROE ) SS:
CITY OF ROCHESTER )


            AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

       I, Andrew Farnham, being duly sworn, depose and state as follows:

       1.      Your affiant is a Special Agent (SA) with the United States Department

of Justice, Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF), assigned to

the New York Field Division, Rochester Field Office. I have been employed as a

Special Agent since February 2019. Your affiant is a graduate of the Criminal

Investigator School and the ATF National Academy, both of which are located at the

Federal Law Enforcement Training Center in Glynco, Georgia. Prior to being

employed as a Special Agent, I was employed as a United States Border Patrol Agent

since 2008. In August 2021, your affiant completed the Firearms Interstate Nexus

Training Course in Martinsburg, West Virginia. As part of my professional experience,

I have participated in state and federal investigations involving the illegal possession

of firearms and narcotics, narcotics trafficking, and other violations of federal and state

law. Through my training and experience, I have become familiar with, among other


                                            1
    Case 6:25-cr-06064-FPG         Document 1       Filed 04/12/24     Page 3 of 8




things, how firearms, ammunition and narcotics are trafficked throughout the United

States.

                            PURPOSE OF AFFIDAVIT

          2.   This affidavit is submitted in support of a criminal complaint charging

Anthony WILLIAMS (hereinafter “WILLIAMS”) with violations of Title 18, United

States Code, Section 922(a)(5) (Transfer of a Firearm from a Non-Licensee to a Non-

licensed Resident of Another State; and Title 18 United States Code, Section 922(o)(1)

(Transfer of A Machine Gun).

          3.   As more fully described below, the facts in this affidavit are based on a

combination of my personal participation in this investigation, and conversations with

other law enforcement officers involved in this investigation. As detailed below, my

knowledge is also based on information provided by a confidential source (hereafter

“CS-1”). CS-1 has been working with ATF, the Rochester Police Department and

other law enforcement agencies for approximately one year. CS-1 has engaged in

controlled buy operations during this timeframe that has resulted in the seizure of

illegal firearms. CS-1’s information has proven to be truthful and reliable. The basis of

CS-1’s information in this affidavit is his/her personal knowledge unless otherwise

specified. CS-1’s information as it relates to this investigation has been corroborated

on many points, as described in this affidavit. I therefore believe that CS-1’s

information is truthful and reliable. CS-1 is cooperating with the government in the

hopes of receiving a more favorable sentence on a conviction he/she received for a

felony offense in federal court. Since this affidavit is being submitted for a limited

purpose, I have not included each and every fact that I know concerning this


                                           2
    Case 6:25-cr-06064-FPG           Document 1       Filed 04/12/24      Page 4 of 8




investigation. Rather, I have set forth only those facts that relate to the issue of whether

probable cause exists to believe that WILLIAMS committed the above-mentioned

offense.

                                 PROBABLE CAUSE

       4.      Your affiant and other members of the ATF Rochester Field Office have

been working together on a firearms trafficking investigation along with CS-1. On

December 13, 2023, CS-1 received a text message an individual he/she identified in

his/her phone contacts as 400 chop. This person is personally known to CS-1 as

Anthony WILLIAMS. Additionally, ATF agents reviewed the text message and

observed that it came from phone number (314)737-6989. Subscriber information for

this phone number obtained via law enforcement databases revealed that this number

is serviced by AT&T and subscribed to in the name of Anthony Lamar WILLIAMS

with a DOB of XX/XX/1995. A copy of this text message and subsequent pertinent

text message conversations between CS-1 and WILLIAMS have been saved as

evidence by investigating ATF agents. Based on my review of the December 13, 2023

text message as well as my training and experience, in this message WILLIAMS

informs CS-1 that he has two firearms with “buttons” available to sell. Based on my

training and experience, I believe WILLIAMS was referring to devices that can be

affixed to firearms that transforms the firearm from semi-automatic to fully automatic.

At the direction of law enforcement CS-1 indicated that he wanted to purchase the two

firearms with “buttons” and agreed to pay WILLIAMS $4,000 in United States

currency. CS-1 and WILLIAMS were communicating by phone as indicated above.




                                             3
    Case 6:25-cr-06064-FPG        Document 1      Filed 04/12/24     Page 5 of 8




WILLIAMS is personally known to CS-1, and CS-1 is also aware that he presently

resides in St. Louis, Missouri.



       5.     A query of law enforcement databases indicate that WILLIAMS

presently resides at 6118 West Florissant Avenue, St. Louis, Missouri. As part of this

investigation I have reviewed a photographic identification card for WILLIAMS from

the State of Missouri. I have also reviewed booking photographs for WILLIAMS and

social media images pertaining to WILLIAMS. As such, I have become familiar with

the physical appearance of WILLIAMS.



       6.     On December 14, 2023, WILLIAMS and CS-1 communicated via text

message once again. During the course of these text messages WILLIAMS (using

phone number (314)737-6989) advised CS-1 the firearms were wiped down and were

ready to ship. Based on my training and experience, I believe WILLIAMS was

informing CS-1 that he had wiped the firearms down to remove his fingerprints and

DNA. CS-1 told WILLIAMS that the firearms should be shipped to: Josh Abelton

1738 St. Paul Street Rochester, NY, 14621. This was done at the direction of law

enforcement, who anticipated intercepting the firearms. WILLIAMS advised CS-1

that he was mailing the firearms via the United States Postal Service (USPS).



       7.     On December 14, 2023, WILLIAMS shipped the firearms to the address

requested by CS-1. WILLIAMS sent a text message to CS-1 that included a

photograph of the USPS receipt. The receipt included a tracking number of 9505 5104


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    Case 6:25-cr-06064-FPG         Document 1      Filed 04/12/24     Page 6 of 8




5293 3348 4906 76 and a delivery date of Monday December 18, 2023, to Rochester,

NY (hereafter the “Subject Parcel”). The Subject Parcel was mailed from a United

States Post Office Facility in St. Louis, Missouri. U.S. Postal Inspector Keenan

obtained video from the Post Office correlating to the time and date the Subject Parcel

was shipped and he shared a screen shot of this video with me. The screen shot clearly

depicts Anthony WILLIAMS presenting a package for shipment, consistent with the

Subject Parcel.



       8.     Your affiant provided the tracking number to United States Postal

Inspector Keenan, who was able to locate the package in the flow of mail and have it

pulled from circulation. On December 18, 2023, US Postal Inspector Keenan was able

to secure the Subject Parcel in Rochester, New York. Inspector Keenan applied for a

search warrant to open the Subject Parcel.



       9.     During the course of the transit of the Subject Parcel from Missouri to

New York, CS-1 was in contact with WILLIAMS. Based on their text message

conversations, I believe WILLIAMS was also tracking the package. U.S. Postal

Inspector Keenan updated the tracking information for the Subject Parcel to appear as

delivered on December 18, 2023 to avoid drawing suspicion from WILLIAMS. On

December 18, 2023, CS-1 communicated via text message with WILLIAMS and

informed him that the package had been received. CS-1 also asked WILLIAMS where

he should send the agreed upon payment for the funds. WILLIAMS directed CS-1 to

send payment to a Cash App handle of Luckyymore ($luckyymore). CS-1, using


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    Case 6:25-cr-06064-FPG        Document 1      Filed 04/12/24    Page 7 of 8




official funds and at the direction of law enforcement, paid WILLIAMS $4,000 in

United States currency via Cash App.



       10.    On December 26, 2023, US Postal Inspector Keenan obtained a federal

search warrant from Magistrate Judge Pedersen and opened the Subject Parcel.

Located inside was a Glock 23 Gen 5 .40 caliber pistol bearing serial number of

BXZZ469, and a Glock 9mm pistol bearing serial number BUYV279. The 9mm

pistol bearing S/N BUYV279 had a complete machine gun conversion device

attached. Based on my training and experience, this would allow the firearm to fire in

a fully automatic mode, and would qualify as a machine gun under federal law.



       11.    A query of Federal Firearms Licensee revealed WILLIAMS was not a

Federal Firearms Licensee. A query of the National Firearms Registration and

Transfer Record System revealed WILLIAMS was not able to legally possess a

machine gun. CS-1 is not a Federal Firearms Licensee either, nor was there any

reasonable reason for WILLIAMS to believe that CS-1 was.




                                 CONCLUSION

       12.    Based on the above information, your affiant submits that probable

cause exists to believe that beginning on or about December 18, 2023 through and

including on or about December 18, 2023, in the Western District of New York and

elsewhere, WILLIAMS committed violations of Title 18, United States Code, Section

922(a)(5) (Transfer of a Firearm from a Non-Licensee to a Non-licensed Resident of


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    Case 6:25-cr-06064-FPG         Document 1      Filed 04/12/24    Page 8 of 8




Another State; and Title 18 United States Code, Section 922(o)(1) (Transfer of A

Machine Gun).



                                                   ANDREW J. FARNHAM
                                                   Special Agent
                                                   Bureau of Alcohol, Tobacco,
                                                   Firearms and Explosives


Affidavit submitted electronically by email in .pdf format.
Oath administered, and contents and signature attested
to me as true and accurate telephonically pursuant to
                                         12th
Fed. R. Crim. P. 4.1 and41(d)(3) on this ____day   of April, 2024.



HONORABLE MARK W. PEDERSEN
United States Magistrate Judge




                                           7


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