U.S. District Court Criminal Complaint
U.S. District Court Criminal Complaint
U.S. District Court Criminal Complaint
AUSA:
1 filedBarbara
09/11/20
LanningPageID.1 Telephone:
Page 1 of 17226-9100
(313)
AO 91 (Rev. ) Criminal Complaint Special Agent: Brett Brandon Telephone: (313) 202-3400
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 the date(s) of September 10, 2020 in the county of Wayne in the
Eastern District of Michigan , the defendant(s) violated:
Code Section Offense Description
18 USC § 922(n) Receipt of a firearm by a person under Indictment
18 USC § 922(g)(3) Unlawful user of a controlled substance in possession of a firearm
Complainant’s signature
City and state: Detroit, Michigan Hon. R. Steven Whalen, United States Magistrate Judge
Printed name and title
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Detroit Field Division since July 2013. I graduated from the Criminal Investigator
Training Program and the ATF Special Agent Basic Training Program at the
investigations involving the illegal possession, use, and sale of firearms, drug
other law enforcement agents, communications with others who have personal
PROBABLE CAUSE
most recently “_cclslim”. Through training and experience, Affiant knows that
Instagram account users can change their User ID without changing or modifying
“stories” (short videos or images that can be posted to an Instagram user’s account
and displayed publically or to the user’s followers in a private account), and other
State image of MASSEY dated May 17, 2016. Image 6a is MASSEY’s SOS
photo. Affiant identified MASSEY as the individual depicted in the images and
March 30, 2020 and depicts MASSEY (in the jean jacket) holding what appears to
be a black and silver pistol and holding what appears to be a marijuana blunt.
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Affiant knows the individual depicted in the black hoodie to be MYTEZ TERALL
Image 6c.
Image 6a Image 6b
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Image 6c
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plastic bag on a table. The final video in the series showed MASSEY smoking
Image 7a Image 7b
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Image 8a
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9. On August 24, 2020, Instagram User ID “_cclslim” posted Image 14a to the
Instagram User ID “_cclslim” posted a video story of the user retrieving what
appeared to be a Glock pistol from the brown messenger shoulder bag. Image 9b is
Image 9a Image 9b
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while seated in a vehicle. One of the videos captured a Glock pistol pointed at
what appeared to be a marijuana blunt. Images 10a, 10b, and 10c are screenshots.
story depicting the driver of a vehicle holding an opened bag containing what
appeared to be marijuana. Affiant noted the driver of the vehicle, whose face was
not shown, appeared to film the video and was wearing red pants. Image 11a is a
Image 11a
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aftermarket light on a bed next to a black male with what appeared to be braided
hair, similar to MASSEY’s. The face of the person capturing the video is not
visible. Image 20 is a screenshot of this video. Affiant noted the hexagon shapes
patterned on the bed sheet, which appears to be the same bed sheet depicted in the
video of the disassembled Glock posted from the same account on September 1,
2020.
Image 12a
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traffic stop of a white Chevrolet Tahoe in the area of Spencer Street and Eight Mile
Road in the city of Detroit. There were four occupants in the vehicle, including
MASSEY, who was seated in the rear driver’s seat. During the stop, the officers
noted they immediately smelled a strong odor of freshly burnt marijuana emitting
the vehicle and recovered a black pistol from the rear passenger side floorboard.
Sixth Circuit court records, Michigan Sixteenth Circuit court records and MDOC
Oakland County Sixth Circuit Court and Macomb County Sixteenth Circuit Court.
On January 30, 2020 MASSEY was arraigned in 52-1 District Court on an arrest
Circuit Court (Oakland) for Felony – Unarmed Robbery charge and is scheduled
for jury trial on September 18, 2020. Felony – Unarmed Robbery is a charge
Circuit Court (Macomb) on the following charges: Felony Fleeing and Eluding in
Leaving the Scene of a Personal Injury Accident, and Driving While License
Officer are each charges punishable by a sentence of more than one year in prison.
19. On September 10, 2020 at approximately 3:26 pm, the ATF Detroit
Crime Gun Enforcement Team (CGET) executed the federal search warrant at the
unidentified black woman standing in the doorway they had a search warrant for
the residence.
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21. At that time, an ATF Task Force Officer heard bushes rattling in the
backyard of the residence and announced that someone might be running from the
rear of the residence. Another Task Force Officer conducting surveillance for the
operation observed MASSEY, wearing a black t-shirt and red pants, running across
the street directly behind the residence. The Task Force Officer and Detroit Police
backyard of a residence nearby and placed him under arrest. The CGET officers
conducted a search of the Sunset Street residence and recovered one black Glock
41 .45 caliber pistol bearing serial number “YWE990” from inside a brown
23. The firearm and the messenger bag it was contained in appear to be
the same ones MASSEY previously posted to his Instagram account (Images 9a-b,
Images 10a-c, and Image 12a). Affiant also noted the sheets on the bed in the
makeshift bedroom of the basement matched the sheets in the videos MASSEY
previously posted to his Instagram account (Image 12a). The brown messenger bag
and firearm were located at the foot of the bed next to clothes the Affiant
located and photographed MASSEY’s driver’s license and a copy of his birth
and burned marijuana blunts from an ashtray located directly next to the firearm
and messenger bag. CGET officers noted the strong smell of freshly burnt
25. CGET officers also recovered a Glock pistol case with a sticker with
purchaser of the firearm purchased and registered the firearm on August 5, 2020.
To date, the firearm has not been reported stolen in the National Crime Information
Center (NCIC).
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firearms license (FFL) located in Royal Oak, Michigan, who confirmed they sold
the firearm to the purchaser on August 5, 2020. Affiant is aware this occurred after
MASSEY was arraigned in the Sixth Circuit Court of Michigan on March 6, 2020,
and after MASSEY was arraigned in the Sixteenth Circuit Court of Michigan on
Expert, Special Agent Michael Jacobs and provided a verbal description of the
firearm. Based upon the verbal description, Special Agent Jacobs advised the
the state of Michigan after 1898, and therefore had traveled in and affected
interstate commerce.
CONCLUSION
29. Based upon the aforementioned facts stated herein, there is probable
cause to believe JEREMY MASSEY JR., a person under indictment and a user of a
and possess a Glock 41 .45 caliber pistol bearing serial number “YWE990” pistol
Said violation occurring on September 10, 2020, in the city of Detroit, in the
Respectfully submitted,
_________________________________________
Hon. R. Steven Whalen
United States Magistrate Judge