United States v. KAREEM PALMER, Southern District of New York (Jan. 24, 2024) — Complaint

UNITED 
STATES 
DISTRICT 
COURT 
SOUTHERN 
DISTRICT 
OF 
NEW 
YORK 
UNITED 
STATES 
OF 
AMERICA 
V. 
KAREEM 
PALMER, 
Defendant. 
SOUTHERN 
DISTRICT 
OF 
NEW 
YORK, 
ss.: 
AUSAs
: Margaret 
N. Vasu, 
Jennifer 
N . Ong 
2 
L\ 
V\l\.::S-
2(,;,l, 
SEALED 
COMPLAINT 
Violations 
of 
18 
U.S.C
. 
§§ 
1951, 
924( 
c 
)(1 
)(A)(i) 
and 
(ii) 
COUNTY 
OF 
OFFENSE: 
ORANGE 
THOMAS 
L. 
ANDERSON 
being 
duly 
sworn, 
deposes 
and 
says 
that 
he 
is 
a Special 
Agent 
with 
the 
Federal 
Bureau 
oflnvestigation 
("FBI"), 
and 
charges 
as 
follows: 
COUNT 
ONE 
(Hobbs 
Act Robbery) 
1. 
On 
or 
about 
December 
4, 
2023
,  in 
the 
Southern 
District 
of 
New 
York 
and 
elsewhere, 
KAHEEM 
PALMER, 
the 
defendant, 
knowingly 
committed 
robbe1y
, 
as 
that 
term 
is 
defined 
in 
Title 
18, 
United 
States 
Code, 
Section 
1951 
(b 
)(1 
), 
and 
thereby 
obstructed, 
delayed, 
and 
affected 
commerce 
and 
the 
movement 
of 
aiiicles 
and 
commodities 
in 
commerce, 
as 
that 
term 
is 
defined 
in 
Title 
18, 
United 
States 
Code, 
Section 
1951 
(b )(3), 
and 
aided 
and 
abetted 
the 
same
, 
to 
wit, 
PALMER 
and 
another 
person 
robbed 
at gunpoint 
a home 
in 
the 
vicinity 
of 
South 
Clark 
Street, 
Newburgh, 
New York. 
(Title 
18, 
United 
States 
Code, 
Sections 
1951 
and 
2.) 
COUNT 
TWO 
(Firearms 
Use, 
Carrying, 
and 
Possession) 
2. 
On 
or 
about 
December 
4, 
2023 
in 
the 
Southern 
District 
of 
New 
York 
and 
els
ewhere, 
KAREEM 
PALMER, 
the 
defendant, 
during 
and 
in 
relation 
to 
a  crime 
of 
violence 
for 
which 
he 
may 
be 
prosecuted 
in 
a court 
of 
the 
United 
States, 
nam
ely, the 
Hobbs 
Act 
robbe1y 
charged 
in 
Count 
One 
of 
this 
Complaint, 
knowingly 
used 
and 
canied 
a  firearm, 
and 
in 
furtherance 
of 
such 
crime, 

possessed 
a  firearm, 
and 
aided 
and 
abetted 
the 
use, 
carrying, 
and 
possession 
of 
a firearm, 
which 
was 
brandished. 
(Title 
18, 
United 
States 
Code, 
Sections 
924( 
c 
)(1 
)(A)(i) 
and 
(ii), 
and 
2.) 
The 
bases 
for 
my 
knowledge 
and 
for 
the 
foregoing 
charges 
are, 
in 
part, 
as 
follows: 
3. 
I  am 
a  Special 
Agent 
with 
the 
FBI, 
and 
I  have 
been 
personally 
involved 
in 
the 
investigation 
of 
this 
matter. 
This 
affidavit 
is 
based 
in 
part 
on 
my 
conversations 
with 
other 
law 
enforcement 
officers 
and 
others, 
and 
my 
examination 
of 
cmTespondence, 
video 
surveillance, 
reports, 
and 
records. 
Because 
this 
affidavit 
is 
being 
submitted 
for 
the 
limited 
purpose 
of 
establishing 
probable 
cause, 
it 
does 
not 
include 
all 
the 
facts 
that 
I  have 
learned 
during 
my 
investigation. 
Where 
the 
contents 
of 
documents 
or 
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 
review 
of 
reports 
and 
records 
in 
this 
investigation, 
sworn 
statements 
from 
the 
victims, 
GPS 
and 
cellphone 
location 
records, 
and 
video 
surveillance 
footage, 
as 
well 
as 
my 
conversations 
with 
other 
law 
enforcement 
officers, 
and 
my 
own 
participation 
in 
this 
investigation, 
I know 
that 
the 
FBI 
and  the 
City 
of 
Newburgh 
Police 
Department 
("CNPD") 
have 
been 
investigating 
the 
anned 
robbery 
of 
a  known 
marihuana-dealing 
location 
in 
the 
City 
of 
Newburgh, 
New 
York 
by 
KAREEM 
PALMER, 
the 
defendant, 
and 
at 
least 
one 
other 
co-
conspirator. 
[ 
Continued 
on 
the 
next 
page] 
2 

The 
Report 
of 
the 
Robbery 
5. 
In 
or 
about 
the 
early 
morning hours 
of 
December 
5, 
2023, 
two 
individuals 
reported 
an 
armed 
robbery 
of 
a residence 
on 
South 
Clark 
Street 
in Newburgh, 
New 
York 
(the 
"Residence")
. 
1 
Victim-I 
's 
Report 
of 
the 
Robbery 
6. 
One 
individual, 
who 
represented 
that 
he 
lives 
at, 
and 
also 
sold 
marijuana 
out 
of, 
the 
Residence 
("Victim-I") 
was 
interviewed 
by 
CNPD 
and 
provided 
the 
following 
information: 
a. 
He 
was 
sitting 
in 
the 
Residence 
when 
he 
heard 
a  knock 
at 
the 
front 
door, 
which 
he 
knew 
had 
trouble 
closing 
and 
locking. 
After 
going 
to 
the 
door 
and 
looking 
through 
the 
peep 
hole, 
he 
attempted 
to 
move 
his 
sofa 
to 
block 
the 
door. 
An 
individual 
on 
the 
other 
side 
of 
the 
door 
was 
able 
to 
open 
the 
door 
enough 
to 
stick 
a gun 
into 
the 
crack 
in 
the 
door 
and 
prevent 
it from 
closing. 
b. 
The 
individuals 
on 
the 
other 
side 
of 
the 
door 
were 
able 
to 
overpower 
him, 
and 
three 
individuals 
entered 
the 
Residence: 
two 
unlmown 
men 
(the 
"Intruders"), 
both 
of 
whom 
had 
guns, 
and 
one 
Hispanic 
man 
who 
Victim-I 
recognized 
as 
a regular 
customer 
of 
his 
and 
who 
Victim-I 
understood 
had 
come 
to 
the 
Residence 
to 
buy 
marihuana 
from 
him 
("Victim-2"). 
c. 
The 
Intruders 
yelled 
not 
to 
look 
at 
them 
and 
forced 
him 
and 
Victim-2, 
at 
gunpoint, 
into 
the 
bedroom 
and 
to 
kneel 
down 
facing 
the 
bed. 
The 
Intruders 
then 
placed 
fabric 
bags 
over 
Victim-I 
and 
Victim-2 
's 
heads 
and 
placed 
handcuffs 
on 
Victim-I. 
d. 
One 
of 
the 
Intruders 
stood 
over 
him 
and 
Victim-2, 
while 
the 
other 
went 
through 
the 
Residence, 
taking 
things. 
e. 
The 
Intruders 
"kept 
asking 
where 
the 
money 
was, 
where 
the 
safe 
was, 
and 
told 
[him] 
that 
they 
would 
kill 
[him]." 
Victim-I 
told 
the 
Intrnders 
that 
he 
only 
had 
$ 
I ,000 
in 
his 
pocket, 
and 
they 
took 
that money. 
1 
The 
Residence 
is 
known 
to 
law 
enforcement in 
Newburgh 
as 
a marihuana-dealing 
location. 
3 

f. 
At 
one 
point, 
one 
of 
the 
Intruders 
hit 
him over 
the 
head 
approximately 
three 
times 
with 
a gun. 
He 
also 
stated 
that 
at 
one 
point, 
one 
of 
the 
intruders 
placed 
the 
banel 
of 
a gun 
to 
the 
back 
of 
his 
neck 
and 
said, 
"I 
feel 
like 
you 
are 
lying 
to 
me." 
The 
Intruder 
who 
was 
holding 
the 
gun 
to 
Victim-1 
's 
neck 
then 
moved 
the 
gun 
down 
his 
neck, 
and 
back, 
and 
onto 
his 
left 
thigh. 
g. 
The 
Intruders 
told 
him 
"they 
know 
who 
[he 
is] 
and 
are 
coming 
back 
for 
[him]." 
h. 
Before 
the 
Intruders 
left, 
they 
removed 
the 
fabric 
bag 
from 
his 
head, 
duck 
taped 
his 
mouth, 
removed 
the 
handcuffs 
to 
replace 
them 
with 
duct 
tape, 
and 
tied 
his 
legs 
up 
with 
a belt. 
his 
phone. 
1. 
He 
instructed 
Victim-2 
to 
call 
the 
police, 
because 
the 
Intruders 
had 
taken 
J. 
Victim-I 
rep01ied 
the 
following 
items 
stolen: 
(i) 
A 
FedEx 
envelope 
containing 
his 
bi1ih 
certificate, 
immigration 
pape1work, 
social 
security 
card, 
and 
Jamaican 
passport; 
(ii) 
His 
phone, 
a  Samsung 
Galaxy 
6  that 
conesponds 
to 
the 
cellphone 
number 
ending 
in 
6229; 
(iii) 
Approximately¾ 
of 
a pound 
of 
marihuana; 
(iv) 
Approximately 
$1,000 
in 
cash, 
representing 
the 
proceeds 
of 
marijuana 
sales; 
(v) 
A gold-plated 
watch; 
(vi) 
A 
blue 
jug 
filled 
with 
quarters; 
(vii) 
A plastic 
food 
container 
filled 
with 
coins; 
and 
(viii) 
A 
gallon 
bottle 
filled 
with 
coins, 
worth 
approximately 
$2,000. 
4 

k. 
Victim-I 
reported 
that he 
only 
saw 
one 
of 
the 
Intruders 
and 
described 
him 
as 
black. 
He 
identified 
both 
as 
men 
and 
rep01ted 
that 
one 
was 
taller 
than 
the 
other 
and 
that 
one 
was 
wearing 
black 
Nike 
Air 
Max 
shoes
.  Victim-I 
repo1ted 
that 
he 
was 
not 
familiar 
with 
the 
Intruders. 
1. 
Victim-
I  also 
reported 
that 
both 
of 
the 
Intruders 
had 
guns 
-  that 
one 
had 
a 
small 
revolver 
and 
the 
other 
had 
a black 
semi-automatic, 
and 
that 
the semi
-automatic 
gun 
was 
the 
one 
used 
to 
get 
into 
the 
door 
of 
the 
Residence. 
Victim-2 
's Repo
rt 
of 
the 
Robbery 
7. 
Victim-2 
was 
interviewed 
by 
CNPD 
and 
provided 
the 
following 
infonnation: 
a. 
He 
was 
on 
the 
sidewalk 
in 
front 
of 
the 
Residence 
when 
a light-skinned 
black 
male 
grabbed 
him 
("Intruder-I"), 
and 
then, 
after 
Victim-2 
had 
shaken 
him 
off, 
pointed 
a gun 
at 
him 
and 
dragged 
him 
inside 
the 
common 
hallway 
of 
the 
building 
in which 
the 
Residence 
is  located. 
b. 
There 
he 
saw 
a darker-skinned 
black 
male 
inside 
("Intruder-2" 
and
, together 
with 
Intruder-I
, the 
"Intruders"), 
who 
had 
two 
guns. 
The 
Intruders 
instructed 
Victim-2 
to 
knock 
on 
the 
door 
of 
the 
Residence, 
and 
when 
he 
initially 
refused, 
both 
Intruders 
pointed 
guns 
at Victim-
2's 
head
.  Intruder-I 
then 
struck 
Victim-2 
on 
the 
neck 
with 
the 
butt 
of 
his 
gun. 
Victim-2 
fell
, and 
Intruder-I 
then 
held 
Victim-2 
in 
a headlock 
with 
the 
gun 
pointed 
at 
Victim-2's 
head. 
Intruder
-2 
then 
rang 
the  doorbell 
and 
announced 
" delive1y" 
before 
beginning 
to 
kick 
down 
the 
door 
to 
the 
Residence. 
c. 
Once 
inside, 
Intruder-2 
pistol-whipped 
Victim-I 
before 
putting 
Victim
- I in 
handcuffs
. 
The 
Intruders 
brough 
Victim-2, 
along 
with 
Victim-I, 
into 
a  dark 
room 
and 
threw 
Victim-2 
to 
the 
ground
.  At 
this 
point, 
Victim-2 
observed 
Victim-I 
was 
knelt 
over 
the 
bed 
with 
his 
hands 
handcuffed 
behind 
him. 
Intruder-I 
had 
a gun 
pointed 
at Victim-2 
and 
repeated 
"don't 
look 
at 
me
."  The 
Intruders 
went 
through 
Victim-2
' s pockets 
and 
took 
his 
rent 
money 
and 
his 
phone. 
5 

d. 
Victim-2 
believed 
that 
a notification 
had 
popped 
up 
on 
his 
phone 
while 
the 
Intruders 
were 
looking 
at 
it, 
and 
that 
because 
of 
his 
immigration 
status, 
his 
phone 
has 
GPS 
tracking. 
Victim-2 
believed 
that 
this 
upset 
the 
Intruders, 
and 
Intruder
- I then 
hit 
Victim-2 
with 
the 
butt 
of 
a gun 
once 
again. 
At 
this 
point, 
the 
Intruders 
placed 
pillowcases 
over 
Victim-2 
and 
Victim-
1 
's 
heads 
and 
instructed 
Victim-2 
to 
kneel 
beside 
Victim-I. 
e. 
The 
Intruders 
then 
ransacked 
the 
Residence 
and 
continued 
to 
yell 
at 
him 
and 
Victim-I 
the 
whole 
time
. 
f. 
Before 
the 
Intruders 
left, 
they 
removed 
the 
handcuffs 
from 
Victim-I, 
duct 
taped 
Victim-1 
's 
hands 
and 
mouth 
and 
tied 
together 
Victim-1 
's 
legs 
with 
a  belt. 
The 
Intruders 
also 
tied 
Victim-2's 
legs 
with 
a belt. 
g. 
The 
Intruders 
told 
Victim-2 
and 
Victim-I 
that 
they 
were 
going 
to 
come 
back 
and 
kill 
the 
two 
of 
them 
because 
both 
he 
and 
Victim-I 
had 
seen 
their 
faces. 
h. 
Victim-2 
rep01ied 
that 
the 
Intruders 
stole 
$1,600 
from 
him. 
1. 
Victim-2 
fmiher 
described 
Intruder-I 
as 
tall 
and 
stocky, 
wearing 
a black 
jacket 
with 
a black 
hoodie 
underneath, 
black 
pants, 
a black 
beanie, 
and 
black 
Nike shoes
.  Victim-
2 estimated 
that 
Intruder-I 
was 
in 
his 
late 
twenties. 
J. 
Victim-2 
further 
described 
Intruder-2 
as 
tall 
and 
skinnier, 
wearing 
a black 
coat, 
black 
hoodie, 
and 
black 
sweatpants 
and 
as 
having 
a tight, 
groomed 
beard. 
Victim-2 
estimated 
that 
Intruder-2 
was 
older 
that 
Intruder-I, 
perhaps 
in 
his 
thirties. 
k. 
Victim-2 
stated 
that 
the 
Intruders 
spoke 
English 
and 
used 
what 
he 
understood 
to 
be 
Jamaican 
words 
at 
times. 
1. 
Victim-2 
noted 
that 
Intruder-2 
had 
two 
guns 
and 
Intruder-I 
had 
one 
gun. 
He 
described 
all 
three 
as 
black 
guns 
and 
noted 
that 
they 
appeared 
to 
him 
to 
look 
like 
law 
enforcement 
weapons. 
6 

Identification 
of 
Kaheem 
Palmer 
Video 
Footage 
8. 
Video 
footage 
from 
the 
late 
evening 
hours 
of 
on 
or 
about 
December 
4, 
2023 
collected 
from 
surveillance 
cameras 
owned 
by 
residents 
near 
the 
Residence 
shows 
the 
following: 
a. 
At 
approximately 
11: 
15 
p.m. 
on 
December 
4, 
2023, 
two 
male 
individuals 
("Suspect-I" 
and 
"Suspect-2," 
respectively, 
together,  the 
"Suspects") 
are 
observed 
walking 
west 
on 
Renwick 
Street 
before 
turning 
right 
onto 
South 
Clark 
Street 
and 
walking 
north 
on 
South 
Clark 
Street, 
on 
the 
eastern 
side 
of 
the 
street, 
headed 
towards 
Benkard 
Avenue. 
a. 
Suspect-I 
has 
since 
been 
identified, 
including 
through 
self-identification 
during 
a 
Mirandized 
post-anest 
statement, 
by 
Recaldo 
Fray 
of 
Mount 
Vernon, 
New 
York. 
2 
b. 
During 
the 
same 
post-arrest 
statement, 
after 
waiving 
his 
Miranda 
rights, 
Fray 
identified 
the 
other 
individual 
in 
the 
video 
footage, 
Suspect-2, 
as 
Kaheem 
PALMER. 
b. 
Shortly 
thereafter, 
and 
from 
another 
camera 
angle, 
at 
approximately 
11: 
16 
p.m., 
the 
Suspects 
are 
observed 
walking 
north 
on 
the 
eastern 
side 
of 
South 
Clark 
Street, 
in 
front 
of 
the 
Residence 
as 
they 
pass 
out 
of 
the 
view 
of 
the 
camera. 
c. 
At 
approximately 
11 
:32 
p.m., 
Suspect-2 
is 
seen 
walking 
south 
on 
the 
eastern 
side 
of 
South 
Clark 
Street, 
just 
outside 
of 
the 
Residence, 
canying 
a medium 
sized 
item 
in 
his 
left 
hand 
and 
a smaller 
item 
in 
his 
right 
hand. 
d. 
At 
approximately 
11 
:35 
p.m., 
a light-colored 
sedan 
(the 
"Suspect 
Vehicle") 
is 
observed 
driving 
west 
on 
Renwick 
Street 
before 
turning 
right 
on 
South 
Clark 
Street 
and 
parking 
2 
Recaldo 
Fray 
was 
charged 
in 
a three-count 
Complaint 
on 
or 
about 
Januaiy 
15, 
2024 
and 
aITested 
the 
following 
day, 
on 
or 
about 
Janua1y 
16, 
2024. 
7 

shortly 
thereafter 
on 
the 
n01iheast 
corner 
of 
South 
Clark 
Street 
and 
Renwick 
Street, 
approximately 
a 
half 
of 
a block 
south 
of 
the 
Residence. 
Fray 
exits 
the 
driver's 
side 
of 
the 
Suspect 
Vehicle 
and 
walks 
north 
on 
the 
eastern 
side 
of 
South 
Clark 
Street. 
e. 
At 
approximately 
11 
:46 
p.m., 
Suspect
-2 
is 
seen 
walking 
south 
on 
the 
eastern 
side 
of 
South 
Clark 
Street, 
just 
outside 
of 
the 
Residence, 
canying 
what 
appears 
to 
be 
a suitcase 
in 
his 
left 
hand 
before 
loading 
the 
item 
into 
the 
trunk 
of 
the 
Suspect 
Vehicle 
parked 
on 
the 
northeast 
corner 
of 
South 
Clark 
Street 
and 
Renwick 
Street 
approximately 
a 
half 
of 
a  block 
south 
of 
the 
Residence. 
Suspect-2 
then 
walks 
back 
toward 
the 
Residence, 
walking 
on 
the 
eastern 
side 
of 
South 
Clark 
Street. 
At 
approximately 
11 
:47 
p.m., Suspect-2 
reappears, 
again 
walking 
south 
on 
the 
eastern 
side 
of 
South 
Clark 
Street, 
just 
outside 
of 
the 
Residence, 
canying 
what 
appears 
to 
be 
a  5-gallon 
water 
cooler 
jug 
in 
his 
right 
hand, 
before 
loading 
the 
item 
into 
the 
trunk 
of 
the 
Suspect 
Vehicle. 
The 
nature 
of 
Suspect-2's 
gait 
suggests 
that 
the 
item 
in 
his 
right 
hand 
is  quite 
heavy, 
as 
Suspect-2 
is 
seen 
holding 
out 
his 
left 
arm 
for 
balance. 
Suspect-2 
then 
returns 
towards the 
Residence, 
walking 
north 
on 
the 
eastern 
side 
of 
South 
Clark 
Street. 
f. 
At 
approximately 
11 
:51 
p.m., 
the 
Suspects 
are 
seen 
walking 
south 
on 
the 
eastern 
side 
of 
South 
Clark 
Street 
just 
outside 
of 
the 
Residence. 
Suspect-2 
appears 
to 
be 
canying 
a clear 
plastic 
gallon 
jug
.  Suspect-2 
loads 
the 
item 
in his 
hand 
into 
the 
trunk 
of 
the 
Suspect 
Vehicle, 
before 
entering 
the 
passenger 
side, 
as 
Fray 
enters 
the 
driver's 
side 
of 
the 
vehicle. 
At 
approximately 
11 
:52 
p.m., 
the 
Suspect 
Vehicle 
pulls 
away
,  driving 
north 
on 
South 
Clark 
Street 
and 
out 
of 
the 
camera's 
view. 
g. 
At 
approximately 
11 
:52 
p.m
., another 
camera 
angle 
picks 
up 
what 
appears 
to 
be 
the 
Suspect 
Vehicle 
driving 
north 
on 
South 
Clark 
Steet 
before 
making 
a left 
onto 
Benkard 
Avenue 
and 
out 
of 
camera 
view. 
8 

9. 
Video 
footage 
from 
the 
late 
evening 
hours 
of 
on 
or 
about 
December 
4, 
2023 
collected 
from 
Newburgh 
City 
Street 
cameras 
shows 
that 
at 
approximately 
11 
:52 
p.m., 
a vehicle 
comes 
off 
of 
Benkard 
Avenue 
and 
goes 
south 
on 
William 
Street, 
where 
the 
Suspect 
Vehicle 
appears 
to 
stop 
for 
a red 
light 
before making 
a right, 
either 
onto 
Renwick 
Street 
or 
Bridge 
Street, 
and 
driving 
out 
of 
camera 
view
. 
10. 
Video 
footage 
from 
the 
late 
evening 
hours 
of 
on 
or 
about 
December 
4, 
2023 
collected 
from 
the 
local 
school 
district 
shows 
a  vehicle 
that 
appears 
to 
be 
the 
Suspect 
Vehicle 
traveling 
south 
towards 
New 
Windsor 
at 
approximately 
11 
:53 
p.m. 
11. 
Video 
surveillance 
footage 
from 
the 
early 
morning 
hours 
of 
on 
or 
about 
December 
5, 
2023 
collected 
from 
a  particular 
residential 
building 
on 
South 
9
th 
Avenue 
in 
Mount 
Vernon, 
New 
York 
shows 
the 
following: 
a. 
At 
approximately 
I :02 
a.m., 
a vehicle 
that 
appears 
to 
be 
the 
Suspect 
Vehicle 
pulls 
up 
to 
a stop 
in 
front 
of 
the 
residential 
building; 
and 
b. 
Shortly 
thereafter, 
at approximately 
I :04 
a.m., 
a male 
individual 
who 
appears 
to 
be 
Suspect-2 
exits 
the 
Suspect 
Vehicle 
on 
the 
passenger 
side 
and 
walks 
towards 
the 
entrance 
of 
the 
residential 
building. 
Text 
Message 
Exchanges 
12. 
Based 
on 
my 
review 
of 
infonnation 
provided 
by 
AT&T 
Wireless, 
I know 
that 
the 
subscriber 
for 
the 
cellphone 
assigned 
a particular 
number 
ending 
in 
4567 
(the 
"4567 
Number") 
is 
listed 
as 
"Rastanautz
." 
13. 
I have 
reviewed 
the 
public 
profile 
of 
an 
Instagram 
page 
for 
a business 
account 
titled 
"Rastanautz." 
The 
"email" 
tab 
of 
the 
same 
Instagram 
page 
provides 
a linked 
email 
address 
that 
is 
a particular 
email 
account 
(the 
"Email 
Account"). 
9 

14. 
Moreover, 
I know 
from 
my 
review 
ofrecords 
provided 
by 
a particular 
email 
service 
provider 
that 
the 
subscriber 
for 
the 
Email 
Account 
submitted 
the 
4567 
Number 
as 
the 
Recovery 
Text 
Message 
Number 
for 
that 
account. 
I know 
from 
my 
review 
of 
those 
same 
records 
that 
the 
subscriber for 
the 
Email 
Account 
is 
Kaheem 
PALMER. 
15. 
Based 
on 
my 
review 
of 
the 
contents 
of 
a cellphone 
belonging 
to 
Fray, 
I know 
that 
the 
4567 
Number 
was 
saved 
in 
Fray's 
phone 
as 
"Kaheem 
Palmer." 
16. 
Based 
on 
the 
infom1ation 
described 
in 
Paragraphs 
12-15 
above, 
I believe 
that 
the 
4567 
Number 
is 
used 
by 
Kaheem 
PALMER. 
17
. 
Based 
on 
the 
same 
review 
of 
cellphone 
contents 
described 
in 
Paragraph 
15 
above, 
as 
well 
as 
my 
review 
of 
records 
provided 
by 
the 
particular 
email 
service 
provider 
described 
in 
Paragraph 
14 
above, 
I know that 
the 
4567 
Number 
had 
the 
following 
text 
message 
exchange 
with 
Fray
3 
on 
or 
about 
December 
4, 
2023 
between approximately 
6:44 
a.m. 
and 
9:27 
a.m.: 
4567 
Number 
To 
of 
the 
sun 
beloved 
I'm 
off 
on 
Frida 
Kopy 
lemme 
get 
on 
the 
[particular 
map 
service 
rovider 
ma 
s imma 
rab 
I 
Fra 
's Phone 
To 
a 
di 
mawnin 
Sa 
less 
3 
The 
content 
of 
the 
text 
messages 
below 
are 
included 
exactly 
as 
they 
appear 
in 
Fray's 
phone. 
Any 
typographical 
errors 
included 
here 
are 
in 
the 
original 
messages. 
10 

[ 
Street 
Number 
Redacteclj
4 
south 
Clark 
st that 
black 
bm 
his 
shit 
-
In 
through 
the 
door 
is 
a camera 
idk 
if 
it's 
valid 
This 
Frida 
I think 
hell 
fumble 
in 
the 
night 
but 
idk 
he 
get 
u   b   7 
traffic 
is 
s  ot 
so 
I honest! 
can't 
sa 
Mnilim 
Sa 
less 
Yo 
schedule 
chan 
e 
I'm 
free 
till 
Wednesda 
I'm 
at work 
not 
imma 
be 
here 
for 
a little 
then 
I'll 
link 
ou 
when 
I'm 
done 
This 
Frida 
ou 
off? 
Ahh, 
then, 
so 
we 
leave 
in 
the 
night 
or 
day, 
which 
is 
better? 
You 
tell 
me 
7 in 
the 
momin 
? 
Go 
u 
there 
in 
the 
ni 
ht 
a. 
the 
text 
message 
exchange 
between 
the 
4567 
Number 
and 
Fray 
on 
or 
about 
December 
4, 
2023 
resumed 
at approximately 
12:05 
p.m. 
and 
continued 
as 
shown 
below 
through 
approximately 
3:24 
p.m.: 
4 
The 
street 
number 
redacted 
from 
this 
text 
message, 
as 
well 
as 
the 
image 
below, 
is 
the 
same 
street 
number 
as 
the 
Residence, 
which 
is 
on 
South 
Clark 
Street, 
in Newburgh. 
11 

4567 
Number 
Fray's 
Phone 
Okay 
You 
sent 
back 
the 
Amazon 
package? 
Send 
me 
the 
scan 
Nah 
I didn't 
send 
it back 
Okay 
copy 
Imma 
get 
that 
now 
I'm 
going 
to 
deal 
with 
summing 
then 
imma 
forward 
Omw 
back 
to 
Y O 
now 
Link 
me 
when 
u around. 
I'm 
going 
to 
city 
all 
over 
there 
Kopy 
I'm 
in 
the 
post 
office 
b. 
the 
text 
message 
exchange 
between 
the 
4567 
Number 
and 
Fray's 
Phone 
resumed 
at 
approximately 
2:04 
a.m. 
on 
or 
about 
December 
5, 
2023, 
when 
Fray 
sent 
the 
following 
text 
message 
to 
the 
4567 
Number: 
"Home 
in 
bed 
cuz" 
18. 
On 
or 
about 
January 
18, 
2024, 
I conducted 
a search 
for 
the 
Residence 
address 
using 
the 
same 
maps 
the 
service 
provider 
identified 
in 
the 
text 
message 
exchange 
above 
and 
reviewed 
the 
street 
view 
of 
the 
Residence 
available 
(the 
"Maps 
Street 
View"). 
In 
the 
Maps 
Street 
View 
for 
the 
Residence, 
which 
is 
excerpted 
below, 
a vehicle 
that 
appears 
to 
be 
a black 
BMW 
is 
visible 
parked 
across 
the 
street 
from 
the 
Residence 
(the 
"BMW 
Vehicle"). 
[ 
Continued 
on 
the 
next 
page] 
12 

Exce,pted 
Screens 
hot 
of 
Maps 
Street 
View 
for 
Area 
Near 
the 
Residence 
Image 
Captured 
in 
August 
of 
2023 
Screenshot 
Captured 
on 
January 
19, 
2024 
at 
approximately 
11
:30 
a.m. 
19. 
The 
BMW 
Vehicle 
visible 
in 
the 
Maps 
Street 
View 
for 
the 
area 
near 
the 
Residence 
appears 
to 
be 
the 
same 
vehicle 
driven 
by 
Victim-I 
observable 
in 
video 
surveillance 
footage 
near 
the 
Residence 
and 
matches 
the 
description 
ofVictim-1 
's vehicle 
provided 
to 
CNPD 
-  a 
BMW 
-  provided 
by 
a witness 
to 
another 
incident 
involving 
Fray 
and 
Victim-I. 
20. 
Based 
on 
my 
review 
of 
the 
contents 
of 
Fray's 
cellphone, 
I know 
that: 
a. 
the 
4567 
Number 
had 
the 
following 
text 
message 
exchange 
with 
Fray 
on 
or 
about 
December 
6, 
2023 
between 
approximately 
6:34 
a.m
. and 
1 
:45 
p.m.: 
4567 
Number 
-Fray's 
Phone 
f 
One 
voice 
messa~e 
sent, 
unavailable 
l 
Top 
of 
the 
sun 
link 
yuh 
when 
I get 
off 
Cool 
Yo 
u asked 
home 
boy 
if 
he 
could 
take 
care 
of 
the 
herbz 
I'll 
check 
him 
tonight 
but 
my 
dawgz 
in 
queens 
say 
he 
can 
take 
one 
imma 
charge 
him 
18 
but 
if 
he 
takes 
longer 
than 
a week 
22 
Word 
Idk 
bout 
that nigga 
but 
the 
queens 
dawgz 
a 
valid 
flex 
13 

Imma 
link 
my 
next 
dawgz 
see 
if 
he 
can 
help 
me 
out 
You 
got 
nobody 
Eve1ybody 
stopped 
selling 
too 
many 
people 
here 
they 
said 
That's 
why 
I kick 
back 
Lol. 
. I searching 
need 
everything 
to 
be 
gone 
quick 
Lemme see 
what 
I can 
do 
If 
nothing 
we 
leave 
it on 
my 
dogs 
in 
queens 
And 
give 
him 
a low 
number 
Yea 
got 
u 
Imma 
link 
my 
next 
dawgz 
little 
later 
too 
Copy 
Might 
need 
you 
to 
spin 
me 
around 
after 
work 
you 
valid? 
Yeah 
I have 
to 
got 
to 
get 
rid 
of 
them 
Kopy 
b. 
The 
text 
message 
conversation 
between 
the 
4567 
Number 
and 
Fray's 
phone 
resumed 
at approximately 
11: 
10 
p.m. 
on 
or 
about 
December 
6, 
2023 
and 
continued 
until 
approximately 
11 
:24 
p.
m. 
on 
or 
about 
the 
same 
day: 
4567 
Number 
The 
com 
ress 
ones 
dont 
ot 
no 
writin 
s 
And 
the 
two 
other 
shits 
Brio 
14 
Fra 
's Phone 
[ 
One 
video 
sent, 
appears 
to 
be 
a video 
of 
multiple 
vacuum 
sealed 
packages 
of 
marihuana, 
screenshot 
below 
No 

21. 
Based 
on 
my 
training 
and 
experience, 
I understand 
the 
words 
"herbz" 
and 
"gelato" 
to 
be 
references 
to 
marihuana. 
Cellphone 
Location 
Data 
22
. 
Cellsite 
location 
data 
for 
the 
cellphone 
assigned 
the 
4567 
Number 
(the 
"Palmer 
Phone") 
shows 
that 
the 
device 
was 
in 
or 
around 
the 
area 
of 
Mount 
Vernon 
at 
approximately 
9:26 
p.m. 
on 
or 
about 
December 
4, 
2023. 
23. 
The 
same 
data 
shows 
that 
by 
approximately 
9:35 
p.m. 
on 
or 
about 
December 
4, 
2023, 
the 
Palmer 
Phone 
had 
moved 
and 
was 
in 
or 
around 
the 
area 
of 
White 
Plains 
and 
that 
by 
approximately 
10:02 
p.m. 
on 
or 
about  December 
4, 
2023, 
the 
Palmer 
Phone 
had 
reached 
the 
Peekskill 
area. 
24. 
The 
same 
cellsite 
location 
data 
shows 
that 
the 
Palmer 
Phone 
was 
in 
the 
City 
of 
Newburgh 
between 
approximately 
10:30 p
.
m. 
and 
11 
:27 
p.m. 
on 
or 
about 
December 
4, 
2023. 
25. 
The 
Palmer 
Phone 
does 
not 
reappear 
on 
cellsite 
location 
data 
again 
until 
approximately 
5:35 
a.m. 
on 
or 
about 
December 
5, 
2023, 
at which 
point 
it was 
in 
Mount 
Vernon. 
26. 
Based 
on 
my 
training 
and 
experience, 
this 
data 
is 
consistent 
with 
an 
individual 
traveling 
in 
a vehicle 
from 
Mount 
Vernon, 
New 
York 
to 
the 
City 
of 
Newburgh, 
and 
then 
back 
to 
Mount 
Vernon
. 
[ 
Continu
ed on 
the 
next 
page] 
15 

WHEREFORE, 
I respectfully 
request 
that 
a waiTant 
be 
issued 
for 
the 
alTest 
of 
KAHEEM 
PALMER, 
the 
defendant, 
and 
that he 
be 
anested, 
and 
imprisoned 
or 
bailed, 
as 
the 
case 
may 
be. 
Sworn 
to 
me 
through 
the 
transmission 
of 
this 
Complaint 
by 
reliable 
electronic 
means, 
pursuant 
to 
Federal 
Rules 
of 
Criminal 
Procedure 
41(d)(3) 
and 
4.
1, 
this 
:J.:)..n:f 
day 
of 
January, 
2024 
cu 
.. 
r.,_/) 
fl
.
/}) 
e
~
~ 
THE 
HONORABLE 
JUDITH 
c.ccARTHY 
United 
States 
Magistrate 
Judge 
Southern Dish·ict 
of 
New 
York 
16 
Is/ 
rfJo)nt:iS 
t . 
1+na~vn 
hyJcm 
THOMAS 
L. 
ANDERSON 
w_lp(/tr1
;
~s,'r?rJ 
Special 
Agent 
Federal 
Bureau 
of 
Investigation