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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA

V.

JYSHUN TROWER,
a/k/a "JD," and

STIVEN ARTURO MARTINEZ NIN,

Defendants.

INDICTMENT

23 Cr.

23 CR1M 673

COUNT ONE
(Unlicensed Firearms Dealing)

The Grand Jury charges:

1. From at least in or about June 5, 2023, through at least in or about September 29,

2023 , in the Southern District of New York and elsewhere, JYSHUN TROWER, the defendant,

not being a licensed importer, licensed manufacturer, or licensed dealer of firearms within the

meaning of Chapter 44, Title 18, United States Code, willfully engaged in the business of dealing

in firearms, and in the course of such business shipped, transported, and received a firearm in

interstate and foreign commerce, and aided and abetted the same, to wit, TROWER illegally sold

firearms in Manhattan, New York.

(Title 18, United States Code, Sections 922(a)(l)(A) and 2.)

COUNT TWO
(Interstate Transportation and Distribution of Firearms)

The Grand Jury further charges:

2. From at least on or about June 5, 2023, through at least in or about September 29,

2023 , in the Southern District of New York and elsewhere, JYSHUN TROWER, the defendant,

not being a licensed importer, licensed manufacturer, licensed dealer, or licensed collector of

'
firearms within the meaning of Chapter 44, Title 18, United States Code, willfully transferred,

sold, traded, gave, transported, and delivered a firearm to another individual, said person not being

a licensed importer, licensed manufacturer, licensed dealer, or licensed collector of firearms within

the meaning of Chapter 44, Title 18, United States Code, and knowing and with reasonable cause

to believe that said person was not then residing in Virginia, the State in which the defendant was

then residing, to wit, TROWER resided in Virginia and traveled to Manhattan, New York, where

he sold firearms.

(Title 18, United States Code, Sections 922(a)(5) and 2.)

COUNT THREE
(Conspiracy to Distribute Narcotics)

The Grand Jury further charges:

3. From at least on or about November 16, 2023 , through on or about December 14,

2023, in the Southern District of New York and elsewhere, JYSHUN TROWER and STIVEN

ARTURO MARTINEZ NIN, the defendants, and others known and unknown, intentionally and

knowingly combined, conspired, confederated, and agreed together and with each other to violate

the narcotics laws of the United States.

4. It was a part and an object of the conspiracy that JYSHUN TROWER and STIVEN

ARTURO MARTINEZ NIN, the defendants, and others known and unknown, would and did

distribute and possess with intent to distribute a controlled substance, in violation of Title 21,

United States Code, Section 841(a)(l).

5. The controlled substance that JYSHUN TROWER and STIVEN ARTURO

MARTINEZ NIN, the defendants, conspired to distribute and possess with intent to distribute was:

(i) 400 grams and more of mixtures and substances containing a detectable amount of fentanyl,

and (ii) 100 grams and more of mixtures and substances containing a detectable amount of para-

2

fluorofentanyl , a fentanyl analogue, m violation of Title 21, United States Code, Section

841 (b )(1 )(A).

(Title 21 , United States Code, Sections 846, 841(a)(l), and 841(b)(l)(A).)

COUNT FOUR
(Firearms Use)

The Grand Jury further charges:

6. On or about December 14, 2023 , in the Southern District of New York and

elsewhere, JYSHUN TROWER, the defendant, during and in relation to a drug trafficking crime

for which he may be prosecuted in a court of the United States, namely, the drug trafficking crime

charged in Count Three of this Indictment, knowingly used and carried a firearm, and in

furtherance of such crime, possessed a firearm, and aided and abetted the use, carrying, and

possession of a firearm.

(Title 18, United States Code, Sections 924( c )(1 )(A)(i) and 2.)

COUNT FIVE
(Attempted Transfer of a Firearm for use in a Felony or Drug Trafficking Crime)

The Grand Jury further charges:

7. On or about December 14, 2023, in the Southern District of New York and

elsewhere, JYSHUN TROWER, the defendant, knowingly transferred a firearm, and attempted to

do the same, knowing and with reasonable cause to believe that the fuearm would be used to

commit a felony and a drug trafficking crime, to wit, JYSHUN TROWER sold and attempted to

sell numerous firearms, including with large capacity magazines, along with fentanyl, to a

purchaser in the Manhattan, New York.

(Title 18, United States Code, Sections 924(h) and 2.)

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FORFEITURE ALLEGATION

8. As a result of committing the offense alleged in Counts One, Two, Four, and Five

of this Indictment, JYSHUN TROWER, the defendant, shall forfeit to the United States, pursuant

to Title 18, United States Code, Section 924( d)(l) and Title 28 United States Code, Section

2461(c), any and all firearms and ammunition involved in or used in or intended to be used in said

offense, including but not limited to:

a. 45 caliber rifle, serial number 4506575

b. 9mm Glock pistol, serial number AZWl 95US

c. 9mm Smith & Wesson pistol, serial number PJN5949

d. 9mm Smith & Wesson pistol, serial number HXJ7545

e. 9mm Taurus pistol, serial number TNI88096

9. As a result of committing the offense alleged in Count Three of this Indictment,

JYSHUN TROWER and STIVEN ARTURO MARTINEZ NIN, the defendant, shall forfeit to the

United States, pursuant to Title 21, United States Code, Section 853, any and all property

constituting, or derived from, any proceeds obtained, directly or indirectly, as a result of said

offense and any and all property used, or intended to be used, in any manner or part, to commit, or

to facilitate the commission of, said offense, including but not limited to a sum of money in United

States currency representing the amount of proceeds traceable to the commission of said offense.

Substitute Assets Provision

10. If any of the above-described forfeitable property, as a result of any act or omission

of the defendant:

a. cannot be located upon the exercise of due diligence;

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b. has been transferred or sold to, or deposited with, a third person;

c. has been placed beyond the jurisdiction of the Court;

d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be subdivided

without difficulty;

it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p) and

Title 28, United States Code, Section 2461(c), to seek forfeiture of any other property of the

defendant up to the value of the above forfeitable property.

F

(Title 18, United States Code, Section 924;
Title 21, United States Code, Section 853; and
Title 28, United States Code, Section 2461.)

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~® LJ'Jlia/Y0._
DAMIAN WILLIAMS
United States Attorney

' 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 

UNITED STATES OF AMERICA 

V. 

JYSHUN TROWER, 
a/k/a "JD," and 

STIVEN ARTURO MARTINEZ NIN, 

Defendants. 

INDICTMENT 

23 Cr. 

23 CR1M 673 

COUNT ONE 
(Unlicensed Firearms Dealing) 

The Grand Jury charges: 

1. From at least in or about June 5, 2023, through at least in or about September 29, 

2023 , in the Southern District of New York and elsewhere, JYSHUN TROWER, the defendant, 

not being a licensed importer, licensed manufacturer, or licensed dealer of firearms within the 

meaning of Chapter 44, Title 18, United States Code, willfully engaged in the business of dealing 

in firearms, and in the course of such business shipped, transported, and received a firearm in 

interstate and foreign commerce, and aided and abetted the same, to wit, TROWER illegally sold 

firearms in Manhattan, New York. 

(Title 18, United States Code, Sections 922(a)(l)(A) and 2.) 

COUNT TWO 
(Interstate Transportation and Distribution of Firearms) 

The Grand Jury further charges: 

2. From at least on or about June 5, 2023, through at least in or about September 29, 

2023 , in the Southern District of New York and elsewhere, JYSHUN TROWER, the defendant, 

not being a licensed importer, licensed manufacturer, licensed dealer, or licensed collector of 

Case 1:23-cr-00673-DLC   Document 7   Filed 12/19/23   Page 1 of 5



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firearms within the meaning of Chapter 44, Title 18, United States Code, willfully transferred, 

sold, traded, gave, transported, and delivered a firearm to another individual, said person not being 

a licensed importer, licensed manufacturer, licensed dealer, or licensed collector of firearms within 

the meaning of Chapter 44, Title 18, United States Code, and knowing and with reasonable cause 

to believe that said person was not then residing in Virginia, the State in which the defendant was 

then residing, to wit, TROWER resided in Virginia and traveled to Manhattan, New York, where 

he sold firearms. 

(Title 18, United States Code, Sections 922(a)(5) and 2.) 

COUNT THREE 
(Conspiracy to Distribute Narcotics) 

The Grand Jury further charges: 

3. From at least on or about November 16, 2023 , through on or about December 14, 

2023, in the Southern District of New York and elsewhere, JYSHUN TROWER and STIVEN 

ARTURO MARTINEZ NIN, the defendants, and others known and unknown, intentionally and 

knowingly combined, conspired, confederated, and agreed together and with each other to violate 

the narcotics laws of the United States. 

4. It was a part and an object of the conspiracy that JYSHUN TROWER and STIVEN 

ARTURO MARTINEZ NIN, the defendants, and others known and unknown, would and did 

distribute and possess with intent to distribute a controlled substance, in violation of Title 21, 

United States Code, Section 841(a)(l). 

5. The controlled substance that JYSHUN TROWER and STIVEN ARTURO 

MARTINEZ NIN, the defendants, conspired to distribute and possess with intent to distribute was: 

(i) 400 grams and more of mixtures and substances containing a detectable amount of fentanyl, 

and (ii) 100 grams and more of mixtures and substances containing a detectable amount of para-

2 

Case 1:23-cr-00673-DLC   Document 7   Filed 12/19/23   Page 2 of 5



fluorofentanyl , a fentanyl analogue, m violation of Title 21, United States Code, Section 

841 (b )(1 )(A). 

(Title 21 , United States Code, Sections 846, 841(a)(l), and 841(b)(l)(A).) 

COUNT FOUR 
(Firearms Use) 

The Grand Jury further charges: 

6. On or about December 14, 2023 , in the Southern District of New York and 

elsewhere, JYSHUN TROWER, the defendant, during and in relation to a drug trafficking crime 

for which he may be prosecuted in a court of the United States, namely, the drug trafficking crime 

charged in Count Three of this Indictment, knowingly used and carried a firearm, and in 

furtherance of such crime, possessed a firearm, and aided and abetted the use, carrying, and 

possession of a firearm. 

(Title 18, United States Code, Sections 924( c )(1 )(A)(i) and 2.) 

COUNT FIVE 
(Attempted Transfer of a Firearm for use in a Felony or Drug Trafficking Crime) 

The Grand Jury further charges: 

7. On or about December 14, 2023, in the Southern District of New York and 

elsewhere, JYSHUN TROWER, the defendant, knowingly transferred a firearm, and attempted to 

do the same, knowing and with reasonable cause to believe that the fuearm would be used to 

commit a felony and a drug trafficking crime, to wit, JYSHUN TROWER sold and attempted to 

sell numerous firearms, including with large capacity magazines, along with fentanyl, to a 

purchaser in the Manhattan, New York. 

(Title 18, United States Code, Sections 924(h) and 2.) 

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FORFEITURE ALLEGATION 

8. As a result of committing the offense alleged in Counts One, Two, Four, and Five 

of this Indictment, JYSHUN TROWER, the defendant, shall forfeit to the United States, pursuant 

to Title 18, United States Code, Section 924( d)(l) and Title 28 United States Code, Section 

2461(c), any and all firearms and ammunition involved in or used in or intended to be used in said 

offense, including but not limited to: 

a. 45 caliber rifle, serial number 4506575 

b. 9mm Glock pistol, serial number AZWl 95US 

c. 9mm Smith & Wesson pistol, serial number PJN5949 

d. 9mm Smith & Wesson pistol, serial number HXJ7545 

e. 9mm Taurus pistol, serial number TNI88096 

9. As a result of committing the offense alleged in Count Three of this Indictment, 

JYSHUN TROWER and STIVEN ARTURO MARTINEZ NIN, the defendant, shall forfeit to the 

United States, pursuant to Title 21, United States Code, Section 853, any and all property 

constituting, or derived from, any proceeds obtained, directly or indirectly, as a result of said 

offense and any and all property used, or intended to be used, in any manner or part, to commit, or 

to facilitate the commission of, said offense, including but not limited to a sum of money in United 

States currency representing the amount of proceeds traceable to the commission of said offense. 

Substitute Assets Provision 

10. If any of the above-described forfeitable property, as a result of any act or omission 

of the defendant: 

a. cannot be located upon the exercise of due diligence; 

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Case 1:23-cr-00673-DLC   Document 7   Filed 12/19/23   Page 4 of 5



b. has been transferred or sold to, or deposited with, a third person; 

c. has been placed beyond the jurisdiction of the Court; 

d. has been substantially diminished in value; or 

e. has been commingled with other property which cannot be subdivided 

without difficulty; 

it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p) and 

Title 28, United States Code, Section 2461(c), to seek forfeiture of any other property of the 

defendant up to the value of the above forfeitable property. 

F 

(Title 18, United States Code, Section 924; 
Title 21, United States Code, Section 853; and 
Title 28, United States Code, Section 2461.) 

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~® LJ'Jlia/Y0._ 
DAMIAN WILLIAMS 
United States Attorney 

Case 1:23-cr-00673-DLC   Document 7   Filed 12/19/23   Page 5 of 5