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Case 1:16-mj-05845-UA Document 1 Filed 09/13/16 Page 1 of 5

Approved:
HADASSA WAXMAN/DANIELLE R. SASSOO
Assistant United States Attorneys
Before:

THE HONORABLE JAMES L. COTT

Chief United States Magistrate Judge
Southern District of New York
--------------x

SEALED COMPLAINT

UNITED STATES OF AMERICA

- v.

Violations of
18 U.S.C. 1951 and

JUNEAL ALI,
a/k/a "Indian,"

COUNTY OF OFFENSE:
BRONX

Defendant.

- - - - - - - - - - - - - - - - - - x

SOUTHERN DISTRICT OF NEW YORK, ss.:

SETH MASTROPAOLO, being duly sworn, deposes and says
that he is a Special Agent with the Bureau of Alcohol, Tobacco,
Firearms, and Explosives ("ATF"), and charges as follows:
COUNT ONE
(Conspiracy to Commit Hobbs Act Robbery)

1.
Between on or about September 9, 2016, and on or about
September 13, 2016, in the Southern District of New York and
elsewhere, JUNEAL ALI, the defendant, and others known and
unknown, unlawfully and knowingly did combine, conspire,
confederate, and agree with others known and unknown to commit
robbery, as that term is defined in Title 18, United States
Code, Section 1951(b) (1), and would and did thereby attempt to
obstruct, delay, and affect commerce and the movement of
articles and commodities in commerce, as that term is defined in
Title 18, United States Code, Section 1951(b) (3), to wit, ALI
conspired to rob a commercial check cashing establishment in the
Bronx, New York.
(Title 18, United States Code, Section 1951.)

Case 1:16-mj-05845-UA Document 1 Filed 09/13/16 Page 2 of 5

COUNT TWO
(Attempt to Commit Hobbs Act Robbery)

2.
On or about or about September 13, 2016, in the
Southern District of New York and elsewhere, JUNEAL ALI, the
defendant, unlawfully and knowingly did attempt to commit
robbery, as that term is defined in Title 18, United States
Code, Section 1951(b) (1), and would and did thereby obstruct,
delay, and affect commerce and the movement of articles and
commodities in commerce, as that term is defined in Title 18,
United States Code, Section 1951(b) (3), to wit, ALI attempted to
rob a commercial check cashing establishment in the Bronx, New
York.
(Title 18, United States Code, Section 1951 and 2.)
The bases for my knowledge and for the foregoing
charge are, in part, as follows:
3.
I am a Special Agent with the ATF. This affidavit is
based on my personal participation in the investigation of this
matter, including my review of an investigation report prepared
by law enforcement, and conversations with law enforcement
officers and witnesses. 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 the course of my investigation. Where the contents of
documents and 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 participation in this investigation,
including my examination of an investigation report prepared by
law enforcement officers, I have learned, among other things,
that on or about September 12, 2016, an individual ("CC-1")
walked into the 42nd Precinct of the New York City Police
Department in the Bronx, New York, and told law enforcement
officers the following, in substance and in part:
a.
CC-1 was part of a group planning to commit a
commercial robbery at a store that offers financial services
such as money orders and check-cashing, located in the vicinity
of 1998 Bruckner Boulevard in the Bronx, New York ("the Robbery
Location") .

Case 1:16-mj-05845-UA Document 1 Filed 09/13/16 Page 3 of 5

b.
CC-1 was originally contacted by an individual
("CC-2") who put CC-1 in contact with JUNEAL ALI, the defendant,
who was looking for an accomplice to commit a robbery.
c.
CC-1 met with CC-2 and ALI on September 10, 2016,
at about 9:00 p.m. in an apartment on Glebe Avenue in the Bronx,
New York, later identified by law enforcement as CC-2's home
address (the "CC-2 Residence"). At this meeting, CC-1, CC-2,
and ALI planned that on September 11, 2016, the 15-year
anniversary of the September 11th terrorist attacks, CC-1 and
ALI would drive to the Robbery Location dressed in traditional
Muslim attire, display a bomb, and compel the employees at the
Robbery Location to give them cash.
CC-1, CC-2, and ALI
discussed dividing the proceeds. CC-1 then observed what
appeared to be an explosive device made up of what looked like
dynamite sticks tied together with a digital clock. The device
was in ALI's car, which CC-1 described as a white Nissan Maxima
with New York license plates (the "Ali Vehicle").
d.
CC-1 spent the night at the CC-2 Residence and
was picked up the following morning at about 10:00 a.m. on or
about September 11, 2016, by ALI to drive in the Ali Vehicle to
the Robbery Location and commit the planned robbery. Upon
arriving at the Robbery Location, CC-1 stated to ALI, in
substance and in part, that there were too many people around
and that they should postpone the robbery.
CC-1 and ALI then
surveyed the Robbery Location and mapped out potential exit
routes.
e.
CC-1 and ALI decided to postpone the robbery to
the morning of September 13, 2016. ALI agreed to pick up CC-1
the night of September 12, 2016, from his residence (the "CC-1
Residence"), to drive in the Ali Vehicle to the CC-2 Residence,
where they planned to spend the night and then commit the
planned robbery the next morning.
f.
CC-1 then decided instead to walk into the 42nd
precinct on or about September 12, 2016, and report these events
to law enforcement.
5.
As part of my investigation, I have learned from
conversations with other law enforcement officers and my review
of an investigation report prepared by law enforcement, the
following, among other things:
a.
Based on the information provided by CC-1, law
enforcement set up surveillance at the CC-1 Residence to
3

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apprehend JUNEAL ALI, the defendant. At about 1:42 a.m. on

September 13, 2016, a car matching the description of the Ali
Vehicle arrived at the CC-1 Residence.
CC-1 received a text
message from ALI that he had arrived and was waiting in front.
CC-1 provided visual confirmation that ALI was in the awaiting
car, and law enforcement officers executed a stop, removed ALI
from the Ali Vehicle, and, upon searching the car, found in the
trunk what appeared to be an explosive device and an imitation
pistol, as well as dark-colored robes.
Law enforcement officers
determined that what appeared to be an explosive device was
actually made of several sticks of road flares bundled together
with a voltage meter.
6.
On September 13, 2016, after JUNEAL ALI, the
defendant, was arrested, ALI was advised of his Miranda rights
and he agreed to waive them and be interviewed. Based on my
participation in the video-recorded interview, I know that ALI
stated the following, in substance and in part, during the
interview:
a.
On or about September 9, 2016, ALI told CC-2 that
he was strapped for cash.
CC-2 suggested that ALI check out the
Robbery Location as a potential place to rob. CC-2 introduced
ALI to CC-1 as a potential accomplice in the robbery.
b.
On or about September 9, 2016, ALI scoped out the
Robbery Location as a potential robbery target and came up with
the idea to make a fake explosive device to use in carrying out
the robbery, which he constructed shortly thereafter ("the Hoax
Device").
c.
On September 10, 2016, ALI met with CC-2 and CC-1
to discuss the details of carrying out the robbery. ALI showed
CC-2 and CC-1 the Hoax Device.
CC-2 suggested that ALI and CC-1
dress in traditional Muslim attire as a disguise, and after the
meeting ALI procured such attire from his mother for use in the
planned robbery.
d.
ALI claimed that he drove to the CC-1 Residence
on or about September 13, 2016, with the Hoax Device in his
vehicle in order to tell CC-1 that he no longer wanted to commit
the planned robbery.

Case 1:16-mj-05845-UA Document 1 Filed 09/13/16 Page 5 of 5

WHEREFORE, I respectfully request that JUNEAL ALI, the

defendant, be imprisoned or bailed

as the case may be.

Special Agent
Bureau of Alcohol, Tobacco, Firearms,
and Explosives

Sworn
13t

before me this
of September, 2016

MAGISTRATE
DISTRICT OF NEW YORK