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AO91(Rev.08/09) CriminalComplaint .
1,the complainantin thiscase,state thatthe following istnle to the bestofm y knowledge and belief.
On oraboutthedatets)of 04/03/2018-03/21/2019 inthecounty of Palm Beach inthe
Southern Districtof Florida ,thedefendantts)violated:
CodeSection OffknseDescrètion
18USC jj 922(d)(1),924(a)(2) Knowing TransferofFirearmsto a Convicted Felon
18USC jj 922(a)(6),924(a)(2) Making False Statements Materialto the Acqui
sition ofa Firearm to a
Federally Licensed Firearms Dealer
W Continuedontheattachedsheet.
j/:
.y'
Complainant'
ssignature
Sara Connors,SpecialAgent,ATF
Printed nameand title
Date: 04/11/2019
J ge'
ssignature
A FFID AV IT
OF
SA R A C O N N O R S
SPE CIA L A G ENT
BUR EA U O F A LC O H O L,TO BA CC O FIR EA R M S A ND EX PLO SIV ES
casexo.19-23s-wM
follow s:
Y ouraffiantis em ployed asa SpecialA gentw ith the Bureau ofA lcohol,Tobacco,
Firearms and Explosives (ATF) and has been so employed since 1999. Your aftiant's
responsibilities include investigating violations of federal law ,including violations of the G tm
possession of firearm s,to include the unlaw ftzlacquisition of firearm s from Federally Licensed
FireannsDealers(FFLs).Asaresultoftrainingandexperience,youraffiantisextremelyfnmiliar
w ith the m anner in m eans in which prohibited persons, to include convicted felons, acquire
fireanus.
M A RY A N N G OLD STEIN . Because this affidavitisbeing subm itted for the lim ited purpose of
obtaining an arrest w arrant, it does not contain a11 the inform ation know n regarding this
m aterial to the acquisition of tirearm s,in violation of Title 18,U nited States Code, Sections
922(d)(1)and922(a)(6).
Case 9:19-mj-08135-WM Document 1 Entered on FLSD Docket 04/11/2019 Page 3 of 17
OnM arch21,2019,officersoftheTequestaPoliceDepartment(TPD)responded
to a residence located at 16 Live O ak Circle in the V illage of Tequesta,Palm Beach County,
m ade entry into the housethrough the side dooron the low erlevel,rem oving ûçA .T.''safely.Based
announcing their police presence,and calling outto the occupants ofthe upper level,A .T.cam e
Upon being taken into custody, ROB ERT G OLD STEIN w as advised of his
M iranda w arnings by TPD OfficerB aldw in from a preprinted fonn,and RO BERT GO LD STEIN
thatthere w ere m any firearm s in the house,secured in tw o safes and other locations around the
house. RO BERT G OLD STEIN advised that the fireanns and the safes belonged to his w ife.
defendantR OBERT G OLD STEIN 'Sarrest. TPD D etective Sergeant M uniz intelwiew ed M A R Y
RO BERT GO LD STEIN w ould be released from custody and she told Sg4.M uniz she w anted all
fireanns and bladed w eapons out of her house. M A RY A N N G O LD STEW . show ed officers
Case 9:19-mj-08135-WM Document 1 Entered on FLSD Docket 04/11/2019 Page 4 of 17
m en's shirts. Located in the tacticalvestin a V elcro strap holster w as a loaded G lock 43 pistol,
two(2)30roundmagazines,andone8roundmagazine.
Consistentw ith herrequestto rem ove al1firearm sfrom herresidence,M A RY AN N
G OLD STEIN show ed Sgt.M uniz where firearm s w ere located in the house. M A RY AN N
AN N G O LD STEIN w as able to locate a key forthe safe. ltw as opened and officers rem oved 7
firearm -related purchases. M A RY AN N GO LD STEIN told Sgt.M uniz that she purchased the
G OLD STEW approached them ,and requested to provide a voluntary statem entata location other
the Tequesta Police D epartm ent w here she voluntarily provided a sw orn recorded statem ent.
According to Sgt. M uniz, M A RY A N N G OLD STEIN told him that R OBERT G O LD STEIN
convinced her to obtain a concealed carry perm it and purchase a (tseecam p'' pistol for her
transfer m oney via his credit card so M A RY A N N G OLD STEIN could purchase firearm s on
Case 9:19-mj-08135-WM Document 1 Entered on FLSD Docket 04/11/2019 Page 5 of 17
gunbroker.com .l GOLD STEIN would clean, handle,and secure the firearm s inside the hom e.
house. M A RY A N N G O LD STEIN further stated thatshe did know offirearm s thatw ere in the
safesin the house,butdid notknow exactly how m any firearm sofw hattypesw ere located w ithin.
8. The follow ing day,M arch 22,2019,A TF SpecialA gentM ark Finnam ore and A TF
Task Force Ofticer (TFO) Casey Goetz conducted a recorded interview with M ARY ANN
G OLD STEIN atherresidence. M A RY A N N G O LD STEIN invited Goetz and Finnam ore into her
Finnam ore that she had done som e research and realized that she w as a çlstraw purchaser''of
firearm s for her husband. M A RY AN N G OLD STEIN stated that she has a Gunbroker account,
and that her husband w ould 1og onto her account, and shop for firearm s. M A RY AI
NN
G OLD STEIN said that once she picked up the fireanns,using her identification,they w ould be
turned overto RO BERT G O LD STEIN . M ARY AN N G OLD STEIN picked up the tirearm sfrom
a gun store which she referred to as ûiflun H o.'' Y our affiantis aw are thatthis gun store,a FFL
dealer,isnow doing business nnm e of ttM ikelwen SA Firearm s''. A ccording to A TF records,this
lY our aftiantisaw arethatG unbrokeris an online brokerage service sim ilarto Ebay for fireanus.
Once a firearm is purchased,how ever,the transfer of the tireann m ustbe com pleted through a
FFL dealer.
4
Case 9:19-mj-08135-WM Document 1 Entered on FLSD Docket 04/11/2019 Page 6 of 17
w ere ever called to the residence,he did notw antto return to prison,and would shootitoutw ith
the police. ln addition,RO BERT G OLD STEIN told herthatifhe w as losing the battle w ith the
police,he w ould barricade him selfupstairs w ith his wife,killher,setthe house on fire,and then
killhim self. ltshould be noted in thisregard thatSA Finnam ore observed a can ofgasoline in the
upstairsofticeoftheresidence.
10. M ARY AN N G OLD STEIN stated that she had her concealed w eapons perm it.
M AR Y AN N G O LD STEIN also stated thatshe purchased one gun forherself,w hich she keptin
hervehicle. M ARY AI
NN GOLDSTEIN provided consentto S/A Film amore and TFO Goetzto
search her vehicle. TFO G oetz searched the vehicle and recovered a Seecnm p,.32 calibersem i-
agents that for several nights, ROBERT GOLDSTEIN had slept with her daughter in her
daughter's bed. M A RY A N N G OLD STEIN stated thatROBERT G OLD STEIN w ould give her
daughterm oney to purchase cocaine and pillsfrom 45th Streetin Riviera Beach.
D uring the interview w ith S/A Finnam ore and TFO Goetz, M A RY AN N
G OLD TEIN referred to purchasing firearm s,saying she ûçw ould do itin her nam e because he
G OLD STEIN told agents thatw hen RO BERT GO LD STEIN gotarrested,he w entto prison
for13 or 14 yearsand thathe wasa convicted felon. M ARY ANN GOLDSTEIN stated that
ROBER T GO LD STEIN told her that he w as arrested for having fireanns w hen he w as not
allow ed,as w ell as som ething involving a ûdm osque''. M A RY AN N G OLD STEW further
Case 9:19-mj-08135-WM Document 1 Entered on FLSD Docket 04/11/2019 Page 7 of 17
stated she had been advised by ROBERT GOLDSTEIN thatlaw enforcem enthad found
som ething in his com puter aboutblow ing up m osques. M A RY AN N G O LD STEIN added
a w eapon--then ithasto go in m y nam e''. M AR Y AINN G OLD STEIN stated ççldon'thave the
m oney for it. H e has the m oney for it because he is a trust fund baby.'' M A RY A N N
(çl hate to say it, it w as a straw purchase.'' S/A Finnam ore then asked M A RY AN N
ANN GOLDSTEFN explained to S/A Finnam ore thata straw purchase is (tlike 1am buying
som ething for som ebody else. lt w as his m oney,but itw as m y license.'' TFO G oetz then
up the firearm s from the FFLS,to w hich M A RY AINN G OLD STEIN stated ûlyeah hew asw ith
nAe.,5
and Task Force Officers w ere presentforthe execution ofthe search warrant.
condition prior to initiation ofthe search. O nce the search began,Tequesta PD Ofticers,assisted
14. There w asa safe in the garage thatw asopened w ith the assistance ofthe Palm Beach
County Sheriff's Office. Inside the safe,agentsrecovered num erousroundsofam m unition. This
nm m tm ition included shotgun shells and rifle am m unition. A gents observed that no tirearm s
6
Case 9:19-mj-08135-WM Document 1 Entered on FLSD Docket 04/11/2019 Page 8 of 17
comm only associated with cham bering those particular calibers/gaugesofam munition had thus
the house had notyet been recovered,notw ithstanding the prior assistance provided by M A RY
A'
NN GOLDSTEIN . Tequesta Police Officers, S/A Gorlzalez, and S/A Finnam ore began
conductingasearchofthemountedwallunit(hereinaflerûtthewallunif')whichheldthetelevision
in theliving room . A gentsand officersnoticed anom aliesin the sidesofthe tm it. U sing a hnm m er
and tools,agents rem oved the w ood paneling from the leftside ofthe w allunit,and discovered a
hollow com partm ent concealed therein, containing fireanns and am m unition w hich has been
secreted inside the com partm ent. U sing fresh gloves,S/A Finnam ore retrieved the w eapons,al1
* PioneerAnus,AK-47 stylepistol,serialnumberPACI119754(nonmmunition in
the cham ber but w as loaded with one extended m agazine containing unknow n
roundsofammtmition)
* Century A rm s, m odel A K-63D S, A K -47 style pistol, serial num ber A K 63D S-
1704881 (no ammunition in the chamber but was loaded with one extended
magazinecontainingurlknownroundsofammunition)
* M ossbergmodel590 12gaugeshotgun,serialnumberV0811315(loadedwithtwo
roundsofnmmunition)
* Black A ces Proseries 12 gauge tacticalshotgun,serialnum ber PS50033A A w hich
was loaded w ith fourrounds of 12 gauge am m unition.
ln addition,inside the w allunit,agentsrecovered the follow ing item sfrom the w all
*
tlnlt.
district of Florida. Your affiant conducted an interview w ith the m anager of Pirate Firearm s,
by herfonnernam eofM ary Ann TEIX EIR A. M C stated thathe M C stated thathe m etRO BERT
seeing ROBERT G O LD STEIN and M AR Y AN N GO LD STEFN athisstore betw een five and ten
tim es. He specitically rem em bered RO BERT G O LD STEIN because on at least one occasion,
A TF Fonn 4473. ln each ofthe form s,M AR Y AN N G OLD STEIN ,a/k/a,M ary Ann TEIXEIRA ,
answered çûyes''to question 111la'' w hich asks tlAre you the actualbuyer ofthe fireann?'' Y our
affiant subm its that defendant M A RY A N N GO LD STEIN 'S answ er to this question was not
truthful,as she then and there wellknew ,because on the basis of M A RY A N N G O LD STEIN 'S
own adm ission,ROBERT GO LD STEIN w as the actualbuyer of the fireanns. Y our affiant is
furthersubm itsthatsaid false statem entw asm aterialto the transferand acquisition ofthe firearm
from the FFL,ashad M A RY A N N G O LD STEIN answ ered tûno''to question 11a,the FFL could
8
Case 9:19-mj-08135-WM Document 1 Entered on FLSD Docket 04/11/2019 Page 10 of 17
consisting ofin-store purchasesfrom Pirate Firearm s's existing store inventory. In addition,M C
noted thatM ARY AN N G OLD STEIN 'S firstinteraction w ith Pirate Fireanns w asw hen she sold
18. M C recalled thatevery single tim e M A RY A N N G O LD STEIN cam e into the store,
she w as accom panied by RO BERT G O LD STEIN . It should be noted that every tim e M C
m entioned the firearm s sales to M A RY A N N G OLD STEIN ,he referred to her as Gûthey.'' M C
m entioned that ROBERT G O LD STEIN handled firearm s in the store and engaged A4C in
G OLD STEIN w as purchasing allthese w eapons. Y our affiant obtained the A TF Form 4473s
2On the basis of her training and experience,your aftiantknow s the term iltransfer,''as used in
this context,to m ean that the firearm w as originally in the possession of an out-of-area person,
m ostcom m only a FFL in another state,purchased by a localcustom er,and shipped from the out-
of-area sellerto Pirate Firearm s,who w ould then require the com pletion and subm ission ofA TF
Fonu 4473, follow ed by a N ational lnstant Check background check and approval of the
transaction by the FloridaDepartm entofLaw Enforcem ent,before com pleting thetransferofthe
tirearm to the localcustomer,who isthiscasewasrepresented to beM ARY A' N N GOLDSTEIN .
9
Case 9:19-mj-08135-WM Document 1 Entered on FLSD Docket 04/11/2019 Page 11 of 17
bereferredto as&% S.''tCKS''stated thatheknew M ARY ANN TEIXEIRA (a!VaM ARY ANN
GOLDSTEIN)andherhusband,ROBERT GOLDSTEIN. K.S.advisedheknew M ARY ANN
G OLD STEIN through herplace ofem ploym entatan autom obile dealership on O keechobee B lvd
occasions and would usually accom pany M A RY A N N G O LD STEIN to the store w hen she w as
picking outthe firearm s,butnotwhen she w ould return to pick them up. K S recalled thatatone
pointTEIXEIR A gother concealed weaponsperm it. K S told your affiant thathe did notknow
thatRO BERT GO LD STEIN w asaconvicted felon. He said he knew thatRO BERT G OLD STEFN
used to be a doctor.
a/k/a,M ARY ANN TEIXEIRA,purchased the follow ing fireanns from M ikelen SA,a/k/a,as
&ûGUN HO,''a federally licensed fireanns dealer,located in Tequesta,Florida and Lake Park,
(101) SalVancasterenobtained4473sandtwoprivatebillsofsaleforthefireannpurchases.ln
each of the 4473's exam ined,M ARY AN N G OLD STEIN answ ered çsyes''to question tt1la''5
which askslkA re you the actualbuyerofthe firearm ?'' Forthe reasonspreviously setforth above,
10
Case 9:19-mj-08135-WM Document 1 Entered on FLSD Docket 04/11/2019 Page 12 of 17
your affiantsubm itsthatanswer was a materially false statem entin thatthe tnze buyerofthe
InvestigatorV ancasteren from t% .S.'' The private sale paperwork indicatesthe follow ing:
11
Case 9:19-mj-08135-WM Document 1 Entered on FLSD Docket 04/11/2019 Page 13 of 17
24. Seventeen of the aforem entioned firearm s w ere recovered at the G O LD STEIN
residencebetw een thedatesofM arch 21,2019 and M arch 22,2019. The seventeen w eaponsw ere
exam ined by A TF Special A gent M ark Finnam ore. S/A Finnam ore is an expert in fireal'
ms
identification and m anufacturing. S/A Finnam ore exam ined the w eapons and determ ined that
sixteen ofthe seventeen weaponshad previously traveled in interstate and/orforeign comm erce.
12
Case 9:19-mj-08135-WM Document 1 Entered on FLSD Docket 04/11/2019 Page 14 of 17
2019,defendantR obertG OLD STEIN w asa convicted felon,having been convicted ofatleastthe
following offenseseach ofwhich w aspunishable by im prisonm entfora tenn exceeding one year:
26. Based on the foregoing,your affiant believes there isprobable cause to existthat
betw een the datesofA pril3,2018 and N ovem ber24,2018,M A RY AN N GO LD STEIN provided
her husband,RO BERT GO LD STEIN ,a person she ltnew had reasonable cause to know w as a
convicted felon,tirearm s,and in doing so,m ade false statem entsm aterialto the acquisition of
Case 9:19-mj-08135-WM Document 1 Entered on FLSD Docket 04/11/2019 Page 15 of 17
fireannsto FFLSon m ultiple A TF Fonn 4473s, a form which isrequired to be keptlby federally
A
A
SA IIA CON N O RS
SPECIA L A G EN T
BU REA U O F ALCOH O L,TOBA CC O,FIREA RM
& EX PLO SIV ES
H ON .W ILLIAM M A T H EW M A N
U NITED STA TES M A ISTM TE JUD GE
14
Case 9:19-mj-08135-WM Document 1 Entered on FLSD Docket 04/11/2019 Page 16 of 17
Count# 1
Knowing TransferofFirearm s to a Convicted Felon
Title 18,United States Code,Sections 922(d)(1),924(a)(2)
Max.Penalty:0-10 years'im prisonment'
,$250,000 fine;0-3years'supervised release'
.
and,a $100.00 specialassessment.
Count# 2
M aking False Statem ents Materialto the Acquisition ofa Firearm to a Federally
Licensed Firearm s Dealer
Title 18,United StatesCode,Sections 922(a)(6),924(a)(2)
Max.Penalty:0-10 years'imprisonment'
,$250,000 fine;0-3 years'supervised release'
.
and,a $100.00 specialassessment.
Case 9:19-mj-08135-WM Document 1 Entered on FLSD Docket 04/11/2019 Page 17 of 17
M ARY A NN GO LD STEIN
D efendant.
/
D id this m atteroriginate from a matter pending in the CentralRegion ofthe United States
Attorney'sOfficepriortoAugust9,20l3(Mag.JudgeAliciaValle)? Yes V No
2. D id this m atter originate from a m atterpending in the Northern Region ofthe United States
Attorney'sOfficepriortoAugust8,2014(Mag.JudgeShaniekM aynard)? Yes V No
BY
J M CM ILLAN
SISTAN T UN ITED STA A TTO RN EY
Florida BarN o. A5500228
500 South A ustralian Avenue,Suite 400
W estPalm Beach,Florida 33401
Tel: (561)-820-8711
Fax: (561)805-9846
Em ail: