ABJEA
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
a x
UNITED STATES OF AMERICA COMPLAINT.
- against - (P. 18, U.S.C, §§ 1951, 924@)(I(AD
and 924(¢)(1)(A)Gi) and 922(g)(1))
JOSHUA STUART,
Defendant. 18-MJ-929
oe eee _x
EASTERN DISTRICT OF NEW YORK, SS:
MICHAEL GILDEA, being duly sworn, deposes and states that he is a Task
Force Officer with the Federal Bureau of Investigation (“FBI”), duly appointed according to
law and acting as such,
yunt One: Hobbs Act Robbery.
On or about October 1, 2018, within the Eastern District of New York, the
defendant JOSHUA STUART did knowingly and intentionally obstruct, delay and affect
commerce and the movement of articles and commodities in commerce, by robbery, to wit:
armed robbery of United States currency from a tobacco store located at 8313 Third Avenue,
Brooklyn, New York.
(Cite 18, United States Code, Section 1951)
Count ‘Two: Brandishing a Firearm in Furtherance of a Crime of Violence
On or about October 1, 2018,
the Eastern District of New York, the
defendant JOSHUA STUART did knowingly and intentionally use and carry one or more
firearms during and in relation to a crime of violence, to wit: a violation of 18 U.S.C. § 1951,and did knowingly and intentionally possess such firearms in furtherance of that crime of
violence, one or more of which firearms were brandished.
(Title 18, United States Code, Sections 924(c)(1)(A)(i) and 924(c)(1)(A)Gi))
in Pos
Count Three: Fel ion
On or about October 1, 2018, within the Eastern District of New York, the
defendant JOSHUA STUART, having been convicted in a court of one or more crimes
punishable by imprisonment for a term exceeding one year, did knowingly and intentionally
possess in and affecting commerce a firearm, to wit: a 9 mm Poland Lucznik P-83 semi-
automatic pistol, and ammunition,
(Title 18, United States Code, Section 922(2)(1))
‘The source of your deponent’s information and the grounds for his belief are as
1. Lama Task Force Officer assigned to the FBI and New York City
Police Department (“NYPD”) Violent Crimes Task Force, and have been involved in the
investigation of numerous cases involving robberies and firearms offenses. The information.
in this Complaint comes from my personal involvement in the investigation, a review of
records of the FBI, NYPD and other government agencies, including video footage recorded
by surveillance cameras, reports of victim interviews and conversations with other law
enforcement officers, Unless specifically indicated, all conversations and statements
described in this affidavit are related in sum and substance and in part only.
' Because the purpose of this Complaint is to set forth only those facts necessary
to establish probable cause to arrest, I have not described all the relevant facts and
circumstances of which I am aware.2 On or about September 28, 2018, at approximately 4:10 a.m., a white
man, later identified as the defendant JOSHUA STUART, robbed at gunpoint the Ellenville
Regional Hospital in Ellenville, New York. According to a hospital employee (hereinafter
“Vietim-1”), the defendant was a white male patient who, after demanding pain medication,
pulled out a firearm out of his personal belongings and fired a round at a Demerol dispenser
‘The defendant STUART then stole approximately 17 vials of Demerol from the hospital.
3, ‘The defendant STUART thereafter fled in a Dodge Ram pickup truck
from the hospital whereupon New York State Department of Environmental Protection Police
encountered the defendant, The defendant STUART dismounted from the truck and engaged
in a firefight with the police officers. Following the firefight, the defendant STUART fled
through the woods on foot.
4, During the defendants” escape, the defendant STUART conducted a
home invasion at $59 Route 55, Ellensville, New York. The defendant STUART stole U.
currency and the keys to a Honda Pilot, New York license plate BVX 2867. In addition, law
‘enforcement later discovered multiple vials of Demerol in the 559 Route $5 home. Based on
LPR hits of the Honda Pilot, law enforcement tracked the defendant STUART to Brooklyn,
New York.
5. Onor about October 1, 2018 at approximately 8:30 a.m., a white man,
later identified as the defendant JOSHUA STUART, entered a tobacco store located at 8313
Third Avenue, Brooklyn, New York, According to the store employee (hereinafter “Vietim-
2"), the defendant was a white male with light facial hair. According to video surveillance,
the defendant was carrying a green bag and wearing a hooded plaid jacket, black shirt, black