frederick remon robinson criminal complaint

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Case 4:15-mj-00516 Document 1 Filed in TXSD on 04/21/15 Page 1 of 12

AD 91 (Rev 11111) Criminal Complainl

UNITED STATES DISTRICT COURT for the

UnIted States Courts Southam District of Taxas

FILED

Southern District of Texas APR 2 i 2015

United States of America v.

) ) ) ) ) ) )

David J. Bradley, Clerk of COurt

Case No. FREDERICK REMON ROBINSON, aka Freddie Robinson. aka Frederick Ralphal Robinson. aka

Freddie Demon Robinson, aka Malik H EI-Shabbazz H15-516 M De/endan1(s)

CRIMINAL COMPLAINT

I. the complainant in this case, state that the following is true to the best of my knowledge and belief. On or about the date(s) of April 21. 2015 in the county of Harris

Southern District of Texas , the defendant(s) violated: Code Section

18 United States Code Section 922 (g)(1 )

Offense Description Unlawful Possession of a Firearm by a Felon

This criminal complaint is based on these facts :

See attached Criminal Complaint

til Continued on the attached sheet.

Complainant 's signature

Robert Childress. Special Agent, FBI Printed name and title

Sworn to before me and signed in my presence.

Date: 04/21/2015

City and state: Houston, Texas Printed name and title

in the

,

Case 4:15-mj-00516 Document 1 Filed in TXSD on 04/21/15 Page 2 of 12 .

AFFIDA VIT IN SUPPORT OF CRIMINAL COMPLAINT

I, Robert Childress, your affiant, being duly sworn and deposed, state the following:

1. I am a Special Agent with the Federal Bureau of Investigation and have been so

employed since June 2010. I am currently assigned to the Houston Field Office. I have received

training in the preparation, presentation, and service of criminal complaints and arrest and search

warrants, and have been involved in the investigation of numerous types of offenses against the

United States.

2. The information enumerated in the paragraphs below, furnished in support of this

affidavit, is derived from my own observations, training and experience and upon statements

made by witnesses and other law enforcement officers. Because this affidavit is being submitted

for the limited purpose of establishing probable cause for a criminal complaint and arrest

warrant, the affidavit may not contain every fact known to me during the course of the

investigation.

3. As a result of my training and experience as an FBI Special Agent, your affiant is

familiar with federal criminal laws and knows that it is a violation of Title 18, United States

Code, 922(g)( I) for any person, having been convicted of a felony offense, to possess a firearm

that has traveled in interstate commerce.

PERSON TO BE ARRESTED

4. The person to be arrested is FREDERICK REMON ROBINSON, aka Freddie

Robinson, aka Frederick Ralphal Robinson, aka Freddie Demon Robinson, aka Malik H EI-

Shabbazz (hereinafter referred to as ROBINSON).


PROBABLE CAUSE

A. Robinson is a Prohibited Felon

5. In December of 20 14, the affiant and members of a joint state and federal task

force initiated an investigation into ROBINSON, residing at 310 Brushy Glen Dr., Houston, TX,

77073. The affiant conducted an extensive criminal history and intelligence search relative to

ROBINSON. According to the national criminal history database, ROBINSON has felony

convictions for Possession of a Controlled Substance, August 1991; and Possession with Intent

to Deliver Cocaine, November 1992.

6. As a result of my training and experience as an FBI Special Agent, I am familiar

with Federal criminal laws and know that it is unlawful for any person to violate federal firearms

statutes. As a previously convicted felon, your affiant knows ROBINSON is prohibited from

possessing any fireanns, ammunition, or destructive devices.

B. Robinson Unlawfully Possesses Firearms

1. Social Media and Online Posts

7. ROBINSON utilized various fonns of social media to interact with his followers

and the public at large. Those posts show ROBINSON possessed fireanns. He posted videos

online to Y ouTube, used Twitter to post messages, I and also utilized Facebook,2 to espouse his

views on gun use and ownership.

I YouTube is a video-sharing website that allows users to upload, view, and share videos. Twitter owns and operates a free-access social-networking website. It allows its users to create their own protile pages, which can include a short biography, a photo of themselves, and location information. Twitter also permits users create and read 140-character messages called "Tweets."

2 Facebook owns and operates a free-access social networking website of the same name that can be accessed at http://www.facebook.com. Facebook allows its users to establish accounts with Facebook, and users can then use their accounts to share written news, photographs, videos, and other information with other Facebook users, and sometimes with the general public.

Case 4:15-mj-00516 Document 1 Filed in TXSD on 04/21115 Page 4 of 12

a. Twitter Messages and Promotion of Violence

8. ROBINSON uses Twitter under the usemarne Malik H. EI-Shabbazz. The ATF

assesses that ROBINSON is EI-Shabbazz based on a comparison of a picture associated with El-

Shabbazz's Twitter account and a known picture of ROBINSON. In addition, the email address

[email protected] was used to register for the Twitter account. That email address

is registered to Frederick R. Robinson. Thus, the FBI assesses ROBINSON is El-Shabbazz.

9. On October 10,2014, at approximately 5:40pm ROBINSON posted the following

tweet: "if white people hate ISIS so much, then I like ISIS. the enemy of my enemy is my

friend. #chopthemheadsoff Amerikkka is the Black Man's Foe.,,3

10. On or about the same date ROBINSON posted another tweet: "its not going to

stop; the more it continues, the more brazen it'll become, until they legislate slavery without a

fight from Black people" and "i say, don't hesitate - start shooting in their cars. empty whole

clips. find them at home and fire bomb it. anything., do something."

11. On November 3, 2014, ROBINSON used Twitter to post a picture of a hand gun and

stated "white boy cried to me about his $ woes. i said sell me the pistol. He looked at me and

asked, you a Black Panther?"

12. On November 25, 2014, ROBINSON used Twitter to upload a picture of a dark

colored handgun, bullet, key, and wallet and stated "[w]hen I come home, I place my keys, wallet,

fitbit & heat on the counter. All mandatory articles of the day."

13. On December 3, 2014, ROBINSON posted a tweet, "I say don't hesitate - start

shooting in their cars, empty whole clips, find them at home and firebomb it, anything do

something. "

3 ISIS is likely a reference to the Islamic State of Iraq and alSham also known as the the Islamic State of Iraq and Syria, a designated foreign terrorist organization.

3


b. You Tube Video Locking and Loading a Firearm

14. On December 4,2014, ROBINSON posted a video on YouTube that showed him

retrieving a loaded gun from a black holster, removing the loaded magazine from that weapon,

showing the loaded magazine up close with the hollow-point ammunition facing the camera, then

ROBINSON ejected a roWld from the chamber of the firearm. The round ejected and landed

with a thud on a hard surface. ROBINSON reloaded and holstered the firearm.

15. Following the manipulation of the loaded firearm, ROBINSON said the following

into the video recording device: "get yo shit ready. and if a mutha fuckah fuck with you, put that

mutha fuckin heat in they life. No discussions, no questions, no concerns about the fuckin law. Fuck

the law, the law ain't on yo side, period."

c. Use of the Facebook Account to Post Pictures and Videos of ROBINSON and Firearms

16. ROBINSON used his Facebook AccoWlt to post pictures and a video of firearms

he purportedly owns and uses. The Facebook Account is associated with Malik Heru El-

Shabbaz, a similar alias he uses for his Twitter handle, and has a profile picture (a picture

associated with the profile for the Facebook Account) of ROBINSON.

17. On February 28, 2015, ROBINSON posted a picture to the Facebook Account of

what appears to be the same firearm that he loaded on the December 4, 2014 YouTube video

mentioned above.

18. On March 2, 2015, ROBINSON posted a picture to the Facebook Account of

what appears to be him holstering a firearm accompanied by the following post: "I'm ready for

open carry texas .. . this is how I'm walking around everyday!!"

19. On March 22,2015, ROBINSON posted a picture to the Facebook Account ofa

"tactical vest" that would carry a firearm and ammunition, and this particular tactical vest


contains a firearm in its holster. Accompanying the picture is a ROBINSON post where he

stated the picture was of his "new tactical vest," how it "fits the Big Man like a glove," and how

his "trusty .357 sig fits snug too."

20. On March 25, 2015, ROBINSON posted a picture to the Facebook Account of a

firearm with serial number 224-037420. On that same day, he posted at least two more pictures

to the Facebook Account, one of him wearing a vest and pointing a rifle, and the second one

shows someone holding a pistol, a Heckler and Koch VP9, a German made semi-automatic

pistol. Accompanying this last picture is a post by ROBINSON where he claimed that he is

"[g]oing to range this weekend with my new 'girlfriend', HKVP9 LEO ... " A little over a week

later, ROBINSON posted another picture of what appeared to be the same Heckler and Koch

VP9, this time with a mounted light and laser, accompanied by the following post where

ROBINSON appears to name the Heckler and Koch VP9: "Not to berud~, but this cracker in my

house to do work. (Setup cable) .. he must got Black friends because he trying to talk me up.

Instead oftel1ing him stfu, I pull out "Salaam" .. Cracker stopped trying to conversate ... Hk-

vp9 ... her name is Salaam ( the bringer of peace)."

21. On April 9, 2015, ROBINSON posted a video to the Facebook Account. The

video appeared to show him loading a Heckler & Koch semi-automatic pistol, serial number

224-037420 with live hollow-point ammunition. This appears to be the same firearm in previous

Facebook posts.

22. The video shows that the Heckler & Koch semi-automatic pistol is equipped with

a mounted light and laser. After the magazine is loaded, the video pans to what appeared to be

ROBINSON's chin. The video does not show ROBINSON's face, but it is accompanied by a

written post under the profile picture of ROBINSON using the alias Malik Heru EI-Shabbaz.


That written post claims the video is ROBINSON's "opinion about gun ownership and the use of

justified violence against anyone who would threaten your life."

23. On the video, after ROBINSON loaded the Heckler & Koch semi-automatic

pistol, he stated the following while continuing to prominently show the firearm:

We ah in a society where ah we can chant mantras like black lives matter all day long. But protesting ah against police brutality has no affect on the outcome of the next killing by a black ah white police officer against a black person. Now I'm not saying that this gun that I own legally is to be used for ah a police interaction. What I am saying is this gun is in my possession legally for anybody who wants to threaten my life. My life is more important than the person who is threatening my life. I believe in black people owning a gun. In fact, I believe in black people owning multiple guns. And I believe in people teaching their children how to use a gun, when to use a gun, why to use a gun, how to clean a gun. Take them to the range, take them to Disney World, take them to the range if you take them to Chuckee Cheese, take them to the range. Explain to them, the use, the power of this weapon and learn to respect it. We see too many times people on television ah using this weapon, but what you don't see is the blood. As a result of that, we are desensitized to gun death. And by being desensitized, we don't respect it. We will pick it up, and shoot someone, kill them and after you see the blood it's too late you can't come back from that, but my point is in this case, everybody needs a gun. Because one person has a gun everybody needs one. Until no one has a gun, then we won't need'em. I hate to see read about black people being killed. Unarmed black people being killed by white people and there's no justice. I hate that. I'm fortunate that I never have to deal with the police in a way that urn will come down to this. But, I am a black man. I am big. I am menacing appearing. I am all of those things that the police will say that gave them justification to shoot me. And I am all of those things that the people who read about it will say 'yea' the police officer was justified. I am not going to be an unarmed black man. At all. Neither should you, peace.

2. Surveillance Shows Robinson Possessing Firearms

24. There is further evidence, through surveillance, that ROBINSON possesses

firearms beyond the posting of pictures and videos on social media forums. On February 17,

2015, surveillance was established at 310 Brushy Glen Dr., the residence of ROBINSON. At the

residence, resides ROBINSON, an older female, and a young teenage female. The video footage of

the surveillance shows that a high percentage of the time a black male fitting ROBINSON's

description is seen entering the residence, exiting the residence, and driving a silver Mercedes


parked at the residence. In addition foot and vehicle surveillance has confinned that the driver of

that vehicle is ROBINSON.

25. On February 17,2015, at approximately 6:45pm, a Black male fitting the description

of ROBINSON entered into the rear hatch area ofthe silver 2003 Mercedes SUV, bearing Texas

license plate VDB-774. That male retrieved and held a dark colored pistol shaped object in his left hand. The male matching ROBINSON's description went into the residence after retrieving a bag

from the driver's side back seat.

26. On February 18,2015 at approximately 7:30am, a Black male fitting the description

of ROBINSON exited the residence and entered into the rear hatch area of the silver 2003 Mercedes

SUV, bearing Texas license plate VDB-774. That male deposited a dark colored pistol shaped

object into the rear of the SUV and departed the residence. 27. On this same date, at approximately 7:30pm, a Black male fitting the description of

ROBINSON retrieved a dark colored pistol shaped object from the silver SUV and entered into the residence.

28. On February 20, 2015, at approximately 7:36am, a Black male fitting the description

of ROBINSON exited the residence and entered into the rear hatch area of the silver 2003 Mercedes

SUV, bearing Texas license plate VDB-774. That male retrieved a dark colored pistol shaped

object from his left front pocket area and deposited it into the rear of the SUV and departed the residence.

29. On this same date, at approximately 6:45pm, a Black male fitting the description of

ROBINSON entered into the rear hatch area of the silver 2003 Mercedes SUV, bearing Texas

license plate VDB-774. That male retrieved and held a dark colored pistol shaped object in his hand. The male matching ROBINSON's description went into the residence after retrieving a bag


from the driver's side back seat.

30. On February 21,2015, at approximately 11 :OOam, a Black male fitting the

description of ROBINSON exited the residence and entered into the rear hatch area ofthe silver

2003 Mercedes SUV, bearing Texas license plate VDB-774. That male deposited a dark colored

pistol shaped object into the rear of the SUV and departed the residence. 31. On February 22, 2015, at approximately 3:15pm, a Black male fitting the description

of ROBINSON exited the residence and entered into the silver 2003 Mercedes SUV, bearing Texas

license plate VDB-774. That male carried a dark colored pistol shaped object in his right hand as he entered into the SUV and departed the residence.


of ROBINSON exited the residence and entered into the silver 2003 Mercedes SUV, bearing Texas

license plate VDB-774. That male deposited a dark colored pistol shaped object into the SUV and departed the residence.


ROBINSON entered into the rear seat area of the silver 2003 Mercedes SUV, bearing Texas license

plate VDB-774. That male retrieved and is holding a dark colored pistol shaped object in his hand and went into the residence.


of ROBINSON exited the residence and approached the silver 2003 Mercedes SUV, bearing Texas

license plate VDB-774. The male placed a black pistol shaped item on the roof of the silver SUV.

The male eventually placed the black pistol shaped object into the rear seat area of the SUV. 35. On February 28, 2015, at approximately 8:23am, a Black male fitting the description

of ROBINSON and an unidentified Black male exited the residence and entered into the rear hatch


area of the silver 2003 Mercedes SUV, bearing Texas license plate VDB-774. The male matching

the description of ROBINSON had the pistol shaped object in his left hand and that male deposited a dark colored pistol shaped object into the rear of the SUV and departed the residence.

36. On this same date, at approximately 8:45am, a Black male fitting the description of

ROBINSON exits the rear seat area ofthe silver 2003 Mercedes SUV, bearing Texas license plate

VDB-774. That male retrieved and held ~ dark colored pistol shaped object in his left hand. The male matching ROBINSON's description went into the residence.


ROBINSON exited the rear seat area of the silver 2003 Mercedes SUV, bearing Texas license plate

VDB-774. That male retrieved and held a dark colored pistol shaped object in his left hand. The male matching ROBINSON's description went into the residence.

38. On March 2, 2015, at approximately 7:44am, a Black male fitting the description of

ROBINSON exited the residence and entered into the rear hatch area of the silver 2003 Mercedes

SUV, bearing Texas license plate VDB-774. That male wore a dark colored hip holster on his right

side. He removed the holster that appeared to contain a dark object shaped like a pistol and deposited a dark colored pistol shaped object into the rear of the SUV and departed the residence.

39. On March 4,2015, at approximately 6:25pm, a Black male fitting the description of

ROBINSON entered into the rear hatch area ofthe silver 2003 Mercedes SUV, bearing Texas

license plate VDB-774. That male retrieved a long brown box and a dark long object that resembled the shape and profile ofa rifle from the rear of the SUV, and entered the garage of his

residence.

40. On April 8,2015, at approximately 3:20pm, a Black male fitting the description of

ROBINSON exited the residence and entered into the rear seat area ofthe silver 2003 Mercedes


SUV, bearing Texas license plate VDB-774. He removed a dark object shaped like a pistol and

walked into the garage of the residence.

41. On April 11, 2015, at approximately 9: 13am, a Black male fitting the description of

ROBINSON exited the residence and entered into the rear seat area of the silver 2003 Mercedes

SUV, bearing Texas license plate VDB-774. He placed a dark object shaped like a pistol in that

area inside of the silver SUV.

42. On April 20, 2015, the Honorable Frances H. Stacy signed a search warrant for

ROBINSON's residence and the Mercedes SUV described above.

43. On April 21, 2015, in the morning, your affiant, along with other law

enforcement personnel, conducted a search of ROBINSON's residence and the Mercedes SUV,

and located the following firearms:

(1) Heckler and Koch VP9, 9mm pistol, Serial Number 224-037420, found in the Mercedes SUV; and

(2) Smith & Wesson M&P IS, 223 rifle, Serial Number SR24360, found in the residence.

44. You affiant has consulted with an expert in determining the manufacture and origin

of firearms to establish interstate travel and knows that the firearms seized from ROBINSON's

residence and vehicle were in fact manufactured outside the State of Texas, therefore having

traveled in interstate commerce to arrive in Texas.

45. Based on my experience and the aforementioned facts and observations, your affiant

respectfully submits that there is probable cause to believe that ROBINSON, having been convicted

of a felony offense, is in possession of firearms. The violations occurred within the Southern

Judicial District of Texas.


~

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