Case 1:15-cr-00341-LTS Document 1 Filed 01/29/15 Page 1 of 5

Approved:

Before:

HONORABLE SARAH NETBURN

United States Magistrate Judge
Southern District of New York
x

UNITED STATES OF AMERICA

- v.

Violations of
18 u.s.c. 1951,
9 2 4 ( c ) ( 1 ) and 2 .

JOSE WILLIAMS, and

MICHAEL HEYWOOD,
a/k/a "Michael Heyward,"

COUNTY OF OFFENSE:
NEW YORK

Defendants.
------------------

SOUTHERN DISTRICT OF NEW YORK, ss.:

AYESHA WINSTON, 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

1.
From in or about December 2014, up to and including in
or about January 2015, in the Southern District of New York and
elsewhere, JOSE WILLIAMS and MICHAEL HEYWOOD, a/k/a "Michael
Heyward," the defendants, and others known and unknown,
knowingly did combine, conspire, confederate, and agree together
and with each other to commit robbery, as that term is defined
in Title 18, United States Code, Section 195l(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, WILLIAMS and HEYWOOD, and other individuals, known and
unknown, committed armed robberies of employees at commercial
establishments in and around Manhattan, Queens and Staten
Island, New York.
(Title 18, United States Code, Section 1951.)

Case 1:15-cr-00341-LTS Document 1 Filed 01/29/15 Page 2 of 5

COUNT TWO

2.
From in or about December 2014, up to and including in
or about January 2015, JOSE WILLIAMS and MICHAEL HEYWOOD, a/k/a
"Michael Heyward," the defendants, during and in relation to a
crime of violence for which they may be prosecuted in a court of
the United States, namely, the robbery conspiracy charged in
Count One of this Complaint, knowingly did use and carry a
firearm, and, in furtherance of such crime, did possess
firearms, and did aid and abet the use, carrying, and possession
of firearms, which firearms were brandished.
(Title 18, United States Code, Sections 924 (c) (1) (A) (ii) and
( c ) ( 1 ) ( C) ( i ) , and 2 . )

are,

The bases for my knowledge and for the foregoing charges

in part, as follows:

3.
I am a Special Agent with the ATF, and I have been
involved in the investigation of the above-described offenses.
I am familiar with the facts and circumstances set forth below
based on my review of pertinent documents, and from my
conversations with fellow law enforcement officers.
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.
I have spoken with a New York City Police Department
("NYPD") officer regarding a series of robberies of certain
establishments (the "Establishments") in Manhattan, Queens and
Staten Island, New York, from in or about December 2014, up to
and including in or about January 2015 (the "Robberies").
I
have also reviewed police reports regarding certain of these
Robberies.
I have learned, in substance and in part, the
following:
a.
On or about December 30, 2014, at approximately
11:10 p.m., two males entered and robbed the "Hi-Fi News and
Grocery Store" on Second Avenue in New York, New York (the "HiFi Robbery"). In the course of the Hi-Fi Robbery, one of the
robbers brandished what appeared to be a gun, while another
robber took thousands of dollars from a cash register within the
store.

Case 1:15-cr-00341-LTS Document 1 Filed 01/29/15 Page 3 of 5

b.
On or about December 31, 2014, at approximately
12:18 a.m., two males entered and robbed the "Lexington Avenue
Grocery and Convenience Store" on Lexington Avenue, New York,
New York (the "Lexington Robbery").
In the course of the
Lexington Robbery, one of the robbers brandished what appeared
to be a silver gun, and took from the store, among other things,
thousands of dollars in cash, several MetroCards and two cartons
of cigarettes. During the robbery, another robber positioned
himself at the entrance to the door and appeared to be acting as
a look-out. Both robbers then fled to a waiting car.
c.
On or about December 31, 2014 at approximately
12:45 a.m., two males entered and robbed "Papa Johns" on East
37th Street, New York, New York (the "Papa Johns Robbery").
In
the course of the Papa Johns Robbery, the robber brandished what
appeared to be a gun, while another robber took over a thousand
dollars in cash from the cash register.
d.
On or about December 31, 2014, at approximately
11:53 p.m., two males entered and robbed the Alingan Liquor
Store at Ditmars Boulevard, Astoria, Queens (the "Alingan Liquor
Robbery").
In the course of the Alingan Liquor Robbery, one of
the robbers brandished what appeared to be a gun, ordered a
store employee to lie on the floor, and hit the employee in the
back of the head with the firearm. The robber then demanded the
employee open the cash register, and took from the register
thousands of dollars in cash, while the other robber acted as a
look-out.
e.
On or about January 1, 2015, at approximately
1:31 a.m., two males entered and attempted to rob "Hot Bagels"
on Arthur Kill Road, Staten Island, New York (the "Hot Bagels
Robbery").
In the course of the Hot Bagels Robbery, both
robbers displayed what appeared to be black handguns, and
demanded cash. When the victims refused to comply, one robber
shot one victim in the shoulder, and another victim in the
abdomen. The robbers then fled to a waiting car.
f.
On or about January 12, 2015, at approximately
10:09 p.m., two males entered and robbed the "Subway Sandwich
Shop" on Lexington Avenue, New York, New York (the "Subway
Robbery").
In the course of the Subway Robbery, one of the
robbers brandished what appeared to be a black gun, demanded a
store employee open the cash register, and took from the
register hundreds of dollars in cash.
g.

On or about January 16, 2015, at approximately

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2:18 a.m., two males entered and robbed the "Basal Deli" on
Second Avenue, New York, New York (the "Basal Deli Robbery")
In the course of the Basal Deli Robbery, both robbers brandished
what appeared to be firearms, placed an employee on the ground
and demanded that another employee open the cash register. The
robbers fled from the store with thousands of dollars of cash
and a carton of cigarettes.
5.
On or about January 19, 2015, an NYPD Detective
interviewed an individual who is now cooperating with the
Government in the hopes of obtaining leniency at sentencing
("Cooperating Witness-1" or "CW-1").
CW-1 told the NYPD in
substance and in part:
a.

CW-1 drove the two robbers to each of the

Robberies.
b.
CW-1 waited in the car for the robbers while they
robbed each Establishment. CW-1 was the get-a-way driver.
c.
CW-1 provided law enforcement agents with the
cellular phone numbers of the two robbers, who CW-1 identified
as "Jose Williams" (the "Williams Cellphone") and "Mike" (the
"Heywood Cellphone").
d.
CW-1 identified a photograph of JOSE WILLIAMS,
the defendant, and stated that Williams was one of the robbers
involved in the Robberies described above.
6.
On or about January 26, 2015, I and an NYPD Detective
interviewed CW-1, who told us in substance and in part:
a.
CW-1 identified a photograph of MICHAEL HEYWOOD,
a/k/a "Michael Heyward," the defendant, and stated that HEYWOOD
was one of the robbers involved in the Robberies described
above.
b.
JOSE WILLIAMS, the defendant, contacted CW-1 in
or about December 2014 and asked for CW-l's assistance in the
Robberies described above.
c.
CW-1 drove WILLIAMS and MICHAEL HEYWOOD, a/k/a
"Michael Heyward," the defendant, to each of the Robberies
described above.
d.
CW-1 witnessed WILLIAMS and HEYWOOD put on masks
before entering each of the Establishments they intended to rob.
e.

CW-1 saw that WILLIAM and HEYWOOD were each

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carrying a firearm during each of the Robberies described above.

7.
On or about January 20, 2015, the Honorable Frank Maas
signed an order permitting law enforcement agents to obtain
historical cell site data for the Williams Cellphone and the
Heywood Cellphone. I have spoken with the NYPD Detective who
reviewed that cell site data, and learned the following:
a.
The Heywood Cellphone was in the immediate
vicinity of the Hot Bagels Robbery on the date and time of that
robbery.
b.
The Williams Cellphone was in the immediate
vicinity of the Alingan Liquor Robbery on the date and time of
that robbery.
WHEREFORE, the deponent respectfully requests that JOSE
WILLIAMS and MICHAEL HEYWOOD, a/k/a "Michael Heyward," the
defendants, be arrested, and that he be imprisoned or bailed, as
the case may be.

AYESHA WINSTON
Special Agent
Bureau of Alcohol, Tobacco, Firearms
and Explosives
Sworn to before me this
29th day of January 2015

r~.-

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HONO!\ABLE SARAH N TBURN

Unit~ States Magi trate Judge
Southern District of New York