44444444444444444444444444444444444444444444444444444444444444444444444 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY 44444444444444444444444444444444444444444444444444444444444444444444444 UNITED STATES OF AMERICA v. HUSSEIN ABUALI NASSER ABUALI and RABI AHMED : : : : : CRIMINAL COMPLAINT Mag. No. 01- I, Patrick Glover, the undersigned complainant, being duly sworn, state the following is true and correct to the best of my knowledge and belief. From at least as early as March 13, 2000 through on or about May 16, 2000, in Essex County, in the District of New Jersey and elsewhere, defendants HUSSEIN ABUALI, NASSER ABUALI, and RABI AHMED did: knowingly, willfully and intentionally conspire and agree with each other and others to buy, receive, and have in their possession goods, that is, Kellogg's cereal products having a value in excess of $1,000, which goods were embezzled, stolen, and unlawfully taken and carried away, and which goods were moving as, were part of, and constituted an interstate shipment of freight, express, and other property, that is from Pennsylvania to Vermont, the defendants knowing such goods to have been embezzled and stolen, contrary to Title 18, United States Code, Section 659, in violation of Title 18, United States Code, Section 371. I further state that I am a Special Agent of the Federal Bureau of Investigation, and that this complaint is based on the following facts: SEE ATTACHMENT A continued on the attached page and made a part hereof. __________________________________ Patrick Glover, Special Agent Federal Bureau of Investigation Sworn to before me and subscribed in my presence, September 19, 2001, at Newark, New Jersey ________________________________ HONORABLE STANLEY R. CHESLER UNITED STATES MAGISTRATE JUDGE ATTACHMENT A I, Patrick Glover, a Special Agent with the Federal Bureau of Investigation (FBI), having conducted an investigation and having spoken with other individuals, have knowledge of the following facts: 1. On or about March 13, 2000, a tractor trailer carrying 1062 cases of Kellogg's cereal products valued at approximately $44,497 left the manufacturer in Lancaster, Pennsylvania en route to a whole-sale distributor in Brattleboro, Vermont. On or about March 14, 2000, the trailer containing the merchandise was stolen from a truck warehouse in Parsippany, New Jersey. 2. On or about May 10, 2000, a tractor trailer carrying 1125 cases of Kellogg's cereal products valued at approximately $43,270 left the manufacturer in Breinigsville, Pennsylvania en route to a wholesale distributor in Brattleboro, Vermont. On or about May 11 or May 12, 2000, the trailer containing the merchandise was stolen from a truck warehouse in Parsippany, New Jersey. 3. On or about May 16, 2000, the Federal Bureau of Investigation was informed that individuals were loading stolen cereal products onto a tractor trailer from the Colonnade Coffee Shop located at 25 Clifton Avenue, Newark, New Jersey. Shortly thereafter, federal agents arrived at that location and observed several individuals taking cases of Kellogg's cereal products from a storage room used by the Colonnade Coffee Shop and loading them onto a tractor trailer. Agents identified Hussein Abuali and Rabi Ahmed as individuals who appeared to be supervising those loading the merchandise. Thereafter, Hussein Abuali and Rabi Ahmed voluntarily agreed to speak with federal agents. Prior to the interviews both Hussein Abuali and Rabi Ahmed were told that they were not under arrest and were free to end the questioning at any time. In addition, both individuals were advised of their constitutional rights and signed a waiver of rights form. 4. Hussein Abuali stated, in substance and in part, that Nasser Abuali, the owner of the Colonnade Coffee Shop, was in possession of hundreds of cases of Kellogg's cereal products that Hussein knew to be stolen. Hussein also stated that when he asked Nasser if the cereal was stolen, Nasser told Hussein not "worry about it" and that Nasser "had too much" and had to "get rid of it." Hussein then agreed to purchase ten cases of the stolen cereal from Nasser, and for a fee of $1,500 find Nasser a buyer for the rest of the merchandise. Hussein further stated, in substance and in part, that he arranged for Nasser to sell the rest of the stolen cereal products to Rabi Ahmed. 5. Rabi Ahmed stated, in substance and in part, that he agreed to purchase several hundred cases of Kellogg's cereal products from Nasser Abuali in exchange for $15,000. Rabi Ahmed also stated that he met Nasser Abuali on May 12, 2000 at the Colonnade Coffee Shop at which time Ahmed gave Nasser $15,000 in cash. On or about May 16, 2000, Ahmed rented a tractor trailer and paid several workers to take the merchandise from the Colonnade Coffee Shop and load the boxes onto the truck. Ahmed further stated that he knew "there was something wrong" and that the cereal might be stolen. 6. On May 16, 2000, FBI special agents recovered approximately 956 cases of Kellogg's cereal products from the Colonnade Coffee Shop and from the tractor trailer rented by Rabi Ahmed. Further investigation revealed that this cereal had been stolen on or about May 11 or May 12, 2000 from the truck warehouse in Parsippany, New Jersey as described in paragraph 2 above. 7. In addition, on May 16, 2000, FBI special agents recovered several Kellogg's cereal products from the Colonnade Coffee Shop that were on display for sale. Further investigation revealed this cereal had been stolen on or about March 14, 2000 from the truck warehouse in Parsippany, New Jersey as described in paragraph 1 above.