United States v. RECALDO FRAY, Southern District of New York (Jan. 24, 2024) — Complaint

AUSAs: Margaret N. Vasu, Jennifer N. Ong 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
v. 
RECALDO FRAY, 
 Defendant. 
 SEALED COMPLAINT 
 Violations of 18 U.S.C. §§ 1951,  
 924(c)(1)(A)(i) and (ii), 1512(b)(1), 
 and (2) 
 COUNTY OF OFFENSE: 
 ORANGE 
SOUTHERN DISTRICT OF NEW YORK, ss.: 
THOMAS L. ANDERSON being duly sworn, deposes and says that he is a Special Agent 
with the Federal Bureau of Investigation (“FBI”), and charges as follows: 
COUNT ONE 
(Hobbs Act Robbery) 
1.On  or  about December 4,  2023,  in  the  Southern  District  of  New  York  and
elsewhere, RECALDO  FRAY,  the  defendant,  knowingly  committed robbery,  as  that  term  is 
defined in Title 18, United States Code, Section 1951(b)(1), and thereby obstructed, delayed, and 
affected 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), and aided and abetted the same, to 
wit, FRAY and another person robbed at gunpoint a home in the vicinity of South Clark Street, 
Newburgh, New York. 
(Title 18, United States Code, Sections 1951 and 2.) 
COUNT TWO 
(Firearms Use, Carrying, and Possession) 
2.On or about December 4, 2023 in the Southern District of New York and elsewhere,
REYCALDO FRAY, the defendant, during and in relation to a crime of violence for which he may 
be prosecuted in a court of the United States, namely, the Hobbs Act robbery charged in Count 
One of this Complaint, knowingly used and carried a firearm, and in furtherance of such crime, 

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possessed a firearm, and aided and abetted the use, carrying, and possession of a firearm, which 
was brandished. 
(Title 18, United States Code, Sections 924(c)(1)(A)(i) and (ii), and 2.) 
COUNT THREE 
(Witness Tampering) 
3.On or about December 16, 2023, in the Southern District of New York and
elsewhere, RECALDO FRAY the defendant, knowingly used intimidation, threatened, or 
corruptly persuaded another person, and attempted to do so, and engaged in misleading conduct 
toward another person with intent to influence, delay, and prevent the testimony of any person in 
an official proceeding, and cause and induce any person to withhold testimony from an official 
proceeding, to wit, on or about December 16, 2023, FRAY approached a victim of the Hobbs 
Act Robbery described in Count One in front of the victim’s home, also the location of the 
robbery, and displayed an item that the victim recognized as his own driver’s license as an 
individual the victim recognized as the other person which whom FRAY committed the Hobbs 
Act Robbery described in Count One attempted to enter the victim’s vehicle, before the victim 
fled. 
(Title 18, United States Code, Sections 1512(b)(1) and 2.) 
The bases for my knowledge and for the foregoing charges are, in part, as follows: 
4.I  am  a  Special  Agent  with  the  FBI,  and  I  have  been  personally  involved  in  the
investigation  of  this  matter.   This  affidavit is  based  in  part  on  my  conversations  with  other law 
enforcement  officers  and  others,  and  my  examination  of  correspondence,  video  surveillance, 
reports,  and  records.    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  my 
investigation.  Where the contents of documents or the actions, statements, and conversations of 

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others  are  reported  herein,  they  are  reported  in  substance  and  in  part,  except  where  otherwise 
indicated.  
5. Based on my review of reports and records in this investigation, sworn statements 
from  the  victims  and  a  witness,  License  Plate Recognition (“LPR”) data, GPS  and  cellphone 
location  records,  and  video  surveillance  footage,  as  well  as my  conversations  with  other  law 
enforcement officers, and my own participation in this investigation, I know that the FBI and the 
City of Newburgh Police Department (“CNPD”) have been investigating the armed robbery of a 
known marijuana-dealing location in the City of Newburgh, New York by RECALDO FRAY, the 
defendant, and at least one co-conspirator, and the attempted witness intimidation of a victim of 
the robbery, also by  FRAY and at least one co-conspirator.   
The Report of the Robbery 
6. In or about the early morning hours of December 5, 2023, two individuals reported 
an armed robbery of a residence on South Clark Street in Newburgh, New York (the “Residence”).
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Victim-1’s Report of the Robbery 
7. One individual, who represented that he lives at, and also sold marijuana out of, the 
Residence (“Victim-1”) was interviewed by CNPD and provided the following information: 
a. He was  sitting  in  the  Residence  when  he heard  a knock  at  the  front  door, 
which he knew had trouble closing and locking.  After going to the door and looking through the 
peep hole, he attempted to move his sofa to block the door.  An individual on the other side of the 
door was able to open the door enough to stick a gun into the crack in the door and prevent it from 
closing.  
b. The individuals on the other side of the door were able to overpower him, 
and three individuals entered the Residence: two unknown men (the “Intruders”), both of whom 
 
1
 The Residence is known to law enforcement in Newburgh as a marihuana-dealing location.  

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had guns, and one Hispanic man who Victim-1 recognized as a regular customer of his and who 
Victim-1 understood had come to the Residence to buy marihuana from him (“Victim-2”).   
c.The  Intruders  yelled  not  to  look  at  them  and forced  him  and  Victim-2,  at
gunpoint, into the bedroom and to kneel down facing the bed.  The Intruders then placed fabric 
bags over Victim-1 and Victim-2’s heads and placed handcuffs on Victim-1. 
d.One  of  the  Intruders  stood  over  him  and  Victim-2,  while  the  other  went
through the Residence, taking things. 
e.The Intruders “kept asking where the money was, where the safe was, and
told [him] that they would kill [him].”  Victim-1 told the Intruders that he only had $1,000 in his 
pocket, and they took that money. 
f.At one point, one of the Intruders hit him over the head approximately three
times with a gun.  He also stated that at one point, one of the intruders placed the barrel of a gun 
to the back of his neck and said, “I feel like you are lying to me.”  The Intruder who was holding 
the gun to Victim-1’s neck then moved the gun down his neck, and back, and onto his left thigh. 
g.The Intruders told him “they know who [he is] and are coming back for
[him].” 
h.Before the Intruders left, they removed the fabric bag from his head, duck
taped his mouth, removed the handcuffs to replace them with duct tape, and tied his legs up with 
a belt.  
i.He  instructed  Victim-2  to  call  the  police,  because  the  Intruders  had  taken
his phone. 
j.Victim-1 reported the following items stolen:
(i)A  FedEx  envelope containing  his  birth  certificate,  immigration
paperwork, social security card, and Jamaican passport; 

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(ii) His phone,  a Samsung  Galaxy  6 that  corresponds to  the  cellphone 
number ending in 6229; 
(iii) Approximately ¾ of a pound of marijuana; 
(iv) Approximately   $1,000   in   cash,   representing   the   proceeds   of 
marijuana sales; 
(v) A gold-plated watch;  
(vi) A blue jug filled with quarters; 
(vii) A plastic food container filled with coins; and 
(viii) A gallon bottle filled with coins, worth approximately $2,000. 
k. Victim-1 reported that he only saw one of the Intruders and described him 
as black.  He identified both as men and reported that one was taller than the other and that one 
was  wearing  black  Nike  Air  Max  shoes.  Victim-1  reported  that  he  was  not  familiar  with  the 
Intruders.  
l. Victim-1 also reported that both of the Intruders had guns – that one had a 
small revolver and the other had a black semi-automatic, and that the semi-automatic gun was the 
one used to get into the door of the Residence.  
Victim-2’s Report of the Robbery 
8. Victim-2 was interviewed by CNPD and provided the following information: 
a. He was on the sidewalk in front of the Residence when a light-skinned black 
male grabbed him (“Intruder-1”), and then, after Victim-2 had shaken him off, pointed a gun at 
him and dragged him inside the common hallway of the building in which the Residence is located.   
b. There he saw a darker-skinned black male inside (“Intruder-2” and, together 
with Intruder-1, the “Intruders”), who had two guns. The Intruders instructed Victim-2 to knock 
on the door of the Residence, and when he initially refused, both Intruders pointed guns at Victim-

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2’s head.  Intruder-1 then struck Victim-2 on the neck with the butt of his gun.  Victim-2 fell, and 
Intruder-1 then held Victim-2 in a headlock with the gun pointed at Victim-2’s head.  Intruder-2 
then rang the doorbell and announced “delivery” before beginning to kick down the door to the 
Residence.   
c.Once inside, Intruder-2 pistol-whipped Victim-1 before putting Victim-1 in
handcuffs.    The  Intruders  brough Victim-2,  along  with Victim-1, into  a  dark  room  and  threw 
Victim-2 to the ground.  At this point, Victim-2 observed Victim-1 was knelt over the bed with his 
hands handcuffed behind him.  Intruder-1 had a gun pointed at Victim-2 and repeated “don’t look 
at me.”  The Intruders went through Victim-2’s pockets and took his rent money and his phone.   
d.Victim-2 believed that a notification had popped up on his phone while the
Intruders  were  looking  at  it,  and  that  because  of  his  immigration  status,  his  phone  has  GPS 
tracking.  Victim-2 believed that this upset the Intruders, and Intruder-1 then hit Victim-2 with the 
butt of a gun once again.  At this point, the Intruders placed pillowcases over Victim-2 and Victim-
1’s heads and instructed Victim-2 to kneel beside Victim-1.  
e.The Intruders  then  ransacked  the  Residence  and  continued  to  yell  at  him
and Victim-1 the whole time. 
f.Before the Intruders left, they removed the handcuffs from Victim-1, duct
taped  Victim-1’s hands and mouth  and tied  together Victim-1’s legs with a belt.  The Intruders 
also tied Victim-2’s legs with a belt.   
g.The Intruders told Victim-2 and Victim-1 that they were going to come back
and kill the two of them because both he and Victim-1 had seen their faces. 
h.Victim-2 reported that the Intruders stole $1,600 from him.

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i.Victim-2  further  described  Intruder-1  as  tall  and  stocky,  wearing  a  black
jacket with a black hoodie underneath, black pants, a black beanie, and black Nike shoes.  Victim-
2 estimated that Intruder-1 was in his late twenties.  
j.Victim-2 further described Intruder-2 as tall and skinnier, wearing a black
coat, black hoodie, and black sweatpants and as having a tight, groomed beard.  Victim-2 estimated 
that Intruder-2 was older that Intruder-1, perhaps in his thirties.  
k.Victim-2  stated  that  the  Intruders  spoke  English  and  used  what  he
understood to be Jamaican words at times. 
l.Victim-2  noted  that  Intruder-2  had  two  guns  and Intruder-1  had  one  gun.
He  described  all  three  as  black  guns  and  noted  that  they  appeared  to  him  to  look  like  law 
enforcement weapons.  
The Intimidation of Victim-1 
9.On or about December 16, 2023, Victim-1 returned to a CNPD precinct to report
an incident. 
Victim-1’s Report of the Intimidation Incident 
10.Victim-1 stated that at approximately 11:45 am on or about December 16, 2023, he
was sitting in his car in front of the Residence, when he saw a newer style Acura drive past him, 
do a U-turn, and then drive back towards him before stopping next to his car.  
11.Victim-1 reported that the driver of the Acura rolled down the driver’s side window
halfway,  allowing Victim-1 to observe half of the driver’s face, which Victim-1  described  as  a 
dark-skinned, black male, who wore glasses and had a beard.  The driver of the Acura then held 
up  what Victim-1 recognized as his own driver’s license with  the  photo facing  the  driver  as  he 
looked  at Victim-1  and  instructed Victim-1  to  roll  down  his  window.   Victim-1  was  able  to 
recognize his driver’s license because it is discolored in a particular and identifiable way.  

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12.Victim-1  stated  that  as  he  rolled down  his  window,  another  man,  a  light-skinned
black  man, exited  the  passenger  side  of  the  Acura  and  came  around  to  the  passenger  door  of 
Victim-1’s vehicle, as  both  men,  the  driver  and  the  passenger,  instructed Victim-1  to  open  the 
door.  Victim-1 did not open the door and drove away quickly. 
13.Victim-1 reported that he recognized both men, the driver and the passenger of the
Acura, as the Intruders from the night of the robbery. 
14.Victim-1 reported that as he drove away, he observed the Acura following him and
so he drove towards the CNPD precinct and pulled into the CNPD precinct parking lot. 
15.As Victim-1  was  waiting  in  the  lobby  of  CNPD,  a  construction  worker  (the
“Witness” walked into the precinct and asked Victim-1 if he was being chased by an Acura.  When 
Victim-1  responded  in  the  affirmative,  the  Witness  told Victim-1  that  he  had  gotten  the  license 
plate  of  the  Acura  and  provided  it  to Victim-1  before  walking  away.  The  license  plate  number 
provided was New York State Tag (“NYST”) KJM 7196.   
The Witness’s Report of the Intimidation Incident 
16.The Witness reported that on or about December 16, 2023, at approximately 11:45
am, he was driving his truck when he observed two other vehicles – a BMW and a gray Acura – 
run a red light.   
17.The Witness further reported that he watched as the BMW pulled into the CNPD
parking lot, and the gray Acura made a U-turn and drove away.  As this happened, the Witness 
made note of the license plate of the gray Acura.  The Witness then walked into the CNPD and 
spoke with the driver of the BMW, providing him the license plate number.  
18.The  Witness  confirmed that  the  license  plate  number  that  he  provided  was  KJM
7196. 

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Identification of Recaldo Fray 
Video Footage 
19. Video  footage  from  the  late  evening  hours  of on  or  about December  4,  2023 
collected from surveillance cameras owned by residents near the Residence shows the following: 
a. At  approximately 10:55 pm  on  December  4,  2023, a  male  individual 
(“Suspect-1”) exits a light-colored sedan vehicle (the “Robbery Suspect Vehicle”) parked on the 
southeast  corner  of  South  Clark  Street  and  Renwick  Street.   Suspect-1 walks  east  on  Renwick 
Street out of the camera’s view.  Shortly thereafter, someone who appears to be Suspect-1, crosses 
South Clark Street going east on Renwick Street before again exiting the camera’s view.  
b. Approximately one minute later, someone who appears to be Suspect-1 re-
enters the camera’s frame, walking east on Renwick Street, before turning right on South Clark 
Street and walking down the west side of the street towards the camera’s view. Suspect-1 continues 
walking directly in front of the camera, before walking out of the camera’s view.  
i. On  or  about  January  12,  2024,  the  video  footage  described  in Paragraph 
19b, above, was shown to an individual familiar with RECALDO FRAY, 
the defendant.
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ii. The   individual viewed   the   footage   and   immediately   stated   that   he 
recognized Suspect-1 as RECALDO FRAY.  
c. At  approximately  10:57  pm,  an  individual  who  appears  to  be  Suspect-1 
crosses South Clark Street and enters the Robbery Suspect Vehicle.  
 
2
 The individual described in Paragraphs 19a(i) and (ii) above served as FRAY’s instructor and trainer for a 12-week 
training program that began in April of 2023, prior to FRAY beginning his work with his current employer, 
Westchester County Department of Corrections.  During this 12-week period, the individual observed and interacted 
with FRAY on a near-daily basis.  

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d.At approximately 11:00 pm, the Robbery Suspect Vehicle pulls away from
its parking spot, briefly driving north on South Clark Street before turning right on Renwick Street 
and out of camera view.  
e.At  approximately  11:11  pm,  the  Robbery  Suspect  Vehicle  is  observed
driving  north  on  South  Clark  Street  before  slowly  turning  right  on  Renwick  Street  and  out  of 
camera view.  
20.Video  footage  from  the late  evening  hours  of on  or  about December  4,  2023
collected  from  Newburgh  City  Street  cameras  shows  that  at  approximately  11:11  pm,  a  vehicle 
comes from South Clark Street and makes a right onto Renwick Street before parking on the south 
side of Renwick Street.   
a.This  vehicle  matches  the Robbery  Suspect  Vehicle  observed  as  described
in Paragraph 19 above, and as the video is in color, shows that the vehicle is light gray or silver in 
color.  
21.Based on my training and experience, the behavior described in Paragraphs 19 and
20 above  is  consistent  with  casing  behavior – observation  and  exploration  of  a  location  in 
preparation for and in advance of a burglary or robbery of that location.  
22.Video  footage  from  the  late  evening  hours  of on  or  about December  4,  2023
collected  from  surveillance  cameras  owned  by  residents  near  the  Residence  further  shows  the 
following: 
a.At  approximately  11:15  pm  on  December  4,  2023,  two  individuals  are
observed walking west on Renwick Street before turning right onto South Clark Street and walking 
north on South Clark Street, on the eastern side of the street, headed towards Benkard Avenue.  
b.Shortly thereafter, and from another camera angle, at approximately 11:16
pm, two males, including one male who appears to be Suspect-1 and male individual (“Suspect-

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2”) are observed walking north on the eastern side of South Clark Street, in front of the Residence 
as they pass out of the view of the camera.  
c. At approximately 11:32 pm, an individual who appears to be Suspect-2 is 
seen walking south on the eastern side of South Clark Street, just outside of the Residence, carrying 
a medium sized item in his left hand and a smaller item in his right hand.  
d. At  approximately  11:35  pm,  a  vehicle  that  appears  to  be  the  Robbery 
Suspect Vehicle is observed driving west on Renwick Street before turning right on South Clark 
Street and parking shortly thereafter on the northeast corner of South Clark Street and Renwick 
Street, approximately a half of a block south of the Residence.  An individual exits the driver’s 
side of the vehicle and walks north on the eastern side of South Clark Street.  
e. At approximately 11:46 pm, an individual who appears to be Suspect-2 is 
seen walking south on the eastern side of South Clark Street, just outside of the Residence, carrying 
what appears to be a suitcase in his left hand before loading the item into the trunk of vehicle that 
appears to be the Robbery Suspect Vehicle and is parked on the northeast corner of South Clark 
Street and Renwick Street approximately a half of a block south of the Residence.  Suspect-2 then 
walks  back  toward  the  Residence,  walking  on  the  eastern  side  of  South  Clark  Street. At 
approximately  11:47  pm,  the  individual  who  appears  to  be  Suspect-2 reappears,  again walking 
south on the eastern side of South Clark Street, just outside of the Residence, carrying what appears 
to be a 5-gallon water cooler jug in his right hand, before loading the item into the trunk of the 
Robbery Suspect Vehicle.  The nature of Suspect-2’s gait suggests that the item in his right hand 
is quite heavy, as Suspect-2 is seen holding out his left arm for balance.  Suspect-2 then returns 
towards the residence, walking north on the eastern side of South Clark Street.   
f. At  approximately  11:51  pm,  two  individuals  who  appear  to  be  Suspect-1 
and Suspect-2 are seen walking south on the eastern side of South Clark Street just outside of the 

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Residence.  Suspect-2 appears to be carrying a clear plastic gallon jug.  Suspect-2 loads the item 
in his hand into the trunk of what appears to be the Robbery Suspect Vehicle, before entering the 
passenger side, as Suspect-1 enters the driver’s side of the vehicle.  At approximately 11:52 pm, 
the  Robbery  Suspect  Vehicle  pulls  away,  driving north  on  South  Clark  Street  and  out  of  the 
camera’s view.  
g.At approximately 11:52 pm, another camera angle picks up what appears to
be  the  Robbery  Suspect  Vehicle driving  north  on  South  Clark  Steet  before making  a  left  onto 
Benkard Avenue and out of camera view.  
23.Video  footage  from  the late  evening  hours  of on  or  about December  4,  2023
collected  from  Newburgh  City  Street  cameras  shows that  at  approximately  11:52  pm,  a  vehicle 
comes off of Benkard Avenue and goes south on William Street, where the vehicle appears to stop 
for a red light before making a right, either onto Renwick Street or Bridge Street, and driving out 
of camera view.  
24.Video  footage  from  the  late  evening  hours  of on  or  about December  4,  2023
collected  from  the  local  school  district  shows  a  vehicle  that  appears  to  be  the  Robbery  Suspect 
Vehicle traveling south towards New Windsor at approximately 11:53 pm.  
License Plate Recognition Information & Cellphone Location Data 
25.On  or  about  December  8,  2023,  law  enforcement  showed  stills  from  the  video
described  above  that  showed  the  Suspect  Robbery  Vehicle  to  a  Sales  Manager  at  a  local  Acura 
dealership.    This  individual  confirmed that  the  vehicle  in  the  images  was  indeed  an  Acura,  and 
advised that it was a 2009-2014 Acura TSX.  
26.A check of License Place Recognition (“LPR”) information for the Town of New
Windsor showed only one Acura traveling between 11:53 pm on or about December 4, 2023 and 
12:00  am  on or  about December  5,  2023.   That  vehicle – a  4  door  2009 gray Acura  TSX  with 

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NYST KZP 2935 (the “Acura Sedan”) – passed through a New Windsor LPR on Route 9W south 
towards New Windsor at approximately 11:54 pm on or about December 4, 2023.   
27.According  to  New  York  State  DMV  records,  the  Acura  Sedan  is  registered  to
RECALDO FRAY, the defendant, with a particular date of birth in 1992, at a particular address in 
Mount Vernon, New York (the “Subject Address”).   
28.Based on my review of paperwork submitted by RECALDO FRAY, the defendant,
to his current employer, the Westchester County Department of Corrections, I have learned, among 
other things, that FRAY listed his phone number as one ending in 1320 (the “1320 Number”) and 
listed his prior address as a particular residence on North 6
th
 Avenue in Mount Vernon (the “Prior 
Address”). Based on my review of subscriber records for the cellphone assigned the 1320 Number 
(the “Fray Phone”), I know that it is subscribed to another individual, who I believe is a relative 
of FRAY
3
 at the Prior Address. 
29.Cellsite  location  data for  the Fray  Phone shows  that the  Fray Phone was in  the
Newburgh area at approximately 10:22 pm on or about December 4, 2023. 
30.LPR  data  from  New  Windsor  shows  that  the  Acura  Sedan  was  near  Route  9W
traveling north towards Newburgh at approximately 10:31 pm on or about December 4, 2023.   As 
noted  above,  the  same  data  shows  the  Acura  Sedan  traveling  south  on  Route  9W  towards  New 
Windsor at approximately 11:54 pm on or about December 4, 2023.   
31.LPR data for the Governor Mario Cuomo Bridge (“MCB”) shows that the Acura
Sedan was traveling southbound on the MCB at approximately 12:31 am on or about December 5, 
2023. 
3
 The subscriber is listed as FRAY’s relative on FRAY’s birth certificate, which he submitted to his current 
employer as part of the paperwork discussed in Paragraph 28 above.  

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32.Based  on  my  training  and  experience,  this  data  is consistent with  an  individual
traveling in a vehicle from Mount Vernon, New York to the City of Newburgh, and then back to 
Mouth Vernon.  
33.The  vehicle  with  a  NYST  KJM  7196 – the  license  plate  number  provided  by
Victim-1  and  the  Witness – is  a  2020  Acura  MDX in gray (the “Acura SUV”), which is also 
registered  to RECALDO  FRAY, the  defendant, with  the  same date  of  birth in 1992 and at the 
Subject Address.  
34.Location data for the Fray Phone shows that the device was in the vicinity of the
Subject Address at approximately 10:36 am on or about December 16, 2023.  The same location 
data shows that the Fray Phone was traveling north between approximately 10:57 am and 11:32 
am on or about December 16, 2023.  
35.LPR data from Briarcliff, New York shows that the Acura SUV was traveling north
on Route 9A, near North State Road at approximately 11:13 am on or about December 16, 2023. 
36.Location data for the Fray Phone shows that the device was at or near the Residence
between  approximately  11:41  am and  12:06  pm  on  or  about  December  16,  2023.  The  same 
location data shows that the Fray Phone was traveling south, away from Newburgh between 12:10 
pm and 12:31 pm on or about December 16, 2023.  
37.LPR data for the MCB shows that the Acura SUV was traveling southbound on the
MCB at approximately 12:45 pm on December 16, 2023. 
38.Location data for the Fray Phone shows that the device continued to travel south on
the eastern side of the Hudson River between approximately 12:53 pm and 12:57 pm on or about 
December 16, 2023, before arriving in Yonkers, New York at approximately 1:15 pm on or about 
December 16, 2023.  

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39.LPR data from Yonkers confirms that the Acura SUV had arrived in Yonkers by
approximately 12:58 pm on or about December 16, 2023. 
40.LPR  data  from  Mount  Vernon  shows  that  at approximately  1:37  pm  on or  about
December 16, 2023, the Acura SUV was traveling south on Fleetwood Avenue at Broad Street. 
This location is approximately 0.6 miles from the Current Address.  
41.Based  on  my  training  and  experience,  this  data  is consistent with an  individual
traveling in a vehicle from Mount Vernon, New York to the City of Newburgh, and then back to 
Mouth Vernon.  
WHEREFORE, I respectfully request that a warrant be issued for the arrest of RECALDO 
FRAY, the defendant, and that he be arrested, and imprisoned or bailed, as the case may be. 
/s/ Thomas L. Anderson (signed by VR with permission) 
THOMAS L. ANDERSON 
Special Agent 
Federal Bureau of Investigation  
Sworn to me through the transmission of this  
Complaint by reliable electronic means, pursuant to  
Federal Rules of Criminal Procedure 41(d)(3) and 4.1, 
this ___th day of January, 2024 
___________________________________ 
THE HONORABLE VICTORIA REZNIK 
United States Magistrate Judge 
Southern District of New York 
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