STATE GRAND JURY JUDGE - PDF document

1 1 FILED March 30 , 2021 STATE
1 FILED March 30 , 2021 STATE GRAND JURY JUDGE SUPERIOR COURT OF NEW JERSEY LAW DIVISION - CRIMINAL State Grand Jury Number _ SGJ751 - 21 - 19 _________ Superior Court Docket Number STATE OF NEW JERSEY ) INDICTMENT v. ) ROBERT CROSLEY ) MATTHEW ZOBA ) VICTORIA ZIPF ) a nd ) YURI LYUBINSKIY ) The Grand Jurors of and for the State of New Jersey, upon their oaths, present that: COUNT ONE (Conspiracy Second Degree) ROBERT CROSLEY MATTHEW ZOBA VICTORIA ZIPF

2 and YURI LYUBINSKIY who are name
and YURI LYUBINSKIY who are name d as defendants herein, and other persons whose identities are known and unknown to the Grand Jurors, who are named 2 as co - conspirators but not has defendants herein , between on or about March 1 , 2019 , and on or about January 22, 2020 , at the City of Camden , at the Township of Cherry Hill, in the County of Camd en , in the Commonwealth of Pennsylvania, elsewhere, and within the jurisdiction of this Court, with the purpose of promoting or facilitat ing the commission of the crime s of Transporting Weapons i nto the State for Unlawful Sale or Transfer, Unlawful Disposition of Firearms , Unlawful Disposition of Assault Fire

3 arms, Unlawful Disposition of a Sawed -
arms, Unlawful Disposition of a Sawed - Off Shotgun or Rifle, and Unlawful Disposition of Large Capacity Ammunition Magazines, did agree togeth er, and with person s whose identit ies are unknown to the Grand Jurors, who at all times relevant to this indictment w ere an undercover agent of the Drug Enforcement Administration and an agent of the New Jersey State Police, that: 1. One or more of them would engage in conduct which would constitute the aforesaid crime s , or 2. One or more of them would aid in the planning, solicitation or commission of said crimes, that is: A. K nowingly or purposely transport, ship, or otherwise bring into this Sta te any firearm for the

4 purpose of unlawfully selling, transfer
purpose of unlawfully selling, transferring, giving, assigning, or disposing of that firearm to another individual, contrary to N.J.S.A. 2C:39 - 9i . 3 B . Knowingly transpo rt, ship, sell, or dispose of a firearm without being licensed or registered to do so as provided in Chapter 58 , contrary to N.J.S.A. 2C:39 - 9d. C . Knowingly transport, ship, sell, or dispose of an assault firearm, without being registered or licensed to do so pursuant to N.J.S.A. 2C:58 - 1 et . seq ., contrary to N.J.S.A. 2C:39 - 9g. D. K nowingly manufacture, transport, ship, sell, or dispose of a sawed - off shotgun or rifle , contrary to the provisions of N.J.S.A. 2C:39 -

5 9b . E . Knowingly transport, ship,
9b . E . Knowingly transport, ship, sell, or dispose of a large capacity ammunition magazine, contrary to the provisions of N.J.S.A. 2C:39 - 9h. All in violation of N.J.S.A. 2C:5 - 2, and against the peace of this State, the government and dignity of the same. 4 COUNT TWO (Conspiracy – Second Degree) ROBERT CROSLEY MATTHEW ZOBA VICTORIA ZIPF and YURI LYUBINSKIY who are named as defendants herein, and other persons whose identities are known to the Grand Jurors, who are named as co - conspirators but not as defendants herein , between on or about March 1 , 2019, and on or about January 22 , 2020 , at the City of Camden, at the Townsh

6 ip of Cherry Hill, in the County of Cam
ip of Cherry Hill, in the County of Camd en, in the Commonwealth of Pennsylvania, elsewhere, and within the jurisdiction of this Court, with the purpose of promoting or facilitat ing the commission of the crime of Distribution of a Controlled Dangerous Substance, did agree together, and with person s w hose identit ies are unknown to the Grand Jurors, who at all times relevant to this indictment w ere an undercover agent of the Drug Enforcement Administration, and an agent of the New Jersey State Police, that: 1. One or more of them would engage in conduc t which would constitute the aforesaid crime s , or 2. One or more of them would aid in the planning, 5 solicitati

7 on or commission of said crimes, that is
on or commission of said crimes, that is: A. Knowingly or purposely distribute a controlled dangerous substance, that is, methamphetamine , in a quantity of five ounces or more, including any adulterants or dilutants, contrary to the provisions of N.J.S.A. 2C:35 - 5a(1), N.J.S.A. 2C:35 - 5b( 8 ), and N.J.S.A. 2C:35 - 5c. All in violation of N.J.S.A. 2C:5 - 2, and against the peace of this State, the government and dignity of the same. 6 COUNT T HREE (Promoting Organized Street Crime – First Degree) ROBERT CROSLEY between on or about March 1 , 2019, and on or about January 22, 2020, at the City of Camd

8 en, at the Township of Cherry Hill, in
en, at the Township of Cherry Hill, in the County of Camden, in the Commonwealth of Pennsylvania, elsewhere, and within the jurisdiction of this Court, knowingly did conspire with others as an or ganizer, supervisor, financier, or manager , to commit one or more of the crimes enumerated in N.J.S.A. 2C:33 - 30, specifically, Unlawful Possession of a Sawed - Off Shotgun or Rifle , in violation of N.J.S.A. 2C:39 - 3 b ; Possession of Hollow Nose Ammunition , in violation of N.J.S.A. 2C:39 - 3 f ; Possession of Large Capacity Ammunition Magazine s , in violation of N.J.S.A. 2C:39 - 3j ; Unlawful Possession of a Handgun , in violation N.J.S.A. 2C:39 - 5b ; Unlawful Possessi

9 on of a Rifle , in violation N.J.S.A.
on of a Rifle , in violation N.J.S.A. 2C:39 - 5 c(1) ; Unlawful Possession of an Assault Firearm, in violation of N.J.S.A. 2C:39 - 5f ; Manufacture, Transport, Disposition of a Sawed - Off Shotgun or Rifle, in violation of N.J.S.A. 2C:39 - 9b ; Manufacture, Transport, Disposition of a Weapon , in violation of N.J.S.A. 2C:39 - 9d ; Manufacture, Transport, Disposition of an Assault Firearm, in violation of N.J.S.A. 2C:39 - 9g ; Manufacture, Transport, Disposition of Large Capacity Ammunition Magazines, in violation of N.J.S.A. 2C:39 - 9h ; and/or 7 Transporting a Firearm into this State for an Unlawful Sale or Transfer, in violation N.J.S.A. 2C:39 - 9i, co

10 ntrary to the provisions of N.J.S.A.
ntrary to the provisions of N.J.S.A. 2C:33 - 30 , and against the peace of this State, the government and dignity of the same. 8 COUNT FOUR (Promoting Organized Street Crime – First Degree) MATTHEW ZOBA between on or about November 5, 2019, and on or about January 6 , 2020, at the City of Camden, in the County of Camden, in the Commonwealth of Pennsylvania, elsewhere, and within the jurisdiction of this Court, knowingly did conspire with others as an organizer, supervisor, financier, or manager , to commit one or more of the crimes enumerated in N.J.S.A. 2C:33 - 30, specifica lly, Distribution of a Controlled Dangerous Substa

11 nce , in violation of N.J.S.A. 2C:3
nce , in violation of N.J.S.A. 2C:35 - 5, contrary to the provisions of N.J.S.A. 2C:33 - 30 , and against the peace of this State, the government and dignity of the same. 9 COUNT FIVE (Distribution of a Controlled Dangerous Substance - First Degree) ROBERT CROSLEY between on or about March 1 , 2019 , and on or about December 17, 2019 , at the City of Camden , at the Township of Cherry Hill, in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly or purposely did distribute a controlled dangerous substance, that is, methamphetamine , in a quantity of five ounces or more, including any adulterants or dilutants

12 , contrary to the provisions of N.J.S.
, contrary to the provisions of N.J.S.A. 2C:35 - 5a(1), N.J.S.A. 2C:35 - 5b( 8 ), N.J.S.A. 2C:35 - 5(c), N.J.S.A. 2C:2 - 6, and against the peace of this State, the government and dignity of the same. 10 COUNT SIX (Distribution of a Controlled Dangerous Subs tance - First Degree) MATTHEW ZOBA between on or about November 5, 2019, and on or about January 6, 2020, at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly or purposely did distribute a control led dangerous substance, that is, methamphetamine , in a quantity of five ounces or more, including any adulterants or dilutants, contra

13 ry to the provisions of N.J.S.A. 2C:3
ry to the provisions of N.J.S.A. 2C:35 - 5a(1), N.J.S.A. 2C:35 - 5b( 8 ), N.J.S.A. 2C:35 - 5(c), N.J.S.A. 2C:2 - 6, and against the peace of this State, the government and dignity of the same. 11 COUNT S EVEN ( Transporting Weapons into the State for Unlawful Sale or Transfer – Second Degree) ROBERT CROSLEY MATTHEW ZOBA VICTORIA ZIPF and YURI LYUBINSKIY between on or about March 1 , 2019, and on or about January 22 , 2020 , at the City of Camden, at the Township of Cherry Hill, in the County of Camd en, in the Commonwealth of Pennsylvania, elsewhere, and within the jurisdiction of this Court, knowingly or purposely did trans

14 port, ship, or otherwise bring into this
port, ship, or otherwise bring into this State any firearm for the purpose of unlawfully selling, transferring, giving, assigning, or disposing of that firearm to another individual, contrary to N.J.S.A. 2C:39 - 9i, N.J.S.A. 2C:2 - 6, and against the peace of this State, the government and dignity of the same. 12 COUNT EIGHT (Unlawful Possession of a Rifle - Third Degree) ROBERT CROSLEY and YURI LYUBINSKIY on or about March 1, 2019 , at the Township of Cherry Hill, in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did possess a firearm , that is , a .223 Remington caliber Olympic Arms M.F.R. semi - automatic r

15 ifle, serial nu mber JS00902 ; and/
ifle, serial nu mber JS00902 ; and/ or a .223 Remington caliber Eagle Arms Eagle - 15 semi - automatic rifle, serial number M22 - 37736, without having first obtained a firearms purchaser identification card in accordance with the provisions of N.J.S.A. 2C:58 - 3 , contrary to the provisions of N.J.S.A. 2C:39 - 5 c(1) , N.J.S.A. 2C:2 - 6 , and against the peace of this State, the government and dignity of the same. 13 COUNT NINE (Unlawful Possession of Large Capacity Ammunition Magazine s - Fourth Degree) ROBERT CROSLEY and YURI LYUBINSKIY on or about March 1, 2019 , at the Township of Cherry Hill, in the County of Camden,

16 elsewhere, and within the jurisdiction
elsewhere, and within the jurisdiction of this Court, knowingly did possess two large capacity ammunition magazine s , contrary to the provisions of N.J.S.A. 2C:39 - 3j , N.J.S.A. 2C:2 - 6 , and against the peace of this State, the government and dignity of the same. 14 COUNT TEN ( Manufacture, Transport, Disposition of a Rifle – Fourth Degree) ROBERT CROSLEY and YURI LYUBINSKIY on or about March 1, 2019 , at the Township of Cherry Hill, in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did transport, ship, sell, or dispose of a firearm , that is, a .223 Remington caliber Olympic Arms M.F

17 .R. semi - automatic rifle, serial nu
.R. semi - automatic rifle, serial number JS00902 ; and /or a .223 Remington caliber Eagle Arms Eagle - 15 semi - automatic rifle, serial number M22 - 37736, without being licensed or registered to do so as provided in Chapter 58 , contrary to the provisions of N.J.S.A. 2C:39 - 9d , N.J.S.A. 2C: 2 - 6, and against the peace of this State, the government and dignity of the same. 15 COUNT ELEVEN ( Manufacture, Transport, Disposition of Large Capacity Ammunition Magazine s - Fourth Degree) ROBERT CROSLEY and YURI LYUBINSKIY on or about March 1, 2019 , at the Township of Cherry Hill, in the County of Camden, elsewhere, and within

18 the jurisdiction of this Court, knowi
the jurisdiction of this Court, knowingly did transport, ship, sell, or dispose of large capacity ammunition magazine s , contrary to the provisions of N.J.S.A. 2C:39 - 9h , N.J.S.A. 2C: 2 - 6, and against the peace of this State, the government and dignity of the same. 16 COUNT TWELVE (Unlawful Possession of an Assault Firearm - Second Degree) ROBERT CROSLEY on or about October 3, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did have in his possession an assault firearm, that is, a 7.62 x 39 mm caliber Century Arms VSKA semi - automatic rifle, serial number

19 SV7009208 , contrary to the provisions o
SV7009208 , contrary to the provisions of N.J.S.A. 2C:39 - 5f, and against the peace of this State, the government and dignity of the same. 17 COUNT T HIRTEEN (Unlawful Possession of a Large Capacity Ammunition Magazine - Fourth Degree) ROBERT CROSLEY on or about October 3, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did possess a large capacity ammunition magazine, contrary to the provisions of N.J.S.A. 2C:39 - 3j , and against the peace of this State, the government and dignity of the same. 18 COUNT FOURTEEN ( Manufact

20 ure, Transport, Disposition o f an As
ure, Transport, Disposition o f an Assault Firearm - Third Degree) ROBERT CROSLEY on or about October 3, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did transport, ship, sell, or dispose of an assault firearm, that is, a 7.62 x 39 mm caliber Century Arms VSKA semi - automatic rifle, serial number SV7009208 , without having been registered or licensed to do so pursuant to N.J.S.A. 2C: 58 - 1 et . seq . , contrary to the provisions of N.J.S.A. 2C:39 - 9g, and against the peace of this State, th e government and dignity of the same. 19 COUNT F

21 IF TEEN Manufacture, Transport, Dispos
IF TEEN Manufacture, Transport, Disposition of a Large Capacity Ammunition Magazine - Fourth Degree) ROBERT CROSLEY on or about October 3, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did transport, ship, sell, or dispose of a large capacity ammunition magazine, contrary to the provisions of N.J.S.A. 2C:39 - 9h , and against the peace of this State, the government and dignity of the same. 20 C OUNT SIX TEEN (Unlawful Possession of an Assault Firearm - Second Degree) ROBERT CROSLEY on or about October 17, 2019 , at the City of Camden , in the County of C

22 amden, elsewhere, and within the jurisdi
amden, elsewhere, and within the jurisdiction of this Court, knowingly did have in his possession an assault firearm, that is, a 5.56 x 45mm caliber Smith & Wesson M&P15 semi - automatic rifle, serial number SM93944 , contrary to the provi sions of N.J.S.A. 2C:39 - 5f, and against the peace of this State, the government and dignity of the same. 21 COUNT S EVEN TEEN (Unlawful Possession of a Weapon - Second Degree) ROBERT CROSLEY on or about October 17, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did possess a certain weapon , that is, a 9mm Luger caliber Jim e nez

23 Arms JA9 semi - automatic pistol , ser
Arms JA9 semi - automatic pistol , serial number 441588 , without first having obtained a permit to ca rry same as provided in N.J.S.A. 2C:58 - 4, contrary to the provisions of N.J.S.A. 2C:39 - 5 b , and against the peace of this State, the government and dignity of the same. 22 COUNT EIGH TEEN (Unlawful Possession of a Large Capacity Ammunition Magazine - Fourth Degree) ROBERT CROSLEY on or about October 17 , 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did possess a large capacity ammunition magazine, contrary to the provisions of N.J.S.A. 2C:39 - 3j , an

24 d against the peace of this State, the
d against the peace of this State, the government and dignity of the same. 23 COUNT NINE TEEN ( Manufacture, Transport, Disposition of an Assault Firearm - Third Degree) ROBERT CROSLEY on or about October 17, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did transport, ship, sell, or dispose of an assault firearm, that is, a 5.56 x 45mm caliber Smith & Wesson M&P15 semi - automatic rifle, serial number SM93944 , without having been registered or licensed to do so pursuant to N.J.S.A. 2C: 58 - 1 et . seq . , contrary to the provisions

25 of N.J.S.A. 2C:39 - 9g, and against
of N.J.S.A. 2C:39 - 9g, and against the peace of this State, the governmen t and dignity of the same. 24 COUNT TWENTY ( Manufacture, Transport, Disposition of a Weapon – Fourth Degree) ROBERT CROSLEY on or about October 17, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did transport, ship, sell, or dispose of a firearm , that is, a 9mm Luger caliber Jim e nez Arms JA9 semi - automatic pistol , serial number 441588 , without being licensed or registered to do so as provided in C hapter 58 , contrary to the provisions of N.J.S.A. 2C:39 - 9d

26 , and against the peace of this State, t
, and against the peace of this State, the government and dignity of the same. 25 COUNT TWENTY - ONE ( Manufacture, Transport, Disposition of a Large Capacity Ammunition Magazine - Fourth Degree) ROBERT CROSLEY on or about October 17, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did transport, ship, sell, or dispose of a large capacity ammunition magazine, contrary to the provisions of N.J.S.A. 2C:39 - 9h , and against the peace of this State, the government and dignity of the same. 26 C OUNT TWENTY - TWO

27 (Unlawful Possession of an Assault Fi
(Unlawful Possession of an Assault Firearm - Second Degree) ROBERT CROSLEY on or about October 24, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did have in his possession an assault firearm, that is, a 7.62 x 39mm caliber Century Arms VSKA semi - automatic rifle, serial number SV7007533 , contrary to the provis ions of N.J.S.A. 2C:39 - 5f, and against the peace of this State, the government and dignity of the same. 27 COUNT TWENTY - T HREE (Unlawful Possession of a Large Capacity Ammunition Magazine - Fourth Degree) ROBERT CROSLEY on or about October 2

28 4, 2019 , at the City of Camden , in th
4, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did possess a large capacity ammunition magazine, contrary to the provisions of N.J.S.A. 2C:39 - 3j , and against the peace of this State, the government and dignity of the same. 28 COUNT TWENTY - FOUR ( Manufacture, Transport, Disposition of an Assault Firearm - Third Degree) ROBERT CROSLEY on or about October 24, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did transport, ship, sell, or dispose of an assault firearm, that is, a 7.62 x

29 39mm caliber Century Arms VSKA semi - a
39mm caliber Century Arms VSKA semi - automatic rifle, serial number SV7007533 , without having been registered or licensed to do so pursuant to N.J.S.A. 2C:58 - 1 et . seq . , contrary to the provisions of N.J.S.A. 2C:39 - 9g, and against the peace of this State, the government and dignity of the same. 29 COUNT TWENTY - F IVE ( Manufacture, Transport, Disposition of a Large Capacity Ammunition Magazine - Fourth Degree) ROBERT CROSLEY on or about October 24, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did manufacture, transport, ship, sell, or dispose of a

30 large capacity ammunition magazine, c
large capacity ammunition magazine, contrary to the provisions of N.J.S.A. 2C:39 - 9h , and against the peace of this State, the government and dignity of the same. 30 COUNT TWENTY - SIX (Unlawful Possession of a Weapon - Second Degree) ROBERT CROSLEY and MATTHEW ZOBA on or about November 5, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did possess a certain weapon , that is, a 9mm Luger caliber Glock model 43 semi - automatic pistol , serial number ACWC016 , without first having obtained a permit to car ry same as provided in N.J.S.A. 2C:58 - 4, contrary t

31 o the provisions of N.J.S.A. 2C:39 -
o the provisions of N.J.S.A. 2C:39 - 5 b , N.J.S.A. 2C:2 - 6 , and against the peace of this State, the government and dignity of the same. 31 COUNT T WENTY - S EVEN ( Manufacture, Transport, Disposition of a Weapon – Fourth Degree) ROBERT CROSLEY and MATTHEW ZOBA on or about November 5, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did transport, ship, sell, or dispose of a firearm , that is, a 9mm Luger caliber Glock model 43 semi - automatic pistol , serial number ACWC016 , without being licensed or registered to do so as provided in C hapter 58 , contr

32 ary to the provisions of N.J.S.A. 2C:
ary to the provisions of N.J.S.A. 2C:39 - 9d , N.J.S.A. 2 - 6, and against the peace of this State, the government and dignity of the same. 32 COUNT TWENTY - EIGHT (Unlawful Possession of a Weapon - Second Degree) ROBERT CROSLEY on or about November 18, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did possess a certain weapon , that is, a .357 M agnum caliber Smith & Wesson revolver, bearing serial number 77K8240 , and/ or a 9mm Luger caliber Smith & Wesson semi - automatic pistol , serial number TAL8669 , without first having obtained a permit to carry same

33 as provided in N.J.S.A. 2C:58 - 4,
as provided in N.J.S.A. 2C:58 - 4, contrary to the provisions of N.J.S.A. 2C:39 - 5 b, and against the peace of this State, the government and dignity of the same. 33 COUNT TWENTY - NINE (Manufacture, Transport, Disposition of a W eapon – Fourth Degree) ROBERT CROSLEY and MATTHEW ZOBA on or about November 18, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did transport, ship, sell, or dispose of a firearm , that is, a .357 Magnum caliber Smith & Wesson revolver, serial number 77K8240 , and /or a 9mm Luger caliber Smith & Wesson semi - automatic pistol ,

34 serial number TAL8669 , without bein
serial number TAL8669 , without being licensed or registered to do so as provided in C hapter 58 , contrary to the provisions of N.J.S.A. 2C:39 - 9d , N.J.S.A. 2C:2 - 6, and against the peace of this State, the government and dignity of the same. 34 COUNT T HIRTY (Unlawful Possession of a Weapon - Second Degree) ROBERT CROSLEY and YURI LYUBINSKIY on or about November 21, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did possess a certain weapon , that is, a .38 S pecial caliber Smith & Wesson revolver, serial number K273433 , without first having obtained a pe

35 rmit to carry a handgu n as provided in
rmit to carry a handgu n as provided in N.J.S.A. 2C:58 - 4, contrary to the provisions of N.J.S.A. 2C:39 - 5 b , N.J.S.A. 2C:2 - 6 , and against the peace of this State, the government and dignity of the same. 35 COUNT THIRTY - ONE (Manufacture, Transport, Disposition of a Weapon – Fourth Degree) ROBERT CROSLEY and YURI LYUBINSKIY on or about November 21, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did transport, ship, sell, or dispose of a firearm , that is, a .38 S pecial caliber Smith & Wesson revolver, serial number K273433 , without being license

36 d or registered to do so as provided i
d or registered to do so as provided in C hapter 58 , contrary to the provisions of N.J.S.A. 2C:39 - 9d , N.J.S.A. 2C: 2 - 6, and against the peace of this State, the government and dignity of the same. 36 COUNT THIRTY - TWO ( Possession of Hollow Nose Ammunition – Fourth Degree) MATTHEW ZOBA on or about December 3, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did possess a prohibited weapon or device, that is, hollow nose ammunition , contrary to the provisions of N.J.S.A. 2C:39 - 3f , and against the peace of this State, the government and dignity of the s

37 ame.
ame. 37 COUNT THIRTY - T HREE (Unlawful Possession of a Weapon - Second Degree) ROBERT CROSLEY on or about December 4, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did possess a certain weapon , that is, a .3 57 Magnum caliber Smith & Wesson revolver, serial number 9K2144 , without first having obtained a permit to carry same as p rovided in N.J.S.A. 2C:58 - 4, contrary to the provisions of N.J.S.A. 2C:39 - 5 b, and against the peace of this State, the government and dignity of the same. 38 COUNT TH

38 IRTY - FOUR (Manufacture, Transport, D
IRTY - FOUR (Manufacture, Transport, Disposition of a Weapon – Fourth Degree) ROBERT CROSLEY on or about December 4, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did transport, ship, sell, or dispose of a firearm , that is, a .3 57 Magnum caliber Smith & Wesson revolver, serial number 9K2144 , without being licensed or registered to do so as provided in C hapter 58 , contrary to the provisions of N.J.S.A. 2C:39 - 9d , and against the peace of this State, the government and dignity of the same. 39 COUNT THIRTY - F IVE (Unlawful Possession

39 of a Weapon - Second Degree) ROB
of a Weapon - Second Degree) ROBERT CROSLEY on or about December 17, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly possess a certain weapon , that is, a 9mm Luger caliber Glock semi - automatic pistol , serial number BHHH030 , without first having obtained a permit to same as provided in N.J.S.A. 2C:58 - 4, contrary to the provisions of N.J.S.A. 2C:39 - 5 b, and against the peace of this State, the government and dignity of the same. 40 COUNT THIRTY - SIX (Unlawful Possession of a Rifle - Third Degree) ROBERT CROSLEY on or about December 17, 2019 ,

40 at the City of Camden , in the County
at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did possess a firearm, that is , a 7.62 x 39mm caliber Yugo slavian semi - automatic rifle, serial number 0 - 00004 , without having first obtained a firearms purchaser identification card in accordance with the provisions of N.J.S.A. 2C:58 - 3 , contrary to the provisions of N.J.S.A. 2C:39 - 5 c(1) , and against the peace of this State, the government and dignity of the same. 41 COUNT THIRTY - S EVEN (Possession of a Sawed - Off Rifle – Third Degree) ROBERT CROSLEY on or about December 17, 2019 , at t

41 he City of Camden , in the County of C
he City of Camden , in the County of Camden , elsewhere, and within the jurisdiction of this Court, knowingly did possess a sawed - off rifle , contrary to the provisions of N.J.S.A. 2C:39 - 3b, and against the peace of this State, the government and dignity of the same. 42 COUNT THIRTY - EIG HT (Unlawful Possession of Large Capacity Ammunition Magazines - Fourth Degree) ROBERT CROSLEY on or about December 17, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did possess two large capacity ammunition magazines, contrary to the provisions of N.J.S.A. 2C:39 - 3j ,

42 and against the peace of this State, t
and against the peace of this State, the government and dignity of the same. 43 COUNT THIRTY - NINE (Manufacture, Transport, Disposition of a Weapon – Fourth Degree) ROBERT CROSLEY on or about December 17, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did transport, ship, sell, or dispose of a firearm , that is , a 9mm Luger caliber Glock semi - automatic pistol , serial number BHHH030 , without being licensed or registered to do so as provided in C hapter 58 , contrary to the provisions of N.J.S.A. 2C:39 - 9d , and against the peace of this State, the

43 government and dignity of the same.
government and dignity of the same. 44 COUNT FORTY ( Manufacture, Transport, Disposition of a Rifle - Fourth Degree) ROBERT CROSLEY on or about December 17, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did transport, ship, sell, or dispose of a firearm, that is, a 7.62 x 39mm caliber Yugoslavian semi - automatic rifle, serial number 0 - 00004, without being licensed or registered to do so as provided in C hapter 58 , contrary to the provisions of N.J.S.A. 2C:39 - 9d , and against the peace of this State, the government and dignity of the same.

44 45 COUNT FORTY - ONE (Manu
45 COUNT FORTY - ONE (Manufacture, Transport, Disposition of a Sawed - Off Rifle – Third Degree) ROBERT CROSLEY on or about December 17, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did transport, ship, sell, or dispose of a sawed - off rifle , that is, a 7.62 x 39mm caliber Yugoslavian semi - automatic rifle, serial number 0 - 00004, contrary to the provisions of N.J.S.A. 2C:39 - 9b, and against the peace of this State, the government and dignity of the same. 46 COUNT FORTY - TWO ( Manufacture, Transport, Disposition of Large Capacity Ammunitio

45 n Magazines - Fourth Degree) RO
n Magazines - Fourth Degree) ROBERT CROSLEY on or about December 17, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did transport, ship, sell, or dispose of two large capacity ammunition magazines, contrary to the provisions of N.J.S.A. 2C:39 - 9h , and against the peace of this State, the government and dignity of the same. 47 COUNT FORTY - T HREE (Unlawful Possession of a Weapon - Second Degree) MATTHEW ZOBA and VICTORIA ZIPF on or about December 18, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court

46 , knowingly did possess a certain weap
, knowingly did possess a certain weapon , that is, a .40 S&W caliber Glock semi - automatic pistol , serial number BELM386 , and/ or a 9mm Luger caliber Smith & Wesson M&P Shield sem i - automatic pistol , serial number JDX6993 , without first having obtained a permit to carry same as provided in N.J.S.A. 2C:58 - 4, contrary to the provisions of N.J.S.A. 2C:39 - 5 b , N.J.S.A. 2C:2 - 6 , and against the peace of this State, the government and dignity of the same. 48 COUNT FORTY - FOUR ( Possession of Hollow Nose Ammunition – Fourth Degree) MATTHEW ZOBA and VICTORIA ZIPF on or about December 18, 2019 , at the City of Camd

47 en , in the County of Camden, elsewhere
en , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did possess a prohibited weapon or device, that is, hollow nose ammunition , contrary to the provisions of N.J.S.A. 2C:39 - 3f, N.J.S.A. 2C:2 - 6 , and against the peace of this State, the government and dignity of the same. 49 COUNT FORTY - F IVE ( Manufacture, Transport, Disposition of a Weapon – Fourth Degree) MATTHEW ZOBA and VICTORIA ZIPF on or about December 18, 2019 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did transport, ship, sell, or dispos

48 e of a firearm , that is, a .40 S&
e of a firearm , that is, a .40 S&W caliber Glock semi - automatic pistol , serial number BELM386 , and /or a 9mm Luger caliber Smith & Wesson M&P Shield semi - automatic pistol , serial number JDX6993 , without being licensed or registered to do so as provided in C hapter 58 , contrary to the provisions of N.J.S.A. 2C:39 - 9d , N.J.S.A. 2C:2 - 6 , and against the peace of this State, the government and dignity of the same. 50 COUNT FORTY - SIX (Unlawful Possession of a Weapon - Second Degree) MATTHEW ZOBA on or about January 6, 2020 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this

49 Court, knowingly did possess a certai
Court, knowingly did possess a certain weapon , that is, a 9mm Luger caliber Ruger EC9S semi - automatic pistol , serial number 456 - 62022 , without first having obtained a permit to carry same as provided in N.J.S.A. 2C:58 - 4, contrary to the provisions of N.J.S.A. 2C:39 - 5 b, and against the peace of this State, the government and dignity of the same. 51 COUNT FORTY - S EVEN (Manufacture, Transport, Disposition of a Weapon – Fourth Degree) MATTHEW ZOBA on or about January 6, 2020 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did transport, ship, sell, or di

50 spose of a firearm , that is, a 9mm
spose of a firearm , that is, a 9mm Luger caliber Ruger EC9S semi - automatic pistol , serial number 456 - 62022 , without being licensed or registered to do so as provided in C hapter 58 , contrary to the provisions of N.J.S.A. 2C:39 - 9d , and against the peace of this State, the government and dignity of the same. 52 COUNT FORTY - EIGHT (Possession of a Controlled Dangerous Substance – Third Degree) ROBERT CROSLEY between on or about March 1, 2019, and on or about January 22, 2020, at the City of Camden, in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly or purposely did possess a controlled dange

51 rous substance, that is, methamphetamin
rous substance, that is, methamphetamine, a Schedule II controlled dangerous substance, contrary to the provisions of N.J.S.A. 2C:35 - 10a(1), and against the peace of this State, the government and dignity of the same. 53 COUNT FORTY - NINE (Possession with the Intent to Distribute a Controlled Dangerous Substance - Second Degree) ROBERT CROSLEY on or about January 22, 2020, at the City of Camden, in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly or purposely did possess with the intent to distribute a controlled dangerous substance, that is, methamphetamine, in a quantity of one - half ounce or more but

52 less than five ounces, including any ad
less than five ounces, including any adulterants or dilutants, contrary to the provisions of N.J.S.A. 2C:35 - 5a(1), N.J.S.A. 2C:35 - 5b(9)(a), and against the peace of this State, the government and dignity of the same. 54 COUNT F IFTY (Possession of a Firearm During the Commission O f Certain Crimes - Second Degree) ROBERT CROSLEY on or about January 22, 2020 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did possess certain weapon s , that is, a .25 Auto caliber F.I.E. Titan semi - automatic pistol, serial number A12657, and a .22 caliber New England Firearms Gardner

53 revolver, serial number NG008637 , wh
revolver, serial number NG008637 , while in the course of committing or attempting to commit a violation of N.J.S.A. 2C:35 - 5, contrary to the provisions of N.J.S.A. 2C:39 - 4.1 , and against the peace of this Sta te, the government and dignity of the same. 55 COUNT FIFTY - ONE (Unlawful Possession of an Assault Firearm - Second Degree) ROBERT CROSLEY on or about January 22, 2020 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did have in his possession an assault firearm, that is, a 5.56 x 45mm caliber Smith & Wesson M&P15 semi - automatic rifle, serial number TM21644 , contrary

54 to the provi sions of N.J.S.A. 2C:39
to the provi sions of N.J.S.A. 2C:39 - 5f, and against the peace of this State, the government and dignity of the same. 56 COUNT FIFTY - TWO (Unlawful Possession of a Weapon - Second Degree) ROBERT CROSLEY on or about January 22, 2020 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did possess a certain weapon , that is, a .25 Auto caliber F.I.E. Titan semi - automatic pistol , serial number A12657 , and/ or a .22 caliber New England Firearms Gardner revolver, serial number NG008637, without first having obtained a permit to carry same as provided in N.J.S.A. 2C:5

55 8 - 4, contrary to the provisions of N
8 - 4, contrary to the provisions of N.J.S.A. 2C:39 - 5 b , and against the peace of this State, the government and dignity of the same. 57 COUNT FIFTY - T HREE (Unlawful Possession of a Shotgun - Third Degree) ROBERT CROSLEY on or about January 22, 2020 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did possess a firearm , that is , a Saiga model 12 12 - gauge semi - automatic shotgun , serial number 14605398 , and/ or a Benelli SuperNova 12 - gauge pump action shotgun , se rial number Z720904Q14 , without having first obtained a firearms purchaser identification card in

56 accordance with the provisions o f N.
accordance with the provisions o f N.J.S.A. 2C:58 - 3 , contrary to the provisions of N.J.S.A. 2C:39 - 5 c(1) , and against the peace of this State, the government and dignity of the same. 58 COUNT FIFTY - FOUR (Unlawful Possession of a Sawed - Off Shotgun – Third Degree) ROBERT CROSLEY on or about January 22, 2020 , at the City of Camden, in the County of Camden , elsewhere, and within the jurisdiction of this Court, knowingly did possess a sawed - off shotgun , contrary to the provisions of N.J.S.A. 2C:39 - 3b, and against the peace of this State, the government and dignity of the same. 59 COUNT

57 FIFTY - F IVE ( Possession of Hollow N
FIFTY - F IVE ( Possession of Hollow Nose Ammunition – Fourth Degree) ROBERT CROSLEY on or about January 22, 2020 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Court, knowingly did possess a prohibited weapon o r device, that is, hollow nose ammunition , contrary to the provisions of N.J.S.A. 2C:39 - 3f , and against the peace of this State, the government and dignity of the same. 60 COUNT FIFTY - SIX (Certain Persons Not to Have Weapons - Second Degree) ROBERT CROSLEY between on or about March 1, 2019 , and on or about January 22, 2020 , at the City of Camden , at the Township

58 of Cherry Hill, in the County of Camde
of Cherry Hill, in the County of Camden, elsewhere, and within the jurisdiction of this Court, having been convicted of the crime of felony Manufacture, Deliver, or Possession with Intent to Manufacture or Deliver a Controlled Substance , in Bucks County, Pennsylvania, on or about March 23, 2010 , under CP - 09 - CR - 0000242 - 2010, did purchase, own, possess or control the following firearm s : a .223 Remington caliber Olympic Arms M.F.R. semi - automatic rifle, serial number JS00902 ; and/ or a .223 Remington caliber Eagle Arms Eagle - 15 semi - automatic rifle, serial number M22 - 37736 ; or a 7.62 x 39 mm caliber Century Arms VSKA semi - automatic rifle, seri

59 al number SV7009208 ; and/ or a 5.5
al number SV7009208 ; and/ or a 5.56 x 45mm caliber Smith & Wesson M&P15 semi - automatic rifle, serial number SM93944 ; and/ or a 9mm Luger caliber Jim e nez Arms JA9 semi - automatic pistol , serial number 441588 ; or a 7.62 x 39mm caliber Century Arms VSKA semi - automatic rifle, serial number SV7007533 ; and/ or a 9mm Luger caliber Glock model 43 semi - automatic pistol , bearing serial number ACWC016 ; and/ or a .357 M agnum caliber Smith & Wesson revolver, bearing serial number 77K8240 ; and/ or a 9mm Luger caliber Smith & Wesson semi - automatic pistol , serial number TAL8669 ; and/ or a .38 S pecial caliber Smith 61 & Wesson revolver, serial

60 number K273433 ; and/ or a .3 57
number K273433 ; and/ or a .3 57 Magnum caliber Smith & Wesson revolver, bearing serial number 9K2144; and/ or a 9mm Luger caliber Glock semi - automatic pistol , serial number BHHH030; and/ or a 7.62 x 39mm caliber Y ugoslavian semi - automatic rifle, serial number 0 - 00004; and/ or a 5.56 x 45mm caliber Smith & Wesson M&P15 semi - automatic rifle, serial number TM21644; and/ or a .25 Auto caliber F.I.E. Titan semi - automatic pistol , bearing serial number A12657; and/ or a .22 caliber New England Firearms Gardner revolver, serial number NG008637; and/or a Saiga model 12 12 - gauge semi - automatic shotgun , serial number 14605398; and/ or a Benelli Su

61 perNova 12 - gauge pump action shotgun ,
perNova 12 - gauge pump action shotgun , serial number Z720904Q14; and/ or Victo r Ejector 12 - gauge single barrel shotgun , bearing no serial number, and assigned identification number NJ191555 - 49, contrary to the provisions of N.J.S.A. 2C:39 - 7 b , and against the peace of this State, the government and dignity of the same. 62 COUNT FIFTY - SEVEN (Certain Persons Not to Have Weapons - Second Degree) MATTHEW ZOBA between on or about November 5, 2019, and on or about January 6, 2020 , at the City of Camden , in the County of Camden, elsewhere, and within the jurisdiction of this Cou rt, having been convicted of the crime of Robbery, in Philadelph

62 ia, Pennsylvania, on or about August 23
ia, Pennsylvania, on or about August 23, 2002, under CP - 51 - CR - 1213212 - 2001, and/or felony Manufacture, Deliver, or Possession with Intent to Manufacture or Deliver a Controlled Substance, i n Delaware County, Pennsylvania, on or about March 17, 2003, under CP - 23 - CR - 0000141 - 2003, and/or felony Manufacture, Deliver, or Possession with Intent to Manufacture or Deliver a Controlled Substance, in Delaware County, Pennsylvania, on or about October 4, 2012, under CP - 23 - CR - 0005472 - 2012, did purchase, own, possess or control the following firearm s : a 9mm Luger caliber Glock model 43 semi - automatic pistol, serial number ACWC016 ; or a .40 S&W caliber Glock semi -

63 automatic pistol , serial number BE
automatic pistol , serial number BELM386; or a 9mm Luger caliber Smith & Wesson M&P Shield semi - automatic pistol , serial number JDX6993 ; or a 9mm Luger caliber Ruger EC9S semi - automatic pistol , serial number 456 - 62022, 63 contrary to the provisions of N.J.S.A. 2C:39 - 7 b , and against the peace of this State, the government and dignity of the same . ____________________________ AAG Veronica Allende Director Divisio n of Criminal Justice A TRUE BILL: _ Forep