UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
UNITED STATES OF AMERICA Hon . Joseph A. Dickson
V. Mag. No. 18-6625
JEFFREY GOLDSTEIN CRIMINAL COMPLAINT
I, Maria Una11.ue, being duly sworn, state that the following is true and
correct to the best of my knowledge and belief:
SEE ATTACHMENT A
I further state that I am a Special Agent with the Federal Bureau of
Investigation, and that this complaint is based on the following facts:
continued on the attache: : : . anm
SEE ATTACHMENT B
part hereof.
Special Agent Mana Unanue
Federal Bureau of Investigation
Sworn to before me and subscribed in my presence,
July 30, 2018 at
Date
HONORABLE JOSEPH A. DI CKSON
UNITED STATES MAGISTRATE JUDGE Signature of Judicial Officer
ATTACHMENT A
On or about July 8, 2018, in the special maritime and territorial
jurisdiction of the United States, the defendant
JEFFREY GOLDSTEIN,
intentionally captured an image of a private area of a minor female without her
consent, and knowingly did so under circumstances in which the minor female
had a reasonable expectation of privacy.
In violation of Title 18, United States Code, Section 180 l(a).
ATTACHMENT B
I, Maria Unanue, am a Special Agent with the Federal Bureau of
Investigation. I am fully familiar with the facts set forth herein based on my own
investigation, my conversations with other law enforcement officers, and my
review of reports, documents, and evidence. Where statements of others are
related herein, they are related in substance and part. Because this complaint
is being submitted for a limited purpose, I have not set forth each and every fact
that I know concerning this investigation. Where I assert that an event took
place on a particular date, I am asserting that it took place on or about that date.
1. On or about July 8, 2018, a cruise ship (the "Cruise Ship") embarked
from Bayonne, New Jersey, and began traveling to Bermuda. The defendant
JEFFREY GOLDSTEIN ("GOLDSTEIN"), a 31-year-old Hoboken, New Jersey
resident, was a passenger on the Cruise Ship. That evening, a thirteen-year old
girl ("Victim-1") was standing on the deck of the Cruise Ship, alongside another
minor female. Victim-1 and the other minor female faced outward toward the
water to watch the sun set.
2. Shortly before 8:00 p.m., GOLDSTEIN approached Victim-1.
Without Victim-1 's knowledge or permission, GOLDSTEIN placed his iPhone (the
"iPhone") underneath the skirt of Victim-l's dress. GOLDSTEIN pointed the
iPhone's camera upward toward Victim-l's private area and appeared to take a
photograph of Victim-l's genitalia and buttocks, which were covered by her
undergarments. At the time, Victim-1 felt something touch her leg. GOLDSTEIN
moved to the side of Victim-1 and soon walked away.
3. A nearby adult ("Individual l") observed GOLDSTEIN take a photo
up Victim-l's dress. Cruise Ship personnel subsequently reviewed surveillance
footage of the incident. Surveillance footage confirmed Individual 1 's account.
Using surveillance footage from the Cruise Ship, GOLDSTEIN was identified as
the man in the footage .
4. On or about July 18, 2018, pursuant to a search warrant authorized
by a Magistrate Judge in the District of New Jersey, the FBI downloaded the
contents of the iPhone. A review of the iPhone revealed an image file dated July
8, 2018, which appears to depict Victim-l's private area. Specifically, the image
depicts a private area covered by undergarments and other details matching the
garments worn by Victim-1 on July 8, 2018. The iPhone contained
approximately 42 other image files and one video that appear to depict additional
"up-skirt" images.
