Criminal Cover Sheet and Affidavit in Support of Criminal Complaint — United States v. Charles (Dkt. 1)
Summary
A criminal cover sheet and an affidavit in support of a criminal complaint in United States v. Stevenson Charles, Case No. 1:22-mj-03927, in the U.S. District Court for the Southern District of Florida, Document 1, entered November 15, 2022. In the affidavit, Special Agent Thomas Pavletic of the FBI states that there is probable cause to believe that Charles, on or about October 24, 2022 and November 2, 2022, took a motor vehicle with the intent to cause death and serious bodily harm, in violation of Title 18, United States Code, Section 2119(1). The affidavit also states probable cause for use and carrying of a firearm during and in relation to a crime of violence on those dates, in violation of Sections 924(c)(l)(A)(ii).
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“Criminal Cover Sheet and Affidavit in Support of Criminal Complaint — United States v. Charles (Dkt. 1).”
Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-22-cr-20596-dkt-1-s-d-fla-b23954d78e/
, SHA-256 63b15d465c5fc4db90d7858504de89ca862f359d38a2cb2783a58a3472b496b8.Full text
Case 1:22-cr-20596-PCH Document 1 Entered on FLSD Docket 11/15/2022 Page 1 of 9
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 1:22-mj-03927 Damian
UNITED STATES OF AMERICA
v.
STEVENSON CHARLES,
Defendant.
______________________________/
CRIMINAL COVER SHEET
1. Did this matter originate from a matter pending in the Northern Region of the United States
Attorney=s Office prior to August 9, 2013 (Mag. Judge Alicia O. Valle)? Yes X No
2. Did this matter originate from a matter pending in the Central Region of the United States
Attorney=s Office prior to August 8, 2014 (Mag. Judge Shaniek M. Maynard)? Yes X No
3. Did this matter originate from a matter pending in the Central Region of the United States
Attorney=s Office prior to August 8, 2019 (Mag. Judge Jared M. Strauss)? Yes X No
Respectfully submitted,
JUAN ANTONIO GONZALEZ
UNITED STATES ATTORNEY
BY: _____________________________________
Elena Smukler
Assistant United States Attorney
Fla. Bar No. 91025
99 Northeast 4th Street
Miami, FL. 33132-2111
Tel: (305) 961-9444
Elena.Smukler@usdoj.gov
Case 1:22-cr-20596-PCH Document 1 Entered on FLSD Docket 11/15/2022 Page 2 of 9
1:22-mj-03927 Damian
Case 1:22-cr-20596-PCH Document 1 Entered on FLSD Docket 11/15/2022 Page 3 of 9
AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT
Your Affiant, Thomas Pavletic, being duly sworn, deposes and states as follows:
INTRODUCTION AND AGENT BACKGROUND
1. I am a Special Agent with the FBI and have been so employed since 2019. Thus,
I am an investigative or law enforcement officer of the United States within the meaning of
Title 18, United States Code, Section 2510. That is, I am an officer of the United States who is
empowered by law to conduct investigations of, and make arrests for, violations of federal law,
including the offenses enumerated in Titles 8, 18, 19 and 21 of the United States Code.
2. I am currently assigned to the Miami Field Office South Florida Violent Crimes
Task Force, which targets individuals involved in violent crime. As part of my duties, I
investigate violent crimes, including kidnapping, carjacking, and the use of firearms during
violent offenses, in violation of Title 18, United States Code, Sections 1201, 2119, and 924(c). I
received training on the proper investigative techniques for these violations, including the use of
surveillance techniques and the application and execution of arrest and search warrants,
including warrants for historical and prospective cell-site information. I have conducted and
assisted in fugitive and violent crime investigations, and have executed search warrants that
have led to seizures of evidence related to violent crime.
3. I respectfully submit that there is probable cause to believe that Stevenson
CHARLES (“CHARLES”), (1) on or about on October 24, 2022, did, with the intent to cause
death and serious bodily harm, take a motor vehicle that had been transported, shipped, and
received in interstate and foreign commerce, in violation of Title 18, United States Code,
Section 2119(1); (2) on or about October 24, 2022, did use and carry a firearm during and in
relation to a crime of violence, did knowingly possess a firearm in furtherance of a crime of
Case 1:22-cr-20596-PCH Document 1 Entered on FLSD Docket 11/15/2022 Page 4 of 9
violence, and did brandish said firearm, in violation of Title 18, United States Code, Sections
924(c)(l)(A)(ii); (3) on or about November 2, 2022, did, with the intent to cause death and
serious bodily harm, take a motor vehicle that had been transported, shipped, and received in
interstate and foreign commerce, in violation of Title 18, United States Code, Section 2119(1);
and, (4) on or about November 2, 2022, did use and carry a firearm during and in relation to a
crime of violence, did knowingly possess a firearm in furtherance of a crime of violence, and
did brandish said firearm, in violation of Title 18, United States Code, Sections 924(c)(l)(A)(ii).
4. The statements contained in this affidavit are based on my personal knowledge as
well as information relayed to me by other law enforcement officers and witnesses present on
scene. I have not included in this affidavit each and every fact known to me. Rather, I have
included only those facts that I believe are necessary to establish probable cause for the issuance
of a criminal complaint against CHARLES for the above-described criminal violations.
PROBABLE CAUSE
Victim 1
5. On or about Sunday, October 23, 2022, Victim 1 met another male online using
the “Grindr” application, an online dating and social networking application targeted towards
members of the LGBTQ community. Victim 1 and the male agreed to meet in person at a
residence located at 10403 NW 25th Avenue, Miami, Florida 33147 (the “10403 Residence”).
6. On or about October 23, 2022, at approximately, 11:00 p.m., Victim 1 arrived at
the 10403 Residence and made contact with the male, later identified by law enforcement as
CHARLES. CHARLES invited Victim 1 into the residence. Victim 1 and CHARLES then
proceeded to CHARLES’s bedroom. Victim 1 noticed that CHARLES was wearing an ankle
monitor during their interaction. A short time later, CHARLES produced a black firearm,
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pointed it at Victim 1, and demanded his cell phone. Victim 1 provided his cell phone to
CHARLES. Victim 1, in fear for his life, and in attempt to get out of the residence, told
CHARLES that he would drive him to a bank and withdraw money for him.
7. CHARLES entered the front passenger seat of Victim 1’s vehicle, a 2021 red
Honda which had previously been transported, shipped, or received in interstate or foreign
commerce (hereinafter, “Victim 1’s Vehicle”). Victim 1 drove CHARLES to a Wells Fargo
bank located at 13100 NW 27th Avenue in Miami, Florida. CHARLES pointed a firearm at
Victim 1 as he was driving. Victim 1 withdrew $380.00 in U.S. currency from Wells Fargo and
handed it to CHARLES. Victim 1 then drove to a Bank of America, located at 13300 NW 27th
Avenue in Miami, Florida, and withdrew $760.00 in U.S. currency, which he also handed to
CHARLES. CHARLES then instructed Victim 1 to sit in the front passenger seat so that he
could drive. As CHARLES was driving Victim 1’s Vehicle, he ordered Victim 1 to exit his
vehicle at an unspecified highway exit; CHARLES then fled in Victim 1’s Vehicle. The Victim
walked to a nearby gas station and called the police.
8. A search of the Florida Driver and Vehicle Information Database (“DAVID”)
revealed that the 10403 Residence is listed as CHARLES’s residence. Furthermore, a search of
law enforcement databases revealed that CHARLES was on probation and being monitored by
the Miami-Dade County Corrections Boot Camp program using a GPS ankle monitor at the
time of the incident. Probation records revealed that after the incident on October 24, 2022,
CHARLES removed his GPS ankle monitor. Probation records also indicate that the 10403
Residence is CHARLES’s residence, as reported to probation.
9. Victim 1 provided law enforcement with his bank transaction records showing the
date and time of the cash withdrawals from Wells Fargo and Bank of America. Law
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enforcement made contact with the Miami-Dade County Corrections Boot Camp program, who
provided GPS monitor location data for CHARLES during the relevant time period. A review
of the location data revealed that CHARLES was at the Wells Fargo and the Bank of America at
the time of the aforementioned cash withdrawals. A review of the location data also confirms
that CHARLES was at the 10403 Residence prior to going to the banks.
Victim 2
10. On or about November 2, 2022, Victim 2 received a message from an unknown
male on the “Grindr” application. The male told Victim 2 that he wanted to meet up and sent his
location to Victim 2. Victim 2 agreed to meet with the male. Victim 2 drove to location
provided by the male: 244 NW 72nd Terrace Miami, Florida (the “244 Residence”). Victim 2
was driving his 2022 black Toyota, which had previously been transported, shipped, or received
in interstate or foreign commerce (hereinafter “Victim 2’s Vehicle”).
11. When Victim 2 arrived at the 244 Residence, he observed CHARLES exiting the
apartment building. Victim 2 stopped his vehicle in front of CHARLES and put the vehicle in
park, causing the doors of the vehicle to unlock. CHARLES entered the backseat of Victim 2’s
Vehicle and pointed a firearm at Victim 2. CHARLES appeared to notice police cars that were
nearby and ordered Victim 2 to drive.
12. Victim 2 did not speak English fluently. CHARLES used a cell phone translator
application to communicate with Victim 2. CHARLES asked Victim 2 where he lived and
instructed Victim 2 to take them to Victim 2’s apartment. Victim 2 drove his vehicle to his
apartment. CHARLES ordered Victim 2 to park inside the parking garage. CHARLES then
instructed Victim 2 to come to the backseat. CHARLES put down the backseat and ordered
Victim 2 to lay down in the backseat-trunk area of the vehicle.
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13. During the course of this incident, CHARLES struck Victim 2 several times about
the head and body with the firearm, causing bruising to Victim 2’s face and shoulder, and a cut
to Victim 2’s head.
14. CHARLES ordered Victim 2 to unlock his phone. CHARLES then used the
phone translator application to ask Victim 2 to log into Victim 2’s bank accounts. CHARLES
noticed Victim 2 had a Bank of America account. CHARLES instructed Victim 2 to login to his
bank account, but Victim 2 was unable to login to his account. While looking through pictures
on Victim 2’s phone, CHARLES observed photographs of Victim 2 with other men; CHARLES
told Victim 2 that he was “going to kill all of you” and struck Victim 2 with the firearm.
15. CHARLES then jumped into the driver’s seat of Victim 2’s Vehicle, leaving
Victim 2 laying down in the backseat-trunk area. Victim 2 could not tell which direction
CHARLES was driving because every time Victim 2 tried to put his head up, CHARLES struck
him with the firearm.
16. CHARLES and Victim 2 ultimately arrived at an unknown Bank of America
location. CHARLES told Victim 2 to exit the vehicle and withdraw money from Victim 2’s
bank account. Victim 2 tried to take out money, but was unsuccessful. CHARLES got out of
Victim 2’s vehicle with a ski mask covering his face and tried withdrawing money with Victim
2; he was also unsuccessful. CHARLES ordered Victim 2 to get into the vehicle again.
17. While going through Victim 2’s phone, CHARLES also noticed that Victim 2 had
an Apple card with an available balance. CHARLES called someone on his phone and asked
how to get the money from an Apple Card. After getting instructions, CHARLES ordered
Victim 2 into the front passenger seat of the vehicle and instructed him to keep his head down.
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18. CHARLES then drove Victim 2’s vehicle to three (3) different Walgreens stores.
Neither CHARLES nor Victim 2 exited the vehicle at the first Walgreens store. At the second
Walgreens store, located at 3007 NE 199th Steet in Aventura, Florida, CHARLES instructed
Victim 2 to stay in the car. CHARLES told Victim 2 that if he tried to leave, he was going to
kill him. CHARLES turned off Victim 2’s Vehicle and exited the vehicle, leaving Victim 2
inside of the vehicle; he then walked into the Walgreens with Victim 2’s Apple card and the
keys to the car. A review of Victim 2’s Apple card transactions revealed that CHARLES used
Victim 2’s Apple card to purchase a $500 Apple gift card at the second Walgreens store.
CHARLES then returned to Victim 2’s vehicle.
19. CHARLES then drove to a third Walgreens store, located at 18665 Biscayne
Boulevard in Aventura, Florida. CHARLES walked into the Walgreens, leaving Victim 2 inside
of the vehicle with the car on; CHARLES took the keys to the car with him. CHARLES used
Victim 2’s phone to access Victim 2’s Apple card and purchased a $500 American Express
Gold Gift Card, a Mountain Dew, and an Aquafina water. A review of Victim 2’s Apple card
transactions reflect that transaction. While CHARLES was inside of the third Walgreens store,
Victim 2 jumped into the driver’s seat of his vehicle and fled in his vehicle.
20. Law Enforcement obtained surveillance video from the 244 Residence. The video
shows CHARLES taking the elevator down from the 10th floor of the building and exiting the
building to meet Victim 2. Law Enforcement investigation revealed that a known female
associate of CHARLES resides in an apartment on the 10th floor of the 244 Residence.
21. CHARLES’s probation officer was shown the video obtained from the 244
Residence. The probation officer confirmed that male in elevator heading down to meet with
Victim 2 is CHARLES.
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