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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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Case 1:22-cr-20596-PCH Document 1 Entered on FLSD Docket 11/15/2022 Page 5 of 9




  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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