Verified Complaint for Forfeiture in Rem — United States v. M/V "Best Bet" et al. (S.D. Fla., Dkt. 1)

Summary

Verified Complaint for Forfeiture in rem filed by the United States in the Southern District of Florida against a 65-foot Hatteras sport fisher yacht, M/V "Best Bet," and a West Marine dinghy. The complaint alleges that on or about December 2, 2025, the United States Coast Guard located the yacht about six nautical miles offshore of Government Cut in Miami, and that agents found over 1,300 packages holding approximately 1,693 kilograms of cocaine. It says the three men aboard were indicted and each pled to one count of conspiring to import more than five kilograms of cocaine. The claim for relief rests on 21 U.S.C. 881(a)(4). A Homeland Security Investigations special agent verifies the allegations.

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“Verified Complaint for Forfeiture in Rem — United States v. M/V ‘Best Bet’ et al. (S.D. Fla., Dkt. 1).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-26-cv-23081-dkt-1-s-d-fla-083d596b52/, SHA-256 70d7996bfb37af6b4b5737fbff16731c48005a88a85e3ecea2e714c4062a798e.

Full text

Case 1:26-cv-23081-CMA Document 1 Entered on FLSD Docket 04/30/2026 Page 1 of 8

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

CASE NO.

UNITED STATES OF AMERICA,

Plaintiff,

ONE (1) 65’ HATTERAS SPORT FISHER
YACHT KNOWN AS M/V “BEST BET”
(HULL NO. HATDA351C989), AND

ONE (1) WEST MARINE DINGHY
(HULL NO. WMPEX056C525),

Defendants In Rem.
/

VERIFIED COMPLAINT FOR FORFEITURE IN REM

Plaintiff, the United States of America (the “United States”), by and through its

undersigned counsel, alleges upon information and belief as follows:

I. NATURE OF THE ACTION

1. This is a civil action in rem under 21 U.S.C. § 881(a)(4), the procedures set forth

in Rule G of the Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture

Actions, the Federal Rules of Civil Procedure, and 18 U.S.C. § 983, to forfeit property, which

was used or intended for use, to transport, or in any manner to facilitate the transportation,

sale, receipt, possession, or concealment of controlled substances.

2. The property consists of, one (1) 1989 65’ Hatteras Sport Fisher Yacht, Hull

No. HATDA351C989, bearing the name “Best Bet,” (“DEFENDANT M/V BEST BET”)

and one (1) West Marine Dinghy, Hull No. WMPEX056C525, (“DEFENDANT DINGHY,”
Case 1:26-cv-23081-CMA Document 1 Entered on FLSD Docket 04/30/2026 Page 2 of 8

and collectively, “DEFENDANT VESSELS”), which are currently in the custody of the

United States and depicted in the photos below:

II. JURISDICTION AND VENUE

3. This Court has jurisdiction over this subject matter. See 28 U.S.C. §§ 1345,

1355(a), and 2461(a).

2
Case 1:26-cv-23081-CMA Document 1 Entered on FLSD Docket 04/30/2026 Page 3 of 8

4. This Court has in rem jurisdiction over the Property. See 28 U.S.C. §§ 1345,

1355(b).

5. Venue for this action is proper in the Southern District of Florida because the

acts or omissions giving rise to the forfeiture occurred in this District, and the related criminal

prosecution was brought in this District. See 21 U.S.C § 881(j); 28 U.S.C. §§ 1355(b)(1)(A),

1395(b).

III. FACTUAL ALLEGATIONS

6. Law enforcement agents working an investigation into the narcotics trafficking

routes between the Dominican Republic and South Florida received information about an

inbound vessel carrying a multi-hundred kilo load of cocaine.

7. On or about December 2, 2025, approximately six (6) nautical miles offshore

of Government Cut in Miami, Florida, the United States Coast Guard ("USCG") located the

DEFENDANT M/V BEST BET 1, which was traveling westbound from international waters,

consistent with the general description, trajectory, and timing given to law enforcement

agents.

8. A safety inspection of the DEFENDANT M/V BEST BET was conducted by

USCG, and U.S. Customs Border Protection- Air and Marine Operations Marine Interdiction

agents joined.

9. During the inspection, agents identified the three individuals on board the

DEFENDANT M/V BEST BET as Erasme Catalino Paulino Rodriguez (“Paulino

1
The DEFENDANT DINGHY was aboard the DEFENDANT M/V BEST BET at all times relevant to the
factual allegations set forth herein.

3
Case 1:26-cv-23081-CMA Document 1 Entered on FLSD Docket 04/30/2026 Page 4 of 8

Rodriguez”), Joseito Dias De Oleo (“Dias De Oleo”), and Ober Alexander Villavicencio

Jimenez (“Villavicencio Jimenez”).

10. The DEFENDANT M/V BEST BET was escorted to USCG Miami Beach by

Air and Marine Operations for further inspection.

11. A K9 inspected the DEFENDANT M/V BEST BET, and the K9 alerted to the

presence of narcotics on the DEFENDANT M/V BEST BET.

(This portion of the page is intentionally left blank.)

4
Case 1:26-cv-23081-CMA Document 1 Entered on FLSD Docket 04/30/2026 Page 5 of 8

12. Agents searched the DEFENDANT M/V BEST BET and located over 1,300

packages in various compartments throughout the DEFENDANT M/V BEST BET that

contained approximately 1,693 kilograms of cocaine. Some of these packages found by

agents in compartments are shown in the photos below:

5
Case 1:26-cv-23081-CMA Document 1 Entered on FLSD Docket 04/30/2026 Page 6 of 8

13. On or around December 17, 2025, the United States indicted Paulino

Rodriguez, Dias De Oleo, and Villavicencio Jimenez in United States v. Paulino Rodriguez, et

al., Case No. 25-CR-20541-GAYLES.

14. On April 20, 2026, Paulino Rodriguez, Dias De Oleo, and Villavicencio

Jimenez each respectively pled to one count of conspiring with others to import more than

five kilograms of cocaine, in violation of 21 U.S.C. §§ 952(a) and 963.

IV. BASIS FOR FORFEITURE

15. Under 21 U.S.C. § 881(a)(4), all conveyances, including aircraft, vehicles, or

vessels, which are used, or are intended for use, to transport, or in any manner to facilitate the

transportation, sale, receipt, possession, or concealment of property described in paragraph

(1), (2), or (9) of 21 U.S.C. § 881, are subject to forfeiture. As relevant here, paragraph 9

describes such property as follows:

(9) all listed chemicals, all drug manufacturing equipment, all tableting
machines, all encapsulating machines, and all gelatin capsules, which have
been imported, exported, manufactured, possessed, distributed, dispensed,
acquired, or intended to be distributed, dispensed, acquired, imported, or
exported, in violation of this subchapter or subchapter II.

21 U.S.C. § 881(a)(9).

16. Cocaine is a listed chemical, a Schedule II controlled substance under 21 U.S.C.

§ 812.

17. Under 21 U.S.C. § 881(h), all right, title, and interest in property described in

21 U.S.C. § 881(a) vests in the United States upon commission of the act giving rise to

forfeiture.

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Case 1:26-cv-23081-CMA Document 1 Entered on FLSD Docket 04/30/2026 Page 7 of 8

CLAIM FOR RELIEF
Conveyance Used to Transport and Conceal Cocaine
(21 U.S.C. § 881(a)(4))

18. The factual allegations in paragraphs 1 to 13 are re-alleged and incorporated by

reference herein.

19. As set forth above, the DEFENDANT VESSELS were used, or intended for

use, to transport, or in any manner to facilitate the transportation, sale, receipt, possession, or

concealment of cocaine, a listed chemical, which was possessed or intended to be imported

in violation of 21 U.S.C. § 952(a).

20. Accordingly, the DEFENDANT VESSELS are subject to forfeiture to the

United States pursuant to 21 U.S.C. § 881(a)(4).

WHEREFORE, Plaintiff, the United States of America that notice of this action be

provided to persons known or thought to have an interest in or right against the

DEFENDANT VESSELS; that the DEFENDANT VESSELS be forfeited and condemned

to the United States of America; and for such other and further relief as this Court may deem

just, necessary and proper.

Respectfully submitted,

JASON A. REDING QUIÑONES
UNITED STATES ATTORNEY

By: s/ Annika M. Miranda
Annika M. Miranda
Assistant United States Attorney
Florida Bar No. 64975
99 N.E. 4th Street, 7th Floor
Miami, Florida 33132-2111
Telephone: (305) 961-9303
Facsimile: (305) 536-4089
annika.miranda@usdoj.gov

7
Case 1:26-cv-23081-CMA Document 1 Entered on FLSD Docket 04/30/2026 Page 8 of 8

VERIFICATION

I, Stefanie Arinus, hereby verify and declare, under penalty of perjury, that I am a

Special Agent with Homeland Security Investigations, currently assigned to the Miami

Maritime Border Enforcement Security Task Force, which focuses on maritime narcotics

investigations, and that the foregoing factual allegations are true and correct to the best of my

knowledge and belief.

The sources of my knowledge and information and the grounds of my belief are the

official files and records of the United States, information supplied to me by other law

enforcement officers, as well as my investigation of this case, together with others, as the

Homeland Security Investigations Special Agent.

Executed on this __30___ of April 2026.

____________________________________
Stefanie Arinus
Special Agent, Homeland Security Investigations

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