Affidavit in Support of an Application for a Criminal Complaint — United States v. Paulino (Document 3-1)

Summary

Affidavit of John A. Bartolomucci, a Task Force Officer with the Federal Bureau of Investigation, in support of an application for a criminal complaint charging Jan Paulino with conspiracy to launder money in violation of Title 18, United States Code, Section 1956(h) (Case 1:25-mj-06667-MPK). It states that in March 2025 investigators spoke with a cooperating witness about a group laundering suspected illegal proceeds through financial entities and cryptocurrency, and that undercover agents picked up bulk cash believed to be drug proceeds. Headings in the affidavit describe Paulino as coordinating dropoffs of $368,260 on March 13, 2025 and $439,020 on March 24, 2025, believed to be illegal proceeds. The affidavit concludes that there is probable cause to believe Paulino committed the charged offense.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Affidavit in Support of an Application for a Criminal Complaint — United States v. Paulino (Document 3-1).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-united-states-v-paulino-dkt-3-1-d-mass-27e50b56c2/, SHA-256 96469edcf9eda0c56039308425954fab250642fd32c5d04509ae34ffbaf89f9a.

Full text

Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 1 of 25

AFFIDAVIT IN SUPPORT OF AN
APPLICATION FOR A CRIMINAL COMPLAINT

I, John A. Bartolomucci, being sworn, state:

Introduction and Agent Background

1. I am a full-time Detective with the City of Watertown, Massachusetts Police

Department and am currently assigned to the Federal Bureau of Investigation (“FBI”) and Boston

Homeland Security Task Force (“HSTF”) Strike Force. I have been a Watertown Police Officer

since 2003 and have been assigned to the Detective Division since 2008 as a narcotics and general

investigator. Since 2012, I have been assigned as a Task Force Officer (“TFO”), defined as a

sworn Special Federal Officer with the FBI, and a sworn Special Deputy United States Marshal

with the United States Marshals Service. I am a “federal law enforcement officer” within the

meaning of Federal Rule of Criminal Procedure 41(a)(2)(C), that is, a government agent engaged

in enforcing the criminal laws and duly authorized by the Attorney General to request a search

warrant.

2. My primary duties include the investigation of organized narcotics traffickers,

narcotics distribution, money-laundering offenses, and other federal and state crimes. I have

written or participated in numerous arrests for both state and federal law violations, seizures of

large quantities of controlled substances and currency, physical and electronic surveillance, the

execution of search warrants, and debriefing of informants. I have participated in at least thirty

investigations that involved the use of court-ordered interception of wire and/or electronic

communications. I have testified in state and federal courts. I have participated in the execution

of over 300 state and federal search warrants for narcotics offenses. I have been the affiant for

over 100 state and/or federal search warrants. These search warrants have led to the seizure of

large amounts of drug evidence and convictions in state and federal court.
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 2 of 25

3. In addition to my Massachusetts Criminal Justice Training Council Academy

training and annual in-service training, I have received over 400 hours of specialized narcotics

training to include undercover survival, and the identification, distribution, packaging, trafficking,

and usage of narcotics. I have also received specialized investigative training from the

Massachusetts Criminal Justice Training Council (“MCJTC”), the Massachusetts State Police

(“MSP”), the FBI, the Drug Enforcement Administration (“DEA”), the Federal Bureau of Alcohol,

Tobacco, Firearms, and Explosives (“ATF”), the University of Tennessee National Forensic

Academy, and the Middlesex District Attorney’s Office regarding criminal and narcotic

investigations. I am also a locally certified Undercover Officer by the FBI and the Boston Police

Department and have worked in covert capacities. I have a Bachelor’s Degree in Criminal Justice

from Northeastern University in Boston, Massachusetts.

4. In the course of my official duties as a police officer, detective, and TFO, I have

interviewed over 300 defendants, informants, and suspects who were consumers and distributors

of controlled substances and who laundered drug proceeds. I am familiar with the street language

of illegal narcotic consumers and distributors and money launderers. I have worked with and have

been trained by officers experienced in the investigations of illegal narcotics trafficking, using

various methods, including but not limited to the following: undercover assignments, both physical

and electronic surveillance, and the establishment of reliable informants. Based on my training

and experience, I have observed numerous types of controlled substances, and I am familiar with

the packaging, pricing structure, distribution methods, and street jargon associated with their sale

and use. I have also encountered and become familiar with the various tools, methods, trends,

paraphernalia, and related articles used by drug traffickers and trafficking organizations in their

efforts to import, conceal, manufacture, and distribute controlled substances.

2
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 3 of 25

5. In conjunction with other federal law-enforcement agencies, I have participated in

over 500 narcotics investigations to include investigations of large scale national and international

drug-trafficking organizations, including organizations actively involved in the laundering of drug

proceeds. These investigations have included the introduction of undercover officers and

confidential informants into these groups, and the implementation of electronic surveillance,

including but not limited to, wiretapping and global positioning systems (“GPS”).

6. Based on my training and experience, I am familiar with the methods of operation

employed by drug traffickers and money launderers operating at the local, state, national, and

international levels, including those involving the distribution, storage, and transportation of

controlled substances and the collection of money that constitutes the proceeds of drug-trafficking

activities. Specifically, I am familiar with the manner in which drug traffickers and money

launderers use vehicles, common carriers, mail and private delivery services, and a variety of other

means to transport and distribute drugs and the proceeds of drug trafficking. I am familiar with

the manner in which drug traffickers and money launderers often store drugs and drug proceeds in

storage sites commonly referred to as “stash houses.”

7. Based on my training and experience, I understand that illegal drug trafficking and

money laundering often involves the local, interstate, and international movement of drugs to

distributors and co-conspirators at multiple levels, and the movement of the proceeds of drug

trafficking among multiple participants including suppliers, customers, distributors, and money

launderers.

Purpose of the Affidavit

8. I submit this affidavit in support of an application for a criminal complaint charging

Jan PAULINO (“PAULINO”) with conspiracy to launder money, in violation of Title 18, United

3
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 4 of 25

States Code, Section 1956(h) (the “Charged Offense”). Based on the facts set forth in this affidavit,

there is probable cause to believe that the PAULINO has committed the Charged Offense.

9. The facts in this affidavit come from my personal observations, my training and

experience, and information obtained from other agents and witnesses. This affidavit is intended

to show that there is probable cause for the requested criminal complaint and does not set forth all

of my knowledge about this matter.

Probable Cause

Investigation Background

10. In March 2025, investigators spoke with a cooperating witness (hereinafter, “CW-

1”), who developed and provided information about a group of individuals operating in Boston

and New York City interested in laundering suspected illegal proceeds through financial entities

and cryptocurrency. CW-1 is willing to testify if needed.1 After conducting several operations

with CW-1, during which investigators identified several targets involved in suspected money

laundering and drug activities, investigators were able to successfully introduce law enforcement

agents acting in undercover capacities as associates of CW-1 to these targets. These undercover

agents were introduced as being capable of accepting bulk cash and converting it into various

forms of cryptocurrency. Since these initial introductions, undercover agents have picked up bulk

cash believed to be drug proceeds from various money launderers and drug traffickers in multiple

1
CW-1 has been cooperating with the government since 2012. CW-1 provides information to law
enforcement for monetary compensation. CW-1 has a criminal record that includes an arrest for credit card fraud.
CW-1 has provided information that has led to identification of narcotics traffickers, arrests of those traffickers, and
large seizures of narcotics. Information provided by CW-1 has been corroborated to the extent possible and is believed
to be reliable.

4
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 5 of 25

locations around the United States and transmitted cryptocurrency to wallets identified by the

traffickers.

11. As described below, CW-1 informed investigators that CO-CONSPIRATOR 12

had access to large quantities of bulk cash that he wanted to be laundered through cryptocurrency

in the Boston area. CO-CONSPIRATOR 1 spoke with CW-1 about CW-1’s ability to launder the

money through cryptocurrency transfers and inquired what percentage fee CW-1 would charge for

his services. At the direction of investigators CW-1 then introduced an investigator acting in an

undercover capacity (“UC-1”) to communicate with CO-CONSPIRATOR 1 to arrange multiple

pickups of bulk cash believed to be illegal proceeds from local couriers employed by CO-

CONSPIRATOR 1.

CO-CONSPIRATOR 1 and PAULINO Facilitated the Delivery of Bulk Cash, Suspected
Illegal Proceeds, to a Cooperating Witness in Exchange for Cryptocurrency.

12. CW-1 had provided CO-CONSPIRATOR 1’s phone number to UC-1 and had

explained to CO-CONSPIRATOR 1 that UC-1 would be contacting him. On March 6, 2025, UC-

1 and CO-CONSPIRATOR 1, using phone number 904-449-0034 (the “0034 Phone”), began

exchanging text messages. These text messages were in Spanish and preserved. A Spanish-

speaking investigator has reviewed the messages and provided preliminary translations. In lightly

coded language, CO-CONSPIRATOR 1 explained to UC-1 that CO-CONSPIRATOR 1 was

interested in laundering bulk cash proceeds through cryptocurrency purchases. CO-

CONSPIRATOR 1 and UC-1 then had a recorded phone conversation. During this phone call,

2
I know the identity of CO-CONSPIRATOR 1, but am not including his name in this affidavit because this
investigation is ongoing.

5
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 6 of 25

CO-CONSPIRATOR 1 and UC-1 discussed they type of cryptocurrency CO-CONSPIRATOR 1

wanted to purchase. Based on experience and training, I know that there are multiple types of

cryptocurrency, including Bitcoin, Tether, and TRON, among others. Additionally, CO-

CONSPIRATOR 1 stated he was willing to pay 2% to 2.5% per transaction. In my experience and

training, I know that it is common for a money launderer (which UC-1 was purporting to be) to

charge a commission for each monetary transaction, usually a percentage of the total amount of

money picked up and transferred. UC-1 and CO-CONSPIRATOR 1 agreed that UC-1 would

purchase TRC or TRON cryptocurrency and discussed the logistics of the transaction. CO-

CONSPIRATOR 1 explained that he would have the money dropped off to UC-1 in Boston. UC-

1 and CO-CONSPIRATOR 1 agreed that UC-1 would purchase cryptocurrency and transfer

approximately 60% to 80% of the cryptocurrency at delivery. UC-1 would transfer the remaining

20% to 40% once UC-1 confirmed the total amount of bulk currency picked up through a money

counter.

13. CO-CONSPIRATOR 1 inquired if all transactions needed to occur in

Massachusetts and was interested if they could conduct money pickups in different locations. UC-

1 explained that UC-1 needed to establish a trusting relationship with CO-CONSPIRATOR 1

before they moved locations. CO-CONSPIRATOR 1 explained that he would be interested in

conducting money pickups three to four times per week in the Boston area. However, UC-1 and

CO-CONSPIRATOR 1 agreed to conduct pickups approximately once per week to minimize the

risk of getting caught.

6
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 7 of 25

On March 13, 2025, PAULINO Coordinated the
Dropoff of $368,260, Believed to be Illegal Proceeds, Brokered by CO-CONSPIRATOR 1.

14. On March 12, 2025, UC-1 received a phone call from phone number 347-680-1277

(the “1277 Phone”). This call was recorded. The user of the 1277 Phone identified himself as

“PAULINO” and stated he was calling on behalf of “Paul.” Later in the phone call, PAULINO

explained that “Paul” was actually CO-CONSPIRATOR 1, and that PAULINO was CO-

CONSPIRATOR 1’s cousin. Based on PAULINO’s own statements, his description of CO-

CONSPIRATOR 1 as his cousin, and the information described below, investigators determined

that PAULINO was the user of the 1277 Phone.3 UC-1 and PAULINO agreed to meet so that

PAULINO could provide the money, previously discussed with CO-CONSPIRATOR 1, to UC-1.

UC-1 understood that PAULINO would be delivering the money on behalf of CO-

CONSPIRATOR 1. UC-1 and PAULINO agreed to conduct the money pick up the following day,

March 13, 2025.

15. On March 13, 2025, investigators planned to have another cooperating witness

(“CW-2”)4 actually conduct the money pickup. Prior to the meeting with PAULINO, investigators

met with CW-2 at a predetermined location. Investigators searched CW-2 and CW-2’s vehicle for

3
Described below, PAULINO frequently used rental cars to deliver the money to the CWs. Investigators
obtained rental information for those vehicles. PAULINO rented the vehicles under his name, using his Massachusetts
driver’s license, which listed 132 Ashcroft Street, Dedham, Massachusetts as his address.

4
CW-2 has a criminal history involving convictions for armed robbery and home invasion, among others.
CW-2 served a significant prison sentence for state court convictions. Investigators identified CW-2 as a drug
trafficker as part of a separate drug investigation. After CW-2 sold drugs to a government informant, investigators
approached CW-2 and CW-2 agreed to cooperate with investigators in the hopes that criminal charges could be
avoided or reduced. CW-2 is now also cooperating for monetary compensation. CW-2 has provided information that
has been corroborated and that has led to the identification of additional targets of other investigations and seizures of
drugs. Information provided by CW-2 is believed to be reliable.

7
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 8 of 25

contraband and currency with negative results and equipped CW-2 with an audio/video recording

device. Investigators then surveilled CW-2 as he drove to the meeting location with PAULINO, a

Target store parking lot in Watertown, Massachusetts. CW-2 arrived at the parking lot at

approximately 1:49 p.m. Investigators maintained surveillance of CW-2.

16. At approximately 1:45 p.m., PAULINO arrived at the parking lot. PAULINO

parked his vehicle, walked up to CW-2’s vehicle, and entered the front passenger seat of CW-2’s

vehicle. Once inside CW-2’s vehicle, PAULINO handed CW-2 a large FedEx box containing

bulk cash. During the meeting, CW-2 had an active recorded Facetime call with UC-1. The

purpose of this was so UC-1, the purported boss of CW-2, could verify the transaction. After

PAULINO provided the money to CW-2, PAULINO got back in his vehicle and departed the area.

17. Investigators surveilled CW-2 as he drove back to the predetermined meeting

location. At the meeting location, CW-2 turned over the FedEx box containing the money. The

money was banded in stacks and wrapped in plastic wraps in bundles of $10,000 each.

Investigators searched CW-2 for contraband and currency with negative results. Investigators

conducted an official count of the money and determined it to be $368,260 in bulk U.S. currency.

A second investigator acting in an undercover capacity (“UC-2”) then ultimately transmitted

$368,260, minus the broker fee, in TRON cryptocurrency to a cryptocurrency wallet identified by

PAULINO. Based on my experience and training, and the manner in which this money drop-off

and subsequent cryptocurrency transfer was conducted, investigators believe that this bulk

currency was the proceeds of illegal activity and that CO-CONSPIRATOR 1 and PAULINO

arranged for this money transfer in order to conceal the illegal origin of the money.

8
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 9 of 25

On March 24, 2025, PAULINO Coordinated the
Dropoff of $439,020, Believed to be Illegal Proceeds.

18. On March 23, 2025, UC-1 received a call from the 0034 Phone. This call is

recorded. The caller identified himself as “Juan,” (“JUAN”) and UC-1 believed it was a different

person than UC-1 had spoken to over the 0034 Phone on prior occasions, i.e. not CO-

CONSPIRATOR 1. In lightly coded language, JUAN stated that he was the owner of the money

that UC-1 picked up and converted to TRON. JUAN further stated that he was happy with UC-

1’s business. JUAN stated that he wanted to conduct another money pick up the following day,

March 24, 2025, in the amount of $734,000. JUAN explained that “Jan” would be bringing the

cash to the meeting. UC-1 believed that “Jan” was a reference to Jan PAULINO.

19. Prior to March 24, 2025, through rental vehicle records, driver’s license

information, and physical surveillance, investigators had identified PAULINO’s likely residence

as 132 Ashcroft Street, Dedham, Massachusetts (“132 Ashcroft”). On March 24, 2025,

investigators set up surveillance around 132 Ashcroft. At approximately 10:03 a.m., investigators

observed PAULINO circling the neighborhood around 132 Ashcroft in a BMW rental vehicle. At

10:20 a.m., PAULINO parked in the driveway of 132 Ashcroft. At 12:15 p.m., PAULINO sent a

text message, using the 1277 Phone, to UC-1 explaining that PAULINO was 40 minutes away

from the meeting location. At 12:22 p.m., investigators observed PAULINO pull out of the

driveway in the BMW rental. Investigators followed PAULINO from 132 Ashcroft to the meeting

location in Watertown, Massachusetts. PAULINO did not stop anywhere along the way.

9
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 10 of 25

20. Prior to the arranged meeting with PAULINO, investigators planned to have

another cooperating witness (“CW-3”)3 meet with PAULINO to pick up the money. Prior to

meeting with PAULINO, investigators met with CW-3 at a predetermined location. Investigators

searched CW-3 and his vehicle for contraband and currency with negative results and equipped

CW-3 with an audio/video recording device. Investigators then surveilled CW-3 to the meeting

location with PAULINO.

21. At approximately 1:04 p.m., investigators observed PAULINO arrive in the area of

the meeting location. PAULINO circled the area for several minutes. Based on experience and

training, investigators believe that he was ensuring there was no law enforcement presence in the

area. PAULINO, using the 1277 Phone, then called UC-1 in an attempt to try to locate CW-3 to

conduct the money drop-off. At approximately 1:18 p.m., PAULINO was able to locate CW-3 in

the parking lot.

22. PAULINO retrieved a black suitcase from the trunk of his rental vehicle and placed

it on the rear seat of CW-3’s vehicle. CW-3 then contacted UC-1 and asked UC-1 to send the

cryptocurrency. PAULINO remained in CW-3’s vehicle while he waited for the initial payment

of cryptocurrency to transfer to the recipient wallet. While waiting, PAULINO was speaking on

his cell phone to the ultimate recipient of the cryptocurrency, who PAULINO referred to as “Coca

Cola.” PAULINO also spoke to someone in the Dominican Republic to try to sell that person a

3
CW-3 has a criminal history that includes convictions for drug distribution. CW-3 also lived in the United States for
several years under an assumed identity and was arrested for identity theft in 2019. The charge was later dismissed.
CW-3 has provided assistance to the FBI on numerous investigations since 2018. CW-3 is cooperating in exchange
for monetary compensation and immigration benefits. CW-3 has provided information that has been corroborated and
that has led to the identification of additional targets of other investigations and seizures of drugs and large amounts
of U.S. currency believed to be drug proceeds. Information provided by CW-3 is believed to be reliable.

10
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 11 of 25

stolen Rolex and claimed, to CW-3, that the bulk currency was from stolen goods, specifically

jewelry.

23. After the initial payment of cryptocurrency arrived, PAULINO departed the area.

Investigators surveilled CW-3 back to the predetermined location. At the meeting location, CW-

3 turned over the black suitcase containing the money. The money was banded in stacks and

wrapped in plastic wraps in bundles of $10,000. Investigators searched CW-3 for contraband and

currency with negative results. Investigators conducted an official count of the money and

determined it to be $439,020 in bulk U.S. currency. UC-2 then ultimately transmitted $439,020,

minus the broker fee, in TRON cryptocurrency to a cryptocurrency wallet identified by PAULINO.

Based on my experience and training, and the manner in which this money drop-off and subsequent

cryptocurrency transfer was conducted, investigators believe that this bulk currency was the

proceeds of illegal activity and that PAULINO arranged for this money transfer in order to conceal

the illegal origin of the money.

On April 1, 2025, PAULINO Coordinated the
Dropoff of $194,115, Believed to be Illegal Proceeds.

24. On March 31, 2025, UC-1 received a call from PAULINO, using the 1277 Phone.

This call was recorded. In lightly coded language, PAULINO requested that UC-1 arrange for the

pickup of approximately $200,000 the following day, April 1, 2025. UC-1 confirmed that he

would send his runner (CW-3) to pick up the money the next day in Waltham, Massachusetts.

25. On April 1, 2025, prior to the arranged meeting with PAULINO, investigators met

with CW-3 at a predetermined location. Investigators searched CW-3 and his vehicle for

contraband and currency with negative results and equipped CW-3 with an audio/video recording

11
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 12 of 25

device. Investigators then surveilled CW-3 to the meeting location with PAULINO. Investigators

maintained surveillance around the planned meeting location.

26. On April 1, 2025, at approximately 1:38 p.m., investigators observed PAULINO

arrive at the meeting location in a rental vehicle. PAULINO parked his vehicle near CW-3’s

vehicle. PAULINO retrieved a box and three bags from his vehicle and placed those items in the

rear seat of CW-3’s vehicle. PAULINO stated that the total amount of money should be $204,000.

CW-3 asked PAULINO about buying a watch on the “cheap,” referring to PAULINO’s prior

statement about the money being the proceeds of the sale of stolen goods. PAULINO replied that

it would not be a problem and that he could get CW-3 whatever he wanted.

27. PAULINO departed the area. Investigators surveilled CW-3 back to the

predetermined location. At the meeting location, CW-3 turned over the box and three bags to

investigators, which contained the money. The money was banded in stacks and wrapped in plastic

wraps in bundles of various amounts. The box had a written amount of “110,000” and the three

bags had the amounts, “27,500”, “26,500” and “40,000,” written on them. Investigators searched

CW-3 for contraband and currency with negative results. Investigators conducted an official count

of the money and determined it to be $194,115 in bulk U.S. currency. UC-2 then ultimately

transmitted $194,115, minus the broker fee, in TRON cryptocurrency to a cryptocurrency wallet

identified by PAULINO. Based on experience and training, and the manner in which this money

drop-off and subsequent cryptocurrency transfer was conducted, investigators believe that this

bulk currency was the proceeds of illegal activity and that PAULINO arranged for this money

transfer in order to conceal the illegal origin of the money.

12
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 13 of 25

On April 8, 2025, PAULINO Coordinated the Dropoff of $505,485,
Believed to be Illegal Proceeds.

28. On April 7, 2025, UC-1 received a call from PAULINO, using the 1277 Phone.

This call was recorded. PAULINO stated that he wanted to conduct a money pick up the following

day, April 8, 2025, for approximately $500,000. UC-1 confirmed that he would send his associate

(CW-2) to pick up the money.

29. On April 8, 2025, prior to the arranged meeting with PAULINO, investigators met

with CW-2 at a predetermined location. Investigators searched CW-2 and his vehicle for

contraband and currency with negative results and equipped CW-2 with an audio/video recording

device. Investigators then surveilled CW-2 to the meeting location with PAULINO. Investigators

maintained surveillance around the planned meeting location.

30. Prior to this meeting, investigators had placed a stationary pole camera outside 132

Ashcroft. On April 8, 2025, investigators were monitoring the pole camera. At approximately

3:33 p.m., through pole camera footage, investigators observed PAULINO exit 132 Ashcroft and

wheel a large suitcase to a Kia rental vehicle that was parked on the street. PAULINO placed the

large suitcase in the rear of the Kia rental and removed a bag and box from the suitcase. PAULINO

placed the bag and the box in the rear seat. At 3:37 p.m., PAULINO departed the area of 132

Ashcroft in the Kia rental vehicle. At approximately 4:02 p.m., investigators observed PAULINO

arrive at the meeting location, a Starbucks in Waltham, Massachusetts, in the same rental vehicle.

31. PAULINO parked his vehicle near CW-2’s vehicle. PAULINO removed four

separate packages from his rental vehicle and placed them in CW-2’s vehicle. CW-2 looked in

the packages and confirmed that a large amount of currency was present. PAULINO then departed

the area.

13
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 14 of 25

32. Investigators surveilled CW-2 back to the predetermined location. At the meeting

location, CW-2 turned over the packages to investigators, which contained the money. The money

was banded in stacks and wrapped in plastic wraps in bundles of various amounts. Investigators

searched CW-2 for contraband and currency with negative results. Investigators conducted an

official count of the money and determined it to be $505,485 in bulk U.S. currency. UC-2 then

ultimately transmitted $505,485, minus the broker fee, in TRON cryptocurrency to a

cryptocurrency wallet identified by PAULINO. Based on experience and training, and the manner

in which this money drop-off and subsequent cryptocurrency transfer was conducted, investigators

believe that this bulk currency was the proceeds of illegal activity and that PAULINO arranged

for this money transfer in order to conceal the illegal origin of the money.

On April 15, 2025, PAULINO Coordinated the Dropoff of $515,060
Believed to be Illegal Proceeds.

33. On April 14, 2025, UC-1 received a call from PAULINO, using the 1277 Phone.

This call was recorded. In lightly coded language, PAULINO stated that he wanted to conduct a

money pick up the following day, April 15, 2025, for approximately $200,000. PAULINO then

stated that he may have as much as $500,000 for pick up. UC-1 confirmed that he would send his

associate (CW-3) to pick up the money.

34. On April 15, 2025, prior to the arranged meeting with PAULINO, investigators met

with CW-3 at a predetermined location. Investigators searched CW-3 and his vehicle for

contraband and currency with negative results and equipped CW-3 with an audio/video recording

device. Investigators then surveilled CW-3 to the meeting location with PAULINO. Investigators

maintained surveillance around the planned meeting location.

14
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 15 of 25

35. On April 15, 2025, at approximately 12:32 p.m., while viewing footage from the

pole camera set up in the area of 132 Ashcroft, investigators observed PAULINO approach a White

Mazda vehicle approximately four houses down the street from 132 Ashcroft. PAULINO entered

the vehicle and then moved it into the driveway of 132 Ashcroft, which is out of the view of the

pole camera. At approximately 12:35 p.m., investigators observed PAULINO depart the area of

132 Ashcroft in the Mazda. Investigators were able to confirm that this white Mazda was a rental

vehicle. At approximately 12:58 p.m., investigators observed PAULINO arrive at the meeting

location in Waltham, Massachusetts in the same rental vehicle.

36. PAULINO parked his vehicle near CW-3’s vehicle. PAULINO approached CW-

3’s vehicle and told CW-3 to move to a different location in the parking lot. CW-3 and PAULINO

then both moved their vehicles to the other area of the parking lot. PAULINO then retrieved a

package from the passenger area of his vehicle and placed it in CW-3’s vehicle. CW-3 confirmed

there was a large amount of cash present. PAULINO then departed the area.

37. Investigators surveilled CW-3 back to the predetermined location. At the meeting

location, CW-3 turned over the package to investigators, which contained the money. The money

was banded in stacks and wrapped in plastic wraps in bundles of various amounts. Investigators

searched CW-3 for contraband and currency with negative results. Investigators conducted an

official count of the money and determined it to be $515,060 in bulk U.S. currency. UC-2 then

ultimately transmitted $515,060, minus the broker fee, in TRON cryptocurrency to a

cryptocurrency wallet identified by PAULINO. Based on experience and training, and the manner

in which this money drop-off and subsequent cryptocurrency transfer was conducted, investigators

believe that this bulk currency was the proceeds of illegal activity and that PAULINO arranged

for this money transfer in order to conceal the illegal origin of the money.

15
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 16 of 25

On April 30, 2025, PAULINO Coordinated the Dropoff of $408,150,
Believed to be Illegal Proceeds.

38. On April 26, 2025, PAULINO, using phone number (646) 244-7925 (the “7925

Phone”), sent a text message to UC-1. PAULINO informed UC-1 that UC-1 should communicate

with him using the 7925 Phone going forward. On Monday April 28, 2025, UC-1 responded to

PAULINO, using the 7925 Phone, “Hola” to acknowledge the change in phone numbers.

PAULINO, continuing to use the 7925 Phone, then called UC-1. This call was recorded. In lightly

coded language, PAULINO stated that he had $400,000 to be picked up and they agreed to meet

on April 30, 2025. UC-1 confirmed that he would send his associate (CW-3) to pick up the money.

39. On April 30, 2025, UC-1 received a voice memo from PAULINO, using the 7925

Phone. This voice memo was preserved. In lightly coded language, PAULINO stated that he had

approximately $300,000 available for pickup, but he was trying to get additional money to make

it $500,000 for the day’s pickup. UC-1 acknowledged.

40. On April 30, 2025, prior to the arranged meeting with PAULINO, investigators met

with CW-3 at a predetermined location. Investigators searched CW-3 and his vehicle for

contraband and currency with negative results and equipped CW-3 with an audio/video recording

device. Investigators then surveilled CW-3 to the meeting location with PAULINO. Investigators

maintained surveillance around the planned meeting location.

41. On April 30, 2025, at approximately 12:35 p.m., through the pole camera in the

area of 132 Ashcroft, investigators observed PAULINO exit 132 Ashcroft and wheel a large

suitcase and a backpack to a vehicle that was parked on the street in front of the house. PAULINO

placed the large suitcase in the trunk of the vehicle and got into the back seat. Investigators believe

the vehicle was a ride-share vehicle. At approximately 12:59 p.m., investigators observed

16
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 17 of 25

PAULINO arrive at the meeting location in the ride-share vehicle. He was dropped off and

removed the suitcase and backpack from the vehicle.

42. At approximately 1:02 p.m., CW-3 arrived at the meeting location and picked up

PAULINO. PAULINO entered CW-3’s vehicle with the suitcase and backpack. CW-3 drove

around the parking lot with PAULINO. PAULINO pulled another backpack out of the suitcase

and handed it to CW-3. PAULINO confirmed the total amount of money as $400,000 with the fee

and told CW-3 that he was leaving for Miami after the deal was complete. CW-3 then dropped

PAULINO off in front of a store in the parking lot. Shortly thereafter, PAULINO was picked up

by another ride-share vehicle and departed the area.

43. Investigators surveilled CW-3 back to the predetermined location. At the meeting

location, CW-3 turned over the package to investigators, which contained the money. The money

was banded in stacks and wrapped in plastic wraps in bundles of $10,000, $25,000, and $50,000

with the amounts written on each bundle. Investigators searched CW-3 for contraband and

currency with negative results. Investigators conducted an official count of the money and

determined it to be $408,150 in bulk U.S. currency. UC-2 ultimately transmitted $408,150, minus

the broker fee, in TRON cryptocurrency to a cryptocurrency wallet identified by PAULINO. This

cryptocurrency wallet was a different wallet than the one provided for the prior transactions

described above. Investigators were monitoring the activity in that newly provided wallet. A short

time after UC-2 transferred the cryptocurrency to the new wallet, the cryptocurrency was

transferred to the original wallet identified by PAULINO. Based on my experience and training,

and the manner in which this money drop-off and subsequent cryptocurrency transfer was

conducted, investigators believe that this bulk currency was the proceeds of illegal activity and

that PAULINO arranged for this money transfer in order to conceal the illegal origin of the money.

17
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 18 of 25

On May 9, 2025, PAULINO Attempted to Deliver $877,240 in Suspected Drug Proceeds;
Investigators Seized the Suspected Proceeds.

44. On May 8, 2025, PAULINO, using the 7925 Phone,5 exchanged text messages with

UC-1 regarding a money pickup. These messages are preserved. In lightly coded language,

PAULINO stated that he was going to have approximately $800,000 to be picked up. PAULINO

stated that he needed the money picked up soon. UC-1 stated that they could meet the following

day (May 9, 2025). During this text message exchange, location information for the 7925 Phone

showed that the phone appeared to be moving on the train from New York to Massachusetts. The

location information showed that the 7925 Phone was moving along the rail line through

Connecticut, Rhode Island, and finally to the Westwood Amtrak station in Massachusetts.

45. Shortly after the 7925 Phone arrived in the area of the Westwood Station, through

pole camera footage, investigators observed PAULINO arrive at 132 Ashcroft. PAULINO exited

what appeared to be a ride-share vehicle holding a red and black bag. PAULINO then entered 132

Ashcroft.

46. On May 9, 2025, PAULINO, using the 7925 Phone, continued to exchange text

messages with UC-1 and confirmed the meeting time for the money pickup. Prior to the arranged

money pickup, investigators established surveillance in the area of 132 Ashcroft. Investigators

observed a rental vehicle parked across the street from 132 Ashcroft.6 At approximately 10:56

5
On May 7, 2025, the Honorable M. Page Kelley issued a warrant for historical and prospective location
information for the 7925 Phone. 25-mj-6226-MPK.

6
As described above, PAULINO frequently used rental cars to deliver the money to the CWs. Investigators
obtained rental information for those vehicles. PAULINO rented the vehicles under his name, using his Massachusetts
driver’s license, which listed 132 Ashcroft Street, Dedham, Massachusetts as his address. On March 13, 2025,
18
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 19 of 25

a.m., investigators observed PAULINO exit 132 Ashcroft with a red and black bag and enter the

rental vehicle on the street. Investigators followed PAULINO in the rental towards Route 128/95

North. While on 128/95 North in Dedham, a marked Massachusetts State Police (“MSP”) cruiser

pulled over PAULINO in the rental vehicle for an unsafe lane change.

47. During the motor vehicle stop, MSP troopers spoke with PAULINO. PAULINO’s

story changed multiple times but admitted that he was transporting a large amount of currency to

be structured into small checks through the bank system. PAULINO lastly stated that the money

was from jewelry sales. During the stop, between speaking with the MSP Trooper, PAULINO

sent a text message to UC-1, which stated, “Leave now[.]” PAULINO further stated that he would

call UC-1 later. Based on experience and training, investigators believe that PAULINO was

warning UC-1 to leave the planned meeting location to avoid law enforcement detection.

48. Investigators found the red and black bag in the vehicle which contained $877,240

in U.S. currency. The currency was seized. Prior to submission to evidence, a MSP K9 conducted

a random sniff of the bag to include the currency, and the K9 alerted to the presence of narcotics.

Based on experience and training, the communications leading up to this planned money drop-off,

and the positive K9 alert for the presence of narcotics odor, investigators believe that this currency

is drug proceeds.

PAULINO Communicated with CW-1 about Drug Trafficking and Money Laundering.

49. On or about May 15, 2025, while monitoring the location information and call

activity for the 7925 Phone, investigators observed that activity ceased on this phone. Based on

PAULINO delivered suspected narcotics proceeds in a rental vehicle and had listed phone number (786) 412-8440
(the “8440 Phone”) on the rental agreement.

19
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 20 of 25

experience and training, investigators believed that PAULINO had discontinued use, or “dropped,”

the 7925 Phone. Based on experience and training, investigators know that it is common for drug

traffickers and money launderers to drop their phones after being contacted by law enforcement,

as PAULINO was on May 9, 2025, as described above.

50. On May 19, 2025, PAULINO sent CW-1 a text message from phone number (347)

776-3922 (the “3922 Phone”), and stated that the 3922 Phone was his new phone number, and that

CW-1 should pass the phone number on to UC-1. UC-1 attempted to contact PAULINO several

times on the 3922 Phone, but PAULINO did not respond.

51. On May 23, 2025, at investigators direction, CW-1 made a recorded Facetime call

to PAULINO, using the 8440 Phone.7 During the call in Spanish, and in lightly coded language,

CW-1 asked PAULINO, “if he had any of the other stuff we spoke of?” PAULINO responded

that “he was waiting to meet in person to discuss.” CW-1 explained that UC-1 was “having a

problem with the guy who passes [UC-1] the stuff.” PAULINO responded, “Do you need it there

or over here?” CW-1 responded, “Boston,” and said that he would pay PAULINO, the same way,

meaning through cryptocurrency. PAULINO responded, “Yeah, I understand what you are saying.

When we meet up, we can talk more.” CW-1 further reiterated that UC-1 was “looking for the

white and Fernando. Good quantities.” Based on experience and training, and a debriefing of CW-

1, investigators believe that PAULINO was discussing narcotics, specifically cocaine (“white”)

7
CW-1 had previously informed investigators that one of PAULINO’s phones was the
8440 Phone. CW-1 stated that PAULINO used the 8440 Phone for personal matters, but as
described below, investigators learned that PAULINO also uses the 8440 Phone as a backup phone
to discuss criminal activity.

20
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 21 of 25

and fentanyl (“Fernando”). Investigators further believe that PAULINO did not want to discuss

the details of a future drug transaction over the phone (“When we meet up, we can talk more.”).

On May 28, 2025, PAULINO Arranged a Meeting with
CW-1 to Discuss Narcotics Trafficking.

52. On May 28, 2025, at investigators’ direction, CW-1 contacted PAULINO, using

the 8440 Phone, to arrange an in-person meeting, requested in the May 23, 2025 exchange

described above. PAULINO agreed to meet the following day (May 29) at a restaurant in the

Boston area.

53. On May 29, 2025, prior to the arranged meeting, investigators met with CW-1 at a

predetermined location and searched him for contraband and currency with negative results.

Investigators equipped CW-1 with an audio/video recording device and surveilled CW-1 to the

restaurant. Investigators maintained surveillance inside and outside the restaurant during this

meeting.

54. Investigators observed PAULINO arrive at the restaurant and go inside. PAULINO

sat down at a table with CW-1. During this meeting, in lightly coded language, PAULINO

explained that the money seized during the May 9 traffic stop was money being laundered for

Mexicans. CW-1 understood this comment to mean that PAULINO was laundering the money for

Mexican drug traffickers. PAULINO stated that he was getting indirect pressure from the money

owners (the drug traffickers) to pay the money back and that PAULINO was not allowed to launder

any more funds until half of the seized money was paid down to the drug traffickers. PAULINO

stated that he had obtained a lawyer and paid a Jewish man in New York City to falsify jewelry

receipts so that PAULINO could submit a claim to have the seized funds returned to him.

PAULINO further explained that he would be looking to sell UC-1 cocaine to help him pay the

21
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 22 of 25

funds back. PAULINO stated that he did not want to risk traveling with narcotics for fear of being

stopped by police and that his plan was to introduce UC-1 directly to PAULINO’s drug

connections.

On May 28, 2025, PAULINO Arranged a Meeting
with UC-1 to Discuss Narcotics Trafficking.

55. On May 28, 2025, UC-1 contacted PAULINO, using the 3922 Phone, to arrange an

in-person meeting on May 30. PAULINO agreed to meet with UC-1 at a restaurant in the Boston

area.

56. On May 30, 2025, prior to meeting with PAULINO, investigators equipped UC-1

with an audio/video recording device. Investigators established surveillance both inside and

outside the restaurant prior to the planned meeting. Investigators observed PAULINO arrive at

the restaurant and go inside. PAULINO sat down at a table with UC-1. In lightly coded language,

PAULINO offered to introduce UC-1 to a Dominican drug supplier in the Boston area who would

sell kilograms of cocaine for $13,000 per kilogram. PAULINO stated that he was also attempting

to reach out to a fentanyl and methamphetamine supplier, but PAULINO did not yet have prices

for these drugs. PAULINO stated that UC-1 would be able to pay for any narcotics through

cryptocurrency to the same wallet PAULINO had provided to launder money in the prior money

drop-offs. UC-1 explained that UC-1 intended to “start small” with one or two kilograms of

narcotics to “test” the product. If the product was high-quality, then UC-1 would order greater

bulk quantities. PAULINO stated that would not be a problem. PAULINO indicated that the drug

product would be coming from the same Mexican money owners (drug traffickers). PAULINO

also offered to introduce a Colombian source of supply for pink cocaine in the Miami area that he

knows separately. Based on experience and training and prior communications with PAULINO,

22
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 23 of 25

investigators believe that PAULINO was attempting to sell narcotics to UC-1 in an attempt to

recoup the money seized on May 9 for his Mexico-based drug suppliers.

57. At the end of the meeting UC-1 complained that PAULINO was not answering the

3922 Phone in a timely manner. PAULINO stated that he does not always check the 3922 Phone.

PAULINO then asked UC-1 to communicate with PAULINO on the 8440 Phone if he cannot reach

PAULINO on the 3922 Phone. However, PAULINO stated that they would still use the 3922

Phone for “business,” which UC-1 understood to mean drug trafficking and money laundering.

UC-1 and PAULINO agreed that they would communicate further during the week on June 2 to

set up a cocaine transaction.

PAULINO Continued to Communicate With UC-1 and CW-1 About Future Narcotics Sales and
Provided CW-3 with a Free Sample of Suspected Cocaine.

58. In the days leading up to August 19, 2025, CW-1 and PAULINO exchanged calls

and text messages regarding future drug transactions. PAULINO agreed to provide CW-1 with a

free sample of cocaine in anticipation of future drug deals on behalf of CW-1. They agreed to

meet on August 19, 2025. CW-1 arranged for the drug sample pickup, but as described below,

CW-3 actually picked up the drug sample.

59. On August 19, 2025, prior to the arranged meeting with PAULINO, investigators

met with CW-3 at a predetermined location. Investigators searched CW-3 and his vehicle for

contraband and currency with negative results and equipped CW-3 with an audio/video recording

device. Investigators then surveilled CW-3 to the meeting location with PAULINO. Investigators

maintained surveillance around the planned meeting location.

60. At approximately 3:30 p.m., investigators observed PAULINO arrive at the

planned meeting location. PAULINO then entered CW-3’s vehicle. In lightly coded language,

23
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 24 of 25

CW-3 asked PAULINO how strong the cocaine was in case CW-3 wanted to cut it. PAULINO

stated that he did not know how strong the cocaine was, but that CW-3 should let him know if it

was good quality. PAULINO told CW-3 to test the cocaine and let PAULINO know if CW-3

needed more of it. PAULINO then exited CW-3’s vehicle and departed the area.

61. Investigators surveilled CW-3 back to the predetermined location. At the meeting

location, CW-3 turned over the suspected cocaine to investigators. Investigators searched CW-3

and CW-3’s vehicle for contraband and currency with negative results. Investigators conducted a

field test of the suspected cocaine, and it returned a positive result for the presence of cocaine.

Based on experience and training, the physical appearance of the substance, and the positive field

test, investigators believe the substance contains cocaine. The suspected cocaine was sent to the

DEA laboratory for testing and the results are pending.

62. During the weeks of November 3 and 10, 2025, UC-1 and CW-1 continued

communicating with PAULINO regarding a future cocaine purchase. During these discussions,

in lightly coded language, PAULINO stated that he could sell one kilogram of cocaine for $15,500

to be paid through cryptocurrency. PAULINO stated that the deal would have to take place in

New York and that PAULINO would put UC-1 in contact with a New York-based drug courier to

complete the sale and that PAULINO would provide a cryptocurrency wallet to receive the

cryptocurrency payment for the cocaine. As of November 13, 2025, PAULINO informed CW-1

that PAULINO’s source of cocaine was not responding to PAULINO’s phone calls. PAULINO

stated that he owed the IRS $88,000 related to the May money seizure described above and that

he feared going to jail for tax evasion. PAULINO stated that he planned to leave the United States

and travel to the Dominican Republic to avoid these potential criminal tax charges.

24
Case 1:25-mj-06667-MPK Document 3-1 Filed 11/14/25 Page 25 of 25

Conclusion

63. Based on the foregoing, there is probable cause to believe that PAULINO

committed the Charged Offense.

Respectfully submitted,

/s/ John A. Bartolomucci

John A. Bartolomucci, Task Force Officer
Federal Bureau of Investigation

Sworn to telephonically in accordance with Federal Rule of Criminal Procedure

14
4.1 on November ____, 2025.

_________________________________________
Hon. M. Page Kelley
United States Magistrate Judge

File and source

File: 3-att1.pdf
Size: 221,191 bytes
SHA-256: 96469edcf9eda0c56039308425954fab250642fd32c5d04509ae34ffbaf89f9a
Our copy: 3-att1.pdf
Original: No public link identified.