Professional Documents
Culture Documents
vs.
Defendant.
1. Did this matter originate from a matter pending in the Northern Region of the United States
Attorney's Office prior to October 14, 2003? 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 September 1, 2007? Yes X No
Respectfully submitted,
WIFREDO A. FERER
ACTING UNITED STATES ATTORNEY
BY:
RICHARD D. GREGOl
Ul
ASSISTANT UNITED STATES ATTORNEY
Florida Bar No.549495
99 N. E. 4th Street, 7th Floor
Miami, Florida 33132-2111
TEL (305) 961-9148
FAX (305) 536-7213
Case 1:10-mj-03468-AMS Document 1 Entered on FLSD Docket 10/26/2010 Page 2 of 11
/o - zvcv-JMS
vs.
) Case No.
RAFAEL RAMOS DE LA ROSA )
)
Defendant
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date of i2m/2oo9-io/24/2oioin the county of Miami-Dade in the Southern District of
Florida , the defendant violated Title 18 U. S. C. § 1951 and 1952 , an offense described as follows:
Conspiracy to and attempt to interfere with interstate and foreign commerce under color of official right and by
wrongful use of fear of economic harm, in violation of Title 18, United States Code, Section 1951(a) and Interstate
and foreign travel and use of facilities, including e-mail, to promote, manage and carry on the unlawful activity of
extortion, in violation of Title 18, United States Code, Section 1952.
Complainant's signature
ATTACHMENT A
Case 1:10-mj-03468-AMS Document 1 Entered on FLSD Docket 10/26/2010 Page 4 of 11
the Miami, Florida Field Division. I have been a Special Agent with the FBI for approximately
three years and have been assigned to the Miami Division for all three years, during which time I
have personally been involved in the investigation of Rafael Ramos and others for conspiracy to
interfere with interstate commerce under color of official right and wrongful use of fear of
economic harm.
2. This affidavit is provided for the limited purpose of establishing probable cause to
support the attached criminal complaint against Rafael Ramos. I have not included all details of
all aspects of this investigation, but rather have set forth only those facts that I believe are
necessary to establish probable cause. The information in this affidavit is based upon my
personal knowledge as well as information 1 have obtained from other law enforcement agents
and officers, including cooperating witnesses, consensually recorded conversations, and from a
VIOLATIONS OF LAW
3. The facts and circumstances set forth below in this affidavit demonstrate that there is
probable cause to believe that Rafael Ramos De La Rosa (hereinafter referred to as "Ramos")
a. Conspiracy to and attempt to interfere with interstate and foreign commerce under
color of official right and by wrongful use of fear of economic harm, in violation of Title 18,
1
Case 1:10-mj-03468-AMS Document 1 Entered on FLSD Docket 10/26/2010 Page 5 of 11
b. Interstate and foreign travel and use of facilities, including e-mail, to promote,
manage and carry on the unlawful activity of extortion, in violation of Title 18, United States
previous owner of Venezuela based securities firm Uno Valores. In early December 2009,
Vasquez left Venezuela for the United Slates due to a relationship he had with Venezuelan
citizen, Eligio Cedeno. Cedeno had tied Venezuela because he had been put in jail by the
Chavez regime. He was subsequently released by a Venezuelan Judge. That Judge was then
jailed for releasing him. Cedeno is currently in the United States and applying for political
5. From or about December 17, 2009 Vasquez learned Uno Valores was taken over by
the Comision Nacional De Valores (CNV). CNV is the Venezuelan securities commission.
Overseeing the receivership of Uno Valores for CNV was Tomas Sanchez Mejias (hereinafter
referred to as "Sanchez"). Sanchez then was responsible for the appointment of Ramos to
contact with Ramos regarding Uno Valores. These conversations pertained to business-related
conversations.
7. In or about April 2010, Vasquez personally met with Ramos. Vasquez met Ramos at
the Ritz Carlton I lotel in Coconut Grove. Florida. Also present at the meeting was Vasquez's
Valores. At the end of the meeting, Ramos told Vasquez that he( Vasquez) needed to speak to
Araujo as he(Araujo) had something to tell him. Ramos left the meeting and Araujo told
Vasquez that he(Vasquez) needed to give Ramos and Sanchez two million dollars. After
Vasquez spoke with Araujo, the two million dollars was reduced to one and a half million
dollars. This money was for Sanchez and Ramos to write a good report on behalf of Uno
Valores. If Vasquez refused to pay, Sanchez would write a bad report on the company and it
would be subsequently liquidated and Vasquez's reputation would be ruined in Venezuela and he
8. On May 24. 2010, Vasquez and Araujo again met Ramos to speak about Uno Valores.
This meeting took place at the Novecento Restaurant in Miami, Florida. The conversation was
about Uno Valores and its daily operations. At the end of the meeting, Ramos told Vasquez that
they needed to resolve what Vasquez had spoken to Araujo about, the $1,500,000.00 payment.
9. During the course of investigation by the FBI, two (2) search warrants were issued by
the United States District Court in Miami. The first search warrant was issued by Magistrate
Judge Edwin G. Torres on September 9, 2010. authorizing the search of the Google e-mail
account ofadrianagrillet@gmail.com for the period December 1, 2009 until September 19, 2010.
The second search warrant was issued by Magistrate Judge Robert L. Dube on September 21,
2010, authorizing the search of the Google e-mail account rafahramos@gmail.com for the period
December 1, 2009 until September 21, 2010. The results of those search warrants are referred to
10. Recorded telephone and personal conversations referred to in this affidavit were in
I Case 1:10-mj-03468-AMS Document 1 Entered on FLSD Docket 10/26/2010 Page 7 of 11
11. On June 10. 2010, Vasquez received a telephone call from Ramos. Ramos requested
that Vasquez meet him at the Warwick Hotel in New York for breakfast. Vasquez flew from
Miami to New York to meet with Ramos for breakfast. At the end of the meeting. Ramos asked
Vasquez why he(Vasquez) had not paid the money to Sanchez and him(Ramos). Ramos advised
Vasquez that Sanchez was going to be good to him by writing a positive report for Uno Valores.
Ramos advised Vasquez that he had sent Araujo the instructions on how to send the money.
12. On August 1, 2010, Araujo spoke telephonically with Vasquez and said that he needed
to send a $50,000 check to Adriana Grillet. Araujo provided a telephone number to call once
the check was drawn so that someone could come pick it up. After the $50,000 check was drawn
then the remainder of the one and a half million was still to be sent.
13. On August 2, 2010, Vasquez spoke telephonically with Araujo. Araujo advised that
he needed to send the money. Vasquez was also contacted by Ramos who stated that he needed
the check as well as the remainder of the money sent to him. Ramos provided Vasquez bank
14. On August 2, 2010, RAMOS sent an email to ARAUJO directing ARAUJO to have
VASQUEZ deposit funds into the account of Bank of America, Jodshad Jewels Investments
LLC, 3440 Hollywood Blvd, Suite 415. Hollywood, FL 33021, Account number: 229028072396,
15. On April 14, 2010, menujinshadah@vahoo.es sent RAMOS an E-mail with the
SUITE 415, HOLLYWOOD, FL 33021. Captioned E-mail was discovered pursuant to a search
warrant issued by the Southern District of Florida on September 21, 2010, for Ramos' e-mail
account rafahramos@gmail.com.
Jewels Investments LLC to be a registered limited liability corporation in the State of Florida.
Jodshad Investments LLC is registered with the following: Address: 3440 Hollywood Blvd,
fourth floor, Suite 415, Hollywood, Fl 33021; Registered Agents: Menujin Shadah and Herman
Shadah.
him to make two transfers equaling $150,000.00 into the bank accounts owned by RAMOS.
requesting him to make one transfer of $150,000.00 into one bank account owned by RAMOS.
RAMOS also advised in the e-mail that he would notify menuiinshadah@vahoo.es when
requesting him to make one transfer in the amount of $150,000.00 to an account in the Cayman
Islands. Ramos advised menuiinshadah@vahoo.es that he would let him know when he was
20. On May 04, 2010, Ramos sent an e-mail to menuiinshadah@vahoo.es. requesting (1)
$100,000.00 transfer into an account in Ramos' name in the Cayman Islands; (2) $70,000.00
transfer into an account in the name of Juna Carlos Gonzalez Gonzalez in Panama (3) $60,000.00
in cash in Caracas and (4) Ramos stated that the difference of $400,000.00 is $20,000.00, of
Case 1:10-mj-03468-AMS Document 1 Entered on FLSD Docket 10/26/2010 Page 9 of 11
which $ 10,000.00 is for menuiinshadah@vahoo.es. Ramos then advised that the rest
21. On April 14, 2010, menuiinshadah@vahoo.es sent RAMOS an E-mail with the
i
following information: BANK OF AMERICA; ABA: 026009593; ACC: 229028072396; I
I
BENEF: JODSHAD JEWELS INVESTMENTS LLC; ADDRESS: 3440 HOLLYWOOD BLVD ;
SUITE 415, HOLLYWOOD, FL 33021. Captioned E-mail was discovered pursuant to a search
warrant issued by the Southern District of Florida on September 30, 2010, for Ramos' e-mail
account rafahramos@gmail.com.
22. On August 03, 2010, at approximately 2:58 P.M., Araujo sent Vasquez an e-mail with
23. On August 04, 2010, Vasquez sent Ramos the following text message at
approximately 3:02 P.M.: "Hello Rafael, I'll be calling you, I'm waiting for the check to give it to •
you". Ramos responded to Vasquez at approximately 3:05 P.M., via text message, and stated:
"Please, when you have it, call Adriana Grillet directly (305/613-7076) and set something up
with her. Let me know." At approximately 3:10 P.M., Araujo sent Vasquez a text message (
i
stating: "I've just been called again by Mrs. Grillet who does not understand the delay. That she's \
been waiting for this since yesterday at 10 AM." At approximately 5:35 P.M., Ramos sent I
l
Vasquez a text message stating: "What's wrong? Something so easy and you don't do it? If \
you're not going to do it, just tell me." Vasquez responded to Ramos at approximately 8:41 P.M.,
via text message, stating: "Rafael, I'm going to do it but they notified me yesterday and I asked
Case 1:10-mj-03468-AMS Document 1 Entered on FLSD Docket 10/26/2010 Page 10 of 11
someone to do me the favor. I can't do it on my end. They're going to give it to me and I'll call
24. On August 05, 2010. at approximately 12:24 P.M.. Vasquez sent Ramos the following
text message: "Dr Ramos, I'll call you tomorrow in the morning. I'm with my family and I left
my agenda in the house. There are several points that have to be reviewed. Please forgive me.
Tomorrow I'll call you and we'll settle things. I'm a little far from home." Vasquez sent another
text message to Ramos at approximately 12:25 P.M. stating: "Doctor Ramos, We can talk this
evening to fix what's pending." Ramos responded to Vasquez at approximately 12:47 P.M.
slating: "Time's up. If Adriana does not receive what was agreed upon by TODAY and,
moreover, you make the transfer to where Rolando (Araujo) knows, there will be NO further
conversations. Don't send messages." Vasquez responded to Ramos at approximately 2:02 P.M.
stating: "Please, if you can, have the American telephone, here where I'm at I can't talk, there's at
25. On August 9, 2010, Vasquez and Ramos spoke via cellular phone. The conversation
was recorded. Vasquez apologized to Ramos for not having paid him and asked Ramos to come
to the United States for the coming weekend. Ramos told Vasquez he would attempt to travel to
the U.S. the coming Saturday. Ramos again expressed the need for Vasquez to pay Grillet.
Ramos told Vasquez that he (Ramos) would not speak with Vasquez again until Vasquez pays
Grillet..
26. On August 10, 2010 Grillet sent Ramos an e-mail, via adrianaGrillet@gmail.com.
The e-mail account for Grillet was searched pursuant to a search warrant signed and issued in the
rafahRamos@gmail.com stating that she has purchased a Land Rover, but is facing penalties for
not paying the full amount of the vehicle. She offered Ramos two options which include 1) he
does not get paid and she cancels the vehicle purchase or 2) Ramos believes he will be paid and
she asks for an extension on final payment. Ramos responds to Grillet, via e-mail, stating he has
talked to "Tomas V" and that he (Tomas V) wants to speak with Ramos in person. Ramos
advised Grillet to call him (Vasquez) and supplies her with Vasquez's cellular phone number.
Ramos advises Grillet to tell Vasquez that if he does not pay by tomorrow, he (Vasquez) can
forget about Ramos traveling to see him. Ramos further advised Grillet not to give him any
options. Ramos then advised Grillet that if Vasquez does not resolve things by tomorrow, she
should pay the penalty regarding the Land Rover. Ramos further stated that more opportunities
will continue to exist in the future and that Vasquez will have to pay sooner or later.
27. On August 11, 2010, Vasquez met with his uncle, Araujo, at the Starbucks Cafe in
Sunny Isles, Florida to discuss the extortion of Vasquez by Venezuelans Ramos and Sanchez.
Araujo had been in contact with Ramos recently. Araujo told Vasquez that Ramos wanted
Vasquez to pay Adriana Grillet $50,000.00. Araujo explained the $50,000.00 was a good faith
payment towards Ramos. Araujo also explained that Grillet would accept part of the
$1,500,000.00 payment for Ramos. Vasquez told Araujo he did not know about the $50,000.00
good faith payment, but would think about it. Araujo urged Vasquez to contact Grillet
telephonically to discuss the issue. Araujo additionally warned Grillet has access to many
members of the Miami, Florida media and would drag Vasquez' name through the mud. Araujo
28. Vasquez told Araujo he would pay the $1,500,000.00 to Ramos and Sanchez, but
wanted Ramos and Sanchez to travel to Miami, Florida to make the payment. Vasquez further
advised he would want Ramos and Sanchez to provide him with the report indicating Vasquez
would get his company, Uno Valores, returned to him. Araujo told Vasquez that he mentioned
this to Ramos and Ramos advised that Sanchez would be traveling to Miami, Florida in
approximately 10 days for vacation. During this vacation, Ramos and Sanchez would meet with
Vasquez to receive the final payment and give Vasquez his report.
29. Vasquez also told Araujo that he was serious about paying Ramos and Sanchez the
$1,500,000.00 and had already obtained a cashier's check in the amount of $1,500,000.00 made
out to cash. Vasquez told Araujo he would show him the check tomorrow (August 12, 2010)
during their meeting. Araujo and Vasquez agreed to meet on August 12, 2010 at approximately
30. On August 12, 2010, Vasquez contacted Grillet telephonically. The conversation was
recorded and contained the following: Vasquez introduced himself to Grillet and she told him he
was not easy to contact. Vasquez responded to Grillet "Yes, yes, it would be nice if you told
Rafael [RamosJ that, that 1 called you. 1 m... I met with Rolando [Araujo] last night and he told
me that you had talked to him, that you have ca... that you have called him several times. As a
matter of fact Rolando [Araujo] felt a little uncomfortable because he felt somewhat pressured.
Rolando told me on Monday of last week that he had to hand you a $50,000 check—the truth is
that I had not been told, I was not even ready. Then I talked to Rafael [Ramos] and he told me to
hand you the $50,000 check, on your name". Vasquez further explained to Grillet that Araujo
31. Grillet responded to Vasquez stating "I believe that you have to understand all this
because this is something that you have discussed previously with Rafael [Ramos]. Rafael
j [Ramos] is not going to ask him to hand over that for nothing, I, I, I know Rafael [Ramos] hum,
i he is like family but I know that he told me if it was a small debt and I told him that there was no
! problem that if I had to pay something for him, to give it to me, I have a company and I'll put
whatever and pay whatever has to be paid and that's that." Vasquez responded to Grillet telling
her he would attempt to square things with her. Vasquez further stated he thought there may be a
misunderstanding and told Grillet "I have some money for him, which he is asking for, and I am
going to, I want to give it to him directly, then they called me to ask for a check and the truth is
that I didn't know how to give you a check too. I was a little confused on giving you a check and
giving a check, I mean, I wanted to give him the money. Then they told me to put some money
on the side of that money and give it to you. And when I talked to Rolando | Araujo] yesterday
Rolando | Araujo] told me that he was worried because you had some ties with communication or
something like that and to please resolve what was yours because you were so mad that you
32. Grillet responded to Vasquez stating "Uh...I don't know what you are talking about.
Excuse me, but I have no idea what you are talking about. The only thing I know is that I was
going to take action. I don't know you but I know Rafael Ramos very well, he is like family to
me, I've known him for almost forty years. And Rafael [ Ramos | told me that you had to pay him
some money." Vasquez told Grillet he was calling her because Araujo did not want to be in the
middle of anything. Grillet responded stating "How's that he doesn't want to feel in the middle
of this? You do me a favor and you tell me how we are going to resolve this, you are going to
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give me a check from Rafael [Ramos], when do you want me to go and get it, how you want to
do it, as you want. But tell me what you are going to do, I'll call Rafael [Ramos] right now, he is
in his house and I'm going to tell him, "Rafael [Ramos], this man finally called me and he told
me this." That's it. That's it." Vasquez agreed that was the best course of action and Grillet
responded "1 don't want to hear any more tales or stories because I don't have to do anything
with this." Grillet told Vasquez he was supposed to have paid her two weeks ago. Vasquez told
Grillet he did not pay her because he was not ready, didn't have a check and/or couldn't give her a
check from his account. Vasquez told Grillet it would take time. Grillet responded stating
"Excuse, excuse me, today is Thursday. I have lived in this country for thirty-nine years—Here
you make a deposit today and if you have money you get a manager's check and it's in your
account in the afternoon. So it doesn't take that long. Mr. Tomas, excuse me, tell me, when can I
go to get Rafael's check so that I can call him right now and tell him that you called me and that
you are going to give me the check at this time? That's the only thing I want to know. I don't
want to know anything else about the situation or any of the stories you are telling me." Vasquez
told Grillet he would meet with Araujo and determine how to pay Grillet, but he asked Grillet to
tell Ramos that he (Vasquez) was attempting to fix the situation with Grillet.
33. On August 13, 2010, Grillet sent an e-mail to Ramos. Grillet told Ramos that she
spoke with Vasquez and that Vasquez attempted to act like he did not know her and did not want
to bother her. Grillet stated she believes Vasquez is a liar and that he is "terrified with fear."
34. On August 13, 2010, Vasquez spoke with Araujo telephonically via Araujo's cellular
phone. Araujo told Vasquez he was in touch with Grillet. Grillet told Araujo that she knew why
Vasquez owes money to Rafael Ramos. According to Vasquez, Grillet is acting as the middle
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man for Rafael Ramos. Ramos will not travel to the United States until Grillet is paid
$50,000.00. Because of Ramos' unwillingness to travel, Araujo gave Grillet the conditions in
which Vasquez will pay Ramos the requested funds. Araujo sent Grillet an email with Vasquez'
35. On August 16, 2010, Vasquez spoke with Araujo. He told Vasquez that he (Araujo)
previously met with Carlos Dorado. Dorado is a Venezuelan citizen who is being extorted by
Ramos. Araujo met with Dorado and Ramos to negotiate a deal between Dorado and Ramos.
36. Araujo confided in Vasquez that he (Araujo) did not feel very good after the first
meeting with Dorado. After the meeting. Araujo told Ramos he would not take part in any
additional meetings with Dorado. Araujo told Ramos he (Araujo) would continue to negotiate
37. According Araujo, he spoke to Adriana Grillet telephonically. Grillet asked Araujo
where the $50,000.00 payment from Vasquez was. Grillet told Araujo that the first $50,000.00
was not hard to get. Araujo was very confused by this statement and asked Vasquez if he had
paid Grillet $50,000.00. Vasquez told Araujo that he had not paid Grillet $50,000.00. Araujo
told Vasquez that Grillet must be referring to Dorado. Araujo believes Dorado paid a $50,000.00
down payment to Grillet on behalf of Ramos. Araujo advised Vasquez he spoke with Ramos.
Ramos and Sanchez will travel to the United States to meet with Vasquez. They intend to travel
38. On August 18, 2010, Vasquez contacted Araujo, via telephone. The conversation
was recorded. Details regarding the conversation are as follows: Vasquez expressed to Araujo
Case 1:10-mj-03468-AMS Document 1-1 Entered on FLSD Docket 10/26/2010 Page 5 of 10
that Ramos would not answer his calls. Araujo told Vasquez "The thing is he told me, 'Look, I
don't want to speak to him. Damn, because at the same time, damn! I don't know. I can be
compromised in some shit.'" Vasquez was surprised by this and Araujo responded stating "I
don't know if they check his phone or some shit like that, [but J he told me."
39. Vasquez asked Araujo about the report Ramos would be preparing regarding
Vasquez' securities company and Araujo stated he would ask Ramos about it. Araujo told
Vasquez that Ramos said "Tell him to count on me for all the cooperation. I don't have anything
with that asshole nor any preference for him or anything like that. I'll explain clearly to him what
he's doing and the agreement we're reaching with that guy; what we have agreed with him."
Vasquez then explained to Araujo "that's the case of Guanonieles, right?" Araujo confirmed that
was correct and Vasquez stated "Because they attempted to come to an agreement with him, but
I'm telling you about the report, because on the last message he send me when he called me on
the...he texted me; but afterwards he sent me, when he spoke to me he told me that, that he was
going to put 'salt and pepper' in the report according to how much money I was going to pay him.
Then that's when I told him...that's when, damn, I got really scared. Because obviously, I mean,
uh...he's..." Araujo confirmed this statement then stated "For sure. Damn, the, the, the last time
he told m. 'Damn! Tell him to take care of me. Shit, man! Damn, 1 have the freedom to do
whatever the hell I want with this shit.' So, 1 told him, 'Take it easy.' I told him 'Wait and see if I
40. Araujo told Vasquez he would call Ramos later and Vasquez expressed the
importance of Ramos bringing the report with him to the U.S. Vasquez told Araujo "No, it's that
to me the report is the most important thing, because I want to know what he... what he's going to
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bring me and what he's going to do. I'm going to pay him l .5 for that, for that report... Araujo
responded stating " Damn, buddy! Don't pay him yet, Tomas. Uh...listen to what I'm telling you.
Damn! I, I gave you good advice. Damn, if you give that to that man, that piece of shit will
disappear tomorrow. Damn, string him along and stuff." Vasquez responded " Yes, well...what
I'm interested in, buddy, for sure is to be able to, damn, return and to be able to keep on working
over in Venezuela. And that..that report is the only thing that's going to help us and he's
threatening me with that." Araujo remarked to Vasquez that Ramos has lowered his defense
because he (Ramos) decided to come to the U.S. Vasquez responded to Araujo "I...No, it's that
for me the fact that he had accepted coming is a good sign and if he comes with Sanchez, because
Sanchez doesn't face the music at all. He always says he speaks on his behalf, but the important
thing is that Sanchez definitively tells me he's going to...damn, he's going to let us, damn, retake
things, the company, all things. I mean, he's going to let us do things and not...". Vasquez and
Araujo spoke for several more minutes regarding Ramos' needs in payment and Ramos'
41. On August 19, 2010, Vasquez spoke with Ramos, via telephone. The conversation
was recorded. Details regarding the conversation are as follows: Vasquez explained his concern
I because Ramos would not answer his calls and Ramos stated he was busy. Vasquez told Ramos
"Yes, well...the only thing is the matter with Mrs Grillet, uh...Mr. Ramos I spoke to Rolando
i
!
! (Araujo) about that, then I met with him, I took the check to him...of what you asked me to...so I
told him, "Look, I already have the check." I'll give it to him, because I asked a friend of mine for
help, because I didn't have the cash available to give you what you had asked me. As a matter of
fact...in fact, I want to speak to you, because 1 wanted to have that done with. Then Rolando
!
| 14
t
; Case 1:10-mj-03468-AMS Document 1-1 Entered on FLSD Docket 10/26/2010 Page 7 of 10
j (Araujo) told me kind of not, kind of to do it in parts and I really want to finish with that matter,
i
\ with that..." To which Ramos responded "Let's finish with that matter once and for all."
\ 42. Vasquez explained to Ramos that he (Vasquez) needed to see the report because
Ramos is the person who decides what to put in the report. Ramos told Vasquez he would bring
a draft of the report with him when he visited Vasquez. Vasquez then explained to Ramos "All
I right, sir. I, I have the whole amount for you. I have the whole 1.5 that you asked me.
Uh...Rolando didn't want...because he...that's why I wanted to speak to you. I told him I wanted
to finish...to finish this thing with you. After that message you sent me, I really felt, uh...very,
very nervous, because I don't want to have any problems with you guys and...and for me...damn, I
know you have the power there and, and that's it. And that's it. 1 really don't want to get in trouble
with you guys." Ramos then told Vasquez "Okay. Well, okay, then, let's do it then. 1,1, I'll
43. Vasquez told Ramos "Okay. I asked, I asked Rolando something that's very important
to me and I also need to speak to him about other matters. But I want to be sure, damn! That, that
Tomas Sanchez is going to...I mean, is going to help us and later on is not going to screw us.
Because if you guys take him out of there afterwards, then another liquidator shows up or
whatever else you do, then I really, I really want to speak to him. Because I...have done this with
a lot of effort and because of this pressure I [UI] the money to be able to give it to you, but
Rolando is on one side telling me one thing and the pressure I have from the clients, and I really
just want to resolve this matter and I don't want to be...I don't want to be damaged any longer.
Mr. Ramos, I just want to return to Venezuela and I don't want to be in this situation anymore."
Ramos' reply to Vasquez is "No, it's all right. What I can do is...eventually...perhaps
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Case 1:10-mj-03468-AMS Document 1-1 Entered on FLSD Docket 10/26/2010 Page 8 of 10
mail with the draft." Vasquez and Ramos discuss how to send the report via e-mail and other
44. Vasquez then asked Ramos if Tomas Sanchez is coming. Ramos replied "No, no, no.
I'll have to keep him out of [stutters] this whole thing, because he's also tied up...they have him
involved in the political arena and a bunch of, and a bunch of circumstances where...he wants to
keep out of it all." Vasquez asked "And isn't there, isn't there another place where we can meet?
But I would really like to speak to him, because he's the one...he's the person...who can really
decide to leave us alone, "Damn! You can leave these people alone. You can't leave these ones
alone." I would really like to see him." Ramos again replied to Vasquez "Yes, no. But just
imagine...I don't think it's going to be possible at the beginning, because he's not, he's not going
to tell you either yes or no. In other words, in fact he'll...[coughs]...I mean, I'm going to write the
report, then the liquidation will be done according to the amounts I'll put down in the report, but
then...basically we're going to do it and liquidate the company, because there's no authority
present; there's no liquidity, bum-bum...I mean, the whole part...basically the capital and the
TV: Okay, but he...but Rolando told...Rolando had told me that from what I was
going to give to him...Tomas was...they were going to give him and that's what
RR: No, well...but I don't know why Rolando told you that, because I haven't spoken
TV: Hm.
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RR: I mean, I won't even involved him in that. I mean, remember that's a very
touchy subject.
TV: Okay.
RR: I mean, he...if he's going to receive something or if he's not going to receive
TV: You would do that, right? He wouldn't... You're going to do that, right?
RR: Yeah, that's not for him...I mean, that's like...if they find out then you're totally
fucked.
45. On August 23, 2010, Vasquez spoke with Araujo, via telephone. The conversation
was recorded. Details regarding the conversation are as follows: Araujo had spoken with Ramos
and Ramos was going to let him know if he (Ramos) would be traveling to Miami soon. Ramos
had asked Araujo if Vasquez had "come through" for Grillet. Araujo told Ramos he did not
46. On August 24, 2010, Vasquez spoke with Ramos, via telephone. Agents attempted
to record the conversation, but the recording device suffered from a "PF." My understanding of a
PF is it indicates a power failure. Prior to suffering from a PF, the device captured seven seconds
of recording. Vasquez reported the conversation containing the following: Ramos and Sanchez
intend to travel to Miami on August 27, 2010 and will be staying at the Hotel Mandarin. Ramos
and Sanchez will meet with Vasquez on August 28, 2010. Ramos confirmed that the check
required of Vasquez should be made payable to Jodshad Jewels Investments. Vasquez also
17
Case 1:10-mj-03468-AMS Document 1-1 Entered on FLSD Docket 10/26/2010 Page 10 of 10
Hollywood, FL 33021 \
47. The report, requested by Vasquez, was originally going to be sent on 08/24/2010 or j
08/25/2010. According to Ramos, the report is complete. Vasquez requested that the report be
sent via email, so that he has sufficient time to review it, prior to the arrival of Ramos and
Sanchez.
48. Ramos indicated that he was not acting on his own accord, but under the direction of j
the President of the Comision Nacional de Valores (CNV), who is Tomas Sanchez. Ramos j
stated that the 'Taliban' (a name used to represent the radical members of the CNV) were putting j
a lot of pressure on the owners and presidents of other brokerage firms, for having denounced i
various members of the Venezuelan government. Vasquez stated that they are placing presidents
of various 'Casas de Bolsa' or brokerage firms, in jail without cause or recourse. Tomas Sanchez
is not only the President of the CNV, but is also the 'Superintendente de Valores de Venezuela' or
49. On August 26, 2010, Ramos sent Grillet an e-mail instructing her to forward a report j
i
entitled Uno Valores to popv85@hushmail.com (Vasquez's e-mail address). Vasquez instructed \
Grillet to remove his name from the e-mail. Ramos also instructed Grillet to notify him when the
e-mail was sent. Ramos attached report to the e-mail and the e-mail was titled 'TNFORME
borrador."
50. On August 27, 2010, Ramos arrived at the Miami International Airport. Ramos was
surveilled by the FBI. He arrived with two females. Ramos and the females were picked up in \
51. On August 27, 2010, Vasquez spoke telephonically with Ramos. The conversation
was recorded and contained the following: Ramos asked Vasquez if he received the e-mail.
Vasquez said that he did not open the e-mail and Ramos tells him that Adriana sent it to him.
Vasquez then asks if the Tocaya came to which Ramos replies "No, no, no, forget about that,
what he wants is blood....I will explain it to you once, once we'll talk." Ramos and Vasquez then
52. On August 28, 2010, Vasquez received an e-mail from Grillet, via e-mail account
AdrianaGrillet@gmail.com. The e-mail was titled kiNFORME borrador" (DRAFT report). The
e-mail was sent at 2:03 P.M. and contained an attachment with a Microsoft word document. The
document was a partially completed report pertaining to Vasquez's company Uno Valores.
53. On August 28, 2010, Vasquez conducted a consensual recording while meeting
Ramos at the Mandarin Hotel in Miami, Florida. During their conversation, Ramos and Vasquez
discussed many issues regarding Venezuelan businesses, businessmen and the current
Venezuelan Government. At several points, the conversation focused on the issue between
54. TV: Yes, but in the current Chavez' anarchy, he's finishing off the country.
RR: He's finishing off the country. That's his objective. And he's fulfilling [his
objective).
TV: Of course. And the problem is that sadly, Rafael, ever...people are, are allowing
him to do it.
RR: And they're going to continue to do it. But then you have to...once in your life,
[you have to] "put your feet on the ground and see what's my problem and
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Case 1:10-mj-03468-AMS Document 1-2 Entered on FLSD Docket 10/26/2010 Page 2 of 13
what's my...how am I going to resolve this?" Not what could have been... in
other words, you have to play it by ear. You could be a great tango dancer, but
if they're playing salsa, you can't do the tango. "Oh, no. We're in Argentina and
it's Carlos Gardel's anniversary." No, no, no, right now the orchestra is playing
salsa, we have to dance salsa. You have to understand that shit. You have to
say, "How am I going to get out of this mess?" The best way possible.
TV: Okay. That's, that's, that's one of the things when I spoke to you the last time...I
don't know, uh, I felt...I saw...the first time we spoke, we spoke over there
when we went, when you went to Coral Gables...and we met in the hotel. I was
interested in speaking to you, because [UI] the company belongs to us, because
RR: Of course.
TV: And the, and the reason was to meet with you, because there was an important
matter to discuss, to learn the company's situation, to see what have been done
[about it] and what hadn't been done [about it]. Rolando speaks to me...when
we left that meeting and Rolando tells me, well that you spoke to him and that I
RR: Hm.
TV: And he asks me right then and there to give him two million dollars.
RR: Well, I didn't approach it like that, but he approached it like that. It doesn't
matter.
TV: Of course. And I told him...and I...and he tells me, "Damn, look...we have to
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Case 1:10-mj-03468-AMS Document 1-2 Entered on FLSD Docket 10/26/2010 Page 3 of 13
give this money to Rafael." So, I...spoke a lot...spoke several times with, with
Rolando about this and Rolando went as far as taking the [UI] away from me,
Rafael.
RR: Of course. The thing is that, at that moment, the problem is that...time passes
and if we would have resolved that problem at that time, we would have cashed
some securities right then and there, [then] we wouldn't have gotten the other
crisis of the brokerage firms. Then that would have been a case of
would be speaking about you now, the way nobody speaks about the guys from
the Bank of the 94. The flavor of the month are the banks of 2009. The ones
from the 94 are no longer in, so nobody would say anything like nobody says
anything about the 21, nobody would say anything about the securities. Then,
because they're speaking about Colinven [PH], they are talking about Bamplo
[PH]. They're speaking about all that shit. Then, that's the country. Then, we
55. Vasquez and Ramos continued their discussion surrounding the situation in
TV: That's the hurdle I have here. So, with so much pressure, with so many
problems I was able to get... No, Rolando told me to give you a million and a
half dollars. I put together and I took it to him and I told him, "Look,
here's the check. Right here. A million and a half dollars. I had the check made
according to the instructions you gave me." Rafael, 1 don't want you to screw
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Case 1:10-mj-03468-AMS Document 1-2 Entered on FLSD Docket 10/26/2010 Page 4 of 13
me, [I don't want] Tomas Sanchez to screw me, because Tomas Sanchez has
RR: No, it's that look...don't expect any help...from Tomas Sanchez and I'm being
honest with you. Tomas Sanchez is not going to help anybody. I mean, he
[clears throat] he's not going to contradict what I'll say or what I'll do. But he's
TV: Uh-huh. But that's where I'm telling Rolando. I mean, I told him. "Here's the
check. I already have the money available to give it to Rafael. I don't want
problems with Rafael and I don't want any more trouble." Uh...and I told
Rolando...I told him, "Damn! Here it is. I'm not... Oh, because there was a
problem with the 50,000 dollars' check you wanted me to pay Adriana Grillet
[PH]." I told him, "I don't know Adriana Grillet." Rafael called me. He asked
me to deposit some money in her account, but I have a check to give to him for
a certain amount and I, and I can't [UI] the check nor give her...nor I'm going to
pay somebody without knowing the reason why. I don't have to give one of my
checks to anybody. At the time, I didn't even have a way to give a check with
50,000 dollars to anybody and that lady treated my like... Well, she...
RR: [OV] I don't know what she spoke to Rolando about, but...
TV: ...she, she, she told me some bull but and I don't even know her.
RR: The only thing I told her was simply this...for an operation she had to do. But
let me tell you, I don't know what she spoke to Rolando about. Because
afterwards she told me, "No, this man who owes you, I told him to pay you
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Case 1:10-mj-03468-AMS Document 1 -2 Entered on FLSD Docket 10/26/2010 Page 5 of 13
what he owed you." I told him, "That man doesn't owe me a cent. I have never
TV: Of course, but she told me I had to give her the 50,000 dollars. And that was a
mess. I told her, "Look, I didn't want to have..." I didn't want any problems
with, uh,..you and that's the truth. So, I told Rolando. "Rolando, don't have me
don't have to speak with anybody else." So, he calmed down when I took the
check to Rolando. He told me, "Okay. I'm not stressed anymore." Now, he told
me since the first time we met, that from the money we were going to give you,
TV: But that's your problem. But... Of course, but Rafael...I'll...I'll give you one and
a half million dollars. You have the power to create a, a report in which you
could directly plunge me into an astronomical problem or you could state that
the company that's going to go out of business and later on I'll face the music.
RR: Exactly. The, the idea is...I mean, you're going to...what I can give you is a
TV: Okay.
56. Vasquez and Ramos continue their discussion about the financial affairs of Vasquez's
situation in Venezuelan, Tomas Sanchez and the current regime. Vasquez returns the
TV: Rafael, with your signature, you have the ability to send me straight into
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RR: Tomas is [stutters] [UI] he's the devil. We have spent 8 months and we haven't
blown the whistle. But we haven't blown the whistle, but we haven't blown the
whistle on the commission either. 1 mean, he would have to explain now, the
reason why he's blowing the whistle now and why he didn't do it before.
TV: Hm-mm.
RR: Or why is he going to blow the whistle, uh..when the report doesn't require it or
TV: Hm-mm.
RR: I mean, the most probable is that this one and this is my intention...that the
matter stays as such. We'll do it. We'll liquidate the matter and that's it.
RR: Just imagine, people...the people from the savings banks haven't made any
either. Then, on the other side that's...that's also fair. Why am I going to make
57. Vasquez and Ramos again turn to affairs regarding the Vasquez's business stating:
TV: Yes. Look, Rafael, I don't, I don't, I don't want to condition you or anything, but
if I did something was...really, and I'm telling you I'm afraid. I went into this
afraid. I told Rolando, "I don't want to have problems and I don't want them to
screw me." I told him that, "I don't think [UI] will screw me, because
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Case 1:10-mj-03468-AMS Document 1-2 Entered on FLSD Docket 10/26/2010 Page 7 of 13
[stutters]."
RR: And I think Tomas won't either. But first of all, you can't discuss money with
Tomas. [UI].
TV: No, because the money...if you're going to talk about the money, you're going
TV: No, the thing is I don't want to speak to him about money. The thing is. I don't
even...
RR: [OV| If the meeting takes place, then tell him, "what I want is to discuss
TV: Rafael, I...not ev....I had the first meeting with you. The second and third time,
I have never spoken to him about money. Rolando was the one who brought up
the money. I have never come here to tell you I was going to give you money...
RR: Yes, because he's very serious and he belongs to Giordani's [PH] group. He's
RR: They have told him something for sure and stuff and he hasn't had any qualms
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Case 1:10-mj-03468-AMS Document 1-2 Entered on FLSD Docket 10/26/2010 Page 8 of 13
about placing himself correctly with the government and doing their bidding.
RR: [SC] [UI]. If we get to...[UI] that behavior where you believe you are...[UI] the
change. I can outline it, but...but I'm telling you...I need to resolve this issue
with you in this trip. Where...let's say, because I have to turn in the report next
week. I have to know what report I'm going to turn in and I can't change my
mind after I turn it in. Then I'm going to be at risk, I could be labeled as your
accomplice and then I'm going to run the risk of, of, of...being your
accomplice...
TV: But why? But why, why your accomplice, Rafael? Because...
TV: Hm-mm.
RR: Huh?
RR: With me. They would be happy. The Prosecution would be happy and then...the
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Case 1:10-mj-03468-AMS Document 1-2 Entered on FLSD Docket 10/26/2010 Page 9 of 13 i
TV: Hm. I
!
RR: Because if I do something...my attorneys are not...[UI] "Chavistas" nor kids just ;
fresh out of college. Then, that will probably be an issue that...will go beyond j
i
that. If they're looking for someone, I don't want them to...be...precisely you are
RR: [UI]. "Oh", you tell me, "We're talking about an amount?". "All right." We j
can...we can go little by little. So you tell me, "Fine. It's all right." [UI] right
now, half of it and the other half when we speak to Tomas or when the |
T V : Yo u ' r e g o i n g t o r e m a i n h e r e u n t i l I u e s d a y, r i g h t ? t i
RR: Until Tu e s d a y. j
RR: No, I believe this is a fair solution for both of us. Take half and the other half.
If the commission doesn't make any changes in the report I'll turn in, then
[clears throat] the commission will come to make a report; like saying [UI]
because you made the accusation, we're going to make the accusation. "Oh, %
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Case 1:10-mj-03468-AMS Document 1-2 Entered on FLSD Docket 10/26/2010 Page 10 of 13
peremptory...time [UI].
TV: Can you speak to, to, to Tomas to see if he can see me?
RR: I can call him. but there's no guarantees. First of all, I don't think he'll dare
travel now.
TV: Well, I could go somewhere else. I can go somewhere else, but believe me...it's
important to me. Rolando told me something and in fact, he, he sold something
Rafael. Believe me, me, I'm sufficiently damaged. I don't want to hurt anybody
i else.
j RR: [OV] I understand your position. But let me tell you, I'm not going to tell you
I
I one thing, "Yes, we're going to speak. Come over...Tomas will come over next
I
j week..." And...Tomas never shows up. Or, or he shows up and then he tells you
I the opposite of what I told you, or he tells you. "Look, he gave me a copy of the
report." So...next week, then the report is something else. To make it different,
1 they change style to the draft or....something, so the attachments will be in
pay the $50,000. Vasquez stated that he is trying to explain this to Ramos and Sanchez and asks
59. On September 14, 2010, Grillet forwarded the message from Vasquez to Ramos.
i Ramos responded to Grillet advising her to send a message that she does not know what he
i (Vasquez) is talking about and if you have a message for Ramos, send it through Rolando
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(Araujo) and do not use my (Grillet's) email address again. Grillet cut and pasted the reply and
sent it to Vasquez.
60. On September 14, 2010, Vasquez spoke with Araujo. Araujo advised that Ramos
wants Vasquez to pay by Friday, September 17, 2010, Ramos is going to come for him and
61. On or about September 24, 2010. Vasquez spoke with Araujo. Araujo advised that
the only way Ramos will return to Miami, is if Vasquez deposits $750,000.00 into an account in
Araujo's name. The additional $750,000.00 will be paid to Ramos upon his arrival to Miami.
62. On or about September 26, 2010, Vasquez, with the assistance of FBI Miami
division, led Araujo to believe that he had an active account containing $750,000.00. FBI Miami
provided Vasquez with a bank statement reflecting $750,000.00 in an account in the name of
Araujo. Vasquez scanned the document, e-mailed it to Araujo for delivery to Ramos.
63. On October 21. 2010, Rafael Ramos flew from Venezuela to Miami, Florida. He
was picked up at the airport by Adriana Grillet in a black Land Rover automobile.
64. On October 22. 2010, Vasquez spoke with Araujo at approximately 11:30 A.M.
Araujo advised Vasquez that no meeting would take place with Ramos because Ramos was
65. Later on October 22, 2010, Vasquez spoke again to Araujo and Araujo advised that
the meeting with Ramos would be delayed until October 23, 2010.
66. On October 23, 2010, Vasquez spoke again with Araujo in the morning and Araujo
explained that Ramos would not meet with Vasquez until$325,000.00 was transferred into the
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Jodshad Jewels Investments LLC bank account. After the $325,000.00 was transferred into the
account, Vasquez was expected to bring a check in the amount of $750,000.00 and wire transfer
an additional $325,000.00 to the account previously stated, Jodshad Jewels Investments LLC, in
67. At approximately 12:23 P.M. on October 23, 2010, Vasquez spoke to Araujo.
Araujo advised that he was meeting with Ramos at 2:00 P.M. and would call Vasquez after the
meeting.
68. At approximately 2:30 P.M on October 23, 2010. Vasquez spoke with Araujo and
Araujo said that the meeting with Ramos was moved to 4:00 P.M.
69. Vasquez contacted Araujo at approximately 6:30 P.M. and Araujo advised Vasquez
that Ramos would not meet with Vasquez personally, but that he (Ramos) would accept the
.i
check from Araujo. Vasquez then requested to meet with Araujo immediately to give him the f
$750,000.00 check. I
70. At approximately 8:00 P.M., the undersigned FBI agent and other agents approached
Araujo and requested his cooperation. Araujo agreed and consented to record his conversations
telephonically and in person with Ramos. Araujo additionally advised that he had met with
71. Araujo placed a consensually recorded phone call to Ramos wherein he agreed to
bring the check to Ramos immediately because he was leaving for Orlando, Florida the next day.
Ramos agreed to meet Araujo in the lobby of the Viceroy Hotel in downtown Miami, Florida.
72. At approximately 10:00 P.M. Araujo met Ramos in the lobby of the Viceroy hotel
and conducted a consensual ly recorded conversation. Araujo gave Ramos the $750,000.00 check
30
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made out to Jodshad Jewels Investments LLC as directed by Ramos. Upon conclusion of the
meeting, Ramos was approached by the undersigned FBI agent and other agents. Ramos agreed
73. Upon arriving at the back of the hotel, Ramos withdrew the $750,000.00 check from
his front left pocket, voluntarily, and turned it over to the FBI. Ramos agreed to talk to the FBI
and was taken to the FBI office. He was not placed in handcuffs, but was searched for weapons.
At the FBI, Ramos was advised of his Miranda rights and admitted to taking part in extorting
Tomas Vasquez, although he was unclear as the legal meaning of whether this was extortion or a
bribe, but admitted that receiving payment for the CNV report was his idea.
Wherefor I submit that there is probable cause to believe that Rafael Horacio Ramos
de la Rosa conspired and attempted to interfere with interstate and foreign commerce under color
of official right and under fear of economic harm in violation of Title 18 United Slates Code
Section 1951(a) and traveled and caused others to travel and used and caused others to use
facilities in interstate and foreign commerce, including e-mail, to promote, manage and carry on
31