You are on page 1of 34

Case 1:10-mj-03468-AMS Document 1 Entered on FLSD Docket 10/26/2010 Page 1 of 11

UNITED STATES DISTRICT COURT


SOUTHERN DISTRICT OF FLORIDA

No. /Q~ SVLft-AMS

UNITED STATES OF AMERICA

vs.

RAFAEL RAMOS DE LA ROSA,

Defendant.

CRIMINAL COVER SHEET

1. Did this matter originate from a matter pending in the Northern Region of the United States
Attorney's Office prior to 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

AO 91 (Rev. 01/09) Criminal Complaint

United States District Court


for the
Southern District of Florida

UNITED STATES OF AMERICA )


)

/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.

This criminal complaint is based on these facts:


See Attachment A

O Continued on the attached sheet.

Complainant's signature

Special Agent Daniel J. Johns, FBI


Primed name and title

Sworn to before me and signed in my presence.

Date : ioMr//0 Jt^^Kj


Judge's signature

City and state: Miami, Florida Andrea M. Simonton, Magistrate Judge


Printed name and title
Case 1:10-mj-03468-AMS Document 1 Entered on FLSD Docket 10/26/2010 Page 3 of 11

ATTACHMENT A
Case 1:10-mj-03468-AMS Document 1 Entered on FLSD Docket 10/26/2010 Page 4 of 11

I, Daniel J. Johns, being duly sworn, depose and state as follows:

1. 1 am a Special Agent of the Federal Bureau of Investigation ("FBI") assigned to

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 specialized in investigations involving counterterrorism, drug trafficking, and smuggling. 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

review of documentary materials.

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")

has committed the following offenses:

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,

United States Code. Section 1951(a)

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

Code, Section 1952.

FACTS AND CIRCUMSTANCES SUPPORTING PROBABLE CAUSE

4. Tomas Andres Vasquez Estrella (hereinafter referred to as "Vasquez") was the

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

asylum in the United States.

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

coordinate the receivership on his behalf.

6. On December 17, 2009 to approximately April 2010, Vasquez maintained consistent

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

uncle Rolando Araujo (hereinafter referred to as "Araujo"). Araujo is a Director of Uno


] Case 1:10-mj-03468-AMS Document 1 Entered on FLSD Docket 10/26/2010 Page 6 of 11

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

could be charged criminally.

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.

The payment discussions were left open.

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

in the below facts.

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

Spanish and have been translated by a certified FBI translator.

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

account information as to where the money should be sent.

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,

ABA number: 026009593.

15. On April 14, 2010, menujinshadah@vahoo.es sent RAMOS an E-mail with the

following information: BANK OF AMERICA: ABA: 026009593; ACC: 229028072396;

BENEF: JODSHAD JEWELS INVESTMENTS LLC; ADDRESS: 3440 HOLLYWOOD BLVD


Case 1:10-mj-03468-AMS Document 1 Entered on FLSD Docket 10/26/2010 Page 8 of 11

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.

16. A search of Florida Department of State, Division of Corporations reveals Jodshad

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.

17. On April 28, 2010, RAMOS sent an e-mail to menuiinshadah@vahoo.es requesting

him to make two transfers equaling $150,000.00 into the bank accounts owned by RAMOS.

18. On April 28, 2010, RAMOS sent a second e-mail to menuiinshadah@vahoo.es

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

he(RAMOS) was ready for the final $70,000.00 transfer.

19. On or about May 03, 2010, Ramos sent an e-mail to menuiinshadah@vahoo.es.

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

ready for the final 70,000.

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

($10,000.00) can be used for expenses.

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

the following information: "Bank of America ABA:026009593 Acc:229028072396 Benef:


i
Jadshad Jewels Investments, LLC, Address: 3440 Hollywood Blvd. Suite 415, Hollywood, FL !
i
33021". !

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

the lady. I committed myself to that."

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

lot of people. I'll call you tomorrow at this."

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

Southern District of Florida on September 09, 2010. Grillet sent an e-mail to


Case 1:10-mj-03468-AMS Document 1 Entered on FLSD Docket 10/26/2010 Page 11 of 11

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

advised that Ramos told him this information.


Case 1:10-mj-03468-AMS Document 1-1 Entered on FLSD Docket 10/26/2010 Page 1 of 10

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

4:00 P.M. EST to further discuss the matter.

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

was pressuring him to call her.


Case 1:10-mj-03468-AMS Document 1-1 Entered on FLSD Docket 10/26/2010 Page 2 of 10

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

would probably put me in the news or something like that."

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

10
Case 1:10-mj-03468-AMS Document 1-1 Entered on FLSD Docket 10/26/2010 Page 3 of 10

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

11
Case 1:10-mj-03468-AMS Document 1-1 Entered on FLSD Docket 10/26/2010 Page 4 of 10

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'

conditions for payment. Araujo sent the e-mail to adrianaGrillet@gmail.com.

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.

Araujo attended the meeting at the behest of 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

for his nephew (Vasquez) with Ramos.

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

to the United States on or about August 27, 2010.

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

can get a hold of him.' Shit, man. Speak to him"

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

13
Case 1:10-mj-03468-AMS Document 1-1 Entered on FLSD Docket 10/26/2010 Page 6 of 10

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'

relationship with Grillet.

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

prepare a draft of the report and we'll meet over there."

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

15
Case 1:10-mj-03468-AMS Document 1-1 Entered on FLSD Docket 10/26/2010 Page 8 of 10

before...uh...we can come to an agreement...[sneezes]...perhaps I can send you...[sneezes]...an e-

mail with the draft." Vasquez and Ramos discuss how to send the report via e-mail and other

issue related to Vasquez' business.

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

money." Vasquez and Ramos then had the following exchange:

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

I wanted to be sure of.

RR: No, well...but I don't know why Rolando told you that, because I haven't spoken

to Rolando about that. So. if anything...

TV: Hm.

16
Case 1:10-mj-03468-AMS Document 1-1 Entered on FLSD Docket 10/26/2010 Page 9 of 10

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

anything, that's not. not...

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

know because he had not been in contact with Vasquez recently.

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

demonstrated an email on his Blackberry with the following information:

Jodshad Jewels Investments LLC.

17
Case 1:10-mj-03468-AMS Document 1-1 Entered on FLSD Docket 10/26/2010 Page 10 of 10

3340 Hollywood Blvd. Suite 415 j

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

the Venezuelan Superintendent of Securities. \

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 \

the passenger pickup near baggage claim by Grillet. '


Case 1:10-mj-03468-AMS Document 1-2 Entered on FLSD Docket 10/26/2010 Page 1 of 13

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

agree to meet the next day, August 28, 2010.

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

Ramos (RR) and Vasquez (TV) to include the following:

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

19
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

damn, so far it continues to be ours in paper.

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

should give him some money to give it to you.

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

20
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

almost...almost an sporadic case and we would have resolved it and nobody

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

have to exteriorize the problem and continue..."

55. Vasquez and Ramos continued their discussion surrounding the situation in

Venezuelan, when Vasquez returns to the issue of paying Ramos by stating:

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

21
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

screwed half of the planet and he has never given a shit.

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

not going to help anybody.

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

22
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

lent a thing to that man, so consequently he doesn't owe me a thing."

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

speak to Adriana. If I have to speak to someone, I have to speak to Rafael. I

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,

we were going to...Tomas Sanchez was going to receive some money.

RR: [OV] [UI] it'll be my problem if he gets any money or not.

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

weapon for you to defend yourself.

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

conversation to the issue of paying Ramos stating:

TV: Rafael, with your signature, you have the ability to send me straight into

23
Case 1:10-mj-03468-AMS Document 1-2 Entered on FLSD Docket 10/26/2010 Page 6 of 13

another huge problem. Tomas Sanchez has...even more power to do whatever

the hell he wants without thinking...

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

when the auditors didn't blow the whistle.

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.

TV: Fine. And, and our intention...we have to...we [UI].

RR: Just imagine, people...the people from the savings banks haven't made any

accusations nor are going to make any accusations. Uh...Horizon Insurance

either. Then, on the other side that's...that's also fair. Why am I going to make

an accusation if the people affected are not blowing the whistle?"

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

24
Case 1:10-mj-03468-AMS Document 1-2 Entered on FLSD Docket 10/26/2010 Page 7 of 13

[stutters]."

RR: No, I'm not going to do a thing regarding that.

TV: [OV]I... But I...

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

to talk about it.

RR: [OV] [UI] if you want to talk to him.

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

several issues with you...several possibilities, whatever..."

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: Remember, he's a public...person; in a public position. He has his aspirations.

He aspires to...they might even appoint him, uh...Finance Minister.

TV: Finance Minister?

RR: Yes, because he's very serious and he belongs to Giordani's [PH] group. He's

close to the President. Giordanni is sick, if he retires... Perhaps he'll be at the

right place at the right time. He has worked hard.

RR: They have told him something for sure and stuff and he hasn't had any qualms

25
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.

TV: To screw with people [chuckles].

RR: [SC] [UI]. If we get to...[UI] that behavior where you believe you are...[UI] the

transformation and |UI[ since it started. Then the power, uh...stuff...the

brainwashing you undergo...a bunch of things...that make people...people to

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...

RR: [OV] They can accuse you.

TV: [OV] But Rafael, let me ask you a question.

RR : [OV] If they were to make an accusation this week...

TV: Hm-mm.

RR: ...everybody would be [UI].

TV: With you?

RR: Huh?

TV: With you?

RR: With me. They would be happy. The Prosecution would be happy and then...the

aggravating circumstances are...if I do it, I'm going to do it right.

26
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

the one who [UI]. '

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 |

liquidation is completed and...and if after the liquidation when...when the ?


i
report is approved and there are no corrections, just to say it like that...from the

commission, uh...then you give me the other half.

TV: Is Rolando here? \

RR: Rolando? Yes. He arrived yesterday.

TV: Because they had told me he was going to go out of town. j

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

TV: Then, we'll fix this...

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, %

nothing happens?" So, one, two months go by...that's more or less a f

27
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

to me... It doesn't matter. What I care is that he doesn't hurt me anymore,

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

| reference to what it says there."


i
58. On September 14, 2010, Vasquez sent an email to Grillet saying that he is ready to

pay the $50,000. Vasquez stated that he is trying to explain this to Ramos and Sanchez and asks

Grillet to please advise him.

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

! 28
Case 1:10-mj-03468-AMS Document 1-2 Entered on FLSD Docket 10/26/2010 Page 11 of 13

(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

Ramos wants his (Vasquez's) head.

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.

Ramos told Araujo that he trusts Araujo.

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

meeting with Carlos Dorado.

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

29
Case 1:10-mj-03468-AMS Document 1-2 Entered on FLSD Docket 10/26/2010 Page 12 of 13

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

order to complete payment.

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

Ramos at the Dolphin Mall one hour before.

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

i I
Case 1:10-mj-03468-AMS Document 1-2 Entered on FLSD Docket 10/26/2010 Page 13 of 13

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

to leave the lobby and speak with agents in private.

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

extortion in violation of Title 18 United States Code Section 1952.


)

Daniel/ff./btuis, Special Agent


Federal Bureau of Investigation

Sworn and subscribed to before me


this a,5(?ay of October. 2010.

/S^2^J 7//. S/wur/J#xJ


ANDREA M. SIMON'I ON
UNITED STATES DISTRICT JUDGE

31

You might also like