Case 2:17-mj-00006-FJL Document 1 Entered on FLSD Docket 01/18/2017 Page 1 of 8

A0 91(R
AUSA CARMEN M . LINEBERGER
ev.08/09) CriminalComplaint

U NITED STATES D ISTRICT C OIJRT

forthe
Southern DistrictofFlorida
United StatesofAm erica

FILED y

V.

..

Case No. 17-006-FJL

RALPH ROBERT JAMES SERGO

JAN 18 2217

STEVEN M LARIMORE

CLoF
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CRIM IN AL COM PLAINT

1,thecomplainantin thiscase,statethatthe following istrue to the bestofm y knowledge and belief.

Onoraboutthedatets)of Oct.11 2016 & Jan.17 201

inthecountyof St.Lucie
Southern
Districtof
Florida
,thedefendantls)violated:
CodeSection
21 U.S.C.Section 952 & 963

OffenseDescri
ption

21U.S.C.Secti
on841(a)(1)and
21 U.S.C.Secti
on 846

18 U.S.C.Secti
on924(c)

inthe

Attempted Importation and Attempted Distribution ofLysergic Acid

Diethylamide,also known as''LSD'',a Schedul
e IControlled Substance, in

viol
ationofTi
tl
e 21,United StatesCode,Sections952,841(a)(1),846.
,
Possessi
on ofa Firearm in Fudherance ofa Drug Trafficking Crime,in

violationofTitle 18,United StatesCode,Section924(c).

Thiscrim inalcom plaintisbased on these facts'

.
See attached affi
davit.

/ Continuedontheattachedsheet.

Complainants
'signature

HSISA James Macek

Printednameand title

Swornto beforem e and signed in my presence.

oate:

//- /
Ju

City and state:

Fod Pierce, Florida

' signature

kJ.L nch Jr. ChiefU.S.Ma istrate Jud e

Printed name and title

Case 2:17-mj-00006-FJL Document 1 Entered on FLSD Docket 01/18/2017 Page 2 of 8

A FFIDA V IT O F
JAM ES E.M A CEK .SPEC IA L A G EN T
H O M ELA ND SEC U RITY INV ESTIG AT IO N S
1,Jam es E.M acek,a SpecialA gent ofthe D epartm entofH om eland Security,H om eland

Security Investigations,being duly sw orn state asfollow s:

l am an investigative or 1aw enforcem entofticer of the United States w ithin the m eaning

ofTitle 18,United StatesCode,Section 251047).lhavebeen employedwith theDepartmentof

Homeland Security (DHS),U.S. lmmigration and Customs Enforcement (ICE), Homeland
Security lnvestigations(HSl)asaSpecialAgentforapproximatelynine(9)years. AsaSpecial
A gent,l am responsible for investigations of offenses under Titles 8, 18,and 21 of the U nited
States Code,including violations of Title 21, United States Code, Section 952 and Title 21,

UnitedStatesCode,Section 841(a)(1).
2)

During my experience in 1aw enforcement, I have participated in numerous drug

investigations as a case agentorin a subsidiary role. 1have debriefed defendants,informants,

andwitnesseswhohadpersonalknowledgeregarding majornarcoticstrafficking organizations.

A dditionally, I have participated in m any aspects of drug investigations including w iretaps,
undercover operations,conducting surveillance,and arrests. l am fam iliarw ith dnlg traffickers'
m ethods of operation,including the distribution,storage,obtaining and transportation of illegal
drugs, and the collection of m oney, proceeds of drug traftk king and m ethods of m oney
laundering used to concealthe nature ofthe proceeds. lam fam iliarw ith the w ays in w hich drug
traffickers conducttheir business,including m ethods of im porting and distributing illegaldnzgs,
m oney laundering,the use of cellular telephones and the internet to facilitate their illegal acts,

and the use ofnum erical codes and code w ords to conductdrug transactions. I am also aw are
that the research, negotiation, purchase, and im portation arrangem ents of narcotics are often
conducted using internet and em ail com m unications w ith individuals in the N etherlands and

Case 2:17-mj-00006-FJL Document 1 Entered on FLSD Docket 01/18/2017 Page 3 of 8

other foreign countdes. O ften,those com m unications are m aintained in electronic form at, or

printed ashardcopy,in notes,and/orledgers.

I subm it this affidavit based on information known to me personally from the
investigation, as w ell as infonnation obtained from other law enforcem ent ofticers w ho have

investigated thism atter,orotherindividuals who have personalknowledge ofthe factsherein.

Although Iam fam iliarwith the f'ullbreadth ofthe factsand circum stancesofthisinvestigation,
this affidavitdoesnotcontain a11the infonnation known regarding thisinvestigation,butrather
those factsnecessary to establish the requisite probable cause to believe thatR ALPH R OBERT
JA M ES SERG O hascom m itted the crim es ofAttem pted lm portation and Attem pted Distribution

of Lysergic Acid Diethylamide,also known as EELSD '',a Schedule 1 Controlled Substance, in

violation ofTitle21,UnitedStatesCode,Sections952,963,841(a)(1),846;andPossession ofa

Firearm in Furtherance ofaDrug Traftk king Crim e,in violation ofTitle 18,United StatesCode,

Section924(c).
BA CK GRO UN D O F TH E IN V ESTIG ATION
On A ugust 24, 2016, 1aw enforcem ent conducted a surveillance of 2447 SE Pascal
Avenue PortSaintLucie,Florida,afterreceiving infonnation thata resident,Ralph SERG O , w as

manufacturinganddistributingLysergicAcid Diethylamide(LSD)attheresidence. Duringthe

surveillance SERGO w as observed and identified com ing from the residence,checking the
m ailbox,retrieving the m ailfrom the m ailbox and returning to the residence.

5)

On August24,2016,law enforcementalso conducted an inspection ofthetrash,which

had been placed at the roadside for trash collection. Inspection of the trash revealed several
papers w ith tabs indicating weights,and quantities of hits''and ttabs''of :CGOT''and CCGD F''
Through m y narcotics training and experience,I believe these to be references to quantities and

Case 2:17-mj-00006-FJL Document 1 Entered on FLSD Docket 01/18/2017 Page 4 of 8

weightsofnarcotics,and Iknow thatthe term :EGDF''isactively being used by LSD vendorson

the internetasa tt
brand''ofLSD .

OnOctober11,2016,atapproximately 2:45pm,Homeland Security Investigations(HS1)

intercepted an intem ationalm ailparcel shipped from Denm ark, atthe m ailfacility in PortSaint
Lucie,Florida. The parcel was addressed to LeBow e LLC ,2447 SE PascalA venue PortSaint

Lucie,Florida. A bordersearch oftheparcel,by HSIAgents,revealed agiftbox containing skin

oilsand skin cream containers. Hidden inside oneofthe skin cream jars,concealedwithin the
cream ,w ere a folded piece of paper and a sm all clear ziplock baggie,both containing a gray

coarse powdersubstance.Atthe tim e,HS1Agentsestim ated the grossweightofthe substance

and packaging to be approxim ately 7.94 gram s.

ThepackagelistedthesenderasJ.Straw Toerdewskjoldsgade33,8200ArgiusDenmark.
The recipient was listed as LeBowe LLC,2447 SE PascalAvenue PortSaint Lucie,Florida
34952. There was a U .S. Postal Service tracking num ber assigned to the package w as

(1G 150749505D1* .Databasequeries,includingSunbiz,madeby HSIAgentsrevealedthatthe

com pany listed Ralph R.Sergo, as the m anager of LeBow e LLC ,w ith a m ailing address and
principaladdressof2447 SE PascalA venue PortSaintLucie,Florida 34952.
A ccording to U .S.PostalService records,tracking num ber 1G 150749505D K ,assigned to

the aforementioned package,was tracked via the U.S.Postal Service tracking website f'
rom

Comcast lnternet Protocol (lP) Address (2601:58b:4001:a6c0:5ce5:5ae0:9f4:ac22) once on

Septem ber22,2016,and fourtim eson Septem ber23,2016.

On Septem ber 26,2016,in response to a subpoena Com castreported thatthe subscriber

for the internet service is Ralph SERG O, at 2447 SE Pascal Avenue Port Saint Lucie, Florida
34952.

Case 2:17-mj-00006-FJL Document 1 Entered on FLSD Docket 01/18/2017 Page 5 of 8

10) The two packages,containing the gray coarse powder substance,were sent to the
CustomsandBorderProtection(CBP)laboratoryin SavanahGeorgiaforanalysis.On December
12, 2016, H SI agents received the laboratory report, indicating that the gray coarse pow der

substance,containedinbothpackages,containedLysergicAcidDiethylamide(LSD).
11)

Florida Driver and Vehicle Information Database system indicated thatDepartmentof

M otorVehiclerecordsindicatethatRalph RobertJam esSergo,awhitem ale,age 23, w asissued

a Flodda driver's license,listing residentialaddress of 2447 SE PascalA venue PortSaintLucie,

Florida 34952,with a 1991 Harley Davidson motorcycle,and a 2016 Honda van atthe same
address.

Surveillance conducted December 19,2016 on 2447 SE PascalAvenue PortSaintLucie,

Florida 34952,revealed a black Jeep SUV parked in the driveway,bearing Florida registration

(DDZT87),which isregistered to JasmineLeilaniSERGO,according totheFlorida Driverand

V ehicle lnfonnation D atabase system , at 2447 SE Pascal A venue Port Saint Lucie, Florida
34952.
O n January 6,2017 l applied for and received a federal search w arrant, approved by

Chief United States M agistrate Frank J.Lynch,for the residence located at 2447 SE Pascal

AvenuePortSaintLucie,Florida34952,includinganycurtilage.(M ag.CaseNo.17-003-FJQ
O n January 17,2017,HSlSpecialA gentsexecuted the aforem entioned search w arranton
the residence located at2447 SE PascalAvenue PortSaint Lucie,Florida 34952. Initially there
w asno one inside the residence w hen agentsarrived.
D uring a search ofthe residence,agents located a sm allplastic bag,containing dark gray

granularpowderandtwo glassjars,containing a light gray colored powder. The dark g'

ray
powderin theplastic bag,and thelightgraypowderin thejars,allfield tested positive forthe
presence ofLSD .

Case 2:17-mj-00006-FJL Document 1 Entered on FLSD Docket 01/18/2017 Page 6 of 8

16)

ln addition to the LSD,agents found paraphernalia,including sheets of paperwith

variousdesigns,comm only known as ''blotterpaper''. From my training and experience, drugs

active in m icrogram range,m ost notably LSD , are com m only distributed for sale on ''blotter

papen'' A liquid solution of the drug is applied to the ''blotter paper,'' which com m only is
pedbrated into tiny squares or ''tabs''to facilitate individualdosing and artfully decorated with
whatis know n as ''blotter art.'' The artw ork is printed onto ''blotter paper,''often w ith grid lines

aspartofthe design,to aid in perforation orto be leftasa cutting grid. ''Blotter''is a delivery
m ethod which allow s for easy dosing ofpotentsubstances and easy sublingualadm inistration of
drugs,like LSD . ln addition to the %6blotlerpaper,''agents discovered shipping m atedals.
During the execution ofthe search w arrant,SERG O arrived atthe residence, driving his
2016 H onda van. A t the tim e he w as encounter by agents,SER GO w as in possession of a
loaded Sm ith and W esson .38 caliber revolver, which w as found on the driver's floorboard
beneath SERGO . Inside the passenger com partm ent of the van,agents found a U nited States

PostalService shipping receipts,including one dated January 17,2017,from the StuartFlorida

PostOffice,with tracking numberCW 911716555. US.Postalrecordsindicate thatthepackage
wasdestined forSonora,M exico.
United StatesPostalInsped ors and HSl SpecialA gentsw entto the PostO ffice in Stuart,
Florida and located the aforem entioned outbound parcel, contirm ing that it w as destined for
M exico. A gents conducted a bordersearch ofthe outbound parceland found thatitcontained an
orange granular substance, which w as field tested positive for the presence of LSD . The
packaged w eightofthe substance w as approxim ately 85 G ram s.

SERGO was advised ofhisM iranda warnings,which he stated thathe understood and

waived. ln the recorded statement, SERGO admitted that there werejarsin the house
thatconG ined pow der LSD and thatitw as forhispersonaluse.

Case 2:17-mj-00006-FJL Document 1 Entered on FLSD Docket 01/18/2017 Page 7 of 8

20) SERGO admitted that, earlier that mom ing, he had mailed a package to Mexico,
containing ''an Orange Dot''ofLSD ,f'
rom the StuartPostO ftice.
W hen he w as asked about the previously intercepted package containing LSD , SER G O
adm itted that there w as a package from D enm ark,thathe had never received. SERG O stated

that he didn't know how m uch EEthey''were sending and he hadn't paid for it yet. SERG O

admitted that he has been doing this for three(3)or four(4)years,that he communicated
with ttthem ''on the internet,and does notknow who itthey''are.SERGO claim ed thathe only
hasordered LSD ontheinternetandno othersubstances.
SERGO was in possession of an Apple I-phone which was seized and m aintained as
evidence pending an application fora search w anunt.
Jasm ine SERG O ,Ralph SERGO 'S w ife,arrived w ith SERG O in the vehicle,w ith their
infant. An A pple I-phone was located on her person, as w ell. Jasm ine SERG O provided the
passw ord for the I-phone. A gents found an Apple laptop com puter, inside of the
residence,w hich w as locked and running w ith encryption.H Sl forensic agents soon determ ined
thatthe l-phone w as synced to the com puter,after both w ere alerted at the sam e tim e, w hen a

CallOrmessage wasreceived. Both item swereseizedand m aintained as evidence,pending an

application for a search w arranton the I-phone.SERGO also advised that they use the A pple
M ac Book forshipping and orders.

24)

An ATF SpecialAgenthasmade a preliminary determination thatthe firearm,found

in SERG O 'S van,wasnotm anufactured in the State of Florida and therefore had traveled in and

affected interstate and/orforeign com m erce.

25)

Based on the foregoing facts, Ibelieve there is probable cause to charge RALPH

RO BERT JA M ES SERG O w ith Attem pted lm portation and Attem pted D istribution ofLysergic
A cid Diethylam ide,also know n as CCLSD '',a Schedule l Controlled Substance,in violation of

Case 2:17-mj-00006-FJL Document 1 Entered on FLSD Docket 01/18/2017 Page 8 of 8

Title 21,United States Code,Sections 952,963, 841(a)(1),846,

'and PossessionofaFirearm in
Furtherance of a Drug Trafficking Crim e,in violation of Title 18, U nited States Code,Section

924(c).FURTHER,YOUR AFFIANT SAYETH NAUGHT.

J

sE.M acek
cialA gent
Homeland Security Investigations

Swornandsubscribedtobeforemethis/vdayofJanuary,2017,atFortPierce,Florida

R 'AN

.
CH Jr.
nited States M agistrate Judge