Case 0:23-mj-06485-PMH Document 1 Entered on FLSD Docket 10/16/2023 Page 1 of 8

AO91(Rev.08/09)CriminalComplaint c
U NITED STATES D ISTRICT C OURT FIkE'DBY '.
forthe gtï jg 2223
Southern DistrictofFlorida ANîEtga. Nrvup
:Wb,XRKGVY'-XXtC
, =X'
United StatesofAmerica
M.
JEFFRY ARISTA, casexo. 23-6485-M J-H UN T
JONATHAN ARISTA,and
RAYMOND GOMEZ,

Depndantls)

CRIM INAL COM PLM NT BY TELEPHONE OR OTHER RELIABLE ELECTRONIC M EANS

1,the com plainantin thiscase,statethatthefollowing istrue tothebestofmy knowledge andbelief.

Onoraboutthedatets)of october14,2023, inthecounty of Broward inthe
Southern Districtof Florida ,thedefendantts)violated:
CodeSection Of/èn-
çcDescription
18 U.S.C.1201(a) Kidnapping and Attempted Kidnapping
18 U.S.C.1201(c) Conspiracy to Kidnap

Thiscriminalcom plaintisbased on these facts:

SEE ATTACHED AFFIDAVIT.

W continuedontheattachedsheet.

Complainant'
ssignature

Jessie Anaza,FBISnecialAcent
Printed nameand title

AtlestedtobytheApplicantin accordancewiththerequirementsofFed.R.Crim.P 4.1by Facerfim e

D ate; 10/15/2023
Judge'
ssi
gnature

City and state: FortLauderdale,Florida Patri

ckM.Hupt,Uni
ted States Magi
strate Judge
Printedname(7:1J title
Case 0:23-mj-06485-PMH Document 1 Entered on FLSD Docket 10/16/2023 Page 2 of 8

AFFIDAW T IN SUPPORT OF SEARCH W ARRANT

YourA ffiant,Jessie A paza,being duly sworn,deposesand statesas follow s;

IN TR O DU CTIO N A ND AG ENT BA CK GR O UND

1am a SpecialAgentfortheFederalBureau ofInvestigation (iTB1'')currently

assignedtotheViolentCrimes/FugitivéTaskForceintheM iam iDivision.Priortomyassignment

to the ViolentCrim esT ugitive Task Force,Iw asassigned to theComplex FinancialCrim essquad

forthreeyears.lhavereceivedtrainingattheFBlAcademyin Quantico,Virginia.AsaSpecial
AgentfortheFBI,my currentdutiesinvolvetheinvestigation ofavariety ofviolationsoffederal

offenses,includingbankrobberies,HobbsActrobberies,extortion,andotherviolationsoffederal

law.lhavebeenanFB1SpecialAgentsinceSeptember20l5and havebeenassignedtotheM iam i

D ivision since M arch 2016.Priorto m y em ploym entasa SpecialA gentw ith theFBI,Iw orked as

an FBllnvestigative Specialistfrom June 2010 to Septem ber2015 w here linvestigated threatsto

nationalsecurity.
2. Thisaffdavitissubm itted in supportofa crim inalcom plaintchargingJeffryA rista,

Jonathan Arista,and Raym ond Gom ez with violations ofTitle 18,United States Code,Sections

1201(a)(kidnappingandattemptedkidnapping)and1201(c)(conspiracytokidnap).
3. ThisAffdavitisbased uponmy personalknowledge,my review ofdocumentsand

other evidence, and my conversations w ith other law enforcem ent personnel and civilian

witnesses.Because this Affidavit is being submitted forthe limited purpose of establishing

probable cause,itdoes notinclude al1the facts that lhave leanwd during the course of my

investigation.Rather,1have included only the factsthatare sufficientto establish probable cause.

W here the contents of docum ents and the actions,statem ents,and conversations of others are

rtported herein,they are reported in substance and in part,exceptwhere otherwise indicated.

Case 0:23-mj-06485-PMH Document 1 Entered on FLSD Docket 10/16/2023 Page 3 of 8

PRO BABLE CAU SE

InitialResponse

4. On October 14, 2023, at approxim ately 2:08 a.m ., law enforcem ent om cers

respondedtoabusiness,locatedinPompanoBeach,BrowardCounty,Florida(theEçBusiness''),in
response to a reported bom b threat.Upon anival,law enforcemcntdiscovered thatthe Victim
calledin abombthreattogetarapidpoliceresponsetohislocation becausehehadbeenthevictim

ofaviolentkidnappingandwastaken,withouthisconsent,toanunknownlocation,lateridentised

as the Residence.The Victim stated to police that his kidnappers m istook his identity for his

coworker(the idcoworker'').Afterthreatening to torture and killhim atthe Residence,the

kidnappersforced the Victim to contactthe Coworker,so thatthey could arrange to kidnap him

instead.U pon fnding out the Coworker was at the Business, and in accordance w ith the

kidnappers' plans,the V ictim w as allowed to go into the Business and m ake contactw ith the

Cow orker.Once inside,the V ictim m ade the bom b threat.

TheK idnappina

5. 0n October 13,2023,som etim e between 7:30 am and 8:00 am ,the V ictim exited

hisresidence,locatedin FortLauderdale,Broward County,Florida.Asheapproached hisvehicle,

which was parked on the tsfth floor of the garage,one ofthe kidnappers (çGKidnapper-l'')
approached the Victim and brandished ablack firearm whilewearing policeattireand afull-face

m ask.The Victim advised thatK idnapper-l wore w hatappeared to be a ballistic vestand a gold

badge on his belt with the rem ainder of his attire being a1l black.K idnapper-l then forced the

Victim toward a white Dodge Chargerwith dark tinted windowsand a çfpolice''light(Cçthe

Dodge'').A secondmalekidnapperCsKidnapper-z'')brietlyexitedtheDodgeanddemandedthat
K idnapper-land the V ictim m ovequickly.TheV ictim w asplaced into theback seatoftheD odge
Case 0:23-mj-06485-PMH Document 1 Entered on FLSD Docket 10/16/2023 Page 4 of 8

andforced to wearablack headcovering to obstructhisvision.Sitting intheback seatwith him

wasKidnapper-l,whileKidnapper-z drove theDodge.The Dodgethen departed thevicinity of

theVictim 'sresidence.During thedrive,oneofthekidnappersthrew theVictim'scellphone out

ofthe m oving car.

6. The Victim wastransported directly to theResidencewhere hewasforced outof
the Dodge and into a garage.The V ictim prim arily interacted with a third kidnapperwho,after

rem oving his m ask,w as observed having a beard and tattoos on his face.This m ale was later

identified as Jeffry A rista.Jeffry A rista asked the Victim to identify him self,im plying they had

kidnapped the wrong individual.The kidnappers furtherconGrm ed this when they rem oved the

V ictim 'swalletfrom hispocketand checked his identification.A tthispoint,thekidnappersbegan

inquiringwhywastheCoworkerusingtheVictim'scarthispastThursday anddemandedto know

where the money was.The money was in reference to whatthe Coworkerallegedly owed the

kidnappers.The kidnappers threatened the Victim by putting an electric drill to his skin and

pointingfirearmstowardshishead.Atonepoint,thekidnappersforced theVictim intoabathroom

insidetheResidencewherethey covered hisfacew ith fourorfiveblack m asksand poured buckets

ofwateron him ,effectively w aterboarding him .D uringthistim e,theV ictim thoughthew asgoing

to droNvn.

7. The kidnappers - com prised of Jeffry A rista;his brother, Jonathan A rista; and

RaymondGomez- then began brainstorm ing onhow theVictim could help luretheCoworkerto

them .They supplied the Victim w ith a new cellphoneand w ereable to accesstheV ictim 'sicloud

accountto obtain theCoworker'scellphonenumber.TheVictim wasthen forcedtom ake contact

with the Coworkerand attemptto m ake plansw ith him .

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Case 0:23-mj-06485-PMH Document 1 Entered on FLSD Docket 10/16/2023 Page 5 of 8

8. Som etim e after 7:30 p.m .,Gom ez transported the V ictim and Jeffry A rista aw ay

from the Residence in ablack Porsche SUV (the dsporsche'').Upon arriving atthe Victim's
apartm ent,Jeffry A ristaexited the Porsche and entered theV ictim 'sapartm entw ith theV ictim .ln

the apartment,Jeffry Arista brandished a silverfrearm with whatappeared to be auniqueésfin''

affixed to thegun.Aftersometime,Jeffry AristacalledJonathan Arista and Gomez,and directed

them toreturntotheapartmentwithdrugs.W hen allthreekidnappersweretogetherintheVictim 's

apartment,the Victim received a text message from the Coworker stating that he was atthe

Business.The kidnappers decided to take the Victim to the Business so thatthey could lure the

Cow orkerout.The kidnappers and the V ictim gotback into the Porsche and drove tow ards the

Business.Upon aniving,the kidnappers and the V ictim located the Coworker's vehicle in the

parking lot.The Victim overheard two of the kidnappers discuss placing a tracker on the

Coworker's vehicle.The Victim subsequently observed one ofthe kidnappersexitthe Porsche

w ith the intentto installa tracker.A fterward,the kidnappers ordered the V ictim to go into the

Businessto findtheCoworker.Once inside,theVictim informedthe Coworkerofeverythingthat

had happenedand called law enforcement.

Further Investization

W hilethe Victim wascom m unicating w ith an officer,he observed Jeffry Arista in

the distance appearing to record him with a cellphone.The V ictim notified law enforcem entand

Jefrry A rista w astaken into custody.

10. Law enforcem entsubsequently observedthePorsche departing thevicinity ofthe

Businessbefore itultim ately crashed ata nearby location.Jonathan A rista wasobserved walking

away from thevicinity ofthe Porsche before being detained by 1aw enforcem ent.

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Case 0:23-mj-06485-PMH Document 1 Entered on FLSD Docket 10/16/2023 Page 6 of 8

During apost-M iranda interview,Jonathan Arista contsrm ed thathe isthe owner

oftheDodge and advised thatitwascurrently parked outsideofthe Residence.Jonathan Arista

claim ed thathe w as in fear for his safety and w as notthe one who planned the events thattook

place.Furthennore,Jonathan A rista confirm ed thathe w as one ofthree individuals thatw entto

the Business in thePorsche.H e confirm ed thatJeffry Arista w as with him .He claim ed the third

individualwasablackmalethatwentby thenam e:çD''.AccordingtoJonathanArista,thePorsche

was a rental.Law enforcem entdeterm ined thatthe Residence was an A irBnB to w hich Jonathan

A rista received access on O ctober l2,2023. W hen asked about how the events first started,

Jonathan Arista stated som eone had approached his brother,Jeffry Arista,approxim ately three

daysearlier.W hen asked to go into detailaboutthedsevent,''Jonathan Arista claim edthathe feared

forhislife ifhe provided additionalinform ation and term inated the interview .

12. On October 14,2023,Iaw enforcem ent drove to the Residence and observed the

Dodge with whatappeared to be a spotlightafsxed to the pillarofthe vehicle.A lso parked in the

drivewaywasawhiteHondaCivicbearingFloridalicvnseplate61-11W 44 (theifl-
londa').While
conducting surveillance,law enforcem entobsenred two m alesgoing in and outofthe Residence

placing bagsinto thetrunk ofthe Honda.Oneofthe maleswasobserved wiping down thefront

door,to includetheinteriorhandle.Furtherm ore,law enforcem entcould seethrough the frontdoor

glasswindow,two malesmoving aroundwith whatappeared to begarbagebags.AhertheHonda

departed theResidence,1aw enforcementmaintained coverageon thevehicle untilthey observed

G om ez exitthe H onda while stopped atan intersection and attem ptto tlee the area.Gom ez w as

subsequently detained by law enforcement.TheHondawasthen located atagas station a short

distanceaway.Law enforcementapproachedthevehicleandspokewiththemaledriver(:çMale'').

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Case 0:23-mj-06485-PMH Document 1 Entered on FLSD Docket 10/16/2023 Page 7 of 8

During a post-M iranda interview,the M ale advised thatGom ez called him from a

phonethatheborrowed from anearby bystanderand toldhim thatheneededhelp becausehewas

in a traffic accident.G om ez requested the M aleto com epick him up from a busterm inallocated

in the area ofM artin LutherK ing Blvd.and Dixie Highway,Pompano Beach,Broward County,

Florida.TheM ale advised thathedrove to the area in theHondaand picked up Gom ez.Gomez

then askedtheM aletotakehim totheResidenct,which Gomezdescribed wasanAirBnB thathe

rented with som efriends.W hiletogether,GomeztoldtheM alethathewasattheBusinessinside

a Porsche w ith two ofhis friends.Gom ez then stated thatone ofthem stepped outofthe vehicle

and began talking on his phone before being arrested.G om ez then stated that law enforcem ent

chased thePorschew ith Gom ezasthedriver.G om ez stated thathe crashed thePorscheand bailed

outofthe vehicle along with the otherpassenger.Gomez stated thathe hid behind bushesafter

getting separated from the other passenger. Gom ez then advised that was able to elude law

enforcementand make his way towards the bus station.The M ale further advised that,upon

arriving atthe Residence,he observed G om ez cleaning the counters w ith bleach and collecting

item sinto m ultiple garbage bagsthathe then loaded into the H onda.

D uring a post-M iranda interviem l G om ez adm itted that he,Jeffry Arista, and

Jonathan Aristawereinvolved in thekidnapping ofthe Victim .Heclaim edthathe and theArista

brotherscommitted thecrime atthe direction ofan unknown male(isunknown Subjecf')who

conferred directly w ith Jeffry Arista over the telephone. Gom ez did not know the Unknown

Subject'strueidentitybutadvisedthattheobjectivewastokidnaptheCoworkerduetoamonetary
debt.ln exchange for his assistance,Gom ez expected to be paid.Gom ez adm itted that, after

1AlthoughGomezinitiallyinvokedhisrights,hesubsequentlyreengagedlaw enforcementandadvisedthathewanted
to speak.Afterbeing advised ofhisM iranda rightsagain and confirm ing thathenow wanted to waivehisrights,
Gom ezprovided astatement.
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Case 0:23-mj-06485-PMH Document 1 Entered on FLSD Docket 10/16/2023 Page 8 of 8

kidnapping the V ictim atgunpointand bringing him to the Residence,he and the Arista brothers

realized thatthey had kidnapped thewrong person.G om ez advised thatJeffry A rista and Jonathan

Arista were involved in w aterboarding the V ictim and threatening him w ith guns,ayellow electric

drill,and tasers.Gom ez claim ed thathe feltbad forthe Victim .Gom ez stated thathedroveJeffry

AristaandtheVictim totheVictim 'sapartmentinthePorschebeforedrivingbacktotheResidence

topick up Jonathan Arista.Gomezclaimed thathe,theAristabrothers,and theVictim werein a

m ore relaxed state oncethey learned oftheCoworker'swhereaboutsand devised a plan tohave

lure the Cow orker out ofthe Business.W hile in the parking lot of the Business,Jeffry A rista

directed Gom ez to place a trackeron the Coworker'svehicle,which Gom ez did.Gom ez adm itted

that,assoon aslaw enforcem entarrested Jeffry Arista,hetled thearea and abandoned thePorsche

afteritcrashed.G om ez stated thatthe M alepicked him up from abusstation and drovehim to the

Residence where G om ez began cleaning the Residence,rem oving clothes,dnzgs,and the drill

before his arrest.G om ez confirm ed thatthere were tw o frearm sinvolved in the kidnapping.

C ON CLUSIO N

l5. Based on my training and experience,and asfurthersupported by the factsinthis

afsdavit,lrespectfully subm itthatprobable cause existsto charge Jeffry Arista,Jonathan Arista,

andRaymondGomezwithviolatingTitle18,UnitedStatesCode,Sections1201(a)and1201(c).
FURTH ER YO UR AFFIANT SA YETH N AUG H T.

JessieA p pecialAgent
FederalBureau ofInvestigation

A ttested to by the applicantand in accordance w ith the requirem ents ofFed.R.Crim .P.4.1
by FaceTim e on 's 15th day ofOctober2023.

PA TRICK M .H UN T
/
UN ITED STA TES M A GISTR ATE JUD GE