Professional Documents
Culture Documents
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(s) of See below in the county of Orange in the
Middle District of Florida , the defendant(s) violated:
Complainant’s signature
COUNTY OF ORANGE
I, Stephanie Pantos, being duly sworn, do hereby depose and state as follows:
have worked since March 2022. In that capacity, my duties include investigating
University of Maryland. Following that, I was a federal law enforcement officer with
PURPOSE OF AFFIDAVIT
establishing probable cause for the issuance of a criminal complaint, I have not
included every fact or facet of the investigation known to me, only enough to
establish probable cause for the issuance of a criminal complaint against ROMERO.
PROBABLE CAUSE
6. On April 16, 2024, HSI San Juan notified HSI Orlando of a suspicious
parcel. This parcel was identified by a source of information who has previously
Addressed To:
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Return Address:
SHIPPING UNLTD
(787) 985-1208
SHIPPING INLTD
1353 AVE LUIS VIGOREAUX
GUAYNABO PR 00966-2715
PUERTO RICO
8. The SUBJECT PARCEL was intercepted on April 17, 2024 at the UPS
examined the exterior of the SUBJECT PARCEL and observed the following
characteristics:
a. The postal meter strip shows that the SUBJECT PARCEL was
shipped from zip code 00966 (Guaynabo, Puerto Rico), a known drug source area;
b. The SUBJECT PARCEL was shipped via UPS 2nd Day Air,
which is a common practice for the shippers of narcotics because the package arrives
faster and on a predictable date. The tracking number allows the sender, recipient, or
anyone else with the tracking number to confirm the delivery of the parcel by
c. The parcel does not require a signature from the recipient, which
would allow it to be left at the delivery address by the UPS without requiring contact
with a recipient. This is typical of narcotics parcels because it allows for the sender
and recipient to stay anonymous and further avoid detection by law enforcement.
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Unltd". This is another known tactic of narcotics smugglers used to conceal their
identity because the shipper is not required to divulge any personal information such
valid address, however the recipient’s name as written on the label, “Rubi Romero
Soto,” does not appear to be associated with the aforementioned address. It was later
12. On April 17, 2024, arrangements were made to have a trained narcotics
Department narcotics detection K9, alerted to the parcel when it was presented to
him among other items in separate arrays. The canine did not alert to any other
13. On April 17, 2024, a state search warrant issued by Ninth Circuit Court
Judge Michael Murphy was executed on the SUBJECT PARCEL to examine the
contents. The SUBJECT PARCEL was found to contain what appeared to be a lamp
fixture. Inside the fixture, three “bricks” (kilograms) were concealed with caulk and
nails. The total weight of the “bricks” was approximately 3.28 kilograms. The bricks
contained a white powdery substance which were field tested and tested positive for
cocaine. Based on my training and experience, I know that narcotics traffickers order
bulk amounts of narcotics in brick form so they can easily distribute the product.
typically sold for $16,000- $20,000. Therefore, this amount of cocaine would be
worth approximately $60,000, which is well above a typical amount for personal use.
14. On April 17, 2024, the parcel was delivered by a St. Cloud Police
Department officer acting in an undercover capacity to 1855 Overcup Ave, St. Cloud
FL at approximately 1:15 p.m. The parcel was placed near the front door. The parcel
15. During the operation, a white Acura SUV was seen conducting
driving around multiple times and the driver appeared to be taking photographs.
Organizations often use countersurveillance tactics to ensure that they are not being
watched or followed by law enforcement. The Acura was seen in the area for
approximately an hour before it actually drove into the driveway, demonstrating that
the driver (ROMERO) was watching for an extended period of time and likely
JZGQ49 drove into the driveway over 1855 Overcup Ave, St. Cloud FL and parked.
This vehicle was the same vehicle seen previously conducting countersurveillance.
17. ROMERO exited the vehicle, carrying a baby, and approached the
parcel. She picked up the SUBJECT PARCEL and placed it into the Acura. At that
time, HSI/DEA agents blocked the vehicle in the driveway and instructed the
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18. ROMERO stated that she arrived to “pick up her lamp” that she
ordered online. ROMERO stated that she does not live at 1855 Overcup Ave.
ROMERO was read her Miranda rights in Spanish by HSI TFO Rivera and agreed to
19. ROMERO stated that she had ordered a lamp on Facebook for $300
and she didn’t know what the problem was. ROMERO stated that she paid for the
lamp via PayPal on her cell phone. At this point in the interview, the parcel had not
been opened in the presence of ROMERO nor had any law enforcement members
told her what was inside the box. The fact that ROMERO mentioned a lamp before
being told what was inside the box demonstrates her knowledge of the contents of
20. ROMERO claimed that she had the SUBJECT PARCEL delivered to
this address, which she said belonged to “a friend who did [her] taxes” because she
didn’t remember her own address. She stated that the parcel was addressed to her
sister because she didn’t like her own name. ROMERO stated that she is not
21. At the time of the encounter, ROMERO was in possession of two cell
phones. ROMERO stated that one phone belonged to her, and one belonged to her
sister. However, later in the interdiction when ROMERO was informed that she was
being placed under arrest, agents asked ROMERO for the name of a person who she
trusted to take custody of her child. ROMERO asked agents to contact her sister and
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agents were able to speak with her sister, Rubi Romero, on the cellphone number
provided. Rubi Romero agreed to come and pick up the child. When asked about
why her name was on the package containing cocaine, Rubi Romero had no
multiple shipments of items to Puerto Rico. ROMERO stated that these shipments
were shoe boxes and that her sister has a shoe company. Based on my training and
23. ROMERO mentioned that she has a boyfriend named Giovany and
that she lives with her sister and boyfriend in Casselberry, Florida. ROMERO’s sister
was identified as Rubi Romero Soto, the recipient of the subject parcel. “Giovany”
has been identified as Giovany Joel CRESPO Hernandez, who has a Puerto Rican
Identification Card. ROMERO lives with her sister, Rubi Romero, and CRESPO at
(DTO) in the Central Florida area and has a significant criminal history including
narcotics possession and intent to distribute. CRESPO was the target of a previous
HSI investigation in 2020 out of Miami, Florida which led to the seizure of over
homicide investigations.
that I was placing ROMERO into custody for the SUBJECT PARCEL, deputies
with the Seminole County Sheriff’s Office executed a state search warrant at
recovered bulk currency ($13,701), narcotics (including fentanyl, cannabis, and drug
jewelry that has been identified as proceeds from robberies and home invasions:
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26. Agents also recovered two Glock firearms, including one in the laundry
room of the residence. In the driveway of the residence was a Toyota that was
hidden compartment with a hydraulic arm that is commonly used by drug traffickers
to secrete narcotics. The recovered firearm from the laundry room and the “trap” is
depicted below:
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CONCLUSION
27. I submit there is probable cause to believe that on April 17, 2024,
and (b)(1)(B).
______________________________
Special Agent Stephanie Pantos
Homeland Security Investigations
______________________________
ROBERT M. NORWAY
United States Magistrate Judge
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