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AO 91(R> .ll/1lj C--'' ltAxm le l
CR IM G A L C O M PLM N T
1,thecomplainantin thiscmse.statethatthefollowing istzuetothebestofmy u owledgeandG lief.
Onoraboutthedatds)of */11Q920,1*11/2X 0'10/12/2020 inthecountyof Browad inthe
Soumem Districtof FlY da .thedefM dnntls)violated:
CodeSection OFevelWachption
18 U.S.C.j 1201(c) ConspiracytoKidnap
18U.S.C.% 1201(a),2 Kidnapping
18U.S.C.j* T(g)(1) PoAr- nlonofaFlrearm byaConvidedFelon(DionteAlexae er-Wie x)
nt
*scriminalcomplaintisbu td onthese facts:
See aa dle Amdavit.
# continuedonieattacheds- t.
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1, Christopher Adam Goodrich, being first duly sworn, hereby depose and state as
follows:
lam aSpecialAgentfortheFederalBureauoflnvestigation(dTBl''),currently
assigned to the ViolentCrimesand FugitiveTask Force in the M iam iDivision.Ihave been an
FBlSpecialA gent since June 2016 and assigned to the M iam iDivision since N ovem ber2016.
Priorto my assignm entto the ViolentCrim es and Fugitive Task Force, I was assigned to the
Violent Crimes Against Children Squad fortwo (2) years.l received training atthe FBl
Academy in Quantico,Virginia.In my currentcapacity,my duties include investigating bank
robberies,HobbsActrobberies,extortion,and otherviolationsoffederallaw .Priorto m y current
employment,IworkedasaPoliceOfficerinNorfolk,Virginia,fornine(9)years.
2. Based on the facts as setforth in this affidavit,there is probable cause to believe
a/k/a ddYung Fokiss,''and DIONTE ALEXAND ER-W ILCOX a/k/a çdD ionte Alexander''a/k/a
experience,and inform ation obtained from other agents and w itnesses.This affidavitis intended
to show sim ply thatthere is sum cientprobable cause forthe requested warrantand does notset
October11,2020
knock at the front door of her residence, located in M iram ar, Florida. She Iooked out the
could talk to him .Victim -l tried to explain thatshe did nothave Anthony'stelephone num ber
but A lexander-W ilcox claim ed that he could not hear her through the window .A s soon as
forehead,andpushedherinsidethehome.Anothermasked individual-believedtobeKejuan
Campbella/k/aSssplashzanotti''a/k/aiisplashzanoti''- quicklyjoinedAlexander-W ilcox inside
the residence.They ordered Victim-l to the ground.lm mediately after V ictim -l w as on the
ground, another m asked individual - believed to be A ntonio Jam es a/k/a ddYung Fokiss''-
Victim-ltocontactherbank,SunTrustBank,andtransfertwentythousanddollars($20,000.00)
from thejointsavingsaccountthatshesharedwithVictim-ztothejointcheckingaccotlnt.Once
the transfer occurred, Campbell took Victim -l's phone and installed Cash App, an internet-
based money transfer application, onto it without her perm ission.4 Cam pbell and the other
6. Atan unknow n tim e butpriorto 8:00 pm ,Cam pbellforced V ictim -lto write five
(5)personalchecksfrom thejointcheckingaccount.Fourofthecheckswereforfivethousand
dollars($5,000.00)apieceand onecheck wasfortwenty thousand dollars($20,000.00).The
SdpayableTo''sectionon each check remained blank.Campbellthen took the checksand drove
attempted to cash the four $5,000.00 checks.Amscotdeclined to process any ofthe checks.
Cam pbellthen returned to the residence and ordered Victim -linto the passengerseatofa white
3Atthetimeoftheeventsdescribedabove,Anthony'sstepfatherresidedapproximatelytwo(2)milesfrom Victim-
1and Victim-z'sresidence.
4The phone num berassociated with the Cash App transactions was754-201-3894.A public recordssearch showed
that754-201-3894 isleased to Pinger,Inc.(stPinger''
),aproviderofVoiceOverlnternetProtocol(V0IP)telephone
numbers. Law enforcement submitted an exigent request to Pinger, which reported that the phone number in
question bore the username -bprodigyantoniojames''and Iisted prodigyantoniojames@gmail.com as the email
address.
5Nissansarem anut
-
actured wholly orin partoutside ofthe state ofFlorida.
3
Case 0:20-mj-06653-AOV Document 1 Entered on FLSD Docket 12/16/2020 Page 5 of 15
it w ith Victim -I. W hile attem pting to cash the checks, Cam pbellcom pleted the l%Financial
ServicesA greem ent''by listing his actualnam e,date Ofbirth,and socialsecurity num ber.6 He
also provided a copy of his Florida driver's license. Am scot again declined to process the
and Victim-l entered the store and walked towardsthe customerservice desk.Upon reaching
thistime.?
victim s'm ovem entsthroughoutthe house,and theiraccessto telephones and the internet.
October 12,2020
7 Based on Call Detail Records associated with Cam pbell's phone, both Cam pbell and James were in
comm unication with oneanotherduring the timesinwhich Cam pbellIeftthe residencewith Victim-lin Campbell's
attemptto obtain the $20,000.00 from the various commercialestablishments.ln your amant's training and
experience,individualswho plan forand execute a kidnapping ohen maintain communication with one other,either
through telephone calls ortextmessaging,to apprise the otherparticipantsoftheirwhereaboutsand the success or
failure ofothercriminalactsdoneduring the comm ission ofthe kidnapping.
4
Case 0:20-mj-06653-AOV Document 1 Entered on FLSD Docket 12/16/2020 Page 6 of 15
the masked subjectforcibly raped Victim-l on top ofthe bed.The masked wbjectwasnot
wearing a condom atthe tim e.He then directed Victim -l to go into the bathroom and shower.
AherVictim-lshowered,sheandthemaskedsubjectreturnedtothelivingroom.
10. Atapproximately 8:55 am,Campbellordered Victim-lintothepassengerside of
determ ine why the banks w ere closed.ltw as then that he realized thatitwas Colum bus Day,a
federalholiday.
11. Atapproximately 9:54 am ,Cam pbelland Victim -l arrived atthe M iam iCasino,
located at3500 N W 37th Avenue,M iam i,Florida.They entered the casino and proceeded to the
cashier's w indow . W hile at the cashier's w indow, Cam pbell attem pted to use V ictim -l's
8 Based on the descriptions that Victim-l provided for each assailant,Victim-l appeared to have identitied the
assailant believed to be Antonio James as the rapist; however, the results ofthe DNA analysis show thatonly
Alexander-W ilcox's sperm was on the bed comforter on which the rape occurred (see Paragraph 17).ln your
aftiant'straining and experience,itis notuncom mon forvictim sofsexualassaultto have dim culty recallingcertain
details,particularly when there werem ultiple masked assailants.
5
Case 0:20-mj-06653-AOV Document 1 Entered on FLSD Docket 12/16/2020 Page 7 of 15
proceeded to the W alm art,located at3200 N W 79thStreet, M iam i,Florida,and attem pted to use
duringthesmokebreakearlierthatday(seeParagraph9.9Headdedthatoneofthesubjectsback
atthe residence with Victim-z wasa Sskiller''who had killed in the past.Thiscaused Victim -lto
SunTrustBank and increase herATM w ithdrawalIim it.A ûerthe bank authorized the increase,
9 victim-z had told Campbell that he disagreed with the decision to rob him and Victim -l for som ething that
Anthony did.
6
Case 0:20-mj-06653-AOV Document 1 Entered on FLSD Docket 12/16/2020 Page 8 of 15
Cam pbellhad a firearm with him during each transaction and keptiton hisperson.A stillimage
sim ilar features to Cam pbell,specifically the tattoos neareach eye and a horizontalscar on his
forehead (seebelowl:lo
Cam pbell Sunl-rustATM tDavie)
A review ofthe surveillance footage confirm ed thatthe Vehiclew asa white N issan A ltim a.ll
A fter successfully com pleting the ATM w ithdrawals, Cam pbell and Victim -l
returned to the residence.Cam pbell,James,and A lexander-W ilcox began cleaning the residence,
even directing the victim s to participate. During the cleanup, the assailants placed m ultiple
clothingitems,jewelry,andliquorbottlesintwo(2)blacksuitcasesthatbelongedtothevictims.
Campbell,Jam es,and A lexander-W ilcox subsequently erased the footage from the surveillance
1lOn October12,2020,a license plate reader(LPR)detected a2017 whiteNissan Altimabearing Florida license
plate JYESI8 approximately a halfmile away from the SunTrustBank in M iramar,around the time thatCampbell
completed the ATM transactions atthis location.The registered ownerofthe vehicle isVictoria Johnson,who is
believed to be the motherofCampbell'schild and whose VOIP telephone numberCampbelllisted on the Financial
ServicesAgreementduring the attempted Am scottransactions.
7
Case 0:20-mj-06653-AOV Document 1 Entered on FLSD Docket 12/16/2020 Page 9 of 15
system ,rem oved the visible surveillance camera from the southwestcorner ofthe residence,and
tam pered with the surveillance cam era thatwas nearthe m iddle ofthe residence.They told the
victim s that their vehicle keys, cellphones, bankcards, and social security cards were in the
garage.Thatafternoon,Cam pbell,Jam es,and A lexander-W ilcox leftthe residence w ith the two
l5. A fter the assailants had departed from the victim s' residence, Jam es used his
cellphonelz to record a video of Cam pbellsitting in the driver seat of a vehicle counting the
Alexander-W ilcox.W hile taking the video, Jam es stated,SiDon't w orry.l ain't posting this.''
12On oraboutNovember l8,2020,law enforcem entseized Jam es'cellphone from hispossession atthetime ofhis
arrestforviolating hispretrialrelease on pending state charges.W hile on scene,James confirmed thatthe cellphone
belonged to him.Aherexecuting a federalsearch warranton the cellphone (20-6605-HIJNT),law enforcement
observed theaforementioned video.
8
Case 0:20-mj-06653-AOV Document 1 Entered on FLSD Docket 12/16/2020 Page 10 of 15
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lm portantly,Cam pbellappears to be wearing the sam e sweatshirt,m ask and hat thathe wore
to the victim sand an identification card belonging to the victim s'fam ily m em ber.Thisappeared
to be one ofthe suitcases taken by Cam pbell,Jam es,and Alexander-W ilcox.Law enforcem ent
provided Victim -l and Victim -z w ith a photograph of the suitcase and its contents. They
13A police reportfrom 2019 identit ied Jam es as a suspectofa domestic incidentthat occurred at7761 N W 41
Street,Davie,Florida,which isin close proximity to the Iocation wherelaw enforcementfound thesuitcase.
9
Case 0:20-mj-06653-AOV Document 1 Entered on FLSD Docket 12/16/2020 Page 11 of 15
AdditionalInvestigativeM aters
Law enforcem ent subm itted m ultiple item s seized from the residence,including
thebed comforteron which the rapeoccurred,and the suitcase found on October l3,2020 (see
Paragraph 16)forDNA analysis.ResultsshowedthatJames'DNA waspresentonanumberof
item s, including the rim of a drinking glass,cigarette butts,and a Ziploc bag. Results also
showed thatA lexander-W ilcox's DNA w as presenton a num berof item s,including a different
l8. O n or about Decem ber l2, 2020, Victim -z contacted law enforcement and
Jam es.A lthough V ictim -z advised that he was not certain that Jam es w as one of the three
l9. Both Jam es' and Cam pbell's social m edia accounts display photographs from
20l8 and 20l9 ofthem together.Alexander-W ilcox's socialm edia accounts depictphotographs
im agesofhim selfin possession offirearm son hissocialmedia accounts.In one ofthese images,
October 11,2020,and October l2,2020,Campbell's phone m ade one hundred and twenty one
togetherback in 2014 and 2015.ln fact,Florida driver's license records identify 7753 Faim ay
Blvd,M iram ar,Florida,as Jam es'last known address.This is the sam e address that Anthony
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Alexander-W ilcox posted a photograph ofhim selfholding a firearm thatbore a serialnum ber.
The im age itselfappears below on the leftw hile a close-up,m irror im age of the serialnum ber
A SpecialAgentwiththeBureauofAlcohol,Tobacco,FirearmsandExplosives($$ATF'')whois
an expert in conducting nexus exam inations of firearm s reviewed the im age of A lexander-
W ilcox above and determ ined that the firearm is a Sm ith & W esson firearm bearing serial
num berFBY7791.The ATF SpecialAgentthen contacted Sm ith & W esson,who confirm ed that
itdid m anufacture a firearm w ith thatexact serialnum berand thatthe firearm - a M odelSD9
VE,9m m sem iautom atic pistol- w asm anufactured in M assachusetts.A recordscheck revealed
that,priorto September 11,2020,Alexander-W ilcox had previously been convicted ofa crime
punishable by im prisonm ent exceeding one year,that is,a felony offense.Because Alexander-
W ilcox had previously served a term ofim prisonm entexceeding one year,he knew thathe was a
CONCLUSION
25. Your am ant believes that probable causv exists to fm d that KEJUA N
tTrapsavage s'' committed violations of Title 18, United States Code, Sections 1201(c)
(conspiracy to kidnap),and 1201(a)(1)and 2 (kidnnpping).Yotlr am antalso believes that
probablc caust cxists to find that ALEX ANDER-W ILCOX com m itted a violation of Title 18,
UnitedStatesCede,Stction922(g)(1)(possessionofahrearm byaconvictedfelon).
FURTHER YO UR AFFIA:
N T SAYETH NA UG HT
/ Z --
Spœ ialA gentChristopherAdam Gooo ch
FederalBureau ofInvestigation
A ICIA 0 .VALLE
U NITED STATES M A GISTRATE JUDG E
14