UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Case No. l:20-mj-02668-AOR 

UNITED STATES OF AMERICA 

v. 

FREROT JOASSAINT, 

Defendant. ______________ / 

CRIMINAL COVERSHEET 

1. Did this matter originate from a matter pending in the Central Region of the United States 

Attorney's Office prior to August 9, 2013 (Mag. Judge Alicia Valle)? _Yes X... No 

2. Did this matter originate from a matte1· pending in the Northern Region of the United States 

Attorney's Office prior to August 8, 2014 (Mag. Judge Shaniek:Maynard)? _Yes K_ No 

By: 

Respectfully submitted, 

ARIANA FAJARDO ORSHAN 

UNITED STATES ATTORNEY 

Dayron Silverio 

Assistant United States Attorney 

Florida Bar No. 112174 

99 N.E. 4th Street, 6th Floor 

Miami, Florida 33132-211 l 

T. (305) 961-9009 

F. (305) 530-7976 

Dayron.Silverio@usdoj.gov 

Case 1:20-mj-02668-AOR Document 1 Entered on FLSD Docket 04/28/2020 Page 1 of 6
Application for a Complaint by Telephone or Other Reliable Electronic Means 

UNITED STATES DISTRICT COURT 

United States of America 

, v. 

FREROT JOASSAINT, 

Defe11da11t(s) 

for the 

Southern District of Florida 

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) 

) 

) 

) 

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Case No. l:20-mj-02668-AOR 

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 April 7, 2020 in the county of Miami-Dade 

Southern District of Florida , the defendant(s) violated: 

Code Section 

18 U.S.C. § 111(a)(1) 

Offense Description 

Forcibly Assaulting a Federal Officer. 

This criminal complaint is based on these facts: 

SEE ATTACHED AFFIDAVIT. 

ref Continued on the attached sheet. 

Attested to by the applicant in accordance with the 

requirements of Fed. R. Crim. P. 4.1 by FaceTime. 

Date: · 04/28/2020 

Julio L. ca·stro, ICE Deportation Officer 

Printed name and title 

in the 

City and state: Miami Florida Alicia M. Otazo-Reyes, Magistrate Judge 

Printed name and title 

Case 1:20-mj-02668-AOR Document 1 Entered on FLSD Docket 04/28/2020 Page 2 of 6
AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLIANT 

I, Julio L. Castro, being duly sworn, hereby depose and state the following: 

1. I am a Deportation Officer with Immigration and Customs Enforcement ("ICE"), 

Enforcement and Removal Operations ("ERO"), United States Department of Homeland Security, 

and have been so employed for the past eight (8) years. I am assigned to the ICE/ERO Miami Field 

Office in Miami, Florida. As an investigative and law enforcement officer of the United States 

within the meaning of Title 8, Title 18, and Title 19 of the United States Code, I am empowered 

by law to investigate, l_ocate, and apprehend individuals in violation of such laws, as well as to 

prncess and remove non-United States Citizens for violating the Immigration and Nationality Act. 

2. The statements in this Affidavit are based on 1?-Y personal lmowledge and 

inf01mation provided by other individuals, including law enforcement officials, as well as my 

review of records, documents, and other physical items obtained during the course of this 

investigation. I have not included each and every fact known to me or law enforcement in this 

investigation, instead including only those facts necessary to establish probable cause. 

3. Based on the facts set f011h in this Affidavit, there is probable cause to believe that, 

on or about April 7, 2020, in Miami-Dade County, in the Southem District of Florida, Frerot 

JOASSAINT ("JOASSAJNTH) did forcibly assault, resist, oppose, impede, intimidate, and 

interfere with R.G., J.R.M., and A.L.M., three persons designated in Title 18, United States Code, 

Section 1114 who were assisting an office1: or employee of the United States and of an agency in 

a bl'anch of the United States Government, that is, the Field Office Director for the ICE/ERO 

Miami Field Office of the United States Department of Homeland Security, while that officer or 

employee was in the performance of his official duties, which include the housing, detention, and 

1 

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management of immigration detainees at the Krome Service Processing Center ("KRO SPC"), in 

violation of Title 18, United States Code, Section lll(a)(l). 

PROBABLE CAUSE 

4. On or about March 17, 2020, the ICE/ERO Miami Secure Communities 

Interoperability Response Center ("IRC") encountered JOASSAINT, A#207 945 403, through a 

joint effort with the Florida Department of Corrections in Miami-Dade County, Florida. ICE/ERO 

Miami IRC lodged an Immigration Detainer (l-247A) with Miami-Dade Department of 

Corrections at the Turner Guilford Knight Correctional Center. 

5. On or about March 19, 2020, JOASSAlNT was transferred to KRO SPC, an ICE 

detention facility in Miami, Florida, to be housed pending immigration proceedings. 

6. On or about April 7, 2020, JOASSAINT assaulted three federal contract detention 

officers at KRO SPC who were assisting the Field Office Director for the ICE/ERO Miami Field 

Office of the United States Department of Homeland Security in the pe1fo11nance of the Field 

Office Director's official duties, which include the housing, detention, and management of 

immigration detainees. 

7. More specifically, at approximately at 6:50 p.m. that day, JOAS SAINT was hitting 

one of the windows in Building 11, a housing unit inside KRO SPC. 

8. In response, R.G., a detention officer employed by a contractor retained by the 

United States to assist in the housing, detention, and management of detainees at KRO SPC, 

ordered JOASSAINT to stop. 

9. Upon refusing specific commands to back away from the window and stop the 

hitting, R.G. gave a custodial touch to separate JOASSAINT from the window. 

2 

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10. At that time, JOASSAINT slapped the hand ofR.G. and told him, "Don't touch me 

or I'm going to fuck you up." 

11. R. G. used force to redirect JOAS SAINT to the ground, where he became combative 

and aggressive. 

12. JOASSAINT resisted by kicking and by biting R.G. in both hands. 

13. During the altercation between R.G. and JOASSAINT, other detainees started to 

attack R.G. 

14. Additional detention officers responded to the "officer needs assistance" call and 

encountered an organized gt'Oup of detainees displaying aggressive and combative behavior, 

blocking the path of the responding detention officers and refusing to comply with the detention 

officers' commands. 

15. Two detention officers, J.R.M. and A.L.M.-also employed by the same federal 

contractor as R.G.-assisted other officers to gain control and restrain JOASSAINT. 

16. In rendering assistance, J.R.M. attempted to gain control over JOASSAINT, who 

responded by grabbing J.R.M. 's collar and choking him. 

17. A.L.M. tried to help J.R.M., but was bitten by JOASSAINT on his left bicep. 

18. During the incident, JOASSAINT also bit J.R.M. 's chest. 

19. After JOASSAINT bit the officers, he was able get loose and run to the other side 

of the housing unit. 

20. Additional officers responded to the incident and were finally able to gain control 

of JOASSAINT and remove him from the housing unit. 

21. Based on the foregoing facts, there is probable cause to believe that, on or about 

April 7, 2020, in Miami~Dade County, in the Southern District of Flodda, Frerot JOASSAINT 

3 

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("JOASSAINT") did forcibly assault, resist, oppose, impede, intimidate, and interfere with R.G., 

J.R.M., and A.L.M., three persons designated in Title 18, United States Code, Section 1114 who 

were assisting an officer or employee of the United States and of an agency in a branch of the 

United States Govemment, that is, the Field Office Director for the ICE/ERO Miami Field Office 

of the United States Department of Homeland Security, while that officer or employee was in the 

performance of his official duties, which include the housing, detention, and management of 

immigration detainees at the Krome Service Processing Center ("KRO SPC"), in violation of Title 

18, United States Code, Section 111 ( a)(l ). 

FURTHER AFFIANT SA YETH NAUGHT. 

Deportation Officer 

U.S. Immigration and Customs Enforcement 

Attested to by the applicant in accordance with 

the requirements of Fed. R. Crim. P. 4.1 by: 

FaceTime. 

(specify reliable electronic means). 

Date: 4/28/20 

U.S. MAGISTRATE JUDGE 

4 

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