UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 1:20mj03178 Reid - 3CCD

UNITED STATES OF AM ERICA

V5.

UNTARIUS DEM ONT ALEXANDER and

RODRICK M AURICE HAM ILTON,

D efendants.

/

CRIM INAL COVER SHEET

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

Attorney's Office prior to August 8, 2014 (Mag. Judge Shaniek Maynard)? Yes X No

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

Attorney's Office prior to October 3, 2019 (M ag. Judge Jared Strauss)? - Yes Z. No

Respectfully subm itted,

ARIANA FAJA RD O ORSHA N

U NITED STA TES A TTORNEY

BY: /s/shane Butland

Shane Butland

A ssistant United States Attorney

Southern D istrict of Florida

Court ID N o. A5502525

99 N ortheast 4th Street, 4th Floor

M iam i, Florida 33132-21 l l

Telephone: (305) 961-9123

E-mail; Shane.Butland@usdoj.gov

Case 1:20-mj-03178-LMR Document 1 Entered on FLSD Docket 07/20/2020 Page 1 of 7
AO 91 (Rev 08/09) Crlmlnal Complalnt

U NITED STATES D ISTRICT COURT

for the

Southern District of Florida

United States of America

V.

Case No. 1:20mjQ3178 Reid - 3CCD

UNTARIUS DEMONT ALEXANDER and

RODRICK MAURICE HAMILTON,

Defendantls)

CRIM INAL COM PLAINT

1, the complainant in this c>e, state that the following is true to the best of my knowledge and belief.

On or about the datets) of Se.py4mk4r.;-ia49.1-%-- ---- in the county of -..-- -Mhm..(rpade-...-.- - in the

smuthern -- District of Flofita - - - - , the defendantts) violated:

Code Secdon

18 U.S.C. ! 1951(a)

18 U.S.C. j 1951(a)

18 U.S.C. j 924(c)(1)(A)(ii) and (iii)

Ofense Description

Conspiracy to Cemmit Hebbs Ad Robbery

Attempted Hobbs Act Robbery

Brandishing and Discharging a Firearm in Furtherance of a Crime of Violence

This criminal complaint is ba ed on these facts:

SEE ATTACHED AFFIDAVIT.

W continued on the attached sheet.

; 

'

Com ir/o?1 ' signatttre

TFQ -K, mrmolh. V,- QIOg.ATF

Pritïled name tw7c/ tille

Attested to by the applicant in accordance with the

requirements of Fed. R. Crim. P. 4.1 by Face Time.

Date: J uly..l 7, 2020

City and state: . Miymia Flpridp

w *

Jltdge b- signature

Lisette M. Reid. U.S. Magistrate Judge . .

Printed name and tf//e

Case 1:20-mj-03178-LMR Document 1 Entered on FLSD Docket 07/20/2020 Page 2 of 7
A FFID AVIT IN SUPPO RT O F CRIM IN AL CO M PLA INT

1, Kenneth Veloz, being first duly sworn, hereby depose and state as follows:

I am a Task Force Officer with the Bureau of Alcohol, Tobacco, Firearms, and

Explosives CW TF''). l have served as an ATF Task Force Officer in M iami for approximately nine

(9) years. I have been tmployed as a law enforcement officer with the Miami-Dade Police

Department for twenty-seven (27) years. Currently, I am assigned to the Street Terror Offender

Program (iisTOP'')/High Intensity Dl'ug Trafficking Area ($$HlDTA'') Task Force. M y duties

include the investigation of a variety of federal offenses, including crimes such as Hobbs Act

robbery, the possession of firearms in furtherance of violent crimes, and drug trafficking offenses.

2. The information set forth in this Aftsdavit comes from my personal involvement in

this investigation, as well as from information provided to me by other law enforcement officers

who were involved in the investigation. This Affidavit does not represent every fact known about

this investigation, but is rather submitted for the limited pum ose of establishing probable cause for

the issuance of a criminal complaint charging UNTARIUS DEM ONT ALEXANDER

(CSALEXANDER'') and RODRICK MAURICE HAMILTON CiHAM ILTON'') with conspiracy to

commit Hobbs Act Robbery, in violation of Title 18, United States Code, Section 1951(a); Hobbs

Act Robbery, in violation of Title 18, United States Code, Section l951(a); and Brandishing and

Discharging a Firearm in Furtherance of a Crime of Violence, in violation of Title 18, United

States Code, Section 924(c)(1)(A)(ii) and (iii).

PROBM LE CAUSE

On or about Septem ber 29, 2019, at approxim ately 10:12 a.m ., an arm ed robbery

occurred at the Grab-A-snack Convenience Store (the ç:Store''), located at 1490 NW 7 1St Street,

M iam i, Florida. V ideo surveillance cam eras located inside of the Store captured the robbery, which

Case 1:20-mj-03178-LMR Document 1 Entered on FLSD Docket 07/20/2020 Page 3 of 7
I reviewed. ln the video, two masked individuals entered the Store. One of these masked

individuals, who was later identified as ALEXANDER, was wearing a yellow hooded sweatshirt

and dark pants, and the other individual, who was Iater identiied as HAM ILTON , was wearing a

blackjacket and black pants with gray/white stripes on the side.

ALEXANDER walked into the Store while HAM ILTON remained by the door.

ALEXANDER then attempted to acctss the EdEmployees Only'' area behind the cashier counter

where the Store's clerk (victim :1C.C.'') was standing. This area is largely enclosed by bulletproof

glass, but has an open area in front of the register where customers and the clerk can exchange

money and goods. Other than through that opening, the only altem ative access point for behind

the counter is through a side door. ALEXANDER initially attempted to enter the restricted area

through the side door, but after realizing it was locked, he then moved towards the opening in the

glass enclosure, while HAM ILTON remained by the Store's entrance.

5. ALEXANDER thenjumped on top of the cashier counter and pulled a srearm from

the pouch pocket of his hooded sweatshirt. ln response, C.C. grabbed a firearm from under the

counter and shot at ALEXANDER multiple times, forcing ALEXANDER to retreat from the

window and take cover behind one of the Store's food displays, where ALEXANDER returned

Gre. ALEXANDER and C.C. continued to fire multiple rounds at each other, and during the course

of this exchange, ALEXANDER was struck with a bullet, which resulted in a signiscant amount

of blood being left at the scene. M eanwhile, during the tsrefight, HAM ILTON also brandished a

firearm and shot the srearm in the direction of C.C.

6. HAM ILTON thereafter tled the Store and ran eastbound on N W 71St Street.

ALEXANDER tled the Store approximately one minute later and ran in the same direction as

HA M ILTON . C.C. im m ediately called 9-1-1 for assistance and law enforcem ent responded to the

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Store. On scene, 1aw enforcement collected blood samples from the Store's tloor for subsequent

DNA analysis and com parison.

Shortly thereafter, the City of M iami Police dispatch received a call of a single

vehicle crash at the intersection of 2nd court and NW 71St Street, M iami, Florida, which is located

approximately 1.3 miles east of the Store. Video surveillance from a nearby business showed that

the crash occurred approximately three (3) minutes after ALEXANDER and HAM ILTON tled the

Store.

8. Law enforcement responded to the crash scene and discovered that the crashed

vehicle- a black Ford Explorer SUV (the isvehicle'') with Florida tag number KSAY4&-was

registered to HAM ILTON . Law enforcement officers also observed that the Vehicle's license plate

w as covered w ith a piece of cardboard.

9. Law enforcem ent recovered a Sam sung cellular phone from the front passenger seat

of the Vehicle. A search of that phone, which was conducted pursuant to a search warrant signed

by M iam i-Dade State Court Judge J. M ansfield on or about October 28, 2019, revealed that the

phone was registertd to HAM ILTON .

10. Law enforcement also observed and obtained samples of blood on the front

passenger interior of the Vehicle despite there being no evidence of severe impact or shatttred

glass that could have caused such injuries to the Vehicle's occupantts).

Thereafter, members of the City of M iami Police Department received a report from

individual with the initials 1iP.S.,'' who claimed that she was the owner of the Vehicle and that it

was stolen by an unknown male from her house. W hen interviewed about the thefk P.S.

subsequently adm itted to law enforcem ent in a recorded statem ent that the V ehicle was not stolen

as she initially reported. Rather, P.S. stated that HAM ILTON , who was the registered owner of

3

Case 1:20-mj-03178-LMR Document 1 Entered on FLSD Docket 07/20/2020 Page 5 of 7
the Vehicle and her boyfriend, left her house with the car earlier that m orning after receiving a call

from his friend lsstutter.'' HAM ILTON returned to the house later that morning and told P.S. that

the car had been involved in a bad accident and that Sdstutter'' was shot. HAM ILTON then

demanded that P.S. call the police to report that tht Vehicle was stolen, and told P.S. what to say

to the police.

P.S. reported that HAM ILTON then took the keys to a vehicle registtred to P.S.-

a black Chevy Impala, tag number LM GM 49- and left to get iûstutter.''

13. P.S. further stated to law enforcement that she knew téstutter'' as HAM ILTON'S

friend and positively identitsed a photograph of ALEXANDER as the individual she knew as

tçstutter.''

14. On or about October 4, 2019, ALEXANDER was arrested and charged in state

court with an unrelated crime. ALEXANDER'S cellular telephone was seized incident to his arrest

and subsequently searched pursuant to a search warrant. ALEXANDER'S phone contained a

photograph of him and HAM ILTON on or about September 1, 20l 8. HAM ILTON appears to be

wearing the same pants in that photograph- black pants with three gray/white stripes down the

Iegs- as he was wearing during the robbery on or about Septem ber 29, 2019.

On or about October 7, 2019, law enforcem tnt obtained a buccal swab from

ALEXANDER that was compared with the swabs of the blood Iocated in the Store and inside of

the Vehicle. That comparison revealed that the DNA profile obtained from ALEXANDER'S

buccal swab matched the DNA profile obtained from the swabs of the blood from the Store and

the Vehicle.

l6. HAM ILTON was thereafter arrested by Florida state authorities on or about M arch

20, 2020. HAM ILTON provided an audio-recorded statement to law enforcement after waiving

4

Case 1:20-mj-03178-LMR Document 1 Entered on FLSD Docket 07/20/2020 Page 6 of 7
his M iranda rights, in which he stated that he picked up ALEXANDER in the Vehicle the morning

of September 29, 20 19 and took him to HAM ILTON 'S niece's house, which is located

approximately 0.8 miles from the Store. HAM ILTON stated that he went inside to visit with his

niece while A LEXAN DER stayed in the car, and realized when he exited the residence twenty

(20) minutes later that ALEXANDER took the Vehicle without HAM ILTON'S permission.

HAM ILTON then stated that he took a car service back to P.S.'S residence, at which time

A LEXAN DER showed up with a gunshot w ound but would not provide an explanation as to how

it occurred or the Vehicle's Iocation. HAM ILTON then claimed he took ALEXAN DER to one of

ALEXANDER'S friend's houses in a separate vehicle and cleaned the vehicle afterwards.

1 7. Based on the foregoing, your Am ant respectfully submits that there exists probable

cause to believe that A LEXAN DER and HAM ILTON comm itted the offenses of conspiracy to

commit Hobbs Act robbery, in violation of Title 1 8, United States Code, Section 1951(a);

attempted Hobbs Act robbery, in violation of Title 1 8, United States Code, Section 1951(a); and

Brandishing and Discharging a Firearm in Furtherance of a Crime of Violence. in violation of Title

l 8, United States Code, Section 924(c)(l )(A)(ii) and (iii).

. 

ae

FURTHER YOUR AFFIANT SAYETH NAUGHT ''9

'>

T e O m cer Ken t Veloz

Bureau of A lcohol, Toba , Firearms, and

Explosives

Attested to by the applicant in

accordance w lth the requirem ents

of Fed. R. Crim . P. 4.l , by Face Tim e

this l7thday of July 2020.

< *

ORABLE LIS U E M . REID

UN ITED STATES M AGISTRATE JUDG E

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