UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 22-CR-20389-ALTMAN/REID 

UNITED STATES OF AMERICA 

 

vs. 

 

JULIAN JIMENEZ, et al. 

Defendants. 

 _____________ / 

GOVERNMENT’S MOTION IN LIMINE 

 The United States of America files this Motion in Limine for a pre-trial determination of 

the following evidentiary matters: 

I. FBI Agent Offers Lay Opinion Testimony Regarding Cellular Tower Locations 

The Government will call FBI Special Agent (SA) Ryan Dreibelbis as a summary witness 

offering lay opinion testimony. Agent Dreibelbis will testify concerning his use of cellular 

telephone records to plot the defendants’ locations at particular times based on which cellular 

towers they used and also based on iCloud location data.1 Agent Dreibelbis plotted those points 

on maps already provided to the defense. Pursuant to Local Rule 88.9, the Government conferred 

with Defendant Jimenez and Defendant Serrano who each object, asserting that such testimony is 

the subject of expert, not lay, testimony. 

An FBI agent offers admissible lay witness testimony—not expert opinion—when using 

cellular telephone records, including cell phone tower records, to testify regarding a defendant’s 

location at particular times. See United States v. Batista, 558 F. App’x 874, 876 (11th Cir. 2014) 

1 iCloud location data attached to photographs or videos consists of longitude and latitude 

coordinates that, like cell tower locations, can be inputted into a map to designate where and when 

a photograph or video is uploaded to iCloud. 

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(ruling that lower court’s admitting FBI agent’s lay testimony and map agent produced by relying 

on defendants’ cell phone records and phone companies’ records of cell tower locations). 

Permitting this testimony is not an abuse its discretion. Id. at 876. In Batista, an FBI agent plotted 

which cell towers connected with which defendant’s cell phone at a particular point in time on a 

map. Id. In doing so, the agent relied on the defendants’ cell phone records and the cell phone 

companies records of their cell phone towers’ locations. According to the Eleventh Circuit, the 

testimony qualified as admissible lay opinion since all the agent had to do was read the cell phone 

records to determine which cell tower was used at a particular time, look up the latitude and 

longitude of that cell tower in the companies’ records, and mark the intersection of the latitude and 

longitude on a map. Id. See also United States v. Jeri, 869 F.3d 1247, 1265 (11th Cir. 2017) (“Lay 

witnesses may draw on their professional experiences to guide their opinions without necessarily 

being treated as expert witnesses.”); accord United States v. Caniff, 955 F.3d 1183, 1195 (11th 

Cir. 2020) (“[J]ust because a lay witness’s position and experience could have qualified him for 

expert witness status does not mean that any testimony he gives at trial is considered ‘expert 

testimony.’” (quoting Jeri, 869 F.3d at 1265)); United States v. Feliciano, 300 F. App’x 795, 801 

(11th Cir. 2008) (testimony by a law enforcement witness about historical cell site data was opinion 

lay testimony because the witness, a detective, did not express an expert opinion based on 

scientific, technical, or other specialized knowledge). 

In addition, SA Dreibelbis’s summary charts are supported by the evidence the 

Government intends to introduce and so, are themselves admissible. United States v. Maurya, 25 

F.4th 829, 840 (11th Cir. 2022); see United States v. Richardson, 233 F.3d 1285, 1293-4 (11th Cir. 

2000) (permitting “summary charts incorporating certain assumptions so long as supporting 

evidence has been presented previously to the jury” and the court “made it clear that the ultimate 

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decision should be made by the jury as to what weight should be given to the evidence” (cleaned 

up)). Admitting a summary chart requires the court make clear that the jury ultimately decides the 

weight of that evidence. Richardson, 233 F.3d at 1294. 

II. An FBI Agent Offers Summary Evidence in the Form of a Timeline 

The Government will call FBI SA Ryan Dreibelbis as a summary witness who will use 

information introduced into evidence, too voluminous to access and review in court, to create a 

timeline of the Defendants’ whereabouts and activity for the relevant time period covering the 

alleged acts. Pursuant to Local Rule 88.9, the Government has conferred with counsel for the 

Defendants. Defendant Jimenez agrees that a timeline chart could fall under Rule 1006 or qualify 

as a demonstrative. Defendant Jimenez reserves the right to object to any timeline on other 

grounds. Meanwhile, Defendant Serrano has no objection to timeline testimony provided it is 

given by a witness with the appropriate knowledge. 

Creating and introducing into evidence a timeline is permissible when it will help the jury 

understand voluminous records, and the timeline fairly summarizes evidence. See, e.g., United 

States v. Ho, 984 F.3d 191, 210 (2d Cir. 2020) (“This court has long approved the use of charts in 

complex trials, and has allowed the jury to have the charts in the jury room during its deliberations, 

so long as the judge properly instructs the jury . . . that it is not to consider the charts as evidence.”); 

United States v. Abou-Khatwa, 40 F. 4th 666, 686 (D.C. Cir. 2022) (finding summary witness’ 

testimony and summary charts, which relied on cross-referencing invoices, was permissible); 

United States v. Borders, 829 F.3d 558, 567 (8th Cir. 2016) (“Summary evidence is proper when 

it assists the jury in understanding the testimony already introduced and fairly summarizes trial 

evidence.” (internal quotation marks omitted)); United States v. Chivers, 488 F. App’x 782, 785 

(5th Cir. 2012) (quoting United States v. Bishop, 264 F.3d 535, 547 (5th Cir. 2001)) (“Summary 

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charts in particular are admissible when (1) they are based on competent evidence already before 

the jury, (2) the primary evidence used to construct the charts is available to the other side for 

comparison so that the correctness of the summary may be tested, (3) the chart preparer is available 

for cross-examination, and (4) the jury is properly instructed concerning use of the charts.”); 

United States v. Olsen, 704 F.3d 1172, 1185 (9th Cir. 2013) (noting government introduced 

summary evidence at trial—consolidating 20,000 pages of evidence—along with a timeline 

showing defendant’s internet activity). 

In this case, the stalking statute charged in Count 1 of the Indictment requires proof that 

the defendants travelled in interstate commerce to, in part, “place under surveillance with intent to 

kill, injure, harass, or intimidate another person.” The Defendants—while in South Florida—did 

exactly this for six (6) days. But that is not all they did. The Defendants’ time away from stalking 

the victim is just as relevant because it demonstrates how they repeatedly reunited to continue 

surveilling—and eventually attack—the victim. The Defendants’ time apart from each other, 

particularly after the attack, shows how the two eventually—and separately—fled, each returning 

to their home state of New York. Once separated, and while still in Florida, each engaged in 

additional activity until August 31, 2019, (for Defendant Jimenez) and September 10, 2019 (for 

Defendant Serrano)—for an additional four (4) days and fourteen (14) days of activity, 

respectively. The Government intends to prove this surveillance and flight by relying on cell-site 

data for three separate telephones, iCloud data, Instagram data from two different accounts, 

photographs, banking records, airline records for at least three people, Lyft data, rental car records, 

Sunpass records, Miami-Dade Expressway Authority records, car purchase records, and Florida 

Department of Transportation records. On June 5, 2022, Defendant Jimenez characterized the 

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state of discovery as “69,700 banker’s boxes of printed paper.”2 Since that time, the Government 

has produced even more data. The information supporting the timeline is extraordinary and not in 

chronological order. Setting out the Defendants’ activity in chronological order given all the data 

is important for the jury to understand who did what, when, and where. Without a timeline, there 

is simply no other way to digest this voluminous information. 

As an example of the complexity involved in contextualizing all this information, the cellsite expert created a report documenting the Defendants’ “pinging” cell towers at or near the 

victim’s business and residence. On just one particular day, the Defendants “ping” near and around 

the victim’s residence and business, their phones moving from tower to tower—sometimes their 

phones using the same towers, and other times different towers from each other. Separating 

fourteen days of “pings” into chronological order required hours of work by the Government. See 

e.g. Exhibit 1 A, B of plotted data. Cell-site data is only one source used for the proposed timeline. 

It is simply impossible for a jury to understand during trial or deliberations what transpired without 

a streamlined, chronological organization of pertinent events as contained within over 69,000 

banker’s boxes. As such, Agent Dreibelbis will serve the function that serves the very purpose of 

Rule 1006. C.f., United States v. Francis, 131 F.3d 1452, 1457-58 (11th Cir. 1997) (noting court 

may admit summaries where it would be “inconvenient or unnecessarily time-consuming” to 

review the summarized evidence, even including taped conversations). Further, it is not realistic 

to expect the jury to just remember what they saw and heard regarding this timeline during trial if 

it is limited to being only a demonstrative aid. Therefore, the Court should exercise its discretion 

to admit the timeline into evidence consistent with authority cited above. 

2

 “IT staff at the Federal Public Defender’s Office estimates the total quantity of data received to 

date exceeds 697GB, which quantity of data would fill approximately 69,700 banker’s boxes if it 

was all printable documents.” [ECF 129] at 3-4. 

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III. The Government Will Call Hostile Witness(es) To Testify 

The Government seeks to use leading questions during the direct examination of various 

witnesses who are identified in strong and intimate ways with the defendants and/ or who are 

hostile against the Government. This is permitted under Fed. R. Evid. 611(c). For example, the 

Government will call M.J. and E.R. to testify. They are Defendant Jimenez’s father and cousin, 

respectively, and both E.R. and M.J. have said E.R.’s relationship with Defendant Jimenez more 

closely resembles that of a sibling. Each of these witnesses is identified with Defendant Jimenez 

as an adverse party. M.J. is Defendant Jimenez’s father and has denied information to the FBI that 

he freely admitted to others. He has explained the very difficult position he is in given that his son 

is accused of shooting the very good friend of his high profile, longtime friend and employer. He 

has spoken with Defendant Jimenez and the defense team. He has expressed remorse for ever 

giving information that was used to incriminate his son. E.R., the Defendant Jimenez’s “sister,” 

who housed Defendant Jimenez in New York, changed her testimony between interviews, even 

recently remembering a huge swath of information she specifically denied in earlier interviews. 

She specifically denies incriminating information that M.J. says she provided him. Another 

example is Government witness A.O.—Defendant Serrano’s fiancée and mother to his one-yearold child. A.O. engaged in an attempt to deceive the FBI about Defendant Serrano’s whereabout 

in New York when he was inside their house the whole time. The agents have contacted her 

periodically as information has come up, including, but not limited to, proof that Defendant 

Serrano was having affairs. Understandably, A.O. has grown increasingly hostile toward 

government agents over time. A.O. has rejected Government attempts to arrange travel and 

housing for trial, and she has not answered about where she is staying once in South Florida. 

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Despite this hostility, and despite allegedly having no direct knowledge of Defendant Serrano’s 

criminal conduct and no exculpatory information, A.O. has expressed her eagerness to testify. 

After conferring with defense counsel under Local Rule 88.9, Defendant Jimenez and 

Defendant Serrano both assert that the above-mentioned witnesses do not necessarily qualify as 

witnesses identified with an adverse party. Therefore, they object, pending a demonstration of 

hostility and ruling from the Court permitting leading questions. 

Federal Rule of Evidence 611(c) bars an attorney from using leading questions on direct 

examination unless the attorney is examining a hostile witness, an adverse party, or a witness 

identified with an adverse party. M.J., E.R., and A.O. are, at a minimum, witnesses identified with 

an adverse party. Prior to the adoption of Rule 611(c), before a party could lead a witness on direct 

examination, it had to be shown that the witness was either actually hostile or an adverse party, 

officer, director, or managing agent of such adverse party. Haney v. Mizell Mem'l Hosp., 744 F.2d 

1467, 1477–78 (11th Cir. 1984). Rule 611(c), however, significantly enlarged the class of 

witnesses presumed hostile, “and therefore subject to interrogation by leading questions without 

further showing of actual hostility.” Id. (internal citations omitted) (finding that a witness called 

by the plaintiff—an employee of a defendant when alleged malpractice occurred—“certainly was 

identified with a party adverse to” the plaintiff, and the district court, under Rule 611(c), should 

have permitted plaintiff to ask witness leading questions without establishing actual hostility). 

Under Rule 611(c), the Government should be permitted to use leading questions during the direct 

examination of Defendant Jimenez’s father and cousin as well as Defendant Serrano’s fiancée. 

IV. Fair and Accurate Photographs are Admissible. 

The Government intends to introduce into evidence an image of a vehicle and its occupant 

passing through a Florida toll plaza. Sunpass provided this image along with a certificate of 

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authenticity, under Fed. R. Evid. 902(11). A Sunpass camera captured the image during nighttime 

hours. 

An FBI agent opened this image on his computer using a standard, commercially available 

Microsoft program called “Photos.” Once opened, the agent took three simple steps to adjust the 

contrast: the agent (1) selected “Edit”; (2) selected the icon for adjusting light/darkness; and (3) 

slid two different scales to achieve a more discernable image.3 The original image from Sunpass 

is below (left) as Exhibit 2, incorporated herein, and the resulting image is below (right) as Exhibit 

3, incorporated herein: 

 

Assuming relevance, the original is admissible pursuant to the 902(11) certificate, and the 

agent’s image is admissible as a fair and accurate depiction of the original he received from 

Sunpass. 

Pursuant to Local Rule 88.9, Defendant Jimenez took no position on this matter considering 

it irrelevant to Defendant Jimenez. Defendant Serrano objects to the agent’s image, asserting the 

photograph is altered and, therefore, not a fair and accurate depiction of the original. 

3

 The Government video recorded the agent engaging in these steps for reference. See Exhibit 4, 

submitted to the court under separate cover. The Government provided a copy to the defense in 

discovery. 

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The predicate for introducing a photograph is the witness testimony that he recognizes what 

is depicted in the photograph, and that the photograph fairly and accurately depicts that person, 

place, or thing. Under Rule 901(a) of the Federal Rules of Evidence, to satisfy the requirement of 

authenticating or identifying an item of evidence, the proponent must present “sufficient evidence 

to make out a prima facie case that the proffered evidence is what it purports to be.” United States 

v. Ramirez, 658 F. App’x 949, 952 (11th Cir. 2016) (citing United States v. Lebowitz, 676 F.3d 

1000, 1009 (11th Cir. 2012)). Here, the 902(11) certificate establishes the authenticity of the 

original photograph, and the agent’s testimony establishes that the second image “is what it 

purports to be,” that is, a copy of the original photograph, adjusted for light. 

Just like plotting cellular location data (as mentioned above), sliding a scale to adjust a 

photograph takes no particular skill, and is, in fact, something people regularly do to edit contrast, 

color, crop, expose, (to name a few) an image. Here, the resulting image still accurately depicts 

the original, just adjusted for light. The image, now lighter or darker in some places—making the 

image’s content more pronounced—does not suddenly cease to fairly and accurately depict the 

person, place, or thing any more than adjusting the brightness setting on a television changes the 

show into a different show. 

A duplicate photocopy which accurately reproduces the original is admissible to the same 

extent as the original. Fed. R. Evid. 1002. This remains the case unless the opposing party raises a 

genuine question as to the authenticity of the unintroduced original, the trustworthiness of the 

duplicate, or the fairness of substituting the duplicate for the original. Fed. R. Evid. 1003. See

Buczek v. Trans Union LLC, No. 05-80834 CIV, 2006 WL 3666635, at *2 (S.D. Fla. Nov. 9, 2006) 

(citing United States v. Georgalis, 631 F.3d 1199 (5th Cir.1980)). In the instant case, there is no 

substitution of the agent’s image for the original—the Government intends to introduce both. As 

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such, arguments about the difference between the two go to the weight of the evidence, and not 

the admissibility of photograph itself. See e.g. United States v. Clayton, 643 F.2d 1071 (5th Cir. 

1981); see also United States v. Seifert, 351 F. Supp. 2d 926, 928 (D. Minn. 2005) (finding “that 

adjustments to brightness or contrast, or enlargement of the image, while arguably a manipulation, 

are in fact no more manipulative than the recording process itself” and noting other factors, like a 

camera's lens, aperture, shutter speed, or development process, “all affect the image,” but it is 

“entirely unremarkable so long as the ‘image’ remains an accurate recording of that which occurred 

before the camera”), aff’d 445 F.3d 1043 (8th Cir. 2006). 

V. Opening the Door to Evidence of Defendants’ Connection to Additional Suspects 

in Murder-For-Hire Plot

As the Government previously advised, the Government does not intend on presenting 

evidence or making arguments that a particular person or persons had motive to hire or solicited 

or paid the Defendants to commit the acts alleged. The Government has suspects in that regard, 

namely R.R., R.A., and T.M. But, as a possible defense, the Defendants may present evidence, 

conduct examinations, or make arguments to the effect that either the Defendants had no motive 

to commit the alleged acts or that other persons, rather than the Defendants, had the motive to 

commit the crimes alleged. The Defendants’ problem is that most roads lead back to them— 

through R.R., R.A., and T.M.—and the Defendants may “open the door” to such evidence. 

As background this Court has heard before, R.R. and the victim were business partners 

who ended their dealings in a cantankerous federal lawsuit. At the time, R.R. made veiled threats 

against the victim. R.R. is also close friends with R.A., who manages T.M., a music artist. T.M. 

sent funds to Defendant Serrano who—in August 2019—used those funds to buy himself last 

minute travel to South Florida. Defendant Serrano gave a portion of those funds to Defendant 

Jimenez, who also purchased last minute travel on the same plane to South Florida. Once in South 

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Florida, Defendant Serrano spent multiple days with R.A. when he was not surveilling the victim, 

culminating in Defendant Serrano’s purchase of R.A.’s father’s vehicle—at a reduced price—days 

after the shooting. Defendant Serrano used this vehicle to travel back to New York. 

 In the days after the shooting, the victim provided law enforcement with names of persons 

he thought might want to harm him. Among the information provided, the victim named R.R. and 

others related to R.R. If the defense presents evidence, questions witnesses, or lays the groundwork 

for arguing that R.R. or those related to R.R. had the motive to harm the victim, the defense would 

open the door to evidence connecting R.R. to R.A. and T.M.4 In fact, if the Defendants instead 

cherry pick those names that do not link to R.R., the Court should still allow the Government to 

present evidence the Defendants are linked to R.R., R.A., and T.M. If the Defendants are 

permitted to present evidence or arguments that someone else either had a motive to or did commit 

the acts alleged, the jury will be misguided unless the Government is allowed to demonstrate there 

is a more reliable evidentiary chain linking the Defendants to the crime. 

Pursuant to Local Rule 88.9, Defendant Jimenez has no objection. Defendant Serrano’s 

response was unclear to the Government, but he appears to assert that the Government’s 

anticipated evidence—as set forth in FN 4 herein—already opens the door. But, as laid out in the 

footnote, the Government presently intends to introduce only limited evidence regarding T.M. and 

R.A., and no evidence relating to R.R. 

4

 The Government intends to introduce proof of T.M.’s transferring funds to Defendant Serrano 

via CashApp for the sole purpose of demonstrating the immediate expenditure towards travel to 

South Florida. The Government intends to introduce evidence relating to R.A. for the sole purpose 

of demonstrating who Defendant Serrano was with and what he was doing when he was not 

surveilling the victim, as well as to demonstrate his familiarity with R.A., who arranged for 

Defendant to buy the car Defendant used to leave South Florida. The Government does not intend 

to introduce any evidence relating to R.R. 

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VI. Transcript of Jail Call Is Properly Redacted under the Rule of Completeness

The Government intends to offer into evidence a transcript of a call the Federal Detention 

Center recorded between Defendant Jimenez and his mother. During that call, Jimenez made 

incriminatory statements intermingled with statements by him and his mother that are unnecessary 

to place the admissible evidence into context. They each comment on the future, hope, the 

Defendant’s son, family, and second chances—all topics likely to elicit an emotional response and 

to be unfairly prejudicial to the Government. Most importantly, these statements are irrelevant. A 

full transcript of the conversation is attached hereto as Exhibit 5 with proposed redactions. After 

conferring with the Defendants as required by Local Rule 88.9, both Defendant Jimenez and 

Defendant Serrano object under the Rule of Completeness. 

“Under the common law rule of completeness, an opponent against whom a part of an 

utterance is admitted may complement it by submitting the remainder, in order to give the jury a 

complete understanding of the ‘total tenor and effect of the utterance.’” United States v. Santos, 

947 F.3d 711, 729 (11th Cir. 2020) (internal citation omitted). As partially codified in Fed. R. 

Evid. 106, the rule states: “If a party introduces all or part of a writing or recorded statement, an 

adverse party may require the introduction, at that time, of any other part—or any other writing or 

recorded statement—that in fairness ought to be considered at the same time.” Id. at 729–30. Rule 

106 “does not automatically make the entire document admissible” once a portion has been 

introduced. Id. at 730. Rather, Rule 106 “permits introduction only of additional material that is 

relevant and is necessary to qualify, explain, or place into context the portion already introduced.” 

Id. (internal citations omitted) (emphasis added). Although Rule 106 on its face applies only to 

written or recorded statements, this Court has extended the rule to the exculpatory portions of a 

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criminal defendant's post-arrest oral statements. Id. (citing United States v. Range, 94 F.3d 614, 

620-21 (11th Cir. 1996)). 

There is nothing about what the defense wants included in the transcript submitted to the 

jury that would help put into context or elucidate the portion the Government wants them to read. 

VII. The Fact the Defendants Have Infant Children is Not Relevant and Should Be 

Excluded 

Both Defendants have infant children. Defendant Serrano’s fiancée has brought the young 

child to court. The existence of infant children does not tend to prove or disprove a material fact, 

and, so, is not relevant. See Fed. R. Evid. 401. Even if marginally relevant, the evidence proves so 

little—and has the ability to enflame passions so much—that it is not admissible under Fed. R. 

Evid. 403. Upon conferring, Defendant Jimenez believes this fact is relevant to establishing the 

nature of his relationship with Raven Sauri, a witness the Government intends to call who also 

mothered his child. Defendant Serrano asserts such evidence may be relevant, depending on the 

testimony elicited from Defendant Serrano’s fiancée, but would otherwise agree that it is 

irrelevant. 

VIII. A Witness Cannot be Impeached With Another Witness’ Statement 

The victim in this case was an ardent advocate with law enforcement for finding the people 

who tried to kill him and, if there were people that put them up to it, them, too. As a result, he 

engaged in text communications with the local lead detective in the days and months after the 

shooting. Pursuant to Local Rule 88.9, both Defendant Jimenez and Defendant Serrano believe 

that such text threads are “proper impeachment.” 

Yes, a lawyer can impeach a testifying witness with their statement or demonstrate their 

bias by revealing the content of text messages. The Government agrees that during crossexamination of the victim the defense can question him about conversations he had with the lead 

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detective to establish the victim’s bias and credibility. Likewise, the Government agrees that 

during cross-examination of the lead detective the defense can question him about conversation he 

had with others that demonstrate his bias and credibility. The Government writes here to notify 

the Court that there are statements by the non-testifying witness in such exchanges that do not 

serve the purpose of demonstrating bias and credibility. Where the non-testifying witness said 

something in a text message that does not affect the testifying witness’ state of mind, such 

statements do not impeach the testifying witness and are either hearsay or irrelevant or constitute 

improper opinion testimony. 

Respectfully submitted, 

 MARKENZY LAPOINTE 

 UNITED STATES ATTORNEY 

By: /s/ Michael E. Gilfarb 

 Michael E. Gilfarb 

 Assistant United States Attorney 

 Fla. Bar. No. 957836 

 99 N.E. 4th Street 

 Miami, FL 33132-2111 

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on August 1, 2023, I served a copy upon all counsel of record 

using CM/ECF. 

By: s/Michael E. Gilfarb 

Michael E. Gilfarb 

Assistant United States Attorney

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