UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NO. 22-20389-CR-AL TMAN 

UNITED STATES OF AMERICA; 

Plaintiff, 

v. 

JULIAN TIMENEZ, 

Defendant. 

--------------'/ 

FACTUAL PROFFER 

Defendant, Julian Jimenez (hereinafter referred to as "defendant"), his counsel, and the 

United States agree that, had this case proceeded to trial, the United States would have proven 

beyond a reasonable doubt, the following facts. 

On August 20, 2019, Jaime Serrano paid for plane tickets for himself and the defendant to 

fly down to Miami, Florida. On August 21, 2019, the defendant and Jaime Serrano flew on the 

same American Airlines flight from LaGuardia Airport in New York to Miami International 

Airport in Florida. As such, they travelled in or affected interstate conimerce. At the time they 

traveled in interstate commerce, they did so with the intent to injure, harass, intimidate, or place 

'I 

under surveillance with the intent to injure, harass, or intimidate Alex Vega. 

Once in the Southern District of Florida, from August 23, 2019, through August 27, 2019, 

the defendant and Jaime Serrano surveilled Alex Vega, including with the use of a motor vehicle, 

at his business and residence with the intent to injure, harass or intimidate Alex Vega. 

On August 27, 2019, Jaime Serrano drove a blue Nissan Rogue, with the defendant as the 

sole passenger, to the area of the victim's residence. Once in the area, the defendant exited the 

Case 1:22-cr-20389-RKA Document 207 Entered on FLSD Docket 08/09/2023 Page 1 of 3
vehicle with a firearm, eventually putting on a face mask and gloves. The defendant did so-as he 

agreed and planned to with Jaime Serrano-with the intent to shoot Alex Vega in order to kill or 

injure Alex Vega. The defendant received the firearm from Jaime Serrano after their arrival in 

Miami, Florida on August 21, 2019. 

On August 27, 2019, at approximately 8:13 p.m., Alex Vega drove into the garage of his 

residence located in the Southern District of Florida. The defendant approached the vehicle and 

fired multiple rounds into the vehicle at the victim. The victim was shot but survived. The shooting 

placed Alex Vega in reasonable fear of death or serious bodily injury. As a result of this, shooting, 

Alex Vega suffered serious bodily injury. 

After the sho,oting, the defendant fled eastbound through a residential community with the 

purpose of meeting up with Jaime Serrano at a predetermined location in the Nissan Rogue. The 

defendant abandoned the mask, gloves, and the firearm he used to shoot Alex Vega alop.g the way. 

Subsequently, the defendant entered the Nissan Rogue through the trunk, and Jaime Serrano drove 

them away. Nobody else was in the vehicle at the time. The defendant committed the shooting 

with the expectation of receiving U.S. currency in exchange but was never paid because he did not 

kill Alex Vega. 

[This Space Intentionally Left Blank] 

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Case 1:22-cr-20389-RKA Document 207 Entered on FLSD Docket 08/09/2023 Page 2 of 3
Since the defendant's incarceration on these charges, Jaime Serrano convinced the 

defendant to create a handwritten statement that the defendant signed and dated September 25, 

2022, claiming that he acted alo.ne and without Jaime Serrano's knowledge in planning and 

shooting Alex Vega. That handwritten statement is not true. 

Date: 

{ I 

By: 

Date: By: 

Date: By: 

By: 

By: 

By: 

MARKENZY LAPOINTE 

ASSIS 

E 

STATES ATTORNEY 

ABIGAIL BECKER 

ATTORNEY FOR DEFENDANT 

DEFENDANT 

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Case 1:22-cr-20389-RKA Document 207 Entered on FLSD Docket 08/09/2023 Page 3 of 3