UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

22-~~8}~~_-CR-AL TMAN/REID 

18 U.S.C. § 2261A(l) 

18 u.s.c. § 924( o) 

18 U.S.C. § 924(c)(l)(A) 

18 U.S.C. § 924(d) 

UNITED STATES OF AMERICA 

v . 

.JULIAN Jll.'1ENEZ and 

JAIME SERRANO, 

Defendants. ____________ I ....; 

· The Grand Jury charges that: 

INDICTMENT 

COUNTl 

Interstate Stalking 

(18 U.S.C. § 2261A(l)) 

FILED BY MML D.C. 

Aug 24, 2022 

ANGELA E. NOSLE 

CLERK U.S. 01ST. CT. 

S. 0. OF Fl.A. · :\Iiami 

From on or about August 20, 2019, continuing through on or about August 27, 2019, in 

Miami-Dade County, in the Southern District of Florida and elsewhere, the defendants, 

JULIAN JIMENEZ and 

JAIME SERRANO, 

traveled in interstate commerce, that is, from the State of New York to the State of Florida, with 

the intent to kill, injure, harass, and intimidate, and place under surveillance with intent to kill, 

injure, harass, and intimidate another person, that is, A. V ., and in the course of, and as a result of, 

such travel engaged in conduct that placed A. V. in reasonable fear of death and serious bodily 

injury to A.V., in violation of Title 18, United States Code, Sections 2261A(l) and 2. 

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Pursuant to Title 18, United States Code, Section 2261(b)(3), it is further alleged that the 

defendants' conduct resulted in serious bodily injury to A.V. 

Pursuant to Title 18, United States Code, Section 2261(b)(3), it is further alleged that the 

defendants used a dangerous weapon during the offense. 

COUNT2 

Conspiracy to Use and Carry a Firearm During a Crime of Violence 

(18 u.s.c. § 924(0)) 

From on or about August 20, 2019, through on or about August 27, 2019, in Miami-Dade 

County, in the Southern District of Florida and elsewhere, the defendants, 

JULIAN JIMENEZ and 

JAIME SERRANO, 

did knowingly and willfully combine, conspire, ·confederate, and agree with each other and with 

others knovyn and unknown to the Grand Jury, to use and carry a firearm during and in relation to 

a crime of violence, and to possess a firearm in furtherance of a crime of violence, an offense for 

which the defendants may be prosecuted in a court of the United States, that is a violation of Title 

18, United States Code, Section 2261A(l), as charged in Count 1 of this Indictment, in violation · 

of Title 18 United States Code, Section 924( c )(1 )(A); all in violation of Title 18, United States 

Code, Section 924( o ). 

COUNT3 

' Discharging a Firearm in Furtherance of a Crime of Violence 

(18 U.S.C. § 924(c)(l)(A)(iii)) 

On or about August 27, 2019, in Miami-Dade County, in the Southern District of Florida, 

the defendants, 

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Case 1:22-cr-20389-RKA Document 232 Entered on FLSD Docket 08/24/2023 Page 2 of 4
JULIAN JIMENEZ and 

JAIME SERRANO, 

did knowingly use and carry a firearm during and in relation to a crime of violence, and did 

\ 

knowingly possess a firearm in furtherance of a crime of violence, an offense for which the 

defendants may be prosecuted in a court of the United States, that is a violation of Title 18, United 

States Code, Section 2261A(l), as charged in Count 1 of this Indictment, in violation of Title 18, 

United States Code, Sections 924(c)(l)(A) and 2. ; 

Pursuant to Title 18, United States Code, Section 924(c)(l)(A)(iii), it is further alleged that 

the firearm was discharged. 

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All pursuant to Title 18, United States Code, Section_924(d)(l), Title 21, United States 

Code, Section 853, and Title 28, United States Code, Section 246l(c). 

JU 

UNI 

MI 

AS TES ATTORNEY 

C 

.,, 

4 

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