UNITED STATES DISTRICT COURT

for the

__________ District of __________

United States of America )

)

)

)

)

)

v.

Case No.

Defendant(s)

CRIMINAL COMPLAINT BY TELEPHONE OR OTHER RELIABLE ELECTRONIC MEANS

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 in the county of in the

District of , the defendant(s) violated:

Code Section Offense Description

This criminal complaint is based on these facts: 

’ Continued on the attached sheet.

Complainant’s signature

Printed name and title

Judge’s signature

Date:

City and state:

Printed name and title

Attested to by the Applicant in accordance with the requirements of Fed.R.Crim.P. 4.1 by _________________________

AO 91 (Rev. 08/09) Criminal Complaint

 Southern District of Florida

MOHAMMAD AHMED KHAN 

Miami-Dade

Southern Florida

18 U.S.C. §§ 1201(a)(1) and 2 Kidnapping

SEE ATTACHED AFFIDAVIT.

✔

Charles Benson, Special Agent; FBI

FaceTime

Miami, Florida The Honorable Edwin G. Torres, Chief U.S. Magistrate Judge

ID #101003

22-MJ-03644-Torres

Case 1:22-cr-20488-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 1 of 8
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AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

I, Charles Benson, being duly sworn, depose and state that: 

INTRODUCTION AND AGENT BACKGROUND

1. I am a Special Agent with the Federal Bureau of Investigation (“FBI”) and have

served in this capacity since February 2022. Currently, I am assigned to the Violent Crimes and 

Fugitive Task Force of the FBI’s Miami Division and have been at this location since September 

2022. My duties involve investigating bank robberies, Hobbs Act robberies, extortion, 

kidnappings, and other violations of federal law. In my current capacity, I have assisted in the 

execution of search warrants, interviewed subjects, victims, and cooperating individuals; and used 

historical cell site analysis to locate the phones of subjects and victims.

2. I make this Affidavit for the limited purpose of establishing probable cause to

believe that MOHAMMAD AHMED KHAN (“KHAN”), together with others, committed a 

Kidnapping in violation of Title 18, United States Code, Sections 1201(a)(1) and 2.

3. This Affidavit is based upon my personal knowledge, my review of documents and

other evidence, and my conversations with other law enforcement personnel and civilian 

witnesses. Because this Affidavit is being submitted for the limited purpose of establishing 

probable cause, it does not include all the facts that I have learned during the course of my 

investigation. Rather, I have included only the facts that are sufficient to establish probable cause. 

Where the contents of documents and the actions, statements, and conversations of others are 

reported herein, they are reported in substance and in part, except where otherwise indicated.

Case 1:22-cr-20488-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 2 of 8
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PROBABLE CAUSE

Agents Learn of a Kidnapping 

4. On or about September 22, 2022, at 2:34 PM, the Miami-Dade Police Department

(“MDPD”) received a 9-1-1 call from Witness 1 reporting a kidnapping at his residence at 4770 

SW 87th Place, Miami, Florida, 33165 (the “Residence”) and the Domino’s located at 1105 NW 

22nd Avenue, Miami, Florida, 33125 (the “Domino’s”). Witness 1 stated his nanny (“Victim 1”), 

two minor children, ages two and four (“Victim 2” and “Victim 3,” respectively), and wife 

(“Victim 4”) (collectively, the “Victims”) had been kidnapped. MDPD dispatched units to the 

Residence, and notified agents and Task Force Officers with the FBI, who responded to the scene.

The Subjects Kidnap Victim 1, Victim 2, and Victim 3

5. Victim 1 stated that, on or about September 22, 2022, at approximately 11:30 AM,

Victim 1 was on the first floor of the Residence with one minor child while the other minor child 

was asleep on the second floor. Four males (“Subject 1,” “Subject 2,” “Subject 3,” and “Subject 

4”) and two females (“Subject 5” and “Subject 6”) (collectively, the “Subjects”) entered the 

residence. One male subject entered the Residence through the open garage door while the 

remaining subjects entered through the unlocked front door. Victim 1 saw that three of the male 

subjects possessed handguns that were either holstered or in their waistband. 

6. Victim 1 stated that one male subject questioned her about the location of Witness

1 and the roommate living in the Residence, and one male subject went upstairs to retrieve the 

minor child that was sleeping. Victim 1, Victim 2, and Victim 3 were then taken from the home 

and placed into a white Toyota RAV4 (“Vehicle 1”), which was occupied by Subject 5 and 

Subject 6. The four male subjects got into a black BMW (“Vehicle 2”) and a red Jetta (“Vehicle 

3”). All three vehicles then departed the Residence. 

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7. Video surveillance likewise captured the Subjects entering the home and departing

with Victim 1, Victim 2, and Victim 3. 

The Subjects Kidnap Victim 4

8. The Subjects then drove Victims 1, 2, and 3 to Domino’s where Victim 4 was

working. Three of the male subjects were captured on video surveillance entering the Domino’s. 

Victim 4 reported that one male subject jumped over the counter and grabbed Victim 4 by the 

throat. Victim 4 was forced out of the Domino’s and put in the back seat of Vehicle 3. Video 

surveillance captured three male subjects escorting Victim 4 out of the store with one male subject 

maintaining his hand on the back of Victim 4’s neck. Victim 4 stated one male subject appeared 

to be wearing a gun belt and another subject had pepper spray. 

9. Victim 4 described that Vehicle 1, Vehicle 2, and Vehicle 3 departed the Domino’s

and drove for approximately 7-10 minutes before arriving behind a black commercial building 

where Victim 4 was then moved to Vehicle 2. 

10. Victim 1 likewise recalled being driven to a second location where she estimated

the car remained for several hours. After an unknown amount of time Victim 1 stated that Vehicle 

3 left the parking lot to find a new spot that had less people walking around. 

11. Victim 4 stated that one of the male subjects demanded Victim 4 pay him money

or they would kill Victim 4 as well as Victim 1, Victim 2, and Victim 3. Victim 4 stated that the 

same subject attempted to contact TD Bank to access an account previously held by Victim 4 and 

attempted to gain access to Victim 4’s bank accounts via her cellular telephone. The subject then 

utilized Victim 4’s cellular telephone to contact Witness 1. He told Witness 1 he would kill all 

the Victims if Witness 1 did not wire $100,000 to a specified bank account. The subject also used 

Victim 4’s cellular telephone to send photos of the Victims to Witness 1.

Case 1:22-cr-20488-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 4 of 8
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The Victims are Released

12. After an unknown amount of time, Victim 1 stated that Subject 5 and Subject 6

received word to move to another location. Eventually, all three vehicles departed separately. 

Victim 1 described Vehicle 1 being driven around aimlessly and at one point driven through the 

Miami International Airport. At another point while driving around, Vehicle 1 pulled into a 

parking lot near the vicinity of 9337 Bird Road, Miami Florida 33165. Subject 5 and Subject 6 

then received a call telling them to let Victim 1, Victim 2, and Victim 3 get out of the vehicle. 

All three victims were let out of Vehicle 1 before it departed the vicinity. 

13. At approximately 7:45 PM, one of the subjects left Victim 4 at an unknown

location. There, unidentified individuals agreed to assist Victim 4 in ordering her an Uber that 

returned her to the Domino’s. 

KHAN’s Statements

14. Surveillance images from a business near the Domino’s captured the license plate

of Vehicle 3. Vehicle 3 is registered to KHAN. On September 23, 2022, law enforcement 

reported to KHAN’s known address in an effort to discuss Vehicle 3’s involvement in the 

kidnapping. There, they spoke with a male who placed them in contact with KHAN. KHAN 

agreed to meet with officers at his place of employment. 

15. There, law enforcement observed Vehicle 3. KHAN agreed to speak with law

enforcement officers. As he was advised of his Miranda rights, KHAN stated that he may need 

to speak with a lawyer. KHAN then asked if he could make a call to his wife. After doing so, he 

advised officers that he wished to speak with them. Officers again advised KHAN of his Miranda 

rights, which he waived in writing. 

Case 1:22-cr-20488-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 5 of 8
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16. KHAN admitted to acting as a security guard during the kidnapping of the Victims,

although he disagreed that the events of September 22, 2022, should be characterized as a 

kidnapping. KHAN stated that on approximately September 21, 2022, he was contacted by a

male subject requesting to hire two security guards for what KHAN stated was described as a 

“transaction.” KHAN maintained that he was unfamiliar with the nature of the transaction with 

which the individual required assistance. KHAN stated he asked the individual whether he 

wanted KHAN to bring his firearm to the transaction, confirmed that a second armed “guard” was 

requested, and noted that KHAN and the other guard had a concealed carry permit. This male 

subject then called KHAN and asked that he and the other individual bring their firearms to the 

transaction. 

17. KHAN and the second guard, who was contacted by KHAN, met with the male

subject requesting security at a specified location and followed him, using Vehicle 3, to a 

residence in Southwest Miami-Dade County. KHAN described that he and the second guard

entered a home there with the male subject who hired them, one other male subject, and two 

female subjects. He described that the male subject who hired him was “rude” to the female 

encountered in the home—Victim 1. KHAN described that Victim 1, Victim 2, and Victim 3 

were then removed from the home and placed in one of the other two vehicles on scene. KHAN 

admitted that he carried his firearm, which was holstered and visible on his hip, during this 

encounter and the remainder of his time with the Victims.

18. Next, KHAN described that he and the second guard followed the other vehicles to

a Domino’s pizza store. There, KHAN stated he entered a Domino’s while the individual who 

hired him removed a woman from the premises. As noted in paragraph 8, supra, Victim 4 reported

that one male subject jumped over the counter and grabbed Victim 4 by the throat to remove her 

Case 1:22-cr-20488-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 6 of 8
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from the location. KHAN is depicted in video surveillance, standing by while Victim 4 is 

retrieved from behind the counter. KHAN stated the subjects then escorted Victim 4 briefly to 

the vehicle that contained the other victims, and then placed Victim 4 in KHAN’s vehicle, Vehicle 

3. Victim 4 stated that, once in Vehicle 3, the individual who was wearing a hat and sunglasses

during the kidnapping—which KHAN identified as himself in surveillance images from the 

kidnapping—instructed her to provide her bank account information to the other subjects. 

19. KHAN stated he then drove Vehicle 3, with Victim 4, to a location as directed by

the male subject who hired him. KHAN stated that all participants who were originally at the 

residence in Southwest Miami-Dade County, and the Domino’s Pizza location, eventually met at 

this location. KHAN stated he heard the male subjects demanding money from Victim 4 and 

stating that she owed them money. KHAN maintained he did not know the nature of what was 

going on, and stated he assumed the encounter involved some sort of domestic dispute. He stated 

his role during the encounter was to protect the male subject who had hired him—the same 

individual who forcibly removed Victim 4 from the Domino’s. 

20. KHAN did not leave the scene where the Victims were held until he realized he

was going to be late for another job. At that time, he departed in Vehicle 3, leaving the Victims 

and the second guard behind. Once at his other job location, KHAN called the subject who had 

hired him and told him he still owed KHAN money for his work that evening. The subject who 

hired KHAN then drove to KHAN’s other job location, as directed by KHAN, and provided him 

and the second guard with $200 each in payment. The Victims were still with the other subjects 

at the time of this payment. KHAN stated that all the Victims were driven away from his job 

location and he did not know the outcome nor the fate of the Victims. 

Case 1:22-cr-20488-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 7 of 8
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CONCLUSION

21. Based upon the information provided above, your Affiant respectfully submits that

probable cause exists to believe that, on or about September 23, 2022, MOHAMMAD AHMED 

KHAN committed a Kidnapping in violation of Title 18, United States Code, Sections 1201(a)(1)

and 2. 

FURTHER YOUR AFFIANT SAYETH NAUGHT.

Respectfully submitted, 

Special Agent Charles Benson

Federal Bureau of Investigation 

Attested to by the applicant in accordance 

with the requirements of Fed. R. Crim. P. 4.1 

by FaceTime, on this __ day of September 2022, 

at Miami, Florida. 

_______________________________________ 

THE HONORABLE EDWIN G. TORRES

CHIEF UNITED STATES MAGISTRATE JUDGE 

Case 1:22-cr-20488-JEM Document 1 Entered on FLSD Docket 09/26/2022 Page 8 of 8