UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

No. 

UNITED STATES OF AMERICA

vs. 

FERNANDO CLAVERIAMARTINEZ, 

/ 

CRIMINAL COVER SHEET

1. 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

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

Attorney’s Office prior to October 3, 2019 (Mag. Judge Jared Strauss)? Yes X No

Respectfully submitted,

JUAN ANTONIO GONZALEZ

UNITED STATES ATTORNEY

By: 

Christine Hernandez 

Assistant United States Attorney

Florida Bar. 15349 

11200 NW 20th Street 

Miami, Florida 33172

Tel: (305) 715-7641 

Christine.Hernandez@usdoj.gov 

hristine Hernandez

Case 1:22mj03748 Becerra

Case 1:22-cr-20508-PCH Document 1 Entered on FLSD Docket 10/14/2022 Page 1 of 8
AO 91 (Rev. 08/09) Criminal Complaint

UNITED STATES DISTRICT COURT

for the

__________ District of __________

United States of America )

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v.

Case No.

Defendant

CRIMIAL COMPLAIT%<7(/(3+21(2527+(55(/,$%/((/(&7521,&0($16

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: 

u Continued on the attached sheet.

Complainant’s signature

Printed name and title

Judge’s signature

Date:

City and state:

Printed name and title

$WWHVWHGWRE\WKH$SSOLFDQWLQDFFRUGDQFHZLWKWKHUHTXLUHPHQWVRI)HG5&ULP3E\

 Southern District of Florida

FERNANDO CLAVERIA-MARTINEZ,

October 13, 2022 Miami-Dade

Southern Florida

Title 21, United States Code,

Sections 846.

Conspiracy to Possess with intent to distribute a controlled substance.

SEE ATTACHED AFFIDAVIT.

✔

Victor Randou, ATF Special Agent

Miami, Florida Hon. Jacqueline Becerra, United States Mag

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1:22mj03748 Becerra

10/14/2022

Case 1:22-cr-20508-PCH Document 1 Entered on FLSD Docket 10/14/2022 Page 2 of 8
AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT 

I, Victor Randou, having been first duly sworn, do hereby depose and state as follows: 

INTRODUCTION AND AGENT BACKGROUND

1. I am a “federal law enforcement officer” within the meaning of Federal Rule of

Criminal Procedure 41(a)(2)(C), that is, a government agent engaged in enforcing the criminal 

laws and duly authorized by the Attorney General to request a search warrant. I am a Special 

Agent with the Bureau of Alcohol, Tobacco, Firearms and Explosives (“ATF”) and have been so 

since 2017. I have received training and participated in investigations related to firearms, 

narcotics, violent crimes, drug, and violent crime street organizations. I am currently assigned to 

the ATF High Intensity Drug Trafficking Area (HIDTA) Task Force. I have personally been 

involved in numerous investigations concerning the possession, manufacturing, distribution, and 

importation of controlled substance, as well as methods used to finance drug transactions and 

launder drug proceeds. As a part of my duties and responsibilities, I investigate violations of 

federal and state laws, including those pertaining to firearms, narcotics, and violent crimes. As 

an ATF Special Agent, I am authorized to conduct investigations into criminal violations of the 

laws of the United States, including narcotics offenses, such as conspiracy to possess with intent 

to distribute controlled substances, in violation of Title 21, United States Code, Section 846, and 

possession with intent to distribute controlled substances, in violation of Title 21, United States 

Code, Section 841(a)(1). I am thus a “federal law enforcement officer” as defined by Rule 

41(a)(2)(C) of the Federal Rules of Criminal Procedure. 

2. During my career in law enforcement, I have specialized in narcotics investigations

and received training relating to the methods used by narcotics traffickers to import and 

distribute narcotics, launder narcotics proceeds, and protect narcotics and proceeds through the 

Case 1:22-cr-20508-PCH Document 1 Entered on FLSD Docket 10/14/2022 Page 3 of 8
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use of firearms. I have been personally involved in numerous investigations concerning the 

possession, manufacture, distribution, and importation of controlled substances, as well as 

methods used to finance drug transactions and launder drug proceeds. During the course of these 

investigations, I have seized cocaine and methamphetamine. I have also debriefed defendants, 

informants, and witnesses who had personal knowledge of major narcotics trafficking 

organizations. I have conducted physical surveillance and have participated in numerous 

narcotics investigations that utilized court-authorized Title III interceptions of wire and 

electronic communications. 

3. As a result of my experience and training, I am familiar with the manner in which

various types of illegal drugs are cultivated, manufactured, stored, packaged, smuggled, 

distributed, and protected, as well as the various methods used by narcotics traffickers to finance 

drug transactions and launder drug proceeds. I am also familiar with some of the code that 

narcotics traffickers use when discussing narcotics transactions. I have received training and 

significant experience in the preparation and execution of search warrants authorizing the search 

of physical locations, including private residences, for evidence of unlawful narcotics trafficking. 

PROBABLE CAUSE 

4. This affidavit is submitted in support of a complaint for the arrest of Fernando

CLAVERIA-MARTINEZ for knowingly and willfully conspiring with other known and 

unknown persons to possess with intent to distribute a controlled substance, that is, a mixture and 

substance containing five kilograms or more of cocaine, in violation of 21 U.S.C. § 841(a)(l) 

and 841(b)(l)(C), all in violation of 21 U.S.C. § 846. 

5. The facts listed in this affidavit are known personally to me or have been provided

to me by other law enforcement officers participating in the investigation. The affidavit is 

Case 1:22-cr-20508-PCH Document 1 Entered on FLSD Docket 10/14/2022 Page 4 of 8
3 

provided solely for the purpose of establishing probable cause to arrest CLAVERIAMARTINEZ. Accordingly, this affidavit does not contain all of the facts known to me and other 

law enforcement concerning this investigation. 

6. As part of an on-going investigation, law enforcement identified Fernando

CLAVERIA-MARTINEZ, and others, as participants in drug trafficking activities. CLAVERIAMARTINEZ is believed to be the leader of the drug trafficking organization (DTO) responsible 

for the distribution of multiple kilograms of cocaine throughout the Miami, Florida, area. 

7. On October 13, 2022, based on T-III wire intercepts, and cell site tracking data, as

well as the investigation to date, law enforcement set up surveillance at a residence in MiamiDade County in order to observe CLAVERIA-MARTINEZ and others conducting the pickup of 

narcotics. Law enforcement observed CLAVERIA-MARTINEZ arrive at the location. Shortly 

thereafter two unidentified males arrived to meet with CLAVERIA-MARTINEZ. One of the 

unidentified males, passed CLAVERIA-MARTINEZ a box and entered the vehicle with 

CLAVERIA-MARTINEZ. CLAVERIA-MARTINEZ was observed moving around inside the 

vehicle. The unidentified male exited the vehicle with the now empty box and discarded it in the 

trash at the residence. CLAVERIA-MARTINEZ stayed in the vehicle for a short time thereafter. 

CLAVERIA-MARTIENZ subsequently left the area in the vehicle. Law enforcement followed 

CLAVERIA-MARTINEZ as he drove from the location to the southwest Miami area, in the 

general direction of his business, located at 13758 SW 84th Street, in Miami, Florida. 

8 . At approximately 3:25 p.m., law enforcement conducted an investigative stop on 

CLAVERIA-MARTINEZ's vehicle. As law enforcement approached CLAVERIAMARTINEZ’s vehicle, CLAVERIA-MARTINEZ had one arm raised outside his window. In 

plain view, law enforcement observed a revolver in the cup holder of the vehicle. Law 

Case 1:22-cr-20508-PCH Document 1 Entered on FLSD Docket 10/14/2022 Page 5 of 8
4 

enforcement was aware that CLAVERIA-MARTINEZ had previously been convicted of a 

felony and was not permitted to possess a firearm. At 3:39 p.m., a narcotics canine conducted a 

search of the vehicle and positively alerted to the rear passenger area of the vehicle. 

9. CLAVERIA-MARTINEZ was read Miranda per card and agreed to speak with law

enforcement without an attorney present. CLAVERIA-MARTINEZ advised the officers that he 

had narcotics in the vehicle. The narcotics was hidden in the vehicle in an area commonly 

referred to in drug investigations as a “trap.” Once the “trap” was opened, law enforcement 

observed rectangular packages wrapped in tape which law enforcement believed, based on law 

enforcement’s training and experience, were kilograms of narcotics. A search of the “trap” 

revealed approximately six (6) rectangular and square packages which were sized in kilogram 

quantity packages. One of the packages was opened and contained a white substance which field 

tested positive for the presence of cocaine. 

 [INTENTIONALLY LEFT BLANK] 

Case 1:22-cr-20508-PCH Document 1 Entered on FLSD Docket 10/14/2022 Page 6 of 8


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Case 1:22-cr-20508-PCH Document 1 Entered on FLSD Docket 10/14/2022 Page 7 of 8
UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

CASE NUMBER: 1 :22mj03748 Becerra 

BOND RECOMMENDATION 

DEFENDANT: FERNANDO CLAVERIA-MARTINEZ 

Pretrial Detention 

(Personal Surety) (Corporate Surety) (Cash) (Pre-Trial Detention) 

By: ~ ti~ 

AUSA: Christine Hernantlz 

Last Known Address: _____.a ___ ....;..__· __ -----· __ ---_--_-_-__ _ 

What Facility: FDC MIAMI 

33 NE 4th Street, Miami, FL 

Agent(s): VICTOR RANDOU, ATF 

(FBI) (SECRET SERVICE) (DEA) (IRS) (ICE) (OTHER) 

Case 1:22-cr-20508-PCH Document 1 Entered on FLSD Docket 10/14/2022 Page 8 of 8