UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

UNITED STATES OF AMERICA 

vs. 

KELLEY EVERETT,

Defendant.

______________________________________/ 

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)? 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)? No

Respectfully submitted,

JUAN ANTONIO GONZALEZ

UNITED STATES ATTORNEY

BY: ____________________________________ 

Abbie D. Waxman

Assistant United States Attorney

Florida Bar No.: 109315 

99 Northeast 4th Street 

Miami, Florida 33132-2111 

Tel: (305) 961-9240 

Email: Abbie.Waxman@usdoj.gov 

____________________

Abbie D. Waxman

CASE NO. _____________________ 22-mj-03777-AOR

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Face Time

22-mj-03777-AOR

Case 1:22-cr-20518-KMM Document 1 Entered on FLSD Docket 10/19/2022 Page 2 of 7
AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT 

Your Affiant, Jordan Petitta, being duly sworn, deposes and states as follows: 

INTRODUCTION AND AGENT BACKGROUND 

1. I am a Special Agent for the Federal Bureau of Investigation (“FBI”) currently

assigned to the Violent Crimes/Fugitive Task Force in the Miami Division. I have been an FBI 

Special Agent since February 2022 and have been assigned to the Miami Division since June 2022. 

I have received training at the FBI Academy in Quantico, Virginia. As a Special Agent for the FBI, 

my current duties involve the investigation of a variety of violations of federal offenses, including 

bank robberies, Hobbs Act robberies, extortion, and other violations of federal law. Prior to my 

employment as a Special Agent with the FBI, I worked as a Special Agent with Homeland Security 

Investigations from January 2019 to May 2020 where I investigated transnational criminal 

organizations. In addition, I worked as a contracted Intelligence Specialist for the Department of 

Defense from May 2020 to February 2022 where I investigated national security matters. 

2. The facts contained in this Affidavit are based on my personal knowledge and

information provided to me by other law enforcement officers and Agents. This Affidavit is being 

submitted for the limited purpose of establishing probable cause for the proposed complaint 

charging KELLEY EVERETT (“EVERETT”) with bank robbery, in violation of Title 18, United 

States Code, Section 2113(a). I have not included every fact known to law enforcement regarding 

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

the issuance of a criminal complaint against EVERETT for the above-described criminal violation. 

3. I respectfully submit there is probable cause to believe that on October 18, 2022,

EVERETT did knowingly take, by intimidation, from the persons and presence of employees of 

T.D. Bank, located at 1500 N.E. Miami Gardens Drive, Miami, Florida 33179, currency belonging

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to, and in the care, custody, control, management, and possession of T.D. Bank, a bank whose 

deposits were then insured by the Federal Deposit Insurance Corporation (“FDIC”). 

PROBABLE CAUSE 

4. On October 18, 2022, at approximately 3:01 p.m., a black male, later identified as

EVERETT, entered the T.D. Bank, located at 1500 N.E. Miami Gardens Drive Miami, Florida. 

T.D. Bank is insured by the FDIC.

5. EVERETT entered the T.D. bank wearing blue ripped jeans, a light-colored long

sleeve shirt, a blue medical face mask, and a black t-shirt on top of his head. He was also holding 

a brown cardboard box. Video surveillance inside the bank showed EVERETT standing next to a 

customer being serviced by the victim bank teller (the “Victim”). Moments later, EVERETT 

interrupted the interaction by approaching the Victim and passing her a note. The note stated, “Pay 

me 20,000 NOW Hurry I got a bomb.” EVERETT also gave the Victim the box he was holding to 

put the money inside. Upon reviewing the demand note, the Victim, in fear for her safety and the 

safety of others, complied and handed over approximately $807 in United States currency, which 

included bait bills1

, a tracking device, and mutilated money2 in the box provided by EVERETT. 

EVERETT took the money and exited the bank on foot.

6. A few minutes later, Miami-Dade law enforcement notified the Broward Sheriff’s

Office (“BSO”) that a robbery had occurred, and that the money taken during the robbery was 

heading northbound on I-95 into Broward County. BSO then utilized the 3SI Security Systems 

1

 A bait bill is a bill that the bank specifically uses to track the bill at a later time (by serial number) 

in case of a robbery. 

2

 The stack of money provided by the Victim to EVERETT contained U.S. currency surrounding 

the tracking device as well as ripped up dollar bills within the stack to conceal it. 

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tracker, which is a program that allowed BSO to live track the tracking device that was placed in 

the stack of money that was given to EVERETT.

7. BSO tracked the money northbound on I-95 into Broward County, Florida. The

device continued to track north on I-95 and then west on 595, exiting the highway at University 

Drive in Davie, Florida. As the money tracked south on University Drive, aviation observed a 

White Nissan Maxima make an abrupt lane change., This abrupt lane change was consistent with 

the live tracking of the tracking device taken during the robbery. BSO detectives arrived in the 

area and observed the White Nissan pull into a gas station. The driver exited the White Nissan 

Maxima and filled the car with gas while nervously looking back and forth and pacing the area. 

The driver re-entered the vehicle and drove eastbound through a parking lot making erratic turns 

as BSO officers followed. The erratic turns of the White Nissan Maxima matched the movement 

pattern of the tracking device with the money EVERETT took during the robbery. 

8. EVERETT then entered the parking lot of the Twin Peaks restaurant in Davie,

Florida. BSO officers surrounded EVERETT’s vehicle and intentionally struck the vehicle from 

the front and back to immobilize it in place. EVERETT was taken into custody and, after providing 

a false first name, was later identified as EVERETT by a Department of Highway Safety and 

Motor Vehicles check. 

9. When law enforcement took EVERETT into custody they observed, in plain view,

what appeared to be the blue surgical mask and the cardboard box used during the robbery inside 

his vehicle. 

10. Law enforcement conducted a search of the vehicle and recovered a cardboard box

on the front passenger floorboard, a light-colored long sleeve shirt underneath the box, and a blue 

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surgical mask on the driver seat. These items all match the items captured on the video surveillance 

of the robbery.

11. Law enforcement also recovered U.S. currency from the vehicle. Some was

recovered on the passenger floorboard and other money, including the bait bills and the tracking 

device, were found inside the glove compartment of EVERETT’s vehicle. The tracking numbers 

on the bait bills matched those given to EVERETT by the Victim during the robbery.

12. EVERETT was transported to the Davie Police Department. I responded to the

Davie Police Department and observed EVERETT wearing the same blue jeans the robber was 

seen wearing on T.D. Bank’s video surveillance of the robbery. EVERETT was also wearing black 

long socks at the police department. These black long socks also matched what EVERETT was 

seen wearing in T.D. Bank’s video surveillance of the robbery.

CONCLUSION

13. Based upon the foregoing, I submit that there is probable cause for the proposed

complaint charging EVERETT with bank robbery in violation of Title 18, United States Code, 

Section 2113(a). 

FURTHER YOUR AFFIANT SAYETH NAUGHT.

 ___________________________________ 

 Jordan Petitta, Special Agent 

Federal Bureau of Investigation

Attested to by the applicant in accordance 

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

by_______________ on ____ day of October 2022.

_____________________________ ______ 

THE HONORABLE ALICIA M. OTAZO-REYES

UNITED STATES MAGISTRATE JUDGE

____________________________

Face Time 19th

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NUMBER: __________________________

BOND RECOMMENDATION

DEFENDANT:

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

By: ________________________________

AUSA:

Last Known Address: 

What Facility: 

Agent(s):

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

____________________

AUSA:

 KELLEY EVERETT

Pre-Trial Detention

6761 Park Boulevard North

Abbie D. Waxman

Apartment 433

FDC

Pinellas Park, Florida 33781

Jordan Petitta, FBI

AUSA:

22-mj-03777-AOR

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