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AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT 

 I, Joshua Youngblood, 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 2022. I am currently assigned to the Miami Field Office South Florida 

Violent Crimes Task Force, which targets individuals involved in violent crime. As part of my 

duties, I investigate violent crimes including kidnappings in violation of Title 18, United States 

Code, Section 1201. In my current capacity, I have assisted in the execution of search and arrest 

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 JOSEPH CHRISTOPHER RICARD (“RICARD”), TRANG NGUYEN 

(“NGUYEN”), CHRISTOPHER ALAN BAIRD (“BAIRD”), LUU NGUYEN DIEU HONG 

(“HONG”), and JOE NATHAN HIGHTOWER (“HIGHTOWER”), 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. 

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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. 

5. As discussed further herein, the Victims were later released. Victim 1 and Victim 

4 were interviewed by law enforcement. Both Victim 1 and Victim 4 viewed six-pack photo 

arrays and identified RICARD, NGUYEN, BAIRD, and HONG as individuals who carried out 

the kidnapping. Victim 4 also positively identified HIGHTOWER as one of the participants.1 

Subjects Kidnap Victim 1, Victim 2, and Victim 3 

6. 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. RICARD, BAIRD, NGUYEN, HONG, and two other male 

subjects entered the Residence without authority. Victim 1 saw that three of the male subjects 

possessed handguns that were either holstered or in their waistband. 

1 Victim 1 viewed a photo array including HIGHTOWER. The witness who performed the photo 

array stated that Victim 1 twice hesitated over HIGHTOWER’s photo, but ultimately stated she 

did not feel she could make a positive identification of anyone within the packet. 

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7. Victim 1 stated that RICARD questioned her about the location of Witness 1 and 

the roommate living in the Residence, and directed another male subject, subsequently identified 

as MOHAMMAD AHMED KHAN (“KHAN”) to go upstairs to retrieve the minor child that was 

sleeping. While the questioning was ongoing, Victim 1 stated that an individual fitting 

HIGHTOWER’s description—a slim Black male with facial hair stood near the doorway and 

appeared to be armed. RICARD also directed Victim 1 to call Victim 4 and tell her that Victim 2 

and Victim 3 were sick and Victim 4 needed to come to the Residence. Victim 1 complied. When 

Victim 4 did not arrive, RICARD reviewed Victim 1’s phone to obtain Victim 4’s work address. 

Victim 1, Victim 2, and Victim 3 were then taken from the Residence. 

8. Surveillance images near the home captured the subjects entering the Residence 

and depict individuals with appearances that are consistent with RICARD, BAIRD, NGUYEN, 

HONG, and HIGHTOWER. The same surveillance captured the subjects exiting the home, with 

RICARD seen carrying one of the minor children outside. 

9. Surveillance images show that Victim 1, Victim 2, and Victim 3 were taken from 

the Residence in a white Toyota RAV4 (“Vehicle 1”). Victim 1 stated that Vehicle 1 was operated 

by NGUYEN and also occupied by HONG. Victim 1 stated that NGUYEN told Victim 1 that she 

would not hurt Victim 1, Victim 2, or Victim 3, but that she just wanted money Victim 4 owed 

her. The four male subjects got into a black BMW (“Vehicle 2”) and a red Jetta (“Vehicle 3”), 

and all three vehicles departed the Residence. 

The Subjects Kidnap Victim 4 

10. The Subjects then drove Victim 1, Victim 2, and Victim 3 to the Domino’s where 

Victim 4 was working. There, RICARD, BAIRD, KHAN, and a female that Victim 4 identified 

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as NGUYEN, were captured on video surveillance entering the Domino’s. RICARD is seen 

pointing and gesturing towards Victim 4. The video surveillance then showed RICARD jumping 

the counter and pushing Victim 4 out of the Domino’s. Victim 4 is seen attempting to resist. 

11. Video surveillance then captured RICARD, BAIRD, NGUYEN, and KHAN 

escorting Victim 4 through the parking lot of the Domino’s. Victim 4 stated one male subject 

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

12. Victim 1 stated that Victim 4 was brought to Vehicle 1, where Victim 1 and Victim 

4’s children, Victim 2 and Victim 3, were being held. Victim 4 was shown that her children had 

been taken. 

13. Victim 4 stated she was put in the back seat of a red vehicle, later identified through 

surveillance footage as Vehicle 3. She stated RICARD, HIGHTOWER, and KHAN were in the 

vehicle. Victim 4 was driven to a separate location, where RICARD demanded money from her. 

Victim 1, Victim 2, and Victim 3 were also taken to that same location and RICARD threatened 

to kill the Victims if a sum of money was not paid. 

14. RICARD also photographed the Victims and sent the photos to Witness 1 in order 

to demand payment for their release. Law enforcement reviewed messages sent to Witness 1 

transmitting these photos and demanding payment to a bank account in HONG’s name. Victim 4 

stated that all of the subjects, including BAIRD, NGUYEN, HONG, and HIGHTOWER were 

present for RICARD’s threats and demands for money. 

15. Victim 1 also stated she heard RICARD, NGUYEN, and HONG demanding 

money from Victim 4 and that BAIRD was present while this occurred. She also observed 

RICARD forcefully push Victim 4 in the presence of NGUYEN, HONG, and BAIRD. 

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16. Victim 4 further stated that RICARD, NGUYEN, and HONG attempted to call a 

bank in an effort to impersonate Victim 4 and obtain money from Victim 4. Victim 4 also stated 

that HIGHTOWER directed her to acquiesce to RICARD’s demands for payment if she loved her 

children. At one point, HIGHTOWER and one of the female subjects also escorted Victim 1 to 

a restroom. 

17. Victim 1 and Victim 4 stated the Victims were driven to multiple holding 

locations. Victim 4 reported that, at one point, she was driven to a separate location by BAIRD 

and RICARD where RICARD taped her hands and mouth and continued to demand money from 

Victim 4. Victim 4 stated that RICARD made repeated references to Victim 4 seeing her children 

“for the last time.” 

The Victims are Released

18. After being driven to multiple locations, Victim 1 stated that NGUYEN and HONG 

received a call telling them to release Victim 1, Victim 2, and Victim 3, and all three were released. 

Victim 4 likewise described being transported to multiple holding locations. 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 is Arrested

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

of Vehicle 3, which was used to take Victim 4 from that location. Vehicle 3 is registered to KHAN. 

On September 23, 2022, KHAN agreed to speak with law enforcement. Based on KHAN’s 

statements and other evidence gathered by law enforcement, KHAN was arrested for his role in 

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the kidnapping of the Victims. On October 13, 2022, a Grand Jury sitting in the Southern District 

of Florida indicted KHAN, charging him with conspiracy to kidnap and four counts of kidnapping. 

Additional Investigation

20. KHAN consented to a search of his cellular telephone. Therein, law enforcement 

identified September 22, 2022 communications from a number identified as belonging to RICARD 

discussing whether the two men that RICARD had requested should be armed. This discussion is 

consistent with law enforcement’s understanding that RICARD hired KHAN and HIGHTOWER 

to act as armed guards for the kidnapping. 

21. In addition, law enforcement identified the Aloft Hotel in Miami, Florida as the 

location where RICARD met with KHAN, HIGHTOWER, and NGUYEN prior to the kidnapping. 

Immediately prior to the kidnapping, each are captured on video surveillance at that location, 

where RICARD also reserved two rooms registered in his own name between September 21 and 

September 23, 2022. At least one of those rooms was also linked to a rewards account in BAIRD’s 

name. 

22. Indeed, video surveillance captured BAIRD, NGUYEN, and RICARD, checking 

in to the Aloft Hotel on September 21, 2022. This is consistent with travel records showing that 

RICARD and NGUYEN traveled from California, where they each reside, to Miami, Florida on 

September 21, 2022, the day before the kidnapping. Similarly, travel records confirm that BAIRD 

and HONG traveled from Arizona, where they each reside, to Miami, Florida on September 21, 

2022, the day prior to the kidnapping. 

23. Moreover, RICARD, NGUYEN, and BAIRD, were captured on video surveillance 

associated with the rental of Vehicle 1, which was rented under NGUYEN’s name. NGUYEN 

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also provided her driver’s license when she rented Vehicle 1. Meanwhile, Vehicle 2 was rented 

under BAIRD’s name, who also provided his driver’s license when he rented Vehicle 2. 

24. In addition to the foregoing, law enforcement obtained historical cell site 

information for cellular telephones operated by RICARD, NGUYEN, BAIRD, HONG, and 

HIGHTOWER. 

25. A number ending in 0243 (the “0243 Number”) was identified as RICARD’s. 

Specifically, it is registered to a California business with a location at the address law enforcement 

identified as RICARD’s according to his driver’s license and where public records confirm both 

RICARD and NGUYEN are employed. The 0243 Number was also saved in KHAN’s phone 

under the name “Chris,” with the notation “Aloft Job.” “Chris” is a shortening of RICARD’s 

middle name, Christopher. Notably, Victim 4 stated that the subjects referred to RICARD as 

“Chris” during the kidnapping. 

26. A number ending in 0926 (the “0926 Number”) was identified as NGUYEN’s. 

While the 0926 Number is not registered to a name or address, historical cell site information 

confirms the number was present at NGUYEN’s known place of work on September 20, 2022, 

prior to the date travel records show NGUYEN traveled to Miami. Similarly, cell site information 

places the 0926 Number at NGUYEN’s known residence on September 24, 2022, after she 

departed Miami. 

27. A number ending in 7311 (the “7311 Number”) was identified as HIGHTOWER’s. 

That 7311 Number was saved in KHAN’s phone as “Joe,” a shortening of HIGHTOWER’s first 

name. Subscriber information shows it was registered to a “Joe Black” at an address identified as 

HIGHTOWER’s residential address in Department of Motor Vehicles records. 

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28. Numbers ending in 6826 and 8458 (the “6826 Number” and the “8458 Number,” 

respectively) were identified as belonging to BAIRD and HONG. Both the 6826 Number and the 

8458 Number were registered in BAIRD’s name. Immigration records confirm that BAIRD and 

HONG are married, suggesting each operates one of the phones. 

29. Historical cell site information shows that each of the aforementioned phones 

identified as belonging to RICARD, NGUYEN, BAIRD, HONG, and HIGHTOWER connected 

to a cell site tower in the vicinity of the Residence during the timeframe that Victim 1, Victim 2, 

and Victim 3 were taken from the Residence. 

30. Likewise, historical cell site information shows that each of the aforementioned 

phones identified as belonging to RICARD, NGUYEN, BAIRD, HONG, and HIGHTOWER 

connected to a cell site tower in the vicinity of the Domino’s during the timeframe that Victim 4 

was taken from the Domino’s. 

CONCLUSION 

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

probable cause exists to believe that, on or about September 22, 2022, RICARD, NGYUEN, 

[This Space Intentionally Left Blank] 

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