UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

Case No. 

UNITED STATES OF AMERICA 

v. 

STEVENSON CHARLES,

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 9, 2013 (Mag. Judge Alicia O. Valle)? 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 August 8, 2014 (Mag. Judge Shaniek M. Maynard)? Yes X No

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

Attorney=s Office prior to August 8, 2019 (Mag. Judge Jared M. Strauss)? Yes X No

Respectfully submitted, 

JUAN ANTONIO GONZALEZ

UNITED STATES ATTORNEY 

BY: _____________________________________

Elena Smukler

Assistant United States Attorney

Fla. Bar No. 91025

99 Northeast 4th Street

Miami, FL. 33132-2111

Tel: (305) 961-9444

Elena.Smukler@usdoj.gov

1:22-mj-03927 Damian

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1:22-mj-03927 Damian

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AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

Your Affiant, Thomas Pavletic, being duly sworn, deposes and states as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I am a Special Agent with the FBI and have been so employed since 2019. Thus,

I am an investigative or law enforcement officer of the United States within the meaning of 

Title 18, United States Code, Section 2510. That is, I am an officer of the United States who is 

empowered by law to conduct investigations of, and make arrests for, violations of federal law, 

including the offenses enumerated in Titles 8, 18, 19 and 21 of the United States Code.

2. 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 kidnapping, carjacking, and the use of firearms during 

violent offenses, in violation of Title 18, United States Code, Sections 1201, 2119, and 924(c). I 

received training on the proper investigative techniques for these violations, including the use of 

surveillance techniques and the application and execution of arrest and search warrants, 

including warrants for historical and prospective cell-site information. I have conducted and 

assisted in fugitive and violent crime investigations, and have executed search warrants that 

have led to seizures of evidence related to violent crime.

3. I respectfully submit that there is probable cause to believe that Stevenson

CHARLES (“CHARLES”), (1) on or about on October 24, 2022, did, with the intent to cause 

death and serious bodily harm, take a motor vehicle that had been transported, shipped, and 

received in interstate and foreign commerce, in violation of Title 18, United States Code, 

Section 2119(1); (2) on or about October 24, 2022, did use and carry a firearm during and in 

relation to a crime of violence, did knowingly possess a firearm in furtherance of a crime of 

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violence, and did brandish said firearm, in violation of Title 18, United States Code, Sections 

924(c)(l)(A)(ii); (3) on or about November 2, 2022, did, with the intent to cause death and 

serious bodily harm, take a motor vehicle that had been transported, shipped, and received in 

interstate and foreign commerce, in violation of Title 18, United States Code, Section 2119(1);

and, (4) on or about November 2, 2022, did use and carry a firearm during and in relation to a 

crime of violence, did knowingly possess a firearm in furtherance of a crime of violence, and 

did brandish said firearm, in violation of Title 18, United States Code, Sections 924(c)(l)(A)(ii).

4. The statements contained in this affidavit are based on my personal knowledge as

well as information relayed to me by other law enforcement officers and witnesses present on 

scene. I have not included in this affidavit each and every fact known to me. Rather, I have 

included only those facts that I believe are necessary to establish probable cause for the issuance 

of a criminal complaint against CHARLES for the above-described criminal violations.

PROBABLE CAUSE

Victim 1

5. On or about Sunday, October 23, 2022, Victim 1 met another male online using

the “Grindr” application, an online dating and social networking application targeted towards 

members of the LGBTQ community. Victim 1 and the male agreed to meet in person at a 

residence located at 10403 NW 25th Avenue, Miami, Florida 33147 (the “10403 Residence”).

6. On or about October 23, 2022, at approximately, 11:00 p.m., Victim 1 arrived at

the 10403 Residence and made contact with the male, later identified by law enforcement as 

CHARLES. CHARLES invited Victim 1 into the residence. Victim 1 and CHARLES then 

proceeded to CHARLES’s bedroom. Victim 1 noticed that CHARLES was wearing an ankle 

monitor during their interaction. A short time later, CHARLES produced a black firearm,

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pointed it at Victim 1, and demanded his cell phone. Victim 1 provided his cell phone to 

CHARLES. Victim 1, in fear for his life, and in attempt to get out of the residence, told

CHARLES that he would drive him to a bank and withdraw money for him.

7. CHARLES entered the front passenger seat of Victim 1’s vehicle, a 2021 red 

Honda which had previously been transported, shipped, or received in interstate or foreign 

commerce (hereinafter, “Victim 1’s Vehicle”). Victim 1 drove CHARLES to a Wells Fargo 

bank located at 13100 NW 27th Avenue in Miami, Florida. CHARLES pointed a firearm at

Victim 1 as he was driving. Victim 1 withdrew $380.00 in U.S. currency from Wells Fargo and 

handed it to CHARLES. Victim 1 then drove to a Bank of America, located at 13300 NW 27th

Avenue in Miami, Florida, and withdrew $760.00 in U.S. currency, which he also handed to 

CHARLES. CHARLES then instructed Victim 1 to sit in the front passenger seat so that he 

could drive. As CHARLES was driving Victim 1’s Vehicle, he ordered Victim 1 to exit his

vehicle at an unspecified highway exit; CHARLES then fled in Victim 1’s Vehicle. The Victim 

walked to a nearby gas station and called the police. 

8. A search of the Florida Driver and Vehicle Information Database (“DAVID”) 

revealed that the 10403 Residence is listed as CHARLES’s residence. Furthermore, a search of 

law enforcement databases revealed that CHARLES was on probation and being monitored by

the Miami-Dade County Corrections Boot Camp program using a GPS ankle monitor at the 

time of the incident. Probation records revealed that after the incident on October 24, 2022, 

CHARLES removed his GPS ankle monitor. Probation records also indicate that the 10403 

Residence is CHARLES’s residence, as reported to probation.

9. Victim 1 provided law enforcement with his bank transaction records showing the

date and time of the cash withdrawals from Wells Fargo and Bank of America. Law 

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enforcement made contact with the Miami-Dade County Corrections Boot Camp program, who 

provided GPS monitor location data for CHARLES during the relevant time period. A review 

of the location data revealed that CHARLES was at the Wells Fargo and the Bank of America at 

the time of the aforementioned cash withdrawals. A review of the location data also confirms

that CHARLES was at the 10403 Residence prior to going to the banks.

Victim 2

10. On or about November 2, 2022, Victim 2 received a message from an unknown

male on the “Grindr” application. The male told Victim 2 that he wanted to meet up and sent his 

location to Victim 2. Victim 2 agreed to meet with the male. Victim 2 drove to location

provided by the male: 244 NW 72nd Terrace Miami, Florida (the “244 Residence”). Victim 2 

was driving his 2022 black Toyota, which had previously been transported, shipped, or received 

in interstate or foreign commerce (hereinafter “Victim 2’s Vehicle”). 

11. When Victim 2 arrived at the 244 Residence, he observed CHARLES exiting the

apartment building. Victim 2 stopped his vehicle in front of CHARLES and put the vehicle in 

park, causing the doors of the vehicle to unlock. CHARLES entered the backseat of Victim 2’s

Vehicle and pointed a firearm at Victim 2. CHARLES appeared to notice police cars that were 

nearby and ordered Victim 2 to drive.

12. Victim 2 did not speak English fluently. CHARLES used a cell phone translator

application to communicate with Victim 2. CHARLES asked Victim 2 where he lived and 

instructed Victim 2 to take them to Victim 2’s apartment. Victim 2 drove his vehicle to his 

apartment. CHARLES ordered Victim 2 to park inside the parking garage. CHARLES then 

instructed Victim 2 to come to the backseat. CHARLES put down the backseat and ordered

Victim 2 to lay down in the backseat-trunk area of the vehicle.

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13. During the course of this incident, CHARLES struck Victim 2 several times about

the head and body with the firearm, causing bruising to Victim 2’s face and shoulder, and a cut 

to Victim 2’s head. 

14. CHARLES ordered Victim 2 to unlock his phone. CHARLES then used the

phone translator application to ask Victim 2 to log into Victim 2’s bank accounts. CHARLES 

noticed Victim 2 had a Bank of America account. CHARLES instructed Victim 2 to login to his 

bank account, but Victim 2 was unable to login to his account. While looking through pictures 

on Victim 2’s phone, CHARLES observed photographs of Victim 2 with other men; CHARLES

told Victim 2 that he was “going to kill all of you” and struck Victim 2 with the firearm.

15. CHARLES then jumped into the driver’s seat of Victim 2’s Vehicle, leaving

Victim 2 laying down in the backseat-trunk area. Victim 2 could not tell which direction 

CHARLES was driving because every time Victim 2 tried to put his head up, CHARLES struck 

him with the firearm.

16. CHARLES and Victim 2 ultimately arrived at an unknown Bank of America

location. CHARLES told Victim 2 to exit the vehicle and withdraw money from Victim 2’s 

bank account. Victim 2 tried to take out money, but was unsuccessful. CHARLES got out of 

Victim 2’s vehicle with a ski mask covering his face and tried withdrawing money with Victim 

2; he was also unsuccessful. CHARLES ordered Victim 2 to get into the vehicle again. 

17. While going through Victim 2’s phone, CHARLES also noticed that Victim 2 had

an Apple card with an available balance. CHARLES called someone on his phone and asked 

how to get the money from an Apple Card. After getting instructions, CHARLES ordered

Victim 2 into the front passenger seat of the vehicle and instructed him to keep his head down.

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18. CHARLES then drove Victim 2’s vehicle to three (3) different Walgreens stores.

Neither CHARLES nor Victim 2 exited the vehicle at the first Walgreens store. At the second 

Walgreens store, located at 3007 NE 199th Steet in Aventura, Florida, CHARLES instructed

Victim 2 to stay in the car. CHARLES told Victim 2 that if he tried to leave, he was going to 

kill him. CHARLES turned off Victim 2’s Vehicle and exited the vehicle, leaving Victim 2 

inside of the vehicle; he then walked into the Walgreens with Victim 2’s Apple card and the 

keys to the car. A review of Victim 2’s Apple card transactions revealed that CHARLES used 

Victim 2’s Apple card to purchase a $500 Apple gift card at the second Walgreens store.

CHARLES then returned to Victim 2’s vehicle. 

19. CHARLES then drove to a third Walgreens store, located at 18665 Biscayne

Boulevard in Aventura, Florida. CHARLES walked into the Walgreens, leaving Victim 2 inside 

of the vehicle with the car on; CHARLES took the keys to the car with him. CHARLES used

Victim 2’s phone to access Victim 2’s Apple card and purchased a $500 American Express 

Gold Gift Card, a Mountain Dew, and an Aquafina water. A review of Victim 2’s Apple card 

transactions reflect that transaction. While CHARLES was inside of the third Walgreens store, 

Victim 2 jumped into the driver’s seat of his vehicle and fled in his vehicle. 

20. Law Enforcement obtained surveillance video from the 244 Residence. The video

shows CHARLES taking the elevator down from the 10th floor of the building and exiting the 

building to meet Victim 2. Law Enforcement investigation revealed that a known female 

associate of CHARLES resides in an apartment on the 10th floor of the 244 Residence.

21. CHARLES’s probation officer was shown the video obtained from the 244

Residence. The probation officer confirmed that male in elevator heading down to meet with 

Victim 2 is CHARLES.

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