UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

No. 

UNITED STATES OF AMERICA 

vs. 

FRANCISCO FLORENTINO VALDEZ, 

/ 

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 

22-mj-04102-AOR

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AO 91 (Rev. 08/09) Criminal Complaint

UNITED STATES DISTRICT COURT

for the

__________ District of __________

United States of America )

)

)

)

)

)

v.

Case No.

Defendant

CRIMINAL COMPLAINT BY TELEPHONE OR OTHER RELIABLE ELE&TRONI& 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.3. 4.1 by

22-mj-04102-AOR

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AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

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

1. I am employed as a Special Agent with the United States Department of

Homeland Security (“DHS”), Homeland Security Investigations (“HSI”), and have been so 

employed since December 2018. I am an investigative or law enforcement officer of the United 

States within the meaning of 18 U.S.C. § 2510(7), that is, an officer of the United States who is 

empowered by law to conduct investigations and make arrests for offenses enumerated in Titles 

8, 18, 19, and 21 of the United States Code. I am currently assigned to an investigative group 

responsible for conducting investigations of financial crimes, to include money laundering and 

narcotic violations. As such, I have participated in and conducted numerous criminal 

investigations, and have obtained and executed multiple search warrants. I am also working with 

Special Agents who have conducted multiple complex narcotic investigations and executed 

multiple search warrants. From these experiences, I have become familiar with investigations 

concerning the possession, manufacturing, distribution, and importation of controlled substance, 

as well as methods used to finance drug transactions and launder drug proceeds. 

2. This affidavit is submitted in support of a complaint for the arrest of Francisco

FLORENTINO VALDEZ for knowingly and willfully conspiring with other known and 

unknown persons to import a controlled substance into the United States, in violation of Title 

21, United States Code, Section 963. 

3. 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 provided solely for the purpose of establishing probable cause to arrest 

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2 

FLORENTINO. Accordingly, this affidavit does not contain all of the facts known to me and 

other law enforcement concerning this investigation. 

4. In November 2022, a confidential informant (“CI”) provided law enforcement

information concerning an individual who was shipping large quantities of cocaine into the Port 

of Miami via shipping containers from the Dominican Republic. Law enforcement later 

identified the leader of the Drug Trafficking Organization (“DTO”) as Juan ORAMA-PEREZ. 

5. Throughout the month of November 2022 and at the direction of law

enforcement, the CI placed multiple recorded telephone calls to ORAMA-PEREZ. During these

conversations, ORAMA-PEREZ, ORAMA-PEREZ’s supplier (hereafter known as “SOS”) and 

the CI discussed having a large shipment of cocaine delivered to the Port of Miami from the 

Dominican Republic in December 2022. The CI advised ORAMA-PEREZ that he could arrange 

for the retrieval of narcotics from the Port of Miami and deliver the narcotics to a member of the 

DTO for further distribution. ORAMA-PEREZ advised the CI he (ORAMA-PEREZ) would 

have an individual travel from the Dominican Republic to Miami, Florida, to meet the CI and 

receive the narcotics. 

6. On December 3, 2022, at the direction of law enforcement, the CI conducted a

recorded conversation with ORAMA-PEREZ and the SOS. During the conversation, ORAMAPEREZ advised the CI that a container with a large quantity of cocaine was shipped from the 

Dominican Republic to the Port of Miami for the CI to retrieve. ORAMA-PEREZ advised that 

the individual he was sending to receive the narcotics had departed the Dominican Republic to 

meet with the CI prior to the shipment’s arrival in Miami, Florida. The individual who was sent 

to meet with the CI prior to the shipment’s arrival in Miami, Florida, was later identified as 

FLORENTINO. 

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3 

7. FLORENTINO entered the United States on December 3, 2022, through the

Orlando International Airport from Santo Domingo, Dominican Republic. 

8. On December 4, 2022, a meeting was conducted with FLORENTINO, the CI, and

an undercover agent (“UC”) in Miami, Florida. During the meeting, FLORENTINO provided the 

UC and the CI the container number and location information of the narcotics that were shipped 

from the Dominican Republic. The meeting was audio and video recorded and preserved as 

evidence by law enforcement. 

9. On December 5, 2022, a second meeting was conducted with FLORENTINO, the

CI and UC. During the meeting, FLORENTINO provided the UC and the CI additional details 

concerning how the narcotics were sent and how FLORENTINO was going to distribute the 

narcotics in the Miami, Florida, area. The meeting was audio and video recorded and preserved 

by law enforcement as evidence. 

10. On December 7, 2022, law enforcement seized 90 kilograms of cocaine from the

shipping container that ORAMA PEREZ had sent to the Port of Miami. The narcotics field tested 

positive for cocaine. The location of the container at the Port of Miami and the narcotics was 

information given to the CI and UC by FLORENTINO. 

11. On December 9, 2022, based on recorded conversations, undercover agent

meetings, and cell site tracking data, as well as the investigation to date, law enforcement set up

surveillance in Miami-Dade County. Law enforcement observed FLORENTINO arrive at a 

predetermined meet location where FLORENTINO was to receive the 90 kilograms of cocaine. 

Shortly thereafter, FLORENTINO met with the UC and provided the UC $96,000.00 dollars of 

US currency for the 90 kilograms of cocaine. Subsequently, the UC led FLORENTINO to a 

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4 

location and provided him with 90 kilograms of “sham” cocaine.1 FLORENTINO placed the 

narcotics into his vehicle and departed the location. FLORENTINO was subsequently stopped 

and placed under arrest. 

12. Based on these facts, there is probable cause to believe that, on December 9,

2022, in Miami Dade County, in the Southern District of Florida, and elsewhere, FLORENTINO

did knowingly and willfully conspire with other known and unknown persons to import a 

controlled substance into the United States, in violation of Title 21, United States Code, Section 

963. 

 ________________________ 

 Andrea Randou, Special Agent 

 Department of Homeland Security 

Sworn to and subscribed before me this _10th ___ day of December 2022, in Miami, Florida. 

___________________________________ 

HONORABLE ALICIA M. OTAZO-REYES 

UNITED STATES MAGISTRATE JUDGE 

1

 Upon law enforcement seizing the 90 kilograms of actual cocaine, law enforcement substituted the 90 kilograms 

of cocaine for 90 kilograms of “sham” cocaine to use in the delivery to FLORENTINO. The 90 kilograms of

cocaine have been photographed, impounded, and preserved as evidence by law enforcement. 

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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)

22-mj-04102-AOR

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