UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

No. 

UNITED STATES OF AMERICA

vs. 

DANILO CURBELO, 

/ 

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 

Christine Hernandez

22-mj-04100-AOR

Case 1:22-mj-04100-AOR Document 1 Entered on FLSD Docket 12/12/2022 Page 1 of 7
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

CRIMINAL COMPLAINT%<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

Danilo Curbelo,

December 9, 2022 Miami-Dade

Southern Florida

Title 21, United States Code,

Section 846.

 Title 21, United States Code

Section 841(a)(1)

Conspiracy to Possess with Intent to Distribute a Controlled Substance.

 Attempted Possession with Intent to Distribute a Controlled Substance.

SEE ATTACHED AFFIDAVIT.

✔

Andrea Randou, HSI Special Agent

Miami, Florida Hon. Alicia M.Otazo-Reyes, United States Magistrate Judge

12/10/11

22-mj-04100-AOR

Case 1:22-mj-04100-AOR Document 1 Entered on FLSD Docket 12/12/2022 Page 2 of 7
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 Danilo

CURBELO for knowingly and willfully conspiring with other known and unknown persons to 

attempt to possess with intent to distribute, or 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. 

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 CURBELO. 

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2 

Accordingly, this affidavit does not contain all of the facts known to me and other law 

enforcement concerning this investigation. 

4. On December 7, 2022, law enforcement seized 90 kilograms of cocaine from a

shipping container that a multi-kilogram cocaine trafficker had sent to the Port of Miami from 

the Dominican Republic. The narcotics field tested positive for cocaine. The location of the 

container at the Port of Miami and the narcotics was information given to a confidential 

informant “CI” and undercover agent “UC” by Francisco FLORENTINO VALDEZ, 

CURBELO’s co-conspirator. 

5. 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 CURBELO arrive at 

FLORENTINO’s hotel, the Hilton Garden Inn located at 1695 NW 111th Ave, Sweetwater, 

Florida. Subsequently, law enforcement observed CURBELO meet with FLORENTINO 

VALDEZ and hand FLORENTINO VALDEZ a black and white bag through the driver side 

window of CURBELO’s vehicle. Shortly after, CURBELO departed the Hilton Garden Inn and 

was observed traveling to a Best Buy business located at 10760 NW 17th Street, in Miami, 

Florida. Upon his arrival at the Best Buy business, CURBELO parked his vehicle. CURBELO 

did not exit his vehicle to enter the store but stayed in the vehicle the whole time. 

6. Simultaneously, FLORENTINO VALDEZ departed the Hilton Garden Inn and

traveled to a predetermined meet location to meet with the UC and CI to show payment for the 

90 kilograms of cocaine. The UC and CI confirmed the payment for the narcotics transaction. 

Shortly thereafter, FLORENTINO VALDEZ followed the UC to an undisclosed undercover 

facility. At the location, FLORENTINO VALDEZ provided the UC approximately $96,000.00 

Case 1:22-mj-04100-AOR Document 1 Entered on FLSD Docket 12/12/2022 Page 4 of 7
3 

dollars of US currency for the 90 kilograms of “sham” cocaine. The $96,000 was given to the 

UC in the same bag that law enforcement observed CURBELO hand FLORENTINO a mere 30 

minutes before. FLORENTINO VALDEZ told the UC that he headed to the Best Buy after he 

received the narcotics. In previous recorded conversations with the UC, FLORENTINO had 

indicated that once he would receive the narcotics, he would then have to deliver the narcotics to 

distributors in Miami, Florida. Subsequently, the UC placed the 90 kilograms of “sham” cocaine 

into FLORENTINO VALDEZ’s vehicle and FLORENTINO VALDEZ departed the location. 

7. FLORENTINO VALDEZ was surveilled traveling to the Best Buy located at

10760 NW 17 Street, Miami, Florida. Once again, law enforcement observed FLORENTINO 

VALDEZ meet with CURBELO in the parking lot. At this meeting, FLORENTINO VALDEZ 

and CURBELO exchanged vehicles. CURBELO entered the vehicle containing the 90 kilograms 

of “sham” cocaine and attempted to drive away. FLORENTINO VALDEZ entered the vehicle 

CURBELO had been driving and also attempted to drive away. CURBELO was subsequently 

stopped and placed under arrest. Toll records from FLORENTINO VALDEZ’s phone confirm 

that CURBELO and FLORENTINO VALDEZ had been in contact with each other on December 

9, 2022, leading up to the narcotics transaction. In a post-Miranda statement CURBELO told law 

enforcement that he had just met FLORENTINO VALDEZ on December 9, 2022 and was only 

asked by FLORENTINO VALDEZ to drive him around to different locations in Miami Dade 

County. 

[INTENTIONALLY LEFT BLANK] 

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4 

8. 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, CURBELO did 

knowingly and willfully conspire with other known and unknown persons to possess with intent 

to distribute, or 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. 

 ________________________ 

 Andrea Randou, Special Agent 

 Department of Homeland Security 

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

___________________________________ 

HONORABLE ALICIA M. OTAZO-REYES 

UNITED STATES MAGISTRATE JUDGE 

10th

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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)

___________________________

USA:

DANILO CURBELO

Pretrial Detention

1750 W 60th Street Apt. 2

Christine Hernandez

Hialeah, Florida

FDC MIAMI

33 NE 4th Street, Miami, FL

ANDREA RANDOU, HSI

AUSA:

22-mj-04100-AOR

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