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Adrian Hardy Criminal Complaint
Adrian Hardy Criminal Complaint
AO 91(Rev,08/09) CriminalComplafnt
United StatesofAmerica
V.
4
yu))))yqgyu
Adrian Hardyand casex o
Jerome Simmons
W Continuedontheattachedsheet.
Complainant'
ssignature
Elizabeth Richards,SpecialAnent,ATF
Printed nameand title
IN T RO D U CTIO N A N D A G EN T BA C K G R O UN D
1 am a Senior SpecialA gentw ith the U nited States Bureau ofA lcohol,Tobacco,
Fireanns and Explosives (hereinafter %ATF'') and have been employed by said agency for
approximately fifteen (15)years.In addition to my education,lhave completed approximately
seven (7)months ofbasic and specialized training with the ATF atboth the ATF National
Academ y and the FederalLaw Enforcem entTraining Center located in G lynco,Georgia.During
such tim e,l received specific training in the areas of tirearm s,narcotics,explosives and arson
am presently a Senior SpecialA gentfor the A TF M iam iField D ivision,Fort Lauderdale Field
violent gangs. During my tenure with the ATF, l have conducted num erous investigations
involving illegal firearm s, gang, violent crim e, and narcotics trafficking activities w ith the
This affidavit is subm itted in support of a crim inal com plaint charging A drian
Hardy (CtHARDY'') and Jerome Simmons (EISIM M ONS'') with knowingly and intentionally
obstructing,delaying,or affecting com merce or the m ovementofany article or com modity in
StatesCode,Section 924(c)(1)(A)(ii).
This affidavit is also subm itted in supportof a clim inal com plaint charging that
H ARD Y did know ingly take,with intentto cause death or seriousbodily hann,a m otor vehicle
Case 0:17-mj-06144-BSS Document 1 Entered on FLSD Docket 04/18/2017 Page 3 of 8
that had been transported, shipped, and received in interstate com m erce from the person or
presence of another,by force,violence and intim idation,in violation of Title 18,United States
Code,Section 2119,
*and did unlawfully kidnap,seize,confine,abductand cany away thevictim
using a facility or instrum entality of interstate and foreign com m erce in com m itting or in
the issuance ofan arrest w arrant for HA RDY and SIM M ON S forthe above-described crim inal
violations.
PR O BA BLE CA USE
Florida,to com m it a robbery.The suspects were w earing heavy facial m akeup and w om en's
clothing. The firstm ale w asw earing green pants,a lightblue long sleeve top,and a dark colored
6. The m orning of the robbery,em ployees 'fN .N .''and L.O .''were loading display
who wore thepinkjumpsuit,ifshe could help him. SIM MONS replied,tdl'm looking foran
engagem entrings''w ith whatsounded like a m an'svoice to L.O . H A RDY and the UN SU B then
locked the front door of the store and approached the counter brandishing firearm s. H ARD Y
a firearm to herhead.Atthe sam etime,SIM M ON S forced L.O .to the back room while pointing
in fearfortheirlife,com plied with the robbersdem ands. N .N .and L.O .could hearthe robbers
nlm maging through the safe and display cases.During the robbery,the robberswere overheard
enforcem entoutside,they changed course and ran outthe back doorofthe store dropping a large
system .
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AsHARDY ,SIM M ONS,and the UN SUB entered the storethatm om ing,an off-
duty police officer('witness'')wasnear-by and observed them wearing heavy face makeup,
dressed in w om en's clothing. The w itness saw the robbersenter the store and appear to lock the
doorbehind them . The witnessim mediately called 911to reportthe activity. Law enforcem ent
officers responded to LSO Jewelers and Repair and observed HARDY, SIM M ONS,and the
UNSUB nm outoftherearofthejewelrystore.
8. A footchase ensued and 1aw enforcem entofficersultim ately obselwed SIM M ON S
face,and carrying a walkie-talkie in hishand. SIM M ON S wasarrested on scene and taken into
State custody.Law enforcem entsubsequently located a long sleeve pink sweatshirt,pink sweat
pants,a pair of shoes,and a dark colored wig,underneath a nearby vehicle. The item s were
im pounded into evidence and sentto the crim e laboratory forexam ination.
9. Law enforcem entobserved HARDY running inthe direction ofa nearby hospital.
colored long sleeve top with a brightcolored shirtundem eath,a dark colored wig,gloves,and
sunglasses,attem pt to gain access to the hospital's em ergency room . The surveillance video
approached him and confronted him .The owner ofthe truck told 1aw enforcem entthatH ARD Y
im m ediately exited the tnlck and leftbehind a wig,gloves,and sunglasses. These item s w ere
im pounded by law enforcem entand sentto the laboratory for forensic analysis.
10. Law enforcem entreview ed the video from the store robbery,as w ellas the video
from the hospitaland com pared the clothing item s to the w itnesses' descriptions and item s left
Case 0:17-mj-06144-BSS Document 1 Entered on FLSD Docket 04/18/2017 Page 6 of 8
behind by HA RD Y and SIM M ON S. Law enforcem entwas able to detennine thatH A RDY and
SIMM ONS were in fact two ofthe subjects who committed the robbery while brandishing
firearm s.
Atapproximately 12:06 P.M .,law enforcem entreceived a telephone call from
tV.C.''whocalledtoreporthisfriend(hereinafterreferredtoasd$J.K.'')missingfrom hisresidence.
V.C.advisedlaw enforcem entthatwhen heanived topickup J.K .toplay golf,J.K .w asnotthere.
gallon of m ilk on the kitchen counter. A s 1aw enforcem ent continued to investigate the
disappearance ofJ.K .,J.K .returned hom e to the residence in his Chevy Traverse and advised law
forced to drive their Chevy Traverse bearing Ontario Tag # tICA N Y SCOT''to Brow ard County by
HA RD Y . The investigation revealed thatthe Chevy Traverse w as notm anufactured within the
person orpresence ofanother. J.K .and hisfam ily advised thatHARDY entered theirresidence
forcefully and waswearing black pants,adark colored long sleeve sweaterwith a brightcolored
shirtunderneath,and make up. The fam ily advised thatHARDY wasarm ed with two firearm s;
residence. Law enforcem entnoted thatthe clothing H ARD Y w as described asw earing w hen he
arrived at J.K .'S residence w as consistentw ith the clothing worn during the LSO Jewelry and
Repairsurveillance video,and consistentw ith the video from the hospital.W hile H A RDY w as in
the residence,he told the fam ily that som ething had gone wrong and his tw o friends had been
Case 0:17-mj-06144-BSS Document 1 Entered on FLSD Docket 04/18/2017 Page 7 of 8
w as in the nearby area,and told the fam ily he needed to get aw ay. HA RD Y asked the victim
ordered the victim sto geton 1-95 South and exitSunriseBoulevard.During the drive,HARDY
drank from the water bottle and then urinated in it.H A RDY dem anded to be dropped off at a
parking 1otbehind Tony'sM arketin Ft.Lauderdale,Florida.H ARD Y fled the victim 's Traverse
with theclothinghe anived in,a shopping bag,and both firearm s. HARDY emptied thebottleof
urine in thelot,dropped thebottle,and fled on foot.J.K and hisfam ily subsequently droveback
to Pol4 St.Lucie.
Law enforcem entprocessed J.K 'sresidenceforlatentfingem rintsand lifted a latent
belonging to H ARD Y .Law enforcem ent also collected and processed the w ater bottle that was
dropped in the em pty lot. Latent fingerprints lifted from the w ater bottle w ere also positively
CO NC LU SIO N
Based on the foregoing facts, 1 subm it that there is probable cause to charge
HA RDY and SIM M ON S with knowingly and intentionally obstructing, delaying,or affecting
comm erce or the m ovem entof any article or com modity in comm erce,by robbery,and with
Code,Section l951(a);andTitle18,UnitedStatesCode,Section924(c)(1)(A)(ii).
14. lalso subm itthatbased upon the foregoing factsthereisprobable cause to establish
thatHA RDY didknowingly take,w ith intentto causedeath orseriousbodily hann,am otorvehicle
that had been transported, shipped, and received in interstate com m erce from the person or
6
Case 0:17-mj-06144-BSS Document 1 Entered on FLSD Docket 04/18/2017 Page 8 of 8
presence of another,by force,violence and intim idation,in violation of Title 18,U nited States
Code,Section 2119*
,and did unlaw fully kidnap,seize,confine,abductand cany away thevictim
w ith the intentto collecta ransom ,reward,orotherbenefit,and did hold the victim forthatreason,
using a facility or instrum entality of interstate and foreign eomm erce in com mitting or in
furtheraneeoftheoffense,inviolationofTitle18,UnitedStatesCode,Section1201(a)(1).
F UR TH E R YO UR AFFIA N T NW YE TH NA UGH L