000: PD Document 1 Entered on FLSD Docket 12/22/2021 _ Pag SEALED SEALED ‘AOS (Rey 1/11) Criminal Complaint UNITED STATES DISTRICT COURT for the Southern District of Florida FILED BY___—0© DEC 21 2021 ANGELA E NOBLE United States of America ) SOROP NA SFU LAUD ¥. ) Ryan Hadeed ) cone ) 21-6697-STRAUSS ) ; CRIMINAL COMPLAINT |, the complainant in this case, state that the following is true to the best of my knowledge and belief. ‘Onoor about the date(s) of __ 9/29/2021 through 11/10/2021 _ in the county of Broward inthe Southern District of Florida, , the defendant(s) violated: Code Section Offense Description 1B USC Section 1958 Use of Interstate Commerce Facilties in the Commission of Murder-For-Hire ‘This eriminal complaint is based on these facts: See Attached Affidavit ® Continued on the attached sheet. ‘S/A John Hartis, HSI “Attested to by the applicant in accordance with ‘Printed name and tile the requirements of Fed. R. Crim. P, 4.1 by: FACETIME, Date: December 21,2021 Tudge 5 saure ~ City and state: Fort Leuderdele, FL _HON, JARED MSTRAUSS ne te :Case 0:22-cr-60009-WPD Document 1 Entered on FLSD Docket 12/22/2021 Page 2 of 11 AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT |, John Harris, being first duly sworn, hereby depose and state as follows: INTRODUCTION 1. Lam a Special Agent with Homeland Security Investigations (“HSI”). I have been employed as a Special Agent with HSI since August of 2016, I am currently assigned to the Border Enforcement Security Task Force (BEST) in Fort Lauderdale, Florida. My experience includes the investigation of cases involving money laundering and the use of facilities of interstate and foreign commerce in furtherance of such crimes. I am a graduate of the Federal Law Enforcement Training Center’s Criminal Investigator Training Program and the HSI Special Agent Training Program. I have received training in the investigation of criminal violations of federal law within the jurisdiction of HSI and have received specialized training in the investigation of money laundering and computer crimes. Additionally, I have received training and gained experience in arrest procedures, search warrant applications, the execution of searches and seizures, and various other criminal laws and procedures. Prior to my career with the HSI, I was employed for ten years as a Border Patrol Agent with the United States Border Patrol in California. 2. I submit this Affidavit in support of a criminal complaint against Ryan HADEED (CHADEED”). As explained below, there is probable cause to believe that beginning on or about September 29, 2021, and continuing to on or about November 10, 2021, in Broward County, Florida, HADEED violated Title 18 U.S.C. § 1958 (use of interstate commerce facilities in the commission of murder-for-hire).. 3. The information contained in this Affidavit is based on my personal knowledge, as well as information relayed to me by other law enforcement officials involved in this investigation. T have not included in this Affidavit all the facts known to me about this investigation. Rather, |Case 0:22-cr-60009-WPD Document 1 Entered on FLSD Docket 12/22/2021 Page 3 of 11 have included only the facts that are sufficient to establish probable cause to arrest HADEED for the violations described above, PROBABLE CAUSE 4. In September 2021, the Florida Department of Law Enforcement (“FDLE”) initiated an investigation into a solicitation to murder in Broward and Hillsborough Counties, Florida. A reliable FDLE confidential source (“CS”)! received a detailed letter via United States Postal Service (“USPS”) soliciting a murder for hire of an individual in Tampa, FL. FDLE requested assistance from USPS Inspectors and HSI, who joined the investigative team. 5. On September 29, 2021, the CS contacted investigators regarding a suspicious envelope addressed to him/her, that he/she received via USPS at his/her business, which is gun store located in Coral Springs, Broward County, in the Southem District of Florida. ‘The return address listed “Alan Smithee” with an address in Hialeah, FL. The typed letter inside of the envelope identified a solicitation to murder an unidentified person in Tampa, FL for $10,000.00 (USD). Specifically, the letter stated the following: "I need someone eliminated. I've been told you can arrange that. $10,000 All in cash and upfront. Person located in Tampa. You can be there and back in a day. You get their photo, first name, work address and home address. If you agree on Monday 1! October at 11am go to: The Little Coffee Shoppe 10732 Wiles Rd, Coral Springs, FL 33076 Buy a cup of coffee. Paste a black[?] sheet of white paper on your storefront window from Monday 11 to Wednesday 13, Information and payment will be sent once you accept. If not you will not be contacted again. Name and return address are fake." ‘The CS had previously worked for FDLE, and the CS* reporting has been corroborated through other investigative techniques and has been proven to be accurate, The CS is not being financially compensated and has no criminal history, 2 Believed to be a typo for “blank”Case 0:22-cr-60009-WPD Document 1 Entered on FLSD Docket 12/22/2021 Page 4 of 11 6. On October 11, 2021, as instructed by the letter, the CS posted a white sheet of paper in his store front window, to signal to the solicitor that the CS was willing to take part in the murder for hire, but the CS did not go to the ittle Coffee Shop. After the paper was posted in the window, investigators conducted surveillance to identity the solicitor if they came to check the window. On October 11, 2021, a grey, Honda Accord, with Florida plate CAKB13, was observed driving through the parking lot. Florida plate CAKBIS is registered to B.H.? (Ryan HADEED's brother), in Pembroke Pines, FL. While B.H. is the registered owner of the Accord, vehicle insurance records show that HADEED is the only insured driver for the car. 7. On October 15, 2021, the CS informed investigators that he/she received via USPS a second letter at his/her business. ‘The envelope had the same sender's name (Alan Smithee), however the return address was slightly different. Review of the typed letter showed it stated the followin “Laid there would be no more contact if you weren't at the coffee shop at I1am on October 1 Ith I didn't see you. But there was a white paper outside your storefront. But that could have been there from before. I'm not dragging this out If your still interested in the job mark a large X on a white sheet of paper an hang it outside the storefront from October 20th and for a full week. Once confirmed, you will get the money in full and the details on the person to be eliminated. This is important. You could take the money and do nothing. I would be out 10 gs and have to find someone else. If this works out, theres another job that will pay double or you name your price In a small town in Georgia. Or no more. Tampa first.” 8. On October 20, 2021, the CS posted a white sheet of paper with a black “X” in his storefront window, to signal to the solicitor that the CS was willing to take part in the murder for > Names of parties who may be innocent have been abbreviated to protect their identity. 3Case 0:22-cr-60009-WPD Document 1 Entered on FLSD Docket 12/22/2021 Page 5 of 11 hire. A Coral Springs Police Department (“CSPD”) speed radar trailer equipped with a License Plate Recognition (“LPR”) system was located in a position to view vehicular traffic passing in front of the CS’s gun store. The LPR system uses a special form of optical character recognition OCR"). This technology enables computer systems to read automatically the license plate numbers of vehicles from digital pictures taken by cameras. The pixels of the digital image are transformed into the numbers and alphabetic characters on the license plates and stored electronically. On October 22, 2021, the CSPD LPR system captured an image of a grey, Honda ‘Accord bearing Florida license plate CAKBI3 passing in front of the CS’s gun store. Additionally, on October 25, 2021, the CSPD LPR system captured two images (two minutes apart) of a grey, Honda Accord bearing Florida license plate CAKB13 passing in front of the CS"s gun store. 9. On November 1, 2021, the CS informed law enforcement that he/she received via USPS a third envelope with letter and map at his/her business. The envelope had the same sender's name (Alan Smithee), however the return address was slightly different. ‘The typed letter stated the following: “Saw the X. There’s a problem. The home address of the individual is a gated community. Lake View Oaks ‘Map included shows the general location of the building. Western side of the compound next to a open field. Ifyou wish to continue, the individual’s photo and the exact address with building and apartment number will be included with payment. Indicate with the same X on the storefront from November 4", for a full week.” 10. On November 4, 2021, the CS posted a white sheet of paper with a black *X” in his/her storefront window, to signal to the solicitor that the CS was still willing to take part in the murder for hire, 11, On November 10, 2021, the CS informed investigators that he/she received via USPS, @ padded envelope at his/her business. The parcel had the same sender's name (AlanCase 0:22-cr-60009-WPD Document 1 Entered on FLSD Docket 12/22/2021 Page 6 of 11 Smithee), however the return address was slightly different. Review of the postage label showed the parcel was mailed on November 8, 2021, from a Post Office in Coral Springs, FL. Investigators opened the parcel revealing $10,000 in cash, wrapped in three sheets of white paper bearing several photos of a white, adult male and additional typed information. The typed letter stated the following: [Page 1) “Home Address: 3506 Palm Crossing Dr Unit 204 Tampa, FL. 33613 (Lakeview Oaks apartents) Description: White Male 5°10" (1.78m) 195Ibs (88kg) Age: 54 Ken [Two images of a white male)” [Page 2] “Subject might be out of state for Thanksgiving. Not sure about Veterans Day but he ‘might not be home for that weekend. No info for December. The day and time is up to you. You have the money so your holding all the cards. Will know when the subject is taken out. Need to be done before the end of 2021.” (Page 3] “White Male 5°10" (1.78m) 195Ibs (88kg) Age: 54 [Two images of a white male]” 12, Based on the provided name, address, and images, investigators identified the target of the murder for hire as K.K. On November 12, 2021, law enforcement interviewed K.K. and his fiancé R.R. Law enforcement informed K.K. and R.R. about the letters soliciting the murder for 5Case 0:22-cr-60009-WPD Document 1 Entered on FLSD Docket 12/22/2021 Page 7 of 11 hire of K.K. K.K. informed investigators he recognized the photos of him in the letter from his publicly available Instagram account. While K.K. stated he did not know of anyone who would want to murder him, he did inform investigators the murder for hire letter reminded him of a suspicious letter he received via USPS in May 2020. K.K. had saved this letter and provided it to the investigators. VEE Review of the letter showed the envelope was addressed to K.K. with no return/sender’s address and contained two typed pages with three imate photos of RR. Review of the typed pages showed disparaging remarks about R.R.’s character and fidelity to K.K. While K.K. stated he did not know who sent letter, he believed it was sent to hit in an attempt to break up his relationship with RR. 14, During a follow up phone interview with R.R. on November 14, 2021, R.R. informed law enforcement that she suspected her former boyfriend, HADEI ED, may be the solicitor for the murder for hire plot. R.R. told law enforcement that HADEED was infatuated with her to fan unhealthy degree and had informed her many times of his desire that R.R. leave K.K. and be with HADEED. R.R. relayed that HADEED had previously threatened to harm her during an argument while they were dating. 15, Based on the information provided by R.R. about HADEED, investigators reviewed firearms purchase records from the CS’s gun store. Records showed in September 2018, HADEED completed a firearm transfer and picked up a FN Five-SeveN* pistol at the CS's store. Additionally, investigators queried HADEED's information into Department of Homeland A FN Five-seveN is a semi-automatic pistol designed and manufactured by FN Herstal in Belgium. The pistol is named for its 5.728mm bullet diameter, and the trademark capitalization style is intended to emphasize the ‘manufacturer's initials (“FN"). ‘The EN Five-seveN pistol has been referred to as a “cop killer” because the cartridge is essentially a minirfle round, and because of the high velocity and the relatively small diameter of the bullet, the bullet is able to effectively penetrate body armor commonly wor by law enforcement.Case 0:22-cr-60009-WPD Document 1 Entered on FLSD Docket 12/22/2021 Page 8 of 11 Security (“DHS”) databases. Customs and Border Protection (“CBP”) crossing records showed on October 22, 2021 (two days after the CS posted the X in the store window) HADEED purchased a one-way ticket to Trinidad and Tobago for a flight departing on November 10, 2021 (the same day the $10,000 cash and photos of K.K. were delivered to the CS). CBP crossing records confirmed that HADEED left the United States on that flight, 16. Based on my training and experience, I know persons involved in criminal activity by way of hired proxy, do so to conceal their involvement and avoid detection by law enforcement. Furthermore, I am aware that when the criminal activity occurs, the hiring party often travels great distances away to give themselves an “airtight” alibi if questioned by law enforcement. 17. On December 12, 2021, DHS databases indicated HADEED purchased a return flight for December 15, 2021, from Trinidad and Tobago to Miami, FL. On December 15, 2021, HADEED arrived at the Miami International Airport on board American Airlines Flight 2703. HADEED was referred by CBP for an inbound customs and immigration inspection. During the secondary inspection, a border search was performed on two smartphones in HADEED’s possession, a black, Samsung $8 with no assigned phone number and a blue, AT&T Calypso phone with assigned phone number (305) 733-7421.5 18. Review of HADEED’s black, Samsung S8 smartphone identified an image of a Google search of K.K.’s first and last name. Meta data for this image showed the picture was taken on August 27, 2021 (approximately one month prior to the CS received the first solicitation letter). Additionally, an image of a website displaying K.K.’s name, place employment, address and work phone number was located, Meta data for this image showed the picture was also taken on August 27, 2021. Closer review of these images shows they are not mobile phone “screenshots” 5 Records received from AT&T on November 30, 2021, show phone number (305) 733-7421 is subseribed to JH (Ryan HADEED's father) at 1500 NW 168% Pembroke Pines, FL 33028. UCase 0:22-cr-60009-WPD Document 1 Entered on FLSD Docket 12/22/2021 Page 9 of 11 but pictures of the monitor for a desktop computer. Furthermore, an undated browser tab on the phone displayed K.K.’s LinkedIn account. Lastly, two images of K.K. were located with metadata that indicated they were taken on November 4, 2020. 19, Additionally, the three intimate images of R.R. that were sent in the letter to K.K. in May 2020, were found in HADEED’s Samsung $8 smartphone. Review of these photos showed HADEED’s face inside a square in the upper right comer of the image (similar to FaceTime). These three photos were part of a series of dozens of similar photos found in the smartphone, all with metadata that indicated the images were captured in May 2020. Based on my review of the images and knowledge of smartphones and communication applications, it appears R.R. and HADEED were communication with each other visually through an application similar to FaceTime and HADEED took multiple “screenshots” during the conversation. Comparison of the three photos in the letter to K.K. and the corresponding images in HADEED's device, showed that in the photos to K.K., HADEED’s face in the upper right comer of the image had been cropped out. 20. Review of the AT&T Calypso phone identified two text message conversations where the user of the phone, believed to be HADEED, told the persons he was communicating, with that he drove a grey, Honda Accord. Specifically, on June 26, 2021, phone number (305) 733-7421 (“USER of 7421”), participated in a text message conversation with “Matt,” using phone number (860) 558-2731, where the following was exchanged: MATT: Im here USER of 7421: Parked under a tree USER of 7421: Honda CRV? MATT: Honda Accord? MATT: Yes USER of 7421: YupCase 0:22-cr-60009-WPD Document 1 Entered on FLSD Docket 12/22/2021 Page 10 of 11 21, Additionally, on February 14, 2019, phone number (305) 733-7421, participated in text message conversation with phone number (407) 733-5824, where the following was exchanged: USER of 7421: I pulled up at the back entrance. USER of 7421: Grey Honda Accord. 22. On December 17, 2021, investigators received Wells Fargo Bank records associated to HADEED. Review of HADEED’s Wells Fargo Bank account ending in 2356 showed on November 5, 202! (three days before the $10,000 in cash was mailed to CS), HADEED made a $10,000 cash withdrawal was made from the account. Review of the associated withdrawal slip displays HADEED's name, address, and signature®, Comparison between the signature on the withdrawal slip and HADEED's signature on his Florida Driver License appear consistent, 23. On December 20, 2021, investigators drove by three residences within the Pembroke Isles gated community. Law enforcement and commercial databases have identified that HADEED and his family reside at three residences within the community. While driving past HADDEDs sister’s residence, an investigator observed HADEED standing by himself next to the grey, Honda Accord, Florida plate CAKBI3, which was parked on the street. CONCLUSION 24, Based on the above information, I respectfully submit that there is probable cause to believe that beginning on or about September 29, 2021, and continuing to on or about November Untentionally Left Blank] © Bank CCTV footage of this withdrawal has been requested and is pending production. 9Case 0:22-cr-60009-WPD Document 1 Entered on FLSD Docket 12/22/2021 Page 11 of 11 10, 2021, HADEED, did use USPS mail to solicitate that a murder be committed, in violation of Title 18 U.S.C. § 1958 in Broward County, Florida, ial weenit dmeland Security Investigations ‘Attested to by the applicant in accordance with the requirements of Fed. R. Crim. P. 4.1 by: FACETIME this 21st day of December, 2021 | JARED M. STRAUSS TED STATES MAGISTRATE JUDGE