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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

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UNITED STATES OF AM ERICA

VS.

DANIEL BORRERO VASQUEZ, andJESUS LINARES ANDR ADE,

Defendants.

/

CRIM INAL COVER SH EET

Did this matter originate from a m atter pending in the Northern Region of the United

States Attorney's Oftsce prior to October 14, 20032 Yes X No

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

Attorney's Office prior to September 1, 20077 Yes X No

Respectfully sublnitted,

W IFREDO A. FERRER

UNITED STATES ATTORNEY

gy:

CHRISTOPHER B. BROW NE

Assistant United States Attorney

Southern District of Florida

Florida Bar No. 91337

99 Northeast 4th Street, 6th Floor

M iam i, Florida 33132-21 1 1

Teleyhone: (305) 961-9419Facslmile: (305) 536-4699E-mail: [email protected]

Case 1:15-cr-20026-UU Document 1 Entered on FLSD Docket 01/09/2015 of 6

AO 91 (Rev. 08/09) Criminal Complaint

UNITED STATES DISTRICT COURTfor the

Southern District of Florida

United States of America

V.

DANIEL BORRERO vAsauE ,z andJEsus LINARES ANDRADE,

c--x-. j y- p:)/ J - tvvbc, tzm

CRIM INAL COM PLAINT

1, the complainant in this case, state that the following is true to the best of my knowledge and belief.

On or about the datets) of January 7, 2015 in the county of Miami-Dade in the

Southern District of Florida , the defendantts) violated:

Code SectionTitle 21 , United States Code,Section 841 , aII in violation of Title21, United States Code, 846.

Ojlènse DescriptionThe defendants, DANIEL BORRERO VASQUEZ and JESUS LINARESANDRADE, did knowingly and intentionally combine, conspire, confederate,and agree with each other to possess with the intent to distribute a ScheduleI controlled substance, that is, a mixture and substance containing a

detectable amount of 3,4-methylenedioxymethamphetamine (MDMA or''ECSTASYH), in violation of Title 21, United States Code, Section 841(a)(1)',aIl in violation of Title 21 , United States Code, Section 846.

This crim inal complaint is based on these facts:

SEE ATTACHED AFFIDAVIT

W Continued on the attached sheet.

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THOMAS CASON, SPECIAL AGENTPrinted name and title

Sworn to before m e and signed in my presence.

Date: 01/08/2015

City and state'.

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Judge 's slknature

ANDREA M. SIMONTON, U.S. MAGISTRATE JUDGEPrinted name and title


AFFIDAVIT

1, Thomas Cason, being duly sworn, hereby depose and say that:

l am a Special Agent of the United States Department of Homeland Security,

lmmigration and Customs Enforcement (lCE) and have been so employed since October of 2006. I am

currently assigned to the M iami Florida Office of llwestigations. l am currently assigned to investigate

matters within the jtlrisdiction of the United States Department of Homeland Security, including the

ilwestigation of violations of customs and immigration laws. Prior to this employment, I was a

Customs and Border Protection Officer for four years.

The infonnation contained in this affidavit is based on my personal knowledge, as well

as information relayed to me by other law enforcem ent agents involved in this investigation. The

infonnation set forth in this aftidavit is provided solely for the purpose of establishing probable cause

for the arrest of Daniel BORRERO VASQUEZ and Jesus LINARES ANDRADE. As such, it does not

include everything law enforcem ent officers know about this investigation.

On or about January 7, 201 5,Daniel BORRERO VASQUEZ arrived at Miami

lnternational Airport (MlA) onboard Santa Barbara tlight #SA 1515 from Venezuela. BORRERO

VASQUEZ was selected for a routine inspection by Customs and Border Protection (CBP). Duringthe

inspection by CBP, BORRERO VASQUEZ began exhibiting signs of nervousness and was tmable to

answer various questions as per the purpose of his trip to the United States by CBP oft-icers. Due to the

various inconsistencies in his responses to CBP ofticers, BORRERO VASQUEZ was stlspected of

being a narcotics courier. A subsequent search of BORRERO VASQUEZ body revealed an abnormal

object concealed in his groin area. CBP oftkers removed and examined the objed, whieh appeared to

be a powdel'y substance wrapped in plastic. The powdery substance was consistent with illegal


narcotics. Field testing of the substance produced a positive test for M DM A or Ecstasy.

4. During the subsequent interview of BORRERO VASQUEZ, he stated he was given the

narcotics by an individual from Veneztlela name Jose ALEJANDRO, who told BORRERO VASQUEZ

to deliver it to Miami. BORRERO VASQUEZ stated that he knew the substance was a form of ecstasy

and that ALEJANDRO infonned him that once he delivered the package, the person responsible tbr

retrieving it would pay him an unspecified amount of U.S. currency. BORRERO VASQUEZ stated that

he was told to exit the CBP facility and that someone would be outside waiting to retrieve the ecstasy

and pay him for the delivery. BORRERO VASQUEZ stated that the person that would pick him up

would have of picture of BORRERO VASQUEZ and a description of his clothing.

At approximately 1 :00 P.M ., BORRERO VASQUEZ received a text message from

ALEJANDRO asking why it was taking him so long to exit the airport. The text message also stated

that the person who was sent to pick him up was still at M iam i International Airport waiting for him .

Per the instructions of HS1 special agents, BORRERO VASQUEZ infonned ALEJANDO that he stayed

in imm igration for an extended period of tim e explaining to them the purpose of his trip and that he

finally had cleared lmmigration and Customs and was ready to meet up with the person responsible tbr

picking him up. Shortly thereafter, BORRERO VASQUEZ received another text message from

ALEJANDRO advising him that the person would meet him inside the airport.

At approxim ately 2:30 P.M ., HSl specialagents, along with CBP officers set up

surveillance inside the airport, just outside of the CBP facility near Starbucks in advance of the

attempted control delivery.Shortly thereafter, BORRERO VASQUEZ exited the CBP facility with

other plain clothes special agents and was immediately approached by an individual later identitied as

Jesus LINARES ANDRADE. During the encotlnter, the two discussed at length the narcotics and the


instnlctions that were given to BORRERO VASQUEZ by ALEJANDRO. LINARES ANDRADE told

BORRERO VASQUEZ that he would retrieve the narcotics from him once they entered into his car that

was parked in the parking garage. As the two began to exit the airport, HSl special agents and CBP

officers intercepted both individuals and apprehended them .

Dlzring a subsequent post-M iranda interview of LINARES ANDRADE, he stated that he

was sent by ALEJANDRO to pick up BORRERO VASQUEZ and the ecstasy and was responsible for

selling it. Once he sold the ecstasy, he was told to send the money to Colombia electronically via wire

transfer. Lm ARES ANDRADE stated he had done this before, m ost recentlywas in December of 2014.

LINARES ANDRADE also stated that approximately two weeks prior, BORRERO VASQUEZ had

traveled to M iami t'iom Venezuela and had smuggled the ecstasy on his person in the same way.

LINARES ANDRADE stated that he recently wired approximately $6,000 in drug sale proceeds to

someone in Colombia per the request of ALEJANDRO. LINARES ADNRADE also statedthathe was

still in possession of som e of the ecstasy from the previous shipm ent.

At approxim ately 5:30 P.M ., as pa14 of his voluntary cooperation, LINARES

ANDRADE called his friend and asked the friend to bring the ecstasy that was being stored at his house

to a location in downtown M iami. At approxim ately 6:30 P.M ., special agents set up surveillance at a

restaurant plaza in downtown M iami in anticipation of the friend arriving with the Ecstasy.

Approximately 6:45 P.M ., an individual arrived at the agreed location and presented a black pouch to

Lm ARES ANDRADE. HSI special agents on scene im mediately retrieved the pouch and found apink

powdery substance inside a plastic bag within the pouch. A subsequent tield test of the substance tested

positive for the presence of ecstasy.The total weight of the substance was approximately 47 grams.

The individual who delivered the pouch to LINARES ANDRADE was not arrested.


9. Based upon the foregoing, your Affiant submits there is probable cause to believe that

DANIEL BORRERO VASQUEZ and JESUS LINARES ANDRADE did knowinglyand intentionally

combine, conspire, confederate, and agree with each other to possess with the intent to distribute a

Schedule I controlled substance, that is, a mixttlre and substance containing a detectable nmount of 3,4-

nzethylenedioxymethamphetamine, that is, M DM A or Ecstasy, in violation of Title 2 1 , United States

Code, Section 841(a)(1); al1 in violation of Title 2 1, United States Code, Section 846.

FURTHER YOUR AFFIAN T SAYETH NAUGHT

THO AS CASON, SPECIA L A GENT

HOM ELAND SECUIUTY INVESTIGATIONS

U.S. IM M IGRATION& CUSTOM S ENFORCEM ENT

Sworn to and subscribed before me this

8th day of January, 20l 5

A DREA M . SIM ONTONUNITED STATES M AGISTM TE JUDGE


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