Second Man Charged in Connection with Plot to Kill Haitian

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

No.

22-mj-02070-Louis

IN THE MATTER OF

A SEALED COMPLAINT

CRIMINAL COVER SHEET

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

Attorney’s Office prior to August 9, 2013 (Mag. Judge Alicia Valle)? Yes X No

2. 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

3. 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: /s/

Andrea Goldbarg

ANDREA GOLDBARG

Assistant United States Attorney

Court ID A5502556

JLK Federal Justice Building

99 Northeast 4

Street

Miami, Florida 33132-2111

Telephone: 305-961-9309

Email: [email protected]

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

22-mj-02070-Louis

CASE NO. ________________________

IN RE SEALED

CRIMINAL COMPLAINT

______________________________/

MOTION TO SEAL

NOW COMES the United States of America, by and through its undersigned attorney, and

respectfully requests that the criminal complaint, affidavit, arrest warrant, bond recommendation

form, this motion, and any resulting order be SEALED until the arrest of the defendant or until

further order of this court for the reason that the named defendant may flee and the integrity of the

ongoing investigation might be compromised should knowledge of this criminal complaint become

public, with the exception that the complaint, complaint affidavit, and arrest warrant are unsealed

for the limited purpose of disclosing the existence of or disseminating the complaint, affidavit,

and/or arrest warrant to relevant United States, foreign, or intergovernmental authorities, at the

discretion of the United States and in connection with efforts to prosecute the defendant or to

secure the defendant's arrest, extradition or expulsion, or as otherwise required for purposes of

national security.

Respectfully submitted,

JUAN ANTONIO GONZALEZ

UNITED STATES ATTORNEY

By: /s/

Andrea Goldbarg

ANDREA GOLDBARG

Assistant United States Attorney

Court ID A5502556

JLK Federal Justice Building

99 Northeast 4

Street

Miami, Florida 33132-2111

Telephone: 305-961-9309

Email: [email protected]

____________________________________

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO._________________________

22-mj-02070-Louis

IN RE SEALED

CRIMINAL COMPLAINT

____________________________/

SEALED ORDER

The United States of America, having applied to this Court for an Order sealing the criminal

complaint, arrest warrant, and this order and the Court finding good cause:

IT IS HEREBY ORDERED that the criminal complaint, affidavit, arrest warrant, bond

recommendation form, the government’s motion to seal, and this order shall be filed under seal

until the arrest of the defendant or until further order of this Court, however, with the exception

that the complaint, complaint affidavit, and arrest warrant are unsealed for the limited purpose of

disclosing the existence of or disseminating the complaint, affidavit, and/or arrest warrant to

relevant United States, foreign, or intergovernmental authorities, at the discretion of the United

States and in connection with efforts to prosecute the defendant or to secure the defendant's arrest,

extradition or expulsion, or as otherwise required for purposes of national security.

HONORABLE LAUREN F. LOUIS

UNITED STATE MAGISTRATE JUDGE

SOUTHERN DISTRICT OF FLORIDA

DONE AND ORDERED in chambers at Miami, Florida, this _____ day of January, 2022.

STATES DISTRICT COURT

for the

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Case No.

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

in the county of

, the defendant(s) violated:

Offense Description

This criminal complaint is based on these facts:

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Southern District of Florida

June 1, 2021 throu

hJul

7, 2021

Miami-Dade

Providing Material Support Resulting in Death

Conspiracy to Kill or Kidnap outside the United States

FaceTime

original

__________ District of __________

AO 91 (Rev. 08/09) Criminal Complaint

UNITED

United States of America

22-mj-02070-Louis

RODOLPHE JAAR,

Defendant(s)

CRIMINAL COMPLAINT

On or about the date(s) of in the

Southern

District of

Florida

Code Section

18 U.S.C. § 2339A

18 U.S.C. § 956(a)(1)

SEE ATTACHED AFFIDAVIT.

✔

Continued on the attached sheet.

Date:

01/15/2022

Judge’s signature

City and state:

Miami, Florida

Lauren F. Louis, U.S. Magistrate Judge

Printed name and title

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

I, Jacqueline Valdes, being first duly sworn, hereby depose and state the following:

1. I am a Special Agent with the Federal Bureau of Investigation (“FBI”), having been

so employed since March 2018. I am currently assigned to the Health Care Fraud Strike Force of

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enforcement training, and I have been personally involved in investigations concerning a variety

of violations of federal offenses, including health care fraud, wire fraud, money laundering,

diversion of opioids, bank robbery, international violent crime, and other violations of federal law.

2. This Affidavit is submitted for the limited purpose of establishing probable cause

to charge and arrest Roldolphe JAAR (“JAAR”) for (1) a violation of 18 U.S.C. § 2339A,

providing material support and resources

resulting in death, knowing or intending that such

support and resources are to be used to prepare for, or carry out, enumerated violations, including

a violation of 18 U.S.C. § 956, which prohibits conspiracy to murder or kidnap outside the United

States; and (2) a violation of 18 U.S.C. § 956(a)(1), Conspiracy to Kill or Kidnap outside the

United States.

3. I am personally involved in this investigation, along with other law enforcement

agents, including other FBI agents and Homeland Security Investigations (“HSI”) agents. Because

this Affidavit is being submitted for the limited purpose of establishing probable cause, it does not

contain all of the information known about this investigation. The facts and information contained

“Material support or resources” includes, in relevant part, “any property, tangible or intangible, or service,

including currency or monetary instruments or financial services, lodging, training, expert advice or assistance,

safehouses . . . weapons . . . personnel (1 or more individuals who may be or include oneself), and transportation,

except medicine or religious materials.” 18 U.S.C. § 2339A(b)(1).

18 U.S.C. § 956(a)(1) provides, in relevant part, “[w]hoever, within the jurisdiction of the United States,

conspires with one or more other persons, regardless of where such other person or persons are located, to commit at

any place outside the United States an act that would constitute the offense of murder, kidnapping, or maiming if

committed in the special maritime and territorial jurisdiction of the United States shall, if any of the conspirators

commits an act within the jurisdiction of the United States to effect any object of the conspiracy, be punished . . . .”

in this Affidavit are based on my personal knowledge and observation, as well as information

received in my official capacity from other individuals, including other law enforcement officers

involved in this investigation, as well as the review of records, documents, and other physical items

obtained during the course of this investigation.

PROBABLE CAUSE

4. On July 7, 2021, the President of Haiti, Jovenel Moise, was assassinated in his

residence in Port-au-Prince, Haiti. The First Lady (“M.M.”), suffered multiple gunshot wounds.

M.M. survived and received medical treatment in Miami.

5. According to statements made by Haitian authorities and the autopsy performed by

Haitian officials, the President was shot twelve times and died as a result. Haitian authorities

arrested numerous individuals in connection with the assassination, including several Colombian

nationals and several dual Haitian-American citizens.

6. Through witness interviews and the review of records and seized electronic

evidence, the investigation has revealed that in or around early June of 2021, a group of

approximately twenty Colombian citizens with military training were recruited to assist in the

execution of a purported Haitian arrest warrant for President Moise. Several of the Colombians

stayed at a residence controlled by JAAR. According to interviews, JAAR was responsible for

providing weapons to the Colombians to facilitate carrying out the operation. That same month,

JAAR also attended a meeting that included co-conspirator #1, a Haitian-American citizen, during

which co-conspirator #1 discussed the plan to arrest President Moise.

7. According to witness statements, JAAR was present when co-conspirator #1

secured the signature of a former Haitian judge on a written request for assistance to further the

arrest and imprisonment of President Moise, as well as purporting to provide Haitian immunity for

such actions. On or about June 28, 2021, in furtherance of and to effect the object of the

conspiracy, co-conspirator #1 traveled from Haiti to the United States, specifically the Southern

District of Florida, and provided other individuals with the document. According to interviews of

several co-conspirators in Haitian custody, by this point certain co-conspirators had knowledge, or

at least believed, that the plan was to assassinate rather than kidnap President Moise. On or about

July 1, 2021, co-conspirator #1 flew from Florida to Haiti to participate in the operation.

8. On July 7, 2021, some of the Colombians and others entered the Presidential

residence in Haiti with the intent and purpose of killing President Moise, and in fact, the President

was killed. Later that day, JAAR communicated with co-conspirator #1 and others to assist the

Colombians and co-conspirator #1, who were hiding and feared that they would be captured and/or

killed by Haitian authorities. Co-conspirator #1 was subsequently arrested by Haitian authorities

and is currently in custody in Haiti.

9. On December 9, 2021, JAAR was interviewed outside the United States and

provided U.S. law enforcement with a voluntary statement. In summary, JAAR admitted that he

provided firearms and ammunition to the Colombians to support the assassination operation. He

stated that the operation changed from an arrest operation to an assassination operation after the

initial plan to “capture” the Haitian President at the airport and take him away by plane did not go

forward. JAAR admitted to attempting to assist co-conspirator #1 and the Colombians by directing

them to hide in another country’s embassy in Haiti.

10. Based on the foregoing, your Affiant respectfully submits that there exists probable

cause to believe that JAAR committed the offenses of 18 U.S.C. § 2339A, Providing Material

____________________________________

Special Agent Jacqueline Valdes

Federal Bureau of Investigation

______________________________________

Support or Resources to Carry out a Violation of Section 956, Resulting in Death; and 18 U.S.C.

§ 956(a)(1), Conspiracy to Kill or Kidnap a person outside the United States.

FURTHER YOUR AFFIANT SAYETH NAUGHT.

HONORABLE LAUREN F. LOUIS

UNITED STATES MAGISTRATE JUDGE

SOUTHERN DISTRICT OF FLORIDA

Attested to by the applicant in accordance with the requirements

of Fed. R. Crim. P. 4.1 by FaceTime this ____ day of January 2022.

__________ District of __________

AO 442 (Rev. 11/11) Arrest Warrant

UNITED STATES DISTRICT COURT

for the

Southern District of Florida

United States of America

)

Case No.

22-mj-02070-Louis

RODOLPHE JAAR,

)

Defendant

ARREST WARRANT

To: Any authorized law enforcement officer

YOU ARE COMMANDED to arrest and bring before a United States magistrate judge without unnecessary delay

(name of person to be arrested)

RODOLPHE JAAR

who is accused of an offense or violation based on the following document filed with the court:

u Indictment u Superseding Indictment u Information u Superseding Information u

Complaint

u Probation Violation Petition

u Supervised Release Violation Petition

This offense is briefly described as follows:

Conspiracy to Kill or Kidnap outside the United States, in violation of Title 18, United States Code, Section 956(a)(1); and

Providing Material Support or Resources to Carry out a Violation of Section 956, Resulting in Death, in violation of 18

U.S.C. § 2339A

Date:

01/15/2022

Issuing officer’s signature

City and state:

Miami, FL

HON. LAUREN F. LOUIS, U.S. MAGISTRATE JUDGE

Printed name and title

Return

This warrant was received on

(date)

at (city and state)

Date:

, and the person was arrested on

(date)

Arresting officer’s signature

Printed name and title

AO 442 (Rev. 11/11) Arrest Warrant (Page 2)

This second page contains personal identifiers provided for law-enforcement use only

and therefore should not be filed in court with the executed warrant unless under seal.

(Not for Public Disclosure)

Name of defendant/offender:

RODOLPHE JAAR

Known aliases:

Last known residence:

Prior addresses to which defendant/offender may still have ties:

Last known employment:

Last known telephone numbers:

Haiti

Place of birth:

Date of birth:

Social Security number:

Height: Weight:

male

Sex: Race:

Hair: Eyes:

Scars, tattoos, other distinguishing marks:

History of violence, weapons, drug use:

Known family, friends, and other associates

(name, relation, address, phone number):

FBI number:

Complete description of auto:

Investigative agency and address:

FEDERAL BUREAU OF INVESTIAGTION

2030 SW 145th AVE, MIRAMAR, FL 33027

Name and telephone numbers (office and cell) of pretrial services or probation officer

(if applicable):

Date of last contact with pretrial services or probation officer

(if applicable):

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NUMBER: __________________________

22-mj-02070-Louis

BOND RECOMMENDATION

RODOLPHE JAAR

DEFENDANT:

PRE-TRIAL DETENTION

(Personal Surety) (Corporate Surety) (Cash) (Pre-Trial Detention)

By:

$86$ANDREA GOLDBARG

NDREA

GOLDBA

Last Known Address:

HAITI

________________________________

_____________________

What Facility:

Agent(s):

JACQUELINE VALDES

(FBI) (SECRET SERVICE) (DEA) (IRS) (ICE) (OTHER)

Count #:

* Max.Penalty:

Count #:

* Max.Penalty:

Count #:

* Max.Penalty:

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

PENALTY SHEET

Defendant's Name:

Rodolphe JAAR

Case No:

22-mj-02070-Louis

Count #:

Providing Material Support or Resources to Carry out a Violation of Section 956, Resulting in Death

Title 18, United States Code, Section 2339A

*Max. Penalty:

Life Imprisonment

Count #:

Conspiracy to Kill or Kidnap a person outside the United States

Title 18,United States Code, Section 956(a)(1)

*Max. Penalty:

Life Imprisonment

Count

Refers only to possible term of incarceration, does not include possible fines, restitution,

special assessments, parole terms, or forfeitures that may be applicable.