Case 6:24-mj-01414-RMN Document 1 Filed 04/19/24 Page 1 of 11 PageID 1

AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

for the
Middle District
__________ DistrictofofFlorida
__________

United States of America )

v. )
Monicsabel Romero Soto
) Case No.
) 6:24-mj- 1414
)
)
)
Defendant(s)

CRIMINAL COMPLAINT
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 See below in the county of Orange in the
Middle District of Florida , the defendant(s) violated:

Code Section Offense Description

21 U.S.C. § 841(a)(1) Possession with intent to distribute a mixture and substance containing cocaine

This criminal complaint is based on these facts:

See attached affidavit

✔ Continued on the attached sheet.

u

Complainant’s signature

Stephanie Pantos, Special Agent

Printed name and title

Sworn to before me and signed in my presence.

Date: April 19, 2024

Judge’s signature

City and state: Orlando, FL Robert M. Norway, U.S. Magistrate Judge

Printed name and title
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STATE OF FLORIDA Case No.: 6:24-mj- 1414

COUNTY OF ORANGE

AMENDED AFFIDAVIT IN SUPPORT OF COMPLAINT

I, Stephanie Pantos, being duly sworn, do hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I am a “federal law enforcement officer” within the meaning of Federal

Rule of Criminal Procedure 41(a)(2)(C), that is, a government agent engaged in

enforcing the criminal laws.

2. I am presently employed as a Special Agent with the United States

Department of Homeland Security, Homeland Security Investigations (HSI), where I

have worked since March 2022. In that capacity, my duties include investigating

federal criminal offenses in the Middle District of Florida, including narcotics

trafficking. During my tenure as a criminal investigator, I have completed

approximately 800 hours of instruction at the Federal Law Enforcement Training

Center in Glynco, Georgia, as well as investigating and assisting with multiple

narcotics related investigations. Prior to my tenure as a criminal investigator, I

completed my bachelor’s degree in Criminology and Criminal Justice from the

University of Maryland. Following that, I was a federal law enforcement officer with

the United States Capitol Police for three years.

3. I am an investigative or law enforcement officer of the United States

within the meaning of 18 U.S.C. § 2510(7) and am empowered by law to conduct

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investigations and to make arrest for offenses enumerated in 18 U.S.C. § 2516, to

include Title 8, 18, 19, and 21 of the United States Code.

PURPOSE OF AFFIDAVIT

4. This affidavit is being submitted to establish probable cause in support

of a criminal complaint charging Monicsabel ROMERO Soto (hereinafter referred to

as ROMERO) for possession with intent to distribute a mixture and substance

containing cocaine, in violation of 21 U.S.C. §§ 841(a)(1) and (b)(1)(B).

5. Because this affidavit is being submitted for the limited purpose of

establishing probable cause for the issuance of a criminal complaint, I have not

included every fact or facet of the investigation known to me, only enough to

establish probable cause for the issuance of a criminal complaint against ROMERO.

PROBABLE CAUSE

6. On April 16, 2024, HSI San Juan notified HSI Orlando of a suspicious

parcel. This parcel was identified by a source of information who has previously

identified multiple parcels found to contain narcotics.

7. The parcel information is as follows:

MANIFEST/ TRACKING NO: 1Z W37 01W 02 5273 4424

Addressed To:

RUBI ROMERO SOTO

(718) 525-4998
1855 OVERCUP AVE
ST CLOUD FL 34771
UNITED STATES

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Return Address:

SHIPPING UNLTD
(787) 985-1208
SHIPPING INLTD
1353 AVE LUIS VIGOREAUX
GUAYNABO PR 00966-2715
PUERTO RICO

8. The SUBJECT PARCEL was intercepted on April 17, 2024 at the UPS

Orlando Processing and Distribution Center located in Orlando, FL after it was

identified as a suspicious parcel.

9. UPS contacted HSI and I was able to go to the processing center. I

examined the exterior of the SUBJECT PARCEL and observed the following

characteristics:

a. The postal meter strip shows that the SUBJECT PARCEL was

shipped from zip code 00966 (Guaynabo, Puerto Rico), a known drug source area;

b. The SUBJECT PARCEL was shipped via UPS 2nd Day Air,

which is a common practice for the shippers of narcotics because the package arrives

faster and on a predictable date. The tracking number allows the sender, recipient, or

anyone else with the tracking number to confirm the delivery of the parcel by

checking the UPS;

c. The parcel does not require a signature from the recipient, which

would allow it to be left at the delivery address by the UPS without requiring contact

with a recipient. This is typical of narcotics parcels because it allows for the sender

and recipient to stay anonymous and further avoid detection by law enforcement.

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10. The return address on this package is a business called "Shipping

Unltd". This is another known tactic of narcotics smugglers used to conceal their

identity because the shipper is not required to divulge any personal information such

as their name or phone number.

11. The recipient’s address of “1855 Overcup Ave” does appear to be a

valid address, however the recipient’s name as written on the label, “Rubi Romero

Soto,” does not appear to be associated with the aforementioned address. It was later

learned that this is the name of ROMERO’s sister.

12. On April 17, 2024, arrangements were made to have a trained narcotics

detection canine examine the SUBJECT PARCEL. Artemis, an Apopka Police

Department narcotics detection K9, alerted to the parcel when it was presented to

him among other items in separate arrays. The canine did not alert to any other

items in the arrays that did not contain controlled substances.

13. On April 17, 2024, a state search warrant issued by Ninth Circuit Court

Judge Michael Murphy was executed on the SUBJECT PARCEL to examine the

contents. The SUBJECT PARCEL was found to contain what appeared to be a lamp

fixture. Inside the fixture, three “bricks” (kilograms) were concealed with caulk and

nails. The total weight of the “bricks” was approximately 3.28 kilograms. The bricks

contained a white powdery substance which were field tested and tested positive for

cocaine. Based on my training and experience, I know that narcotics traffickers order

bulk amounts of narcotics in brick form so they can easily distribute the product.

Based on my training and experience, I know that one brick/kilogram of cocaine is

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typically sold for $16,000- $20,000. Therefore, this amount of cocaine would be

worth approximately $60,000, which is well above a typical amount for personal use.

14. On April 17, 2024, the parcel was delivered by a St. Cloud Police

Department officer acting in an undercover capacity to 1855 Overcup Ave, St. Cloud

FL at approximately 1:15 p.m. The parcel was placed near the front door. The parcel

was monitored by law enforcement for the entirety of the operation.

15. During the operation, a white Acura SUV was seen conducting

countersurveillance in the neighborhood of Overcup Ave. The vehicle was seen

driving around multiple times and the driver appeared to be taking photographs.

Based on my training and experience, I know members of Drug Trafficking

Organizations often use countersurveillance tactics to ensure that they are not being

watched or followed by law enforcement. The Acura was seen in the area for

approximately an hour before it actually drove into the driveway, demonstrating that

the driver (ROMERO) was watching for an extended period of time and likely

observing vehicles that came through the neighborhood to ensure no law

enforcement was present.

16. At approximately 2:15 p.m., the white Acura MX bearing FL plate

JZGQ49 drove into the driveway over 1855 Overcup Ave, St. Cloud FL and parked.

This vehicle was the same vehicle seen previously conducting countersurveillance.

17. ROMERO exited the vehicle, carrying a baby, and approached the

parcel. She picked up the SUBJECT PARCEL and placed it into the Acura. At that

time, HSI/DEA agents blocked the vehicle in the driveway and instructed the
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ROMERO to exit the vehicle.

18. ROMERO stated that she arrived to “pick up her lamp” that she

ordered online. ROMERO stated that she does not live at 1855 Overcup Ave.

ROMERO was read her Miranda rights in Spanish by HSI TFO Rivera and agreed to

waive her rights.

19. ROMERO stated that she had ordered a lamp on Facebook for $300

and she didn’t know what the problem was. ROMERO stated that she paid for the

lamp via PayPal on her cell phone. At this point in the interview, the parcel had not

been opened in the presence of ROMERO nor had any law enforcement members

told her what was inside the box. The fact that ROMERO mentioned a lamp before

being told what was inside the box demonstrates her knowledge of the contents of

the SUBJECT PARCEL.

20. ROMERO claimed that she had the SUBJECT PARCEL delivered to

this address, which she said belonged to “a friend who did [her] taxes” because she

didn’t remember her own address. She stated that the parcel was addressed to her

sister because she didn’t like her own name. ROMERO stated that she is not

employed and receives welfare checks.

21. At the time of the encounter, ROMERO was in possession of two cell

phones. ROMERO stated that one phone belonged to her, and one belonged to her

sister. However, later in the interdiction when ROMERO was informed that she was

being placed under arrest, agents asked ROMERO for the name of a person who she

trusted to take custody of her child. ROMERO asked agents to contact her sister and
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agents were able to speak with her sister, Rubi Romero, on the cellphone number

provided. Rubi Romero agreed to come and pick up the child. When asked about

why her name was on the package containing cocaine, Rubi Romero had no

explanation and denied any knowledge of the SUBJECT PARCEL.

22. In ROMERO’s vehicle, multiple receipts were found which showed

multiple shipments of items to Puerto Rico. ROMERO stated that these shipments

were shoe boxes and that her sister has a shoe company. Based on my training and

experience, I know it is common for Drug Trafficking Organizations to launder

money through the mail and often mail money in shoeboxes.

23. ROMERO mentioned that she has a boyfriend named Giovany and

that she lives with her sister and boyfriend in Casselberry, Florida. ROMERO’s sister

was identified as Rubi Romero Soto, the recipient of the subject parcel. “Giovany”

has been identified as Giovany Joel CRESPO Hernandez, who has a Puerto Rican

Identification Card. ROMERO lives with her sister, Rubi Romero, and CRESPO at

1440 Guinevere Dr. Casselberry FL 32707.

24. CRESPO is a known member of a Drug Trafficking Organization

(DTO) in the Central Florida area and has a significant criminal history including

narcotics possession and intent to distribute. CRESPO was the target of a previous

HSI investigation in 2020 out of Miami, Florida which led to the seizure of over

$330,000. CRESPO is also a person of interest in a series of home invasions and

homicide investigations.

25. Unrelated to my investigation, and occurring at around the same time

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that I was placing ROMERO into custody for the SUBJECT PARCEL, deputies

with the Seminole County Sheriff’s Office executed a state search warrant at

ROMERO’s residence on 1440 Guinevere Dr. Casselberry FL 32707. Inside, they

recovered bulk currency ($13,701), narcotics (including fentanyl, cannabis, and drug

paraphernalia), drug ledgers, multiple cellphones, and several items of high-value

jewelry that has been identified as proceeds from robberies and home invasions:

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26. Agents also recovered two Glock firearms, including one in the laundry

room of the residence. In the driveway of the residence was a Toyota that was

registered to ROMERO. On the passenger side of the vehicle was a “trap” — a

hidden compartment with a hydraulic arm that is commonly used by drug traffickers

to secrete narcotics. The recovered firearm from the laundry room and the “trap” is

depicted below:

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CONCLUSION

27. I submit there is probable cause to believe that on April 17, 2024,

ROMERO did possess with intent to distribute a controlled substance involving

cocaine, a Schedule II controlled substance, in violation of 21 U.S.C. §§ 841(a)(1)

and (b)(1)(B).

______________________________
Special Agent Stephanie Pantos
Homeland Security Investigations

Affidavit submitted by email and attested

to me as true and accurate by telephone
conference or video conference consistent
with Fed. R. Crim. P. 4.1 and 41(d)(3)
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before me this ______ day of April, 2024.

______________________________
ROBERT M. NORWAY
United States Magistrate Judge

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