Cordoba Complaint

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UNITED STATES DISTRICT COURTSOUTHERN DISTRICT OF FLORIDAn - Q3O3 - KkAKASE NO.

Sealed

UM TED STATES OF AM ERICAVS.PAIJL CORDOBA, M ARLON CORDOBA,and JEFFERSON CASTILLO,

Defendants. /CRIM INAL COVER SHEET

Did this matter originate from a matter pending in the Northern Region of the United StatesAttorney's Oo ce prior to October 14, 2003? Yes x NoDid this matter originate from a matter pending in the Central Region of the United StatesAttorney's Oo ce prior to September 1, 2007? Yes x No2.

Respectfully submitted,W IFREDO A. FERRERUM TED STATES ATTORNEY

rBY: %ERIC A. HERNANDEZA SSISTANT UM TED STATES ATTORNEFlorida Bar No. 034073099 N. E. 4th StreetM inmi, Florida 33132-21 1 1'I'EL (305) 961-9423FAX (305) 530-7976

Case 1:12-cr-20157-FAM Document 3 Entered on FLSD Docket 03/06/2012 Page 1 of 5


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A0 91 (Rev.08/09) Criminal ComplaintU NITED STATES D ISTRICT COURT

for theSouthern District of Florida

United States of AmericaV. case xo. h R - m 303- (r K'NAKPAUL CORDOBA MARLON CORDOBA, andJEFFEVON CASTILLO,

CRIM INAL COM PLAINT1, 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 Auqust 1-2, 2009 in the county of Miami-Dade in theSouthern District of Florida , the defendantts) violated:Code SectionTitle 21 , United States Code,Sections 952(a), 963, 841(a)(1) and846.

Offense DescriptionThe defendants, PAUL CORDOBA, MARLON CORDOBA, and JEFFERSONCASTILLO, did knowingly and intentionally com bine, conspire,confederate and agreewith each other to import into the United States, from a place outside thereof, aSchedule 11 controlled substance, that is, a mixture and substance containing adetectable amount of cocaine, in violation of Title 21, United States Code, Section 952(a); alI in violation of Title 21, United States Code, Section 963; and did knowingly andintentionally combine, conspire, confederate and agree with each other to possesswith the intent to distribute a Schedule 11 controlled substance, that is, a mixture andsubstance containing a detectable amount of cocaine, in violation of Title 21, UnitedStates Codev Section 841(a)(1), aII in violation of Title 21, United States Code, Section846.This criminal complaint is based on these facts:SEE ATTACHED AFFIDAVIT.

W Continued on the attached sheet.

Complainant 's signature

Sworn to before me and signed in my presence.

G- V D t rate:

u x z 6o n 44 &Printed name nd title- wx gsv z jw tjuwa,m os

Judge 's signatureCity and state: Miami, Florida PATRICK A. W HITE, U.S. MAGISTRATE JUDGEPrinted name and title



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AFFIDAVIT1, Albert Ordonez, being duly sworn, depose and state:

1. I am a Special Agent with the Department of Hom eland Security, Hom elandSecurity lnvestigation (DHS/HSI) and have been so employed since March, 2009. l nmcurrently assigned to the Special Agent in Charge Oftsce in M iami, Florida, and myduties include the investigation of financial crim es thatinfrastnzcture of the United States, which include money

threaten the inanciallaundering and narcotics

trafficking. I am an investigative or law enforcement oftker of the United States within

the meaning of Title 18, United States Code, Section 2510(7), in that I nm empowered by1aw to conduct investigations of, and m ake arrests for, offenses enumerated in Title 21,United States Code, Sections 841, 846, 952, and 963. l submit this afsdavit based oninformation known to m t personally from the investigation, as well as obtained fromother law enforcement officers who have investigated this matter, or other individualswho have personal knowledge of the facts herein.

This affidavit is submitted to establish probable cause to arrest Paul CORDOBA,M arlon CORDOBA, and Jefferson CASTILLO. Because this affdavit is subm itted forthe limited purpose of establishing probable cause to arrest Paul CORDOBA, M arlonCORDOBA, and CASTILLO, it does not include a11 the details of the investigation ofwhich l am aware.

On or about August 1, 2009, in the Southern District of Florida,Paul CORDOBAand M arlon COO OBA smuggled from Venezuela to the United States over 300kilograms of cocaine aboard private aireraft N ZIN W .



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4.of Valencia, Venezuela; M arlon CORDOBA accom panied Paul CORDOBA aboard thistlight. Paul CORDOBA and M arlon CORDOBA then flew private aircraft N21NW toLas Americas Airport in the Dominican Republic to refuel. From the Dom inican

On or about August 1, 2009, Paul CORDOBA piloted private aircraft N21NW out

Republic Paul CORDOBA and Marlon CORDOBA tlew private aircraft N21NW toLynden Pindling International Airport in Nassau, Bahamas From N assau, PaulCOO OBA and M arlon CORDOBA tlew private aircraft N21NW to W ilmingtonIntem ational Airport in W ilm ington, North Carolina.5. After clearing custom s at W ilmington International, on or about August 2

,2009,Paul CORDOBA and M arlon CORDOBA flew private aircraft N21N W fromW ilm ington lntemational Airport to Ft. Lauderdale Executive Airport in FtLauderdale,Florida, carrying over 300 kilograms of cocaine. On that same date JeffersonCASTILLO was at Ft. Lauderdale Executive Airport helping to import the cocaine byconducting cotmter-surveillance in the event 1aw enforcement was in the area.

On August 2009, Paul CORDOBA, M arlon CORDOBA, and other co-conspirators removed the cocaine from the aircraft at FtLauderdale Executive Airport.Paul CORDOBA then gave another co-conspirator 180 kilograms of cocaine for thepurpose of distributing the cocaine. Over a period of three months the co-conspiratordelivered to Paul CORDOBA over $2,700,000 in U.S. currency from the sale of thecocaine.

On January 24, 2012, HSI special agents interviewed a contidential source (CS)regarding the alleged narcotics sm uggling by Paul CORDOBA and M arlon CORDOBA .The CS, who was a participant in the alleged crimes, and assisted in the importation anddistribution of these 300 kilograms of cocaine,provided the facts set forth above.

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8.and Border Protection. These records contirm that on July 31, 2009, Paul CORDOBApiloted private aircraft N21NW from Ft. Lauderdale Executive to Oranjestad, Aruba,N etherlands with M arlon CORDOBA, and others.

On or about January 27, 2012, HSI special agents reviewtd records from Custom

9.CORDOBA, and others traveled aboard private aircraft N21NW from N assau, Baham as

These records also contsrm that on August 1, 2009, Paul CORDOBA, M arlon

to W ilm ington, North Carolina.10. Based upon the foregoing information, your affant asserts that probable causeexists to believe that Paul CORDOBA, M arlon CORDOBA, and Jefferson CASTILLOdid knowingly enter into a conspiracy to im port a controlled substance into the UnitedStates, in violation of Title 21, United States Code, Sections 952 and 963. M oreover,based upon the foregoing infonnation, your afsant asserts that probable cause exists tobelieve Paul CORDOBA, M arlon CORDOBA, and Jefferson CASTILLO did knowinglyenter into a conspiracy to possess with intent to distribute a controlled substance, inviolation of Title 21, United States Code, Sections 841 and 846.

FURTHER AFFIANT SAYETH NAUGHT

SPECIAL AGENT ALBERT 01417 NEZDEPARTM ENT OF HOM ELAND SECURITYHOM ELAND SECURITY W VESTIGATIONS

Subscribed and orn be r m e' f M arc 2.tTHE HONO PATRICK A. WHFTEUNITED STATES M AGISTM TE JUDGE


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