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AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

I, Jason S. Carter, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I am a sworn law enforcement officer with the City of Coral Springs Police

Department currently assigned to the Special Victims Unit with a primary assignment as a Task

Force Officer (“TFO”) with the Federal Bureau of Investigations (“FBI”), United States

Department of Justice (“DOJ”), Broward County Human Trafficking Task Force. I have been a

sworn law enforcement officer with City of Coral Springs Police Department since 2011. I am a

law enforcement officer within the meaning of Title 18, United States Code, Section 2510(7), and

I am empowered by law to conduct, execute and serve search warrants, and make arrests for

offenses enumerated in Title 18 of the United States Code, and for offenses against the United

States, including crimes related to human trafficking, child pornography, and the sexual

exploitation of children.

2. I have participated in investigations of persons suspected of violating federal child

pornography laws and human trafficking, including Title 18, United States Code, Sections 2251,

2252, 2252A, and 1591. These investigations have included the use of surveillance techniques, the

interviewing of subjects and witnesses, and the planning and execution of arrest, search, and

seizure warrants. During these investigations, I have reviewed thousands of still images and

videos, electronic media including computers, digital cameras, and wireless telephones, and have

discussed and reviewed these materials with other law enforcement officers. I have also

participated in training programs for the investigation and enforcement of federal child

pornography and human trafficking laws relating to the use of computers for receiving,

transmitting, and storing this content.

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3. This Affidavit is submitted in support of a criminal complaint charging Kiara

Nunez (hereinafter “NUNEZ”) and Alexandra Ramirez (hereinafter “RAMIREZ”) with two

counts of sex trafficking of a minor, in violation of Title 18, United States Code, Section 1591(a)(1)

and (b)(2), and 2. As explained below, there is probable cause to believe that, from in or around

October 2019 through on or about January 29, 2020, in the Southern District of Florida, NUNEZ

and RAMIREZ did knowingly, in and affecting interstate and foreign commerce, recruit, entice,

harbor, transport, provide, obtain, advertise, maintain, and solicit by any means a person, that is,

the Minor Victims, knowing and in reckless disregard of the fact that the Minor Victims had not

attained the age of eighteen years and would be caused to engage in a commercial sex act.

4. This Affidavit is based on my personal investigation and investigation by others,

including federal and local law enforcement officials whom I know to be reliable and trustworthy.

The facts contained herein have been obtained by interviewing witnesses and examining

documents obtained in the course of the investigation as well as through other means. This

Affidavit does not include every fact known to me about this investigation, but rather only those

facts sufficient to establish probable cause.

PROBABLE CAUSE

5. The investigation, as described in detail below, has revealed that NUNEZ and

RAMIREZ trafficked two 15-year-old females (“Minor Victim 1” and “Minor Victim 2”)

(collectively, the “Minor Victims”) for commercial sex, from in or around October 2019 through

on or about January 29, 2020, in Broward and Palm Beach Counties.

6. On or about January 29, 2020, law enforcement recovered a 15-year-old female

(“Minor Victim 1”) from a hotel in Fort Lauderdale (the “Hotel”) during a human trafficking

undercover operation. During the operation, on that date, law enforcement identified an online

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advertisement for the Fort Lauderdale area that advertised sex in exchange for money and

contained nude images of young females, later identified as the Minor Victims. The advertisement

was located on a website that is often used to advertise or otherwise promote prostitution (the

“Website”).

7. A law enforcement officer working in an undercover capacity (“UC”) contacted the

telephone number listed in the online advertisement and spoke with a female, later determined to

be NUNEZ. During the telephone conversation, NUNEZ negotiated a deal where both she and

another female, later determined to be Minor Victim 1, would engage in a “two girl special” in

exchange for $250. Based on my training and experience, a “two girl special” is a common

reference in prostitution for an individual to engage in sexual contact with two women at the same

time in exchange for money or other thing of value. The UC and NUNEZ agreed to meet at the

Hotel on January 29, 2020.

8. On that date, at approximately 9:12 p.m., NUNEZ arrived at the Hotel with Minor

Victim 1 and knocked on the agreed upon hotel room. NUNEZ and Minor Victim 1 were greeted

by the UC and entered the room. Once inside the room, Minor Victim 1 walked into the bathroom

while NUNEZ confirmed the sexual activity to be performed with the UC for $250. NUNEZ then

provided the UC with a condom that she brought.

9. While waiting for Minor Victim 1 to come out of the bathroom, NUNEZ informed

the UC that Minor Victim 1 is “new” and “gets nervous.” NUNEZ informed the UC that she travels

with her best friend who has taught her "the game." NUNEZ advised the UC that she has another

girl who she sometimes brings to “dates” such as this, and her best friend has other girls. NUNEZ

showed the UC photos and a video of other girls in provocative and undressed poses and stated

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that she and her best friend “do money.” NUNEZ also told the UC that she cleans the girls up. The

UC then asked if Minor Victim 1 worked for NUNEZ, to which NUNEZ responded affirmatively.

10. When Minor Victim 1 exited the bathroom, law enforcement officers entered the

hotel room and recovered Minor Victim 1. She was identified as a 15-year-old female, who was

reported missing to law enforcement by her family on or about January 18, 2020.

11. Further investigation revealed that one of the females depicted in the provocative

nude images and video that NUNEZ showed the UC was Minor Victim 2, who was reported

missing to law enforcement on or about November 18, 2019.

12. On or about January 29, 2020, NUNEZ gave law enforcement consent to search her

cell phone. Although not exhaustive, a forensic examination of NUNEZ’s phone revealed the

following evidence related to the offenses under investigation:

a. Communications between NUNEZ and the Minor Victims, wherein

NUNEZ provided instructions for engaging in commercial sex acts, including details of the sex

acts to be performed, prices, location, and method of transportation;

b. Communications between NUNEZ and a phone number that law

enforcement believes belongs to RAMIREZ. 1 For example, on or about December 19, 2019, in a

text message conversation, NUNEZ and RAMIREZ discussed “ugly pics” taken of Minor Victim

2 that NUNEZ and RAMIREZ took while they were in Palm Beach. RAMIREZ then sent three

nude photos of Minor Victim 2 to NUNEZ via text message; and

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The phone number that law enforcement believes belongs to RAMIREZ is saved in NUNEZ’s phone under
RAMIREZ’s first name. Additionally, several “selfie” type images of RAMIREZ were sent to NUNEZ’s cell phone
from this contact.

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c. Communications between NUNEZ and various individuals who responded

to the online advertisement for commercial sex acts, during which NUNEZ used photos of the

Minor Victims while negotiating prices for requested sex acts. In one particular conversation, on

or about January 26, 2020, NUNEZ sent photos of the Minor Victims to an individual, who

responded, “Ima tear that ass up sexy !!! And how old is your home girl,” referring to Minor Victim

1. NUNEZ stated “she about to turn 18 in April but 17 at the moment.”

A. MINOR VICTIM 1

13. On or about January 29, 2020, during her initial interview with law enforcement,

Minor Victim 1 reported that she had been trafficked by a male that she had met at the beach

around October 2019. Minor Victim 1 stated that the male advertised her for sex on the Website

and forced her to engage in commercial sex acts at hotels and Airbnbs throughout Broward County.

Minor Victim 1 further stated that NUNEZ assisted the male by transporting Minor Victim 1 to

meet with individuals to engage in commercial sex acts and collected the money that Minor Victim

1 made from sex acts.

14. During a follow-up interview with Minor Victim 1, on or about February 5, 2020,

Minor Victim 1 stated that she had falsely identified her “pimp” during her initial interview. Minor

Victim 1 explained that NUNEZ instructed her to provide the male’s name to law enforcement

should they ever be caught. Minor Victim 1 was aware that NUNEZ was being interviewed by law

enforcement in a separate room and therefore, out of fear, lied to law enforcement. Minor Victim

1 further stated that everything that she told law enforcement during her initial interview about the

male was really about NUNEZ. NUNEZ threatened the life of Minor Victim 1 and her family if

she ever told anyone about NUNEZ and RAMIREZ.

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15. Minor Victim 1 advised that NUNEZ learned “the game,” or how to be a pimp,

from RAMIREZ. Minor Victim 1 stated that both NUNEZ and RAMIREZ forced her and Minor

Victim 2 to pose in sexually explicit positions as they took photos to post in online advertisements

on multiple websites for commercial sex acts.

16. Minor Victim 1 advised that NUNEZ and RAMIREZ rented several hotel rooms

and Airbnbs throughout Broward County, and an Airbnb in Lake Worth, for Minor Victim 1 and

Minor Victim 2 to engage in commercial sex acts.

17. Minor Victim 1 stated that NUNEZ also ordered vehicles through Lyft or Uber, if

NUNEZ did not have access to a vehicle, to transport Minor Victim 1 and Minor Victim 2 to meet

with individuals to engage in commercial sex acts.

18. Minor Victim 1 was shown photos from the online escort advertisements that had

been posted on the Website and confirmed that she was one of the females featured in the

advertisements. Minor Victim 1 further stated that NUNEZ posted the online escort advertisements

on the Website.

B. MINOR VICTIM 2

19. Contact was made with Minor Victim 2 on both February 12, 2020 and July 8,

2020. During interviews with Minor Victim 2, she confirmed the incident at the Airbnb in Lake

Worth that Minor Victim 1 discussed with law enforcement. Minor Victim 2 stated that NUNEZ

and RAMIREZ drove both girls to an unknown location in Lake Worth, in Palm Beach County,

for the sole purpose of “making money” engaging in commercial sex acts. Minor Victim 2 advised

that they only had one “date” show up and NUNEZ and RAMIREZ “got mad” that they were not

making money. NUNEZ and RAMIREZ then decided to take better nude photos of Minor Victim

2 to post in the online advertisement.

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20. Minor Victim 2 advised that she told NUNEZ and RAMIREZ that she did not want

to have nude photos taken, however, NUNEZ and RAMIREZ told Minor Victim 2 that if she did

not pose naked, in the way they instructed her to, she had to “get the fuck out of the house.” Fearing

being left in an area she was unfamiliar with, without transportation or money, Minor Victim 2

decided to comply and posed nude as instructed by NUNEZ and RAMIREZ.

21. Minor Victim 2 informed law enforcement that RAMIREZ took the photos and

edited them, while NUNEZ posted them online. Both NUNEZ and RAMIREZ eventually removed

the photos of Minor Victim 2 from the online advertisement because several customers were

complaining that, “the girl looks scared.” Minor Victim 2 advised that she was embarrassed that

she was being forced to take nude photos and purposely tried to look afraid to possibly get help

from anyone who saw them.

22. Minor Victim 2 also advised that NUNEZ provided condoms and collected the

money. NUNEZ set the prices of each commercial sex act depending on whether the commercial

sex act would be a “quick visit,” a half hour, an hour, or a “2 girl special.” According to Minor

Victim 2, in the beginning, NUNEZ would only take 50% of the customer’s money but then began

taking a larger percentage. NUNEZ would also share the money with RAMIREZ.

23. Minor Victim 2 discussed that during these acts, Minor Victim 1 did not like sexual

intercourse and would only perform oral sex, which made NUNEZ mad. As a result, RAMIREZ

provided Minor Victim 1 with pills and told Minor Victim 1 to take them so they would help her

“feel good” when having sex. Minor Victim 2 noted that Minor Victim 1 complied and would take

the pills. NUNEZ and RAMIREZ also attempted to make Minor Victim 2 take the pills, but she

was too afraid after seeing how they made Minor Victim 1 act.

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24. Minor Victim 2 witnessed RAMIREZ pointed a BB gun at Minor Victim 1 during

an argument over being forced to perform sex acts. NUNEZ would tell them, “you’re on my time”

and “if you’re not making money what the fuck good are you?” NUNEZ threatened she would

leave both girls deserted in unknown locations if they did not work for her.

25. Minor Victim 2 identified herself in an online escort advertisement that had been

posted on the Website and stated that NUNEZ posted the advertisements.

26. The Minor Victims, during their separate interviews, reported that RAMIREZ

“dressed them up” and took them to the Las Olas area of Fort Lauderdale. RAMIREZ instructed

them on how to approach and solicit men. RAMIREZ told them to focus on men who appeared to

be “drunk,” to whisper in their ear while touching them gently. RAMIREZ told them to offer a

“date” and if they were not willing to pay the price to move on to the next “drunk” guy. NUNEZ

and RAMIREZ realized they were not making money doing it this way, so NUNEZ continued to

post online advertisements and arrange meetings with individuals for commercial sex acts.

27. Minor Victim 2 further stated that NUNEZ and RAMIREZ would take turns paying

for the Airbnbs that were used for the “dates.” Specifically, NUNEZ and RAMIREZ would find

Airbnbs with multiple rooms, using one room specifically for the performance of the sexual acts.

28. Subpoena returns from Airbnb confirm that RAMIREZ booked approximately six

Airbnbs in the South Florida region during the month of October 2019. NUNEZ booked

approximately five Airbnbs in the South Florida region during the month of November 2019.

CONCLUSION

29. Based on the forgoing, I respectfully submit that there is probable cause to support

a criminal complaint charging Kiara Nunez (hereinafter “NUNEZ”) and Alexandra Ramirez

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