Two Women Accused of Sex Trafficking Minors in Broward, Palm Beach Counties
Two Women Accused of Sex Trafficking Minors in Broward, Palm Beach Counties
Two Women Accused of Sex Trafficking Minors in Broward, Palm Beach Counties
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Case 0:20-mj-06371-LSS Document 1 Entered on FLSD Docket 08/24/2020 Page 2 of 10
I, Jason S. Carter, being first duly sworn, hereby depose and state as follows:
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.
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,
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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.
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
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
(“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”).
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
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
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
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
NUNEZ provided instructions for engaging in commercial sex acts, including details of the sex
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
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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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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
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
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
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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
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
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
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
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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
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
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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