Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 1 of 30 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT IN THE MATTER OF THE ARREST OF WILLIAM ROSARIO LOPEZ and SOLIMAR RODRIGUEZ GONZALEZ Case No. 3:20MJ ___ 348 (SALM) Filed Under Seal April 9, 2020 AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT, ARREST WARRANTS, AND SEARCH WARRANTS I, Lisa C. MacNamara, currently assigned as a Special Agent with Federal Bureau of Investigation, being first duly sworn, hereby depose and state as follows: INTRODUCTION AND AGENT BACKGROUND 1. I submit this affidavit in support of a criminal complaint and application for arrest warrants charging WILLIAM ROSARIO LOPEZ (“ROSARIO LOPEZ”) and SOLIMAR RODRIGUEZ GONZALEZ (“GONZALEZ”) with Hobbs Act Robbery, in violation of Title 18, United States Code, Section 1951, and conspiracy to commit same, and Felon in Possession of a Firearm, in violation of Title 18, United States Code, Section 922(g), and conspiracy to commit same (the “Target Offenses”). 2. I further submit this affidavit in support of an applications for search warrant (“the DNA Sample Warrant”), pursuant to Federal Rule of Criminal Procedure 41, for buccal swab DNA samples from WILLIAM ROSARIO LOPEZ, with a date of birth 10/20/1985. 3. I further submit this affidavit in support of an application for a search warrant (“the Target Vehicle Warrant”), pursuant to Federal Rule of Criminal Procedure 41, to search and seize a black Honda Accord bearing temporary New Jersey license plate 577942R (“the Target Vehicle”). 1 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 2 of 30 4. I am a Special Agent with the Federal Bureau of Investigation (“FBI”). As an FBI Special Agent, I have directed, conducted and participated in many criminal investigations of various federal laws, including bank robberies, commercial robberies, kidnappings, narcotics investigations, and drug related homicides. During the course of these investigations, I have worked together with state and local law enforcement agencies to arrest the individuals responsible for criminal offenses. 5. I have been employed by the FBI as a Special Agent for over 24 years. I am an investigative or law enforcement officer of the United States within the meaning of Title 18, United States Code, Section 2510(7), in that I am empowered by law to conduct investigations of and to make arrests for offenses enumerated in Title 18, United States Code, Section 2516. Prior to becoming a Special Agent for the FBI, I was a sworn police officer in Madison, Connecticut and New Haven, Connecticut for seven years. Since November 2006, I have been assigned to the New Haven Division of the FBI, where my primary duty is the investigation of robbery offenses, as well as other violent crimes. 6. I have participated in numerous investigations involving individuals suspected of bank robberies, commercial robberies, kidnappings, narcotics investigations, and drug related homicides, and written, obtained and coordinated the execution of search and arrest warrants pertaining to individuals involved in federal offenses. I have prepared numerous affidavits in support of applications for search and arrest warrants which have resulted in orders being issued by judges, including authorizations for electronically stored data from telephone service providers which have led to the conviction of numerous defendants for violations of federal laws. I am authorized to investigate violations of the laws of the United States and I am a law enforcement officer with the authority to execute federal search and arrest warrants. 2 Case Document 1-1 Filed 04/09/20 Page 3 of 30 7. The information contained in this affidavit is based on my personal panicipation in the robbery investigation. and information received from other law enforcement officers I am thoroughly familiar with the circumstances of the investigation and the information set forth in this affidavit. The statements contained in this affidavit are based on: (1) my personal panicipation in the investigation; (2) information provided to me by Special Agents of the FBI and members of the Vernon, Southington. Waterbury. Ansonia. New Britain New Haven, and Guilford Police Departments and Connecticut State Police; and (3) my experience and training. This affidavit is intended to show merely that there is sufficient probable cause for the issuance of a criminal complaint, arrest warrants and search warrants and does not set forth all of my knowledge about Ihis maller. 8. Based on the facts set forth in this affidavit there is probable cause to believe that violations of Title 18 U.S.C. 1951 (Hobbs Act Robbery and conspiracy to commit same) and Title 18 U.S.C. 922(g) (Felon in Possession of a Firearm and conspiracy to commit same) have been committed by WILLIAM ROSARIO LOPEZ and SOLIMAR RODRIGUEZ GONZALEZ. There is also probable cause to search and seize buccal swab DNA samples from WILLIAM ROSARIO LOPEZ, with a date of blah-IDES, for evidence of these crimes as described in Attachment A to the DNA Sample Warrant. There is also probable cause to search and seize the Target Vehicle for evidence of these crimes as described in Attachment A to the Target Vehicle Warrant. PROBABLE CAUSE 9. The United States is investigating five gunpoint Hobbs Act robberies that occurred in the District of Connecticut between March 18. 2020 and March 261 2020. In one such robbery a firearm was discharged. As described below Ihere is probable cause to believe and I do believe 3 Case Document 1-1 Filed 04/09/20 Page 4 Of 30 that ROSARIO LOPEZ and GONZALEZ committed these robberies. I further believe that ROSARIO LOPEZ and GONZALEZ have used the Target Vehicle as in instrumentality of the Target Offenses and buccal swab DNA samples from ROSARIO LOPEZ would provide relevant evidence of the crimes. 10. As described below, GONZALEZ stepfather and mother identified GONZALEZ in still photographs of video surveillance footage depicting her just prior to two Hobbs Act robberies that occurred in Vernon on March 18. 2020. and Waterbury on March 22. 2020. In the Vernon robbery, GONZALEZ is wearing what I believe to be the same purple sweatshin worn by the masked male perpetrator, believed to be ROSARIO LOPEZ, in four of the Hobbs Act robberies. In February 202a GONZALEZ was the subject of a missing persons report filed by her parents who believe her to be with her boyfriend. "William." 1 1. As described below, on March 16, 2020. GONZALEZ was present with ROSARIO LOPEZ during a breach of pence complaint made to the New Haven Police Depanment. ROSARIO LOPEZ and GONZALEZ were recorded by the New Haven Police Department on body camera footage. ROSARIO LOPEZ identitied himself as William Rosario Lopez with a date of birth of-1985, an address of_ New Haven, Connecticut and phone number of_. ROSARIO LOPEZ was in possession of a dark Honda Accord bearing temporary New Jersey license plate 577942R, the Target Vehicle. As described below. slepefaiher and mother were later shown still photographs of the New Haven Police body camera footage and identified the individuals depicted as GONZALEZ and her boyfriend "William." 12. As described below, slepefaiher and mother were also shown a photograph of the masked male from the Mach 26' 2020 robbery in New Britain. Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 5 of 30 step-father and mother believed the male looked like ROSARIO LOPEZ, who they know as “William,” because he has a skinny face and nose. GONZALEZ’s step-father stated that he was pretty sure that the male depicted in the New Britain video surveillance was “William,” ROSARIO-LOPEZ. 13. As described below, I reviewed the video surveillance from each of the five Hobbs Act robberies in Vernon, Southington, Waterbury, Ansonia and New Britain. I believe the masked male depicted in video surveillance to be the same individual. I also reviewed still photographs from video surveillance from a March 16, 2020 incident in New Haven, where ROSARIO LOPEZ and GONZALEZ were together and ROSARIO LOPEZ identified himself to police. I also reviewed still photographs from video surveillance from an April 1, 2020 incident in Guilford, where I believe that ROSARIO LOPEZ and GONZALEZ together committed shoplifting. In that instance, ROSARIO LOPEZ was masked, wearing a white surgical-type mask consistent with the male who committed the Hobbs Act robberies. ROSARIO LOPEZ also, based on the New Haven body camera footage and criminal databases, has a consistent height, weight, body type and features as the male who committed the gunpoint Hobbs Act robberies. ROSARIO LOPEZ’s criminal history also revealed New York State felony convictions. 14. Based on information known to me through this investigation, and described in this affidavit, I believe ROSARIO LOPEZ and GONZALEZ to be the individuals who committed the Hobbs Act robberies while in possession of a firearm, utilizing the Target Vehicle. 5 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 6 of 30 The Robberies: A. Vernon Robbery, March 18, 2020 15. On or about March 18, 2020, at approximately 2150 hours, a Shell Gas Station located at 1302 Hartford Turnpike, Vernon, Connecticut, was robbed of approximately $1,188 by a masked male, believed to be ROSARIO LOPEZ, at gunpoint. The victim gas station is located near an onramp to Route I-84. The victim gas station clerk was cleaning a coffee pot when the masked male entered the station. The male was wearing a black mask covering his face, blue latextype gloves, a hooded purple sweatshirt, blue jeans, and black and white sneakers. The masked male pointed a small silver pistol at the clerk, grabbed him by the collar, directed the clerk to walk to the cash register, and struck the clerk in the back of the head as they were walking to the cash register. The clerk opened the cash register as instructed, provided money to the male, was ordered by the male to lay on the floor, and the male fled. 16. Vernon Police responded to the scene after being notified by the clerk, and Detective Tommy Van Tasel of the Vernon Police Department was assigned to the case. Detective Van Tasel reviewed video surveillance from the Shell Gas Station. Video surveillance from a nearby Dunkin Donuts showed what appeared to be the masked male flee the gas station and enter a dark-colored sedan, and drive away from the scene. 17. Video surveillance from the gas station also showed that, approximately 30 minutes before the robbery, a Hispanic woman, believed to be GONZALEZ, entered the gas station to pay for gasoline in cash. The woman was wearing what is believed to be the same hooded purple sweatshirt worn by the masked male, dark pants and sandals with metal accent pieces on the strap of each sandal. The woman entered the store with the hood of the sweatshirt covering her head. The woman was the passenger in a dark-colored sedan (visible on video surveillance as a Honda 6 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 7 of 30 Accord), though investigators were unable to capture the license plate of the vehicle via review of video surveillance. 18. Video surveillance from the gas station also showed that during the time the sandal- wearing woman purchased gas from the gas station prior to the robbery, an individual inside of the dark-colored sedan (visible on video surveillance as a Honda Accord) appears to be using a cellular telephone. The individual, believed to be ROSARIO LOPEZ, was seated in the driver’s seat, with the sandal-wearing woman seated in the passenger seat. Inside of the vehicle, the illuminated screen of what appears to be a smartphone can be observed, and the screen is being manipulated in a “scrolling” gesture by the individual in the driver’s seat. Figures 1 & 2 – Vernon Surveillance Video B. Southington Robbery, March 22, 2020 19. On or about March 22, 2020, at approximately 2157 hours, a Fleet Gas Station located at 1611 Meriden Waterbury Turnpike, Southington, Connecticut, was robbed of approximately $200 by a masked male, believed to be ROSARIO LOPEZ, at gunpoint. The victim gas station is located near the junction of Routes I-84 and I-684. The male was wearing a white 7 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 8 of 30 surgical-type mask covering his face, latex-type gloves, a black baseball hat, a hooded purple sweatshirt, blue jeans, and gray sneakers. The victim gas station clerk was working at the gas station cash register when the masked male pointed a silver pistol at him and, demanded money. The male demanded money, the clerk provided him $200 and the male said, “Give me everything else.” The clerk explained that all the money was already in the safe and he did not possess the combination. The clerk was kicked by the male, and ordered to lay on the floor. The male then fled the scene. 20. Southington Police responded to the scene the next day after being notified by the clerk, and Detective Adam Tillotson was assigned to the case. Detective Tillotson reviewed video surveillance from the Fleet Gas Station. Video surveillance from a nearby inn showed what appeared to be the masked male flee the gas station, enter a dark-colored sedan and drive away. C. Waterbury Robbery, March 22, 2020 21. On or about March 22, 2020, at approximately 2258 hours, a Shell Gas Station located at 883 Hamilton Avenue, Waterbury, Connecticut (approximately 7.5 miles west of the Southington Fleet Gas Station), was robbed of approximately $500 by a masked male, believed to be ROSARIO LOPEZ, at gunpoint. The victim gas station is located near an onramp to Route I84. As depicted below in Figure 4, the male was wearing a white surgical-type mask covering his face, grayish-white latex-type gloves, a black baseball hat, a hooded purple sweatshirt, blue jeans, and gray sneakers. The masked male pointed a small silver pistol at the clerk, and demanded money. The clerk opened the cash register as instructed, provided money to the male and was ordered by the male to lay on the floor. The male then fled the scene. The clerk stated that the male had a Spanish accent. 8 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 9 of 30 22. Waterbury Police responded to the scene after being notified by the clerk, and Detective Kyle Howles was assigned to the case. Detective Howles reviewed video surveillance from the Shell Gas Station. Video surveillance did not cover the exterior of the gas station, though based on the temporal proximity to the Southington robbery, it is likely that the masked male used a vehicle. 23. Video surveillance, from the gas station also showed that approximately 15 minutes before the robbery, a Hispanic woman, believed to be GONZALEZ, had entered the gas station to pay for gasoline in cash, as depicted below in Figure 3. The woman was wearing a blue long sleeve shirt, dark pants and sandals with metal accent pieces on the strap of each sandal. The woman had bright red-dyed hair. The woman appeared to be the same woman as the woman at the scene of the March 18, 2020, Vernon robbery – her height and body type appear similar, and she was wearing sandals in March and the sandals appeared the same as the previous robbery. 24. The masked male was wearing what I believe to be the same clothing as the Southington robbery, which occurred approximately one hour prior to the Waterbury robbery. Figures 3 & 4 – Waterbury Surveillance Video 9 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 10 of 30 D. Ansonia Robbery, March 23, 2020 25. On or about March 23, 2020, at approximately 0042 hours, an attempt to rob a Shell Gas Station located at 696 Main Street, Ansonia, Connecticut, was made by a masked male, believed to be ROSARIO LOPEZ, at gunpoint. The victim gas station is located near State Route 8. The victim gas station clerk was preparing food for sale when the masked male entered the building. The male was wearing a white surgical-type mask covering his face, white latex-type gloves, a hooded purple sweatshirt, a black baseball hat, blue jeans, and white and gray sneakers. The masked male pointed a small silver pistol at the clerk and stated in substance, “Give me the money, don’t call the cops, I’ll shoot you.” The clerk was unable to quickly open the cash register, and the masked male discharged the firearm and fired one round at the clerk and fled. The clerk was not struck by the projectile. 26. Ansonia Police responded to the scene after notified by the clerk, and Detective Rick Esposito was assigned to the case. Detective Esposito reviewed video surveillance from the Shell Gas Station. One latex glove was recovered outside of the gas station in the masked male’s direction of flight and, as described below, was analyzed for DNA. 27. One .25 caliber shell casing was recovered from the floor of the gas station, and was compared against a database of recovered shell casings, without any results. A fired projectile was also recovered behind the counter of the gas station. 10 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 11 of 30 Figures 5 & 6 – Ansonia Surveillance Video E. New Britain Robbery, March 26, 2020 28. On or about March 26, 2020, at approximately 2144 hours, a Citgo Gas Station located at 788 West Main Street, New Britain, Connecticut, was robbed of approximately $250 by a masked male, believed to be ROSARIO LOPEZ, at gunpoint. The victim gas station is located near an onramp to Route I-84. The male was wearing a white surgical-type mask covering his face, a tan bucket hat, black jacket, blue jeans, and white and gray sneakers. 29. Because another customer was in the store, the masked male perused store shelves and picked up several items, including a box of saran wrap and fruit snacks. After the other customer left the store, the masked male approached the counter, pointed a small silver pistol at the clerk and demanded money. The clerk opened the cash register as instructed. The male dropped the saran wrap and fruit snacks, and took money from the cash register drawer. The male then fled to a black four door sedan parked across the street, and drove away from the scene. The clerk stated that the male spoke in both English and Spanish. 30. New Britain Police responded to the scene after being notified by the clerk, and Detective Kiely was assigned to the case. Because the masked male was not wearing gloves during 11 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 12 of 30 the robbery, items that he touched, including the fruit snacks and cash register drawer, were either seized or swabbed for DNA analysis, as described below. Analysis is pending. Figure 7 – New Britain Surveillance Video F. Modus Operandi 31. Here, I believe, based on my training and experience that the sandal-wearing woman, believed to be GONZALEZ as described below, is acting as a lookout or “casing” robbery locations for the masked male, believed to be ROSARIO LOPEZ as described below. Specifically, she is depicted on video surveillance before the Vernon and Waterbury gas station robberies. In advance of many commercial robberies, based on my training and experience, co-conspirators may work as a team where one individual observes or “cases” a target location prior to the robbery. In the context of a commercial robbery, often times one co-conspirator enters the commercial location under the guise of an “everyday customer” and assesses the security weaknesses or strengths of a location (e.g. visible surveillance cameras, or too many customers or other persons present to effectuate the robbery). After assessing or “casing” the target location, the advance co-conspirator 12 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 13 of 30 then communicates with other co-conspirators, often via cellular telephone, to relay an opinion of the likelihood of success of a robbery. If a target location is deemed suitable, and in the context of gunpoint commercial robberies, one or more individuals will then enter the location, commit the robbery, and flee with ill-gained proceeds. Prior to commission of the robbery, in addition to “casing” the target location, and to expedite flight from the robbery location, communications will also occur with any co-conspirators who are acting as either “look-outs” or a “get-away-drivers,” whether that co-conspirator is the same person who “cased” the location, or another co-conspirator. Identification of ROSARIO LOPEZ and GONZALEZ: 32. Investigation of these armed Hobbs Act robberies, possession of a firearm, and other thefts is being conducted by myself and members of the FBI as well as Connecticut State Police, and the Vernon, Southington, Waterbury, Ansonia, New Britain, New Haven and Guilford Police Departments. Video surveillance and still photographs of the Hobbs Act robberies were circulated amongst the Connecticut law enforcement community. Members of these law enforcement agencies have reviewed video surveillance (or still photographs) of the robberies, as well as other larcenies, and have coordinated with each other as part of this investigation. A. The New Haven Police Contact and Body Camera Footage 33. Prior to the Hobbs Act robbery pattern, on March 14, 2020, ROSARIO LOPEZ and GONZALEZ were together when the New Haven Police Department responded to a call for breach of peace at a pet store. ROSARIO LOPEZ was the possessor and operator of a black Honda Accord bearing New Jersey temporary license plate 577942R, the Target Vehicle. ROSARIO LOPEZ purchased a snake which escaped inside the Target Vehicle after purchase. ROSARIO LOPEZ disassembled the dashboard and center console of the Target Vehicle to locate and catch the snake, and then decided that he did not want to keep the snake. The pet store clerk would not provide a 13 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 14 of 30 refund or return of the snake due to the snake having some bruising on it as a result of its escape and capture in the Target Vehicle. ROSARIO LOPEZ kicked windows and knocked over items in the store. The pet store clerk declined to pursue criminal charges, but requested ROSARIO LOPEZ to leave the store. New Haven Police instructed ROARIO LOPEZ to leave, which he did. 34. This contact with law enforcement was captured on New Haven Police body camera footage, with ROSARIO LOPEZ and GONZALEZ observed with the Target Vehicle. ROSARIO LOPEZ informed Officer Landucci that the Target Vehicle was his vehicle. Officer Landucci interacted with ROSARIO LOPEZ and GONZALEZ inside of a pet store, and in the parking lot outside of the pet store, as shown below in Figures 8 and 9: Figures 8 & 9 – New Haven Police Body Camera Footage depicting ROSARIO LOPEZ and GONZALEZ A still shot of body camera video footage depicting ROSARIO LOPEZ with the Target Vehicle is below as Figure 10. 14 Case 3.20emjs0034BsSALM Document lel Flled 04/09/20 Page 15 of 30 Figure 10 -- New Haven Police Eody Came/a Footage The unage Figure la depicts ROSARIO LOPEZ rhe Targer Vehlcle, as well as rhe remporary New Jersey heense plale 577942R. ROSARIO LOPEZ provrded address re the New Haven Pollee Depanmenl as 1523 Chapel SlreeL Apr. 104, New Haven, Connecucul. dare of as-Il9xs, and phone number As descnbed below, GONZALEZ's slepefalher and morher ldenlified GONZALEZ and her boymend "William," ROSARIO LOPEZ as Ihe mdlviduals depleled ln Figure 8. B. Review of Surveillance Video by Guilford Police 35. On Apnl l, 2020. Pollee responded ro a shopliflmg ar a Walrnan srore ar 900 Boston Posr Road. Walman seeanly reponed lhal 5148 la hems had been slolen aner a male and female larled ro pay for |lemsr and len rhe srore and premlses. The Gmllord Investigauon revealed Ihe following lnlormauon: 15 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 16 of 30 a. Video surveillance was obtained from Walmart security. The video depicted a Hispanic male, believed to be ROSARIO LOPEZ, wearing a gray jacket and gray shirt, blue Nike baseball hat, and white surgical-type mask, with a Hispanic female with red hair, believed to be GONZALEZ, in a pink top also wearing a white surgical-type mark. A civilian witness observed the two individuals get into a dark colored Honda Accord bearing New Jersey temporary license plate 577942R. b. Guilford Police Detective Sergeant Fasulo ran the New Jersey license plate through a police database. The inquiry generated a match to the above described New Haven breach of peace complaint from March 14, 2020, where ROSARIO LOPEZ was the possessor and operator of the Target Vehicle, the same vehicle observed by the Guilford civilian witness. c. Guilford Police also searched for Facebook accounts associated with ROSARIO LOPEZ and GONZALEZ. Review of GONZALEZ’s Facebook account – username “Rodriguez Goldii,” described below and confirmed by her mother and step-father to be her account – revealed a photograph from April 2, 2020, depicting ROSARIO LOPEZ wearing a blue hat with a Nike logo and gray jacket with a light gray shirt beneath and pictured with GONZALEZ who has red hair and is wearing a pink top. The clothing worn ROSARIO LOPEZ and GONZALEZ in the Facebook post is consistent with the clothing worn during the Guilford shoplifting incident, including the blue Nike hat, as depicted below in Figures 11 & 12. 16 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 17 of 30 Figures 11 & 12 – Guilford Walmart video surveillance depicting ROSARIO LOPEZ and GONZALEZ Figure 13 – April 2, 2020 GONZALEZ Facebook Post C. Review of Surveillance Video by GONZALEZ’S family members 36. The investigation revealed a New Britain Police Department Incident Report dated February 11, 2020. In that report, Miguel A. Martinez, step-father of GONZALEZ, and Sol 17 Case Document 1-1 Filed 04/09/20 Page 18 of 30 Gonzalez, mother of GONZALEZ, reported their daughter, SOLIMAR RODRIGUEZ GONZALEZ, date of birth as a missing person. Martinez and Sol Gonzalez initially stated that they last had contact with GONZALEZ on or about February 8. 2020. Martinez and Sol Gonzalez were concerned for welfare after she posted photographs on Facebook that they believed may be indicative of selfzhafm. Martinez and Sol Gonzalez believed that GONZALEZ was with her boyfriend "William," whom I believe to be ROSARIO LOPEZ either in New Haven. CT or New York City. 37. New Britain Police followed up with Martinez and Sol Gonzalez several times after taking an initial report. On or about February 17, 2020. Maninez and Sol Gonzalez provided a phone number for but calls to the number went unanswered and unreturned. On or about March 14. 2020, ROSARIO LOPEZ provided-- to the New Haven Police Department. On or about March 25, 2020. Martinez informed New Britain Police that GONZALEZ had communicated with her mother via Facebook messenger, but whereabouts were still generally unknown to Martinez and Sol Gonzalez. I conducted database research and determined that-- and-- are believed to be numbers issued by the Sprint Corporation. On or about April 6, 2020, Grand Jury subpoenas were issued to the Sprint Corporation for subscriber information, billing information, and toll records for each telephone number, though those records have not yet been returned. Open source research revealed that--, the number provided by ROSARIO LOPEZ to New Haven Police. is associated with a WhatsApp account, a messaging application, active as of April 7, 2020 with a profile picture depicting both ROSARIO LOPEZ and GONZALEZ. 38. On or about April 4, 2020. New Britain Police Detectives Christopher Keily and MaIcin spoke wiih Martinez and Sol Gonzalez at their residence in New Britain. 18 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 19 of 30 Martinez and Sol Gonzalez were shown still photographs taken from video surveillance prior to the Vernon robbery committed on March 18, 2020, Figure 14, below, and prior to the Waterbury robbery committed on March 22, 2020, Figure 15, below: Figure 14 – Vernon Robbery Surveillance Figure 15 – Waterbury Robbery Surveillance Martinez and Sol Gonzalez both identified the sandal-wearing woman depicted in Figures 14 and 15 as GONZALEZ. Martinez signed the image depicted in Figure 14, while Sol Gonzalez signed the image depicted in Figure 14. 39. Martinez and Sol Gonzalez confirmed to Detectives Keily and Ratajczak that they still believed GONZALEZ to be with her boyfriend “William,” either in New Haven, CT or New York City. Martinez provided information related to GONZALEZ’s Facebook accounts including recent Facebook Messenger messages from GONZALEZ (using user name: “Rodriguez Goldii”) to Martinez requesting masks and gloves, purportedly due to the COVID-19 outbreak – though 19 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 20 of 30 masks and gloves were used during most of the robberies, as described above. This is the same Facebook account reviewed by Guilford police which revealed a photograph of clothing worn by ROSARIO LOPEZ and GONZALEZ consistent with the Guilford shoplifting incident. 40. On or about April 7, 2020, Grand Jury subpoenas were issued to Facebook for account information related to GONZALEZ’S accounts (one account bearing the name “Goldii Rodriguez” and one bearing the name “Solimar Rodriguez”), though those records have not yet been returned. Review of GONZALEZ’S Facebook accounts revealed photographs of GONZALEZ with “William.” As described below, based on photographs in state DMV and criminal databases, I believe “William” to be ROSARIO LOPEZ. Figure 16 – Facebook Photograph of GONZALEZ and “William” 41. On or about April 7, 2020, New Britain Police Detectives Christopher Keily and Marcin Ratajczak again spoke with Martinez and Sol Gonzalez at their residence in New Britain. Martinez and Sol Gonzalez were shown two still photographs of video surveillance from the March 26, 2020, New Britain gas station robbery, including Figure 7 above. Martinez and Sol Gonzalez 20 Case Document 1-1 Filed 04/09/20 Page 21 of 30 stated that the mnle in the looked similar to ROSARIO LOPEZ, who they know as "William becnuse he has a skinny Pace and nose. Martinez stated that he was "pretty sure" that the male depicted in the New Britain surveillance was "William," ROSARIOVLOPEZ. 42. Martinez Sol Gonznlez nlso identitied still photographs taken from the body camern footage from the 14, 2020 New Haven Police contact, including Figure 8 nbove. During this as described above, ROSARIO LOPEZ provided his nnme and date of birth to New Haven Police. Mnrtinez Sol Gonzalez identitied the individuals depicted in the body camern tootnge ns "William" and GONZALEZ. Mnrtinez and Sol Gonznlez informed the detectives that "Willinm" and GONZALEZ have been dating between tour and six months they have interacted with "William" on at lenst three occasions the last occnsion being npproximately two months ago. D. ROSARIO LOPEZ Database Information 43. Ihave reviewed enforcement databases and searched for intormntion related to WILLIAM ROSARIO LOPEZ date ofbinh-1985: a. Ploridn DMV datnbases revealed a driver's license for William Rosnrio Lopez, of birth-1985' social security number:_; I). New York Slale criminal dalabmes revealed that William Rosario Lopezi data of birth-11985, socinl security Angel Willie Mendez, of birth-11983), was convicted in 2006 of Attempted Murder and Criminal Possession of Weapon. I believe both of these convictions to be felonies, as records show that ROSARIO LOPEZ was sentenced in 2005 to five years prison for these convictions. 21 Case Document 1-1 Filed 04/09/20 Page 22 of 30 c. Pueno Rico criminal databases revealed that William Rosario Lopez. data of birth -1985. social security number:_ was arrested for imponation and unlawful possession of a fireaIm in 2004. and aggravated kidnapping, aggravated assault with a fireaxm. unlawful possession of a firearm. threatening a witness. and aggravated robbery in 2005. with convictions for all charges in 2010. d. Connecticut criminal databases revealed that William Rosario, date of birth -1985, social security number: was arrested in 2005 for Criminal Impersonation. 44. I compared photographs of ROSARIO LOPEZ from these databases with photographs from Eacebook account and believe. based on similarities of physical characteristics that "William" is ROSARIO LOPEZ. E. Review of video Surveillance by the Atrmut 45. Based upon my review of video surveillance from the five Hobbs Act Robberies. as well as video surveillance from the New Haven breach of peace incident and Guilford shoplifting incident. I believe ROSARIO LOPEZ to be the masked male who committed the Hobbs Act robberies described above. I also believe GONZALEZ to be the sandalrwenring woman depicted just prior to the Vernon and Waterbury robberies (and based on temporal proximity. I believe her to have been present at the Southington robbery) who I believe was "casing" the locations. My beliefis based on the following: a. In each of the tive robberies, the masked male uses the same small silver pistol. b. Prior to the Vernon robbery on March 16, GONZALEZ entered the gas station wearing a purple hooded sweatshirt. stepfather and mother 22 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 23 of 30 identified her as the woman in the Vernon video (see Figure 14). The masked male, who I believe to be ROSARIO LOPEZ, then committed the Vernon robbery wearing what I believe is the same purple sweatshirt. This same purple sweatshirt was then also worn during the Southington and Waterbury robberies (see Figure 4) on March 22. GONZALEZ also entered the Waterbury gas station just prior to the Waterbury robbery on March 22, and GONZALEZ’S step-father and mother identified her as the woman in the Waterbury surveillance (see Figure 15). c. Prior to the Vernon robbery on March 18, GONZALEZ fueled a black Honda Accord which appeared to have a temporary license plate affixed to the front windshield. ROSARIO LOPEZ and GONZALEZ interacted with New Haven Police on March 14, while in possession of the Target Vehicle, a black Honda Accord with a temporary New Jersey license plate. GONZALEZ’S step-father and mother identified her as the woman in the New Haven body camera footage, and the male as her boyfriend “William.” ROSARIO LOPEZ identified himself during that incident to New Haven Police. After the New Britain robbery on March 26, the clerk observed the masked male flee in a dark four door sedan. d. During the Guilford shoplift on April 1 a masked male who I believe to be ROSARIO LOPEZ is depicted with GONZALEZ, who has distinct red hair. Both are wearing what I believe to be the same clothing depicted in an April 2, 2020 post to GONZALEZ’s Facebook account: ROSARIO LOPEZ is wearing a blue Nike hat, gray jacket with a light gray shirt beneath, and GONZALEZ is 23 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 24 of 30 wearing a pink top with distinct red hair. ROSARIO LOPEZ and GONZALEZ were also in possession of the Target Vehicle. e. During each robbery, ROSARIO LOPEZ was masked, though in the New Britain robbery his mask is lowered (see Figure 7). In each robbery except for the New Britain robbery, he was wearing gloves. GONZALEZ had sent a message via Facebook messenger asking her father for masks and gloves. During the Guilford shoplift, ROSARIO LOPEZ and GONZALEZ were wearing white surgical-type masks, consistent with those used during the robberies (except the Vernon robbery, which was a black mask). f. According to ROSARIO LOPEZ’s criminal history data, he is 5’7” and 140 pounds which is consistent with the masked individual that committed the robberies. 46. Based upon my review of video surveillance from the five Hobbs Act Robberies, compared to the New Haven Police body camera video and Guilford surveillance video, belief that ROSARIO LOPEZ and GONZALEZ are travelling together and dating, review of GONZALEZ’s social media, confirmation of the identity of ROSARIO LOPEZ and GONZALEZ in certain photographs by GONZALEZ’s family as described above, GONZALEZ’s presence on video prior to at least two of the robberies, use of the Target Vehicle, consistent modus operandi and firearm used by the masked male, and ROSARIO LOPEZ’s consistent physical characteristics to the masked male, I believe ROSARIO LOPEZ and GONZALEZ to be the individuals who committed the above described Hobbs Act robberies. 24 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 25 of 30 Identification of Vehicle 47. As described above, it is believed that ROSARIO LOPEZ and GONZALEZ traveled to and from each robbery in a dark sedan, believed to be Honda Accord: a. Prior to the Vernon robbery on March 18, 2020, video surveillance from the victim gas station shows GONZALEZ pumping gas into a dark Honda Accord. The Honda logo is visible affixed to the front of the vehicle, and based on my training and experience and my familiarity with Honda Accords, a popular and common passenger vehicle, I believe the model of the Honda to be that of an Accord. Based on review of the video surveillance, I believe that the Honda Accord has a temporary license plate affixed to its front windshield, though the issuing state and license plate number are not visible. After the Vernon robbery, surveillance from a nearby Dunkin Donuts showed what appeared to be the masked male flee the gas station and enter a dark-colored sedan, and drive away from the scene. b. After the Southington robbery on March 22, 2020, video surveillance from a nearby inn showed what appeared to be the masked male flee the gas station, enter a dark-colored sedan and drive away. c. Prior to the Waterbury robbery on March 22, 2020, video surveillance from inside the victim gas station shows GONZALEZ paying for gasoline, though the gas station did not have exterior video surveillance depicting a vehicle. d. After the New Britain robbery on March 26, 2020, the male fled to a black fourdoor sedan parked across the street from the victim gas station, and drove away from the scene. 25 Case Document 1-1 Filed 04/09/20 Page 26 of 30 e. Each robbery location was located near an interstate or state route as described above. which I believe was designed to facilitate flight by motor vehicle. 48. As part of this investigation, I also reviewed whether ROSARIO LOPEZ and GONZALEZ had recent contacts with law enforcement. This search revealed: a. On February 22, 2020, ROSARIO LOPEZ and GONZALEZ were together citied by the New Haven Police Department for shoplifting at a Walmart store. b. On March 14. 2020, as described above ROSARIO LOPEZ and GONZALEZ were together and the New Haven Police Department responded to a call for breach of peace at a pet store. During this contact with law enforcement, which was captured on body camera footage ROSARIO LOPEZ was observed in possession of a black Honda Accord bearing New Jersey temporary license plate 577942R. the Target Vehicle as shown in Figure 10 above. c. On April 1. 2020 as described above two individuals, who based upon review of video surveillance I believe to be ROSARIO LOPEZ and GONZALEZ shoplifted from a Walmart in Guilford, CT. though they did not have an interaction with law enforcement 49. On April 7. 2020, as part of this investigation members of the New Haven Police Department the Target Vehicle drive into a rear parking lot of-- in New Haven. This address was the same address provided by ROSARIO LOPEZ to New Haven police on March 14, 2020. 50. I reviewed data from the New Jersey DMV which revealed that a 2015 black Honda Accord Lx is registered to a William Rosario Lopez Garcia. -- Bronx, New York. 26 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 27 of 30 51. Based on the above facts, there is probable cause to believe that the items described in Attachments A of the warrant to search the Target Vehicle (the Target Vehicle Warrant) would identify evidence of the Hobbs Act robberies, possession of a firearm, contraband, fruits of the Hobbs Act robberies, and illegally possessed items, and property designed for use, intended for use, or used in committing the Hobbs Act robberies. I believe the Target Vehicle itself to be an instrumentality of the Hobbs Act robberies, and a search of the Target Vehicle would be reasonably likely to reveal instrumentalities of the Hobbs Act robberies, including the silver pistol and ammunition, surgical-type masks and latex gloves, clothing worn during the commission of the Hobbs Act robberies, and proceeds of the robberies. DNA Evidence: 52. I know, based on my training and experience, that individuals can leave traces of DNA on items that they touch, such as firearms or parts of a vehicle such as a door handle. A qualified laboratory can analyze these DNA traces to determine a DNA profile for the person or persons who touched the object. Additionally, using a sample of DNA from a person, a laboratory can determine a person’s DNA profile. The two profiles can then be compared to see if they are similar. 53. After the Ansonia robbery on March 23, 2020, members of the Ansonia Police Department recovered one latex glove outside on the ground within an area believed to have been discarded on the path of flight of the masked male. On March 24, 2020, Ansonia Police submitted the latex glove to the State of Connecticut Department of Emergency Services and Public Protection, Division of Scientific Services (“DOE”) for DNA Analysis. On April 2, 2020 that laboratory completed an initial DNA report on the latex glove tested for the presence of DNA and 27 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 28 of 30 determined that a male DNA profile (and mixtures) was obtained from the latex glove. The profile is suitable for comparison to other samples. DOE has requested a known sample from any suspect for comparison to evidentiary results. 54. The laboratory queried the Combined DNA Index System (“CODIS”) for the State of Connecticut and did not find a match within the system. The profile was too complex to query against the National CODIS system. 55. After the New Britain robbery on March 26, 2020, the New Britain Police Department recovered two bags of fruit snacks that were touched and held by the masked male, believed to be ROSARIO LOPEZ, who was not gloved during the robbery. The New Britain Police Department also took swabs of the cash register draw, which was touched by the gloveless male. These items were sent to the State of Connecticut DOE for DNA Analysis. Analysis is pending. 56. The DNA samples of DOE sought herein will be collected by buccal swabbing. This method involves taking a sterile swab (similar to a Q-Tip) and gently scrubbing the inside right cheek, then the inside left cheek, for approximately five to ten seconds. Two samples are requested in the event that one of the samples becomes contaminated or otherwise cannot be tested. The seized samples will be submitted to a forensic laboratory and will be subject to examination, testing, and analysis, and will be compared to the DNA material obtained from the physical evidence seized during this investigation. 57. In the event that the defendant is non-compliant, and due to the potential dangers to both the executing officers and defendant associated with executing a validly-issued search warrant of this type on a non-compliant subject, I would request that the Court authorize law enforcement officers, to use reasonable measures necessary to restrain the defendant for the sole purpose of obtaining the DNA sample. See In Re Terrorist Bombings of U.S. Embassies in East 28 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 29 of 30 Africa, 552 F.3d 157, 171 n.8 (2d Cir. 2008) (“The subject of a validly issued search warrant has no right to resist the search”) (citing cases including Bumper v. North Carolina, 391 U.S. 543, 550 (1968)); see also United States v. Bullock, 71 F.3d 171, 176 (5th Cir. 1965) (“The use of force in taking the [hair and blood] samples was caused by Bullock’s refusal to comply with a lawful warrant and was reasonable.”). 58. Based on the above facts, there is probable cause to believe, and I do believe, that obtaining buccal swab samples for DNA analysis from WILLIAM ROSARIO LOPEZ, date of birth 10/20/1985, would identify evidence of the Hobbs Act robberies. AUTHORIZATION REQUEST 26. As set forth above, there is probable cause to believe and I do believe that WILLIAM ROSARIO LOPEZ and SOLIMAR RODRIGUEZ GONZALEZ have committed the Hobbs Act robberies set forth herein and therefore, respectfully request the issuance of the specified arrest warrants by criminal complaint. 27. Based on the foregoing, I further request that the Court issue the proposed search warrants, a warrant to seize and search the DNA of WILLIAM ROSARIO LOPEZ, and a warrant to seize and search the Target Vehicle, pursuant to Federal Rule of Criminal Procedure 41. 28. Issuance of this application, including the affidavit and search warrant, is requested based on information communicated by telephone or other reliable electronic means pursuant to Fed. R. Crim. P. 4(d) and Fed. R. Crim. P. 4.1, based on the ongoing public health crisis related to the COVID-19 pandemic, and state of emergency declared by the Governor of the State of Connecticut. 29 Case 3:20-mj-00348-SALM Document 1-1 Filed 04/09/20 Page 30 of 30 Sarah A. L. Merriam, U.S.M.J. Digitally signed by Sarah A. L. Merriam, U.S.M.J. Date: 2020.04.09 11:19:56 -04'00'