Affidavit in Support of Warrant Your affiant, Special Agent Raul Perez, has been a sworn police officer for over twenty-two years. Your affiant has conducted hundreds of criminal investigations and is currently assigned to the Florida Department of Law Enforcement Public Integrity Squad. Your affiant was assigned to a criminal investigation of Insurance Fraud and Solicitation to Commit Murder involving the Mayor of the City of Hialeah Gardens, Gilda Cabrera Oliveros. As a result of this investigation, your affiant has actual, relayed or constructive knowledge of the following: On August 26, 1999, September 28, 1999, and December 2, 1999, Robert Godwin, pursuant to a subpoena, responded to the Miami-Dade County State Attorney s Office and was interviewed by your affiant, FDLE Special Agent Gale Sampson and Assistant State Attorney Joseph M. Centorino. Godwin stated that he was hired as an Assistant to the City Council of Hialeah Gardens by Mayor Gilda Cabrera Oliveros in February, 1996. In his job he acted as liaison between the Council and the Mayor, but was generally under the Mayor s direction. Godwin further stated that he was fired by Oliveros in May, 1999. Godwin stated that during late 1996, and early 1997, while he was employed by the City of Hialeah Gardens, he was approached by Mayor Oliveros and was solicited to kill her husband, Angel Serafin Ramos aka Angel Ramos Corzo. Godwin stated that Oliveros reiterated this proposition several times. At one point she suggested that she would provide a gun to Godwin, or that she would take Ramos s gun and give it to Godwin, then she would give Ramos sleeping pills or liquor in order to facilitate the murder. Oliveros suggested that Godwin could then make the murder of Ramos look like it had occurred during a robbery. Godwin said he declined to kill Ramos. Godwin stated that Oliveros then solicited another city employee, Rafael Reyes, to kill her husband during March or April of 1997. Godwin added that Oliveros spoke to both Reyes and to him in her City Hall office regarding the murder of her husband during that time, and that she offered them a share in the proceeds of an insurance policy on her husband s life in exchange for their killing him. Godwin said that both he and Reyes declined Oliveros s proposal. Godwin stated that later during 1997 he told Rosa Levy, secretary to Mayor Oliveros, about the Mayor s request that he kill Ramos. On September 22, 1999, Rafael Reyes, pursuant to a subpoena, responded to the Miami-Dade County State Attorney s Office and gave a sworn statement to Assistant State Attorney Howard Rosen, your affiant, and Special Agent Gale Sampson. Reyes stated that he is an employee of the City of Hialeah Gardens, currently out on worker s compensation.
Reyes stated that sometime between the early and middle part of 1997 he was summoned to City Hall to speak with Mayor Oliveros. Reyes stated that Oliveros, in the presence of Robert Godwin, indicated that she had a $40,000.00 insurance policy on her husband and would give them (Reyes and Godwin) a share of the proceeds from the insurance monies for killing him. Reyes stated that Oliveros told him to think about it (the murder of her husband) and get back with her quickly. Reyes stated that within two weeks of the initial solicitation Oliveros again approached him. Reyes stated that Oliveros asked him if he had thought about what they had talked about (the solicitation to murder her husband), and that Reyes replied that he had not. Reyes stated that Oliveros went on to say that Ramos was driving her crazy and that this was the only way she could get rid of him. Reyes stated that Oliveros reiterated her plan to have her husband killed. On October 25, 1999, Rosa Levy, former secretary to Mayor Gilda Cabrera Oliveros, gave a sworn statement under subpoena to ASA Centorino, Agent Gale Sampson and your affiant. During the statement, Levy recalled that she had been told by Godwin during 1997 that Oliveros had asked him to kill her husband. Levy said that Godwin was not joking when he told her about the solicitation. On November 23, 1999, and December 2, 1999, your affiant and ASA Centorino met with Ricardo Vasquez, former City of Hialeah Gardens Parks Director. On the second occasion, Special Agent Gale Sampson was present, and Vasquez gave a sworn statement. Vasquez informed that while he was employed by the city, and shortly before Mayor Oliveros s divorce in 1997 from Angel Ramos, Mayor Oliveros had a conversation with him in which she discussed her desire to have her husband killed. According to Vasquez, he was known by Oliveros to have the prescription drugs Doral, Xanax and Prozac, which had been lawfully prescribed for Vasquez. He said that on previous occasions, at the request of Oliveros, he had given a few pills to Ramos to be used as sleeping pills. Vasquez stated that Oliveros asked him on this occasion to provide her with a mixture of said drugs, and said that the drugs would be used to kill her husband. Vasquez said he did not provide any drugs to Oliveros for this purpose. On September 28, 1999, Sara Gonzalez Lopez, an AIG Life Insurance agent, responded pursuant to subpoena to the Miami-Dade County State Attorney s Office and gave a sworn statement to ASA Centorino, in the presence of your affiant and Special Agent Gale Sampson. Sara Lopez said she met with Gilda Cabrera Oliveros in March, 1997 concerning a life insurance policy. Oliveros obtained a life insurance policy (# ) listing her (then) husband, Angel Serafin Ramos, as the insured party. The policy was in the amount of forty-five thousand dollars ($45,000.00) and listed Oliveros as the primary beneficiary and Ramos s son, Serafin Ramos, as contingent beneficiary. Lopez stated that prior to obtaining the policy Oliveros had inquired of Lopez as to the maximum amount of coverage available on her
husband s life without a medical examination of her husband. The maximum amount of coverage without a medical examination at that time was $45,000.00, and Lopez said that she informed Oliveros of this fact. Lopez stated that the medical screening questions required on the application for the policy were all answered by Oliveros and the application was filled out by Lopez without Ramos being present. Lopez additionally stated that she did not witness Angel Ramos sign the application, as was required. The line requiring the signature of the proposed insured was left blank and the Life Insurance Application was left with Oliveros. Directly above the signature line on the application is the statement Any person who, knowingly and with intent to injure, defraud or deceive any insurer, files a statement of claim or an application containing any false, incomplete or misleading information is guilty of a Felony of the Third Degree. Lopez stated that Oliveros indicated that she would have her husband sign the application and return it to Lopez. Lopez stated that the application was returned to her by Oliveros bearing the purported signature of Angel Ramos Corzo, dated March 26, 1997. On April 30, 1997, Gilda Cabrera Oliveros paid $112.50 as a premium to AIG Life Insurance on policy #, and the policy went into effect at that time. Lopez stated that Oliveros canceled the policy during June, 1997, and that Oliveros had informed Lopez at that time that she (Oliveros) was in the process of obtaining a divorce. Records at the Miami-Dade County Clerk of Courts show that Oliveros filed for divorce against Angel Ramos on May 19,1997. On September 30, 1999, Angel Ramos, pursuant to a subpoena, responded to the Miami- Dade County State Attorney s Office and gave a sworn statement to Assistant State Attorney Joseph M. Centorino in the presence of your affiant and Special Agent Gale Sampson. Ramos stated that he had some knowledge of an insurance policy taken out by his former wife, Gilda Cabrera Oliveros, but was told by her that his son had been named the beneficiary. Ramos stated that he never answered any medical questions relating to the insurance policy and that he never signed the insurance policy. Ramos provided handwriting samples for comparisons. On November 12, 1999, Angel Ramos provided another sworn statement to Assistant State Attorney Centorino, Special Agent Gale Sampson and Special Agent Isabel Hernandez. During that statement, Ramos gave information indicating that the insurance policy application contained false statements and omissions concerning his medical history. These false statements included a denial that he smoked or used tobacco products, when in fact Angel Ramos does smoke and did so at the time that the policy was in effect; failure to disclose that he had had an operation for a hernia; failure to disclose that his mother had died of cancer; and a denial of any driver license restriction or revocation when there had been such a restriction or revocation due to his
prior arrest for Driving While Intoxicated. Ramos stated that he believed these facts should have been known to Oliveros. On or about October 18, 1999, FDLE Criminalist/Handwriting expert. Bruce DeKraker, examined the copies of the insurance policy (AIG policy # ) application bearing the purported signature of Angel Ramos Corzo and compared the signature to standard handwriting exemplars previously provided by Gilda Cabrera Oliveros, pursuant to subpoena, and handwriting exemplars of Angel Ramos. He concluded that signatures of Angel Ramos Corzo on said documents were probably written by Gilda Cabrera Oliveros. On October 5, 1999, Rafael Reyes, acting pursuant to the direction of law enforcement agents, including your affiant, recorded a conversation with Gilda Cabrera Oliveros in the Mayor s Office at Hialeah Gardens City Hall. The conversation occurred in Spanish. An English transcription of the conversation is attached hereto as Exhibit 1. During the conversation, Reyes stated that he had been interviewed by investigators regarding an insurance policy that Angel had. Rafael referred to Robert Godwin, saying, I don t know what Roberto could have said, because you know him, but you know we talked that among the three of us, and nobody else was present. In response to the foregoing statement and without any mention by Reyes of a plot to kill anyone, Oliveros referred to Godwin s having supposedly joked about killing a woman named Margarita, Godwin s wife. She said, It was all kidding we do that among friends... Reyes said later, And suppose Roberto said something and, they want to try something with me. Oliveros replied, That would be Roberto s word against yours and mine... Reyes said later to Oliveros, What if Roberto said something about the gun? You remember about the gun. Oliveros replied, But that is his word, and went on to say that she never did anything, and that she has two guns, one of which is not registered. Reyes said, What if he says everything we had talked about the car, and the police and about getting the gun. Oliveros replied, I don t know. Referring to Godwin later, Reyes said, I don t know at this point if he has spoken to any other person about this and then I will end up being the liar. Oliveros responded, did you talk to anyone about this besides him? You did not say anything, so it is only his word. If he talked to anyone about this, then it is his problem, because he did the talking not you or me. At other times during the conversation, Oliveros suggested that Godwin was a liar, and a thief, and that she could prove him to be so. She also claimed that she was aware that her exhusband, Angel Ramos, had spoken to investigators about the policy, and that he had told them that the signature on the policy was his. In fact, Ramos, while acknowledging to your affiant that he was aware of an insurance policy taken out by Oliveros, denied ever seeing or signing the policy.
Oliveros also discussed with Reyes that the policy was only for $50,000.00 and would help her care for Ramos s son if he were killed. She said that it would be worth it to have someone killed for $500,000.00, but not for $50,000.00. Oliveros also told Reyes that she would provide him with an attorney in the event he were recalled by investigators, and that the attorney could help him to avoid answering questions or incriminating himself. On October 19, 1999, again acting at the direction of law enforcement agents, Rafael Reyes recorded a telephone conversation with Gilda Cabrera Oliveros. An English transcription of the conversation is attached hereto as Exhibit 2. During the conversation, they again discussed that Reyes, if he should return to give a statement to investigators, would be represented by an attorney provided by the City of Hialeah Gardens. Reyes said, With regards to the problem, when they ask me to describe how everything was, I am going to lie to them and say that it was all kidding. Oliveros replied, You tell them that it was all kidding and besides remember this, they can t say anything to you about what you said the other day because you are under medication. At no time during either recorded conversation with Reyes did Oliveros express that she was unaware of what the subject matter of the conversation was or deny that the previous conversations with Reyes and Godwin had taken place. Oliveros appeared to coach Reyes in the presentation of the defense that she had been kidding. Both conversations were spoken in Spanish. Your affiant, who is fluent in Spanish, has reviewed the tapes of both conversations and it is his belief that the conversations corroborate the information previously provided by Godwin and Reyes that Oliveros had solicited them to murder Angel Ramos. Based upon the foregoing, there is probable cause to believe that Gilda Cabrera Oliveros has committed the crimes of: Solicitation to Commit First Degree Murder in violation of F.S. 777.04 and F.S. 782.04 and Insurance Fraud in violation of F.S. 817.234 Affiant/Raul E. Perez, Special Agent FDLE Sworn to and subscribed before me, this day of, 1999. Circuit/County Judge Eleventh Judicial Circuit of Florida