ARREST WARRANT FORM - 11 TH JUDICIAL CIRCUIT - MIAMI-DADE COUNTY, FLORIDA

WARRANT TYPE: AW CASE TYPE: F

AWPS # Refile indicator: YES

Court case number: Division:

TO ALL AND SINGULAR SHERIFFS OF THE STATE OF FLORIDA, GREETINGS:

YOU ARE HEREBY COMMANDED TO IMMEDIATELY ARREST THE DEFENDANT AND BRING HIM OR HER BEFORE ME, A JUDGE
IN THE ELEVENTH JUDICIAL CIRCUIT OF FLORIDA. TO BE DEALT WITH ACCORDING TO LAW.

DEFENDANT'S NAME: (last) Stefano (first Ana middle Lilia

STR/APT/CITY/ST/ZIP: 7609 NW 69 Ave, Medle , Fl, 33166
DOB: 03/02/1964 RACE: White SEX: F HEIGHT: 5 1 3 WEIGHT: HAIR: Dark EYES: Brn
red/ Brown
SID H: FBI H:
use
scars, marks, tattoos FCIC/NCIC abbreviations: : IDS
driver's license # ST: FL

veh ta {f: state: make: model: ear: color:

comments:

BEFORE ME PERSONALLY CAME Eric Rodriguez and Karl Ross (AFFIANTS), WHO, BEING DULY SWORN, STATES
THAT THE DEFENDANT Ana L. Stefano, DID COMMIT THE ACTS STATED IN THE ATTACHED STATEMENT OF FACTS,
BASED UPON THIS SWORN STATEMENT OF FACTS, I FIND PROBABLE CAUSE THAT Ana L.Stefano DID COMMIT
THE CRIMES OF:
CHARGE # INTENT BOND
CHP/SEC/SUBS TYPE/DEGREE COUNTS AMOUNT CHARGE NAME/DESCRIPTION
817.034 4 a l 1st Or Scheme to Defraud over 50,000

812.014 2 b l 2nd Grand Theft Second De ree

IN MIAMI-DADE COUNTY, FLORIDA, CONTRARY TO FLORIDA STATUTES AND AGAINST THE PEACE AND DIGNITY OF THE
STATE OF FLORIDA.

POLICE CASE#: 1M 1-2AGENCY 056 AGENCY NAME: State Attorney's Office

ASA'S APPROVAL INITIAL UNIT#: ECU MIN/MAN: Not Charged/N0t Filed Charge Filed
EXTRADITE INFORMATION
l. Felony - Full extradition [2 B. Misdemeanor - Limited extradition
2. Felony - Limited extradition C. Misdemeanor - Extradition - Surrounding states only
3. Felony - Extradition - Surrounding states only D. Misdemeanor - No extradition
4. Felony - No extradition [2 E. Misdemeanor - Pending extradition
C] A. Misdemeanor - Full extradition

SWORN TO BY AFFIANTS: Eric Rodriguez & Karl Ross Court ID #: 01-41524 & N/A Date: + loc
code if Miami-Dade
 E COUNTY,
BOND AMOUNT
FIRST APPEARANCE JUDGE MAY NOT MODIFY CONDITION OF RELEASE PER RULE 3.13
(judge's initials)

TO ANSWER UNTO THE STATE OF FLORIDA ON AN INFORMATION OR INDICTMENT FILED AGAINST HIM OR HER BY
THE STATE ATTORNEY FOR THE CHARGE(S) OF:
C] UPON ORDER OF A JUDGE IN THE I JUDICIAL CIRCUIT OF FLORIDA FOR FAILURE TO APPEAR IN COURT TO ANSWER THE
PENDING CHARGE(S) OF:
CHP/SEC/SUBS INTENT/TYPE/DEGRE COUNTS VERSION CHARGE NAME/descri tion
E

HARVEY RUVIN, CLERK OF THE COURT BY: (Deputy Clerk)(Date)

IN THE CIRCUIT COURT OF THE ELEVENTHJUDICIAL CIRCUIT

IN AND FOR MIAMI-DADE COUNTY, FLORIDA

BEFORE ME, Judge of the Eleventh

Judicial Circuit Courtin nd for Mia i-Dade Co ty lorida, per nally came Police Det. Eric
Rodriguez of the Miami-Dade County State Attorney's Multi-Agency Public Corruption
Unit Task Force, and Investigator Karl Ross of the Miami-Dade Commission on Ethics and
Public Trust, after being duly sworn, deposes and say they have probable causc for the arrest
of:

Ana Lilia Stef" Stefano

SSN:
DOB: 03/02/1964

Charges: One (1) count of Organized Scheme to Defraud over $50,000 — F.S. 817.034(4)(a)1
One (1) count of Grand Theft over $20,000 - F.S.
1. Your affiant, Det. Eric Rodriguez, has served as a Police Officer with the City

of Miami for more than seven (7) years. Since 2017 he has worked as an investigator with

the police Internal Affairs Section, charged with overseeing the integrity of sworn officers.

Since 2019, he has worked on assignment with the Miami-Dade State Attorney's Multi-

Agency Public Corruption Unit Task Force (hereinafter "PCU Task Force"), and he has

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 worked on multiple cases involving official misconduct, financial fraud, and violations of

campaign finance law.

Your co-affiant, Karl Ross, has worked as an Investigator and Forensic

Accountant with the Miami-Dade Commission on Ethics and Public Trust (hereinafter "COE") for

sixteen (16) years and has completed more than three hundred (300) investigations involving

elected officials, public employees, political campaigns. These have included cases implicating

both civil and criminal offenses resulting in the conviction of public officials, private contractors,

and others. He holds a Master of Accounting degree and is a Certified Fraud Examiner.

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2. This affidavit is provided for the limited purpose of establishing probable cause

in support of an arrest warrant for ANA LILIA STEFANO (hereinafter "STEFANO"). Your

affiants have not included all details of this investigation, but rather have set forth only those

facts that are necessary to establish probable cause. The information in this affidavit is based

upon your affiants' personal knowledge as well as information obtained from interviews with

numerous witnesses, victims, and from a review of documentation related to the

investigation. These include public records, as well as private business and financial records

obtained pursuant to state subpoena and from witnesses and entities cooperating with this

investigation.

3. At times material to this investigation, STEFANO was an elected official with

the Town of Medley or a candidate for elected office in the Town of Medley. Located in the

northwest quadrant of Miami-Dade County, Medley is home to approximately 1,100

residents and occupies 6 square miles. The town has a mayor-council form of government

consisting of a Mayor, Vice Mayor and three (3) elected Councilpersons. STEFANO was

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first elected to the Town Council in 2018 and ran for Mayor unsuccessfully in 2016 and

2020. She was last elected to the position of Councilwoman in a March 2021 Special

Election.

4. At times material to this investigation, STEFANO has served as the Executive

Director of the Santana Moss Foundation (hereinafter "the Foundation"). The Foundation is a

Florida nonprofit corporation and was founded in 2001 by former professional football

player Santana T. Moss. A Miami native, Moss played collegiately for the University of

Miami and remains as an officer in the corporation but lives in the Washington, D.C., area.

He is not involved in overseeing the Foundation's day-to-day affairs. The Foundation is run

by STEFANO and STEFANO has maintained exclusive control over all bank accounts,

donations, vehicles,

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facilities, and other assets of the Foundation and is responsible for meeting

governmental reporting requirements. Until recently, the Foundation was a federally

recognized 501(c)(3) charitable organization but had its status as such revoked earlier this

year.

5. Feeding South Florida (hereinafter "FSF") is a nonprofit food bank serving

needy residents of South Florida and is part of the Feeding America Network of food banks.

It partners with major retailers such as Walmart, Publix, Costco, Aldi and Target, as well as

hundreds of local churches and charitable organizations to distribute donated food items.

FSF requires that charitable organizations such as the Foundation sign Partner Agency

Agreements with FSF to ensure that donated food is handled in a safe and appropriate

manner. These agreements contain multiple provisions prohibiting the sale of donated food

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for any reason. The agreements state that they must be signed by "the highest authority in the

organization."

6. Your affiants obtained copies of recent Partner Agency Agreements with FSF

signed by STEFANO on behalf of the Foundation. The agreements state in Section 3, titled

Distribution without Charge, that: "The [Foundation] will distribute all products free of

charge (monetary, volunteer hours, services or otherwise)." Section 4, titled Use of Donated

Products, states that: "The [Foundation] will not sell or use any donated products in

exchange for money, property (real or personal) or other services, including but not limited

to the use of donated products for fundraising programs and events." Section 5, titled

Bartering, Selling, Fundraising, states that: "The [Foundation] will not sell, trade, barter or

give any products in exchange for donations or compensation of any kind, under any

circumstances."

7. Your affiants further obtained records from FSF reflecting that since January

2018, the Foundation has obtained donated food shipments on approximately a weekly basis, and

that these shipments totaled more than 1.4 million pounds worth of donated food items.

Based on a cost estimate provided by an accounting firm retained by the Feeding America

network, the estimated value of all food items received by the Foundation exceeds $2

million.

8. The investigation originated in June 2020 when a caller to the COE "ethics

hotline" alleged that Stefano was engaged in a scheme to sell donated food items obtained

through the Foundation from local food banks. The caller stated that he was a former

associate of STEFANO's, having served as a volunteer assisting with the Foundation's food

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distribution program. He stated he also served as a volunteer on STEFANO's previous

political campaigns dating back to 2016 when she ran for Mayor and 2018 when she ran for

a Council seat. He claimed to have personal knowledge and electronic records supporting his

allegation that STEFANO was selling donated food items to local religious organizations and

healthcare clinics in Medley and the surrounding towns of Hialeah and Sweetwater and

elsewhere.

9. The informant, later identified as JAVIER VEGA (hereinafter "VEGA"),

provided the names of several paying "customers" involved in this alleged scheme, along

with electronic records such as text messages and computer screen shots he exchanged with

STEFANO and other parties to the food-related transactions, including the ones shown below:

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Your affiants further extracted and recovered all text messages between VEGA and

STEFANO from VEGA's phone and verified the authenticity of the images shown above.

Other messages reference transactions involving donated food, such as one dated April 3,

2019, in which VEGA advised STEFANO that he has obtained email addresses "for all the

pastors so u can send the PayPal invoices." In a reply, STEFANO answers: email me the list

and I will do it tonite (sic)." In another email from STEFANO to VEGA, STEFANO

indicated that she reviewed the payment history of one of the pastors and noted: "I just

checked he paid $300 for last month, he needs to pay this month before Friday." The pastor

in question was identified as "ronny.'

10. VEGA alleged that customers were instructed to obfuscate the purpose of the

payments to the Foundation by adding "maintenance" or "program maintenance" or other

generic descriptions unrelated to the actual purpose of the payments — the purchase of food.

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In many instances, those issuing the checks to the Foundation wrote "food" in the memo line,

but

your affiants found that oftentimes, as shown above, the word food was scratched out or

written over with "maintenance" or other terms intended to conceal the purpose of the

payments.

11. After preliminary inquiry, COE referred this matter to the Miami-Dade
County

State Attorney's Office, leading to a joint inquiry with the Economic Crimes Unit

(hereinafter "ECU") with the assistance of investigators assigned to the PCI-J Task Force.

ECU then issued subpoenas to Wells Fargo Bank for records relating to the Foundation and

personal accounts held by STEFANO, individually or jointly with family members. ECU

further issued a subpoena for relevant business records from PayPal for an account linked to

the Foundation. ECU further issued subpoenas for financial records held by private entities

connected to the scheme.

12. Your affiants reviewed current records on file with the State of Florida

Division of Corporations reflecting that STEFANO serves as the Director and Registered

Agent of the Foundation, while her mother, Nancy Stefano, holds the title of President of the

Foundation. As noted previously, Santana T. Moss was listed as Secretary of the Foundation.

It should further be noted that in early 2019, STEFANO registered a "fictitious name" with

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the state Division of Corporations to create an entity known as the Lily Stefano Foundation.

The records reflect that the Lily Stefano Foundation was owned by the Santana Moss

Foundation. Your affiants learned, over the course of the investigation, that STEFANO

would use these entities interchangeably and that, in some instances, donated food obtained

through the Santana Moss Foundation as a 501(c)(3) entity would be distributed by

STEFANO and volunteers wearing T-shirts with the logo of the Lily Stefano Foundation.

This was observed in Facebook postings by Stefano, such as the one below from May 2020,

that coincided with her campaign for Medley Mayor.

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13. Your affiants further reviewed copies of available IRS Form 990 reports for

the Santana Moss Foundation intended to disclose relevant financial information. The

available reports listed STEFANO as the Treasurer for the Foundation and, in one instance,

as the "Foundation Manager." None of the available reports show that Stefano or any other

officer or employee of the Foundation received paid compensation in connection with their

duties on behalf of the Foundation. Similar reports had not been submitted for the three past

years, causing the Foundation to lose its 501(c)(3) status on or about early 2021, the

investigation found.

14. Your affiants requested and obtained copies of all available financial

disclosure forms filed by STEFANO with the Town of Medley Clerk's Office dating back to

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2017. The forms reflect that STEFANO did not report receiving any income from the

Foundation at times material to this investigation from January 2018 through the present. For

the most recent disclosure forms, STEFANO listed the Town of Medley as her sole source of

income.

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15. Your affiants obtained information from the City of Medley reflecting that

STEFANO holds a personal account with Wells Fargo ending in #6291. A subsequent review

of account records obtained with the issuance of a state subpoena indicated that for the years

2019 and 2020, STEFANO received more than $46,000 in income unrelated to her salary as

Town of Medley councilwoman. This included approximately $18,000 in ATM cash deposits

in Miami and Hialeah, as well as about $6,100 in electronic transfers into her account from

PayPal and Zelle, a payment application provided to customers of financial institutions. The

largest single deposit of outside income was a check for $20,882.35 drawn on an account for

Miccosukee

Indian Gaming located at 500 SW 177 th Avenue and dated June 25, 2019. The check states,

"Total Prizes $22,882.35" and references a $2,000 cash payout. The check was endorsed by

STEFANO on the back and included the number for her personal account.

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 16. The Miami-Dade County Conflict of Interest and Code of Ethics Ordinance

requires that elected officials such as STEFANO report all major source of personal income.

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17. Your affiants obtained and reviewed financial records obtained from Wells

Fargo pursuant to state subpoena for an account held by the Foundation and ending in #1506.

The records covered the period from January 2018 through May 2021. All checks issued on

said account were signed by STEFANO on behalf of the Foundation. Similarly, STEFANO's

signature could be found on the back of all endorsed deposit items including numerous

payments from third-party recipients of food items purchased through the Foundation.

18. A review of deposit items found in the Foundation's business account with

Wells Fargo turned up more than 60 checks from several Medley-area healthcare providers

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and at least five churches located in Medley and surrounding municipalities in the amount of

$18,700. The checks ranged from as little as $75 to as much as $1,500. Many of these checks

stated that the purpose of the payments was "food" or "food bank," but in numerous other

instances the memo line contained evidence of words being scratched out and written over

with "maintenance" or

"program maintenance" or "program administration," the records show.

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 19. A review of PayPal records linked to this account (Wells Fargo ending #1506)

found evidence of additional transactions believed to be related to the sale of donated food

items. These consisted of seven (7) payments from the pastor of a local church worth $2,100,

plus an additional payment from another local pastor in the amount of $100.

20. Financial records obtained from sources interviewed by affiants provided

further evidence of food sales by the Foundation resulting in direct payments of $4,680 to

FANNY DEL VALLE MARTNEZ, aka FANNY MARTINEZ (hereinafter "MARTINEZ).

MARTINEZ is a known associate of STEFANO and served as her campaign treasurer for

her 2020 campaign for Medley mayor. The proceeds of these transaction were not deposited

into the Foundation's account with Wells Fargo, but rather into accounts linked to

MARTINEZ. In some instances, MARTINEZ forwarded these proceeds to STEFANO via

electronic means. STEFANO has stated publicly at a Medley Council meeting this past May

3 that she intends to transfer control of the Foundation to MARTINEZ if and when it is

reinstated as a federally recognized charity. MARTINEZ advised your affiants during a visit

to her home on Sept. 14, 2021, that she was a "volunteer" with the Foundation's food

program and never accepted any payments on behalf of STEFANO or the Foundation. She

later acknowledged, during a sworn statement on Sept. 30, 2021, that she did occasionally

deposit payments intended for the Foundation into her personal account. She claimed that

she did this for safekeeping since she did not feel comfortable holding on to cash and other

monetary instruments before delivering any such payments to STEFANO, who she described

as "the owner of the Santana Moss Foundation.'

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 21. To further the purpose of the above-referenced transactions in excess of

$20,000, your affiants interviewed a number of the alleged or suspected food customers. It

should be noted that documented transactions relating to donated food includes $18,700 in

payments to the Foundation using checks as instruments, $2,200 in electronic payments to

the Foundation using PayPal as the instrument, and another $4,680 in payments to

MARTINEZ using checks and electronic means to carry out the transactions. These alone

represent $25,580 in documented payments in exchange for food provided by the Foundation

to its customers. This total does not include alleged cash payments referenced below.

22. On July 2, 2021, your affiants responded to the Gloria de Dios Church in

Hialeah, and interviewed ANA V. PEREZ (hereinafter "PEREZ"), a church administrator.

PEREZ stated that on five (5) occasions, the church made payments of $75 each to the

Foundation in exchange for donated food items. She said that her husband, the church's

pastor Eduardo Perez, made the checks out to the Foundation and would write the word

"food" in the memo line. She noted that on the copies of the checks, "food" had been

scratched out in several instances and replaced with "monthly maintenance" or "program

maintenance." She stated that this happened after the checks had been turned over to the

Foundation. PEREZ said that while she considered the payments to be "donations," she

advised that the church had never made donations to the FOUNDATION that didn't coincide

with the food transactions. PEREZ stated that the church was familiar with local food banks

and could get the food for free from these providers. She stated that the church purchased

food from the Foundation on the above-referenced occasions because it was more convenient

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to pick the food up in Medley at the Foundation's warehouse. PEREZ further advised that

many of the boxes obtained from the Foundation were similar to those offered by Feeding

South Florida and likely containing donated items from that entity.

23. On September 1, 2021, your affiants took a sworn statement from PEREZ's

husband, Pastor EDUARDO PEREZ (hereinafter PASTOR PEREZ). PASTOR PEREZ

corroborated his wife's account. He was shown copies of the five (5) checks used to make

payment. He said he filled out four of the five checks and that his wife signed the fifth

check. He said he gave the checks to a man named "Javier" when he went to pick up food

from the Foundation's warehouse, except for one of the checks. He said he gave that one to a

woman he believed to be involved in Medley politics, possibly an elected official. He could

not recall her name. He further advised he entered the word "food" in the memo lines but that

entry had been altered each time.

24. On July 2, 2021, your affiants interviewed RONNY CHICA (hereinafter

"CHICA"), who is pastor of the Cornunidad de Fe Ministries of Sweetwater. CHICA advised

that his ministry had been purchasing food from the Foundation since 2018. He stated that he

would pay between $300 and $345 a month for food, and that the food would be picked up

on Fridays at the Foundation's Medley Warehouse. He said he would make a payment to the

Foundation monthly, per his arrangement with STEFANO. He said his ministry would

sometimes make the payments using PayPal, other times using checks drawn on the

ministry's account. He said he considered the payments a "love offering," but advised that the

ministry did not make such offerings to the Foundation unless it was procuring food. He

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provided copies of checks reflecting payments to the Foundation in early 2020. Copies of the

canceled checks showed that on some occasions, CHICA would write "Food Drive/

Community" in the memo line and that in other instances these words had been written over

with "program maintenance." He said that on or about July 2020, he was advised that he

should start making out the checks directly to an associate of STEFANO's named "Fanny."

Copies of the canceled checks showed

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that at least four such payments in the amount of $345 each were made out to FANNY

MARTINEZ. He said at the time that he may also have made payments using PayPal, but he

could not provide additional details of any such transactions. Based on available records,

your affiants were able to confirm payments in the amount of $6,150 made to the Foundation

and/or MARTINEZ from the Comunidad de Fe Ministries of Sweetwater for food.

25. On July 28, 2021, your affiants conducted a sworn statement of AYMEE

MUNERO (hereinafter "MUNERO"), president of the La Esperanza Medical Center in

Medley.

She confirmed that her business and two affiliated businesses — HDH Medical Center and

Diagnostic Centers of Medley, both since closed — had been purchasing food through the

Foundation since at least early 2018. She said that her husband, Deivys Alvarez, made the

arrangements to obtain food for the clinics' customers through an arrangement with

STEFANO. Her husband was later indicted on federal healthcare fraud-related charges. She

confirmed that she or her husband would make payments of $300 a month to STEFANO in

exchange for about 100 boxes a month of food items. She said boxes of food would be

distributed to customers for free, and she provided photographs of several customers posing

with boxes of food.

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 Initials"'/
In two of these photographs, shown above, the customers could be seen posing with

boxes marked with the logo of Feeding South Florida. MUNERO advised that she or another

employee issuing the checks would typically put "donation" or the months of the food

deliveries but said that the payments were clearly linked to the food deliveries. She noted

that on at least one occasion (check #1257) the memo line of a payment to the Foundation

stated "food," in Spanish ("comida"), but observed that the words "program maintenance"

had been written over it. She advised that neither she nor anyone at the clinic had written

"program maintenance." She advised clinic employees would typically pick up the food at

the Foundation's Medley warehouse. She said she would then pay STEFANO for the food

items, but she noted that she would sometimes make the payments to another female, whom

she identified as "Fanny." Your affiants have confirmed payments from La Esperanza

Medical Center and other businesses owned by the MUNERO's to the Foundation totaling

$12,600 and dating back to 2018.

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 26. On August 4, 2021, Pastor GIACOMO CASSESES (hereinafter

"CASSESES") of the Iglesia Cristiana Comunidad Esperanza provided your affiants with a

sworn statement. He stated he has served the church on the 6300 block of Bird Road in

unincorporated Miami-Dade County for 17 years. He said that dating back to early 2019, the

church had been purchasing food from the Foundation and paying $200 a month based on an

arrangement with STEFANO. He said the church would send workers to the Foundation's

warehouse to pick up a "pallet" of food once or twice a month. He said the boxes of food

would come in a variety of boxes. Some would say "Target," while others would state the

name of produce brands such as "Chiquita" or "Dole." He said that this arrangement

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continued until about the middle of 2020, when STEFANO advised him that the Foundation

would no longer be accepting checks as payment. He said that also at about this same time a

woman known to him as "Fanny" advised that the Foundation would be raising its price for

the food deliveries from $200 to $300 a month. He said "Fanny" offered no explanation for

this price increase. He said that as a result of the Covid-19 pandemic, many of his

parishioners were struggling and relied on the donated food to survive. He said that he

agreed to the terms and began to make payments of $150 a week to "Fanny," believed to be

FANNY MARTINEZ, via the Zelle payment application. CASSESES said that because the

church's financial institution does not offer Zelle, he stated he has been making the payments

of $150 a month to MARTINEZ using his personal bank account with Bank of America. He

later provided copies of his account records to your affiants reflecting twenty-two (22)

payments to

"Fanny" in the amount of $150 each for a total of $3,300 in electronic payments.

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 You sent $15000 to
FAN NY

Your affiants confirmed $5,045 in payments from CASSESES and his church, via check and

electronic means, to the Foundation in connection with the sale of food items.

27. On September 1, 2021, your affiants obtained a sworn statement from Pastor

JOSE R. MONTENEGRO (hereinafter "MONTENEGRO") of the Casa de Adoracion

Hossana church at 3033 NW 7th Avenue, Miami. He stated that he had been making monthly

payments to the Foundation in connection with donated food items for approximately two

years. He said he considered the payments as "offerings," but stated that STEFANO had told

him she needed the money to pay for the Foundation's warehouse. He said she told him her

donations were not enough to cover the rent and suggested that he increase his monthly

payment from $ 100 to $ 120.

She further advised that he make the payment in the form of cash instead of a check. He said

STEFANO told him that she preferred cash over checks because checks created accounting

issues for her. He said he made most of the payments to the Foundation in cash, as a result,

adding that he did so because STEFANO told him "checks are too much trouble." He also

stated

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that he would sometimes give the money to MARTINEZ when STEFANO was not present.

He said he also made several electronic payments to MARTINEZ in connection with the

food.

28. On August 26, 2021, your affiants interviewed the Executive Vice President

of FSF, SARI VATSKE (hereinafter "VATSKE") to ask her about the transactions detailed

above. VATSKE indicated that FSF had no knowledge of these transactions. She further

advised that had FSF been aware of the transactions involving the sale of donated food, FSF

would have immediately ceased to provide additional food products to the Foundation.

"Feeding South Florida would absolutely have terminated its partnership agreement with the

Moss Foundation," VATSKE said. "We have a zero-tolerance policy for the selling of food."

VATSKE confirmed that STEFANO was the signatory on all partnership agreements with

FSF at times material to the investigation. She advised that FSF partners such as the

Foundation were authorized to pick up food directly from FSF's retail partners, such as

Target and Publix. She said that only the Foundation's authorized representatives could pick

up donated food items from these outlets. She provided a list of all such representatives to

your affiants. Among those on the list were VEGA, the former volunteer and hotline caller,

as well as (Fanny) MARTINEZ.

29. Your affiants further reviewed disbursements made from the Foundation's

main operating account with Wells Fargo Bank ending in #1506 and noted a pattern of ATM

withdrawals and other disbursements that appeared unrelated to the original mission of the

Foundation to serve the needs of disadvantaged youth and the underprivileged. Dating back

to 2018, your affiants identified approximately 130 cash withdrawals made at ATM

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machines in the Miami-Dade County area. The total amount of cash withdrawn from ATM

machines exceeded $27,000. The review found that more than 100 of these ATM

withdrawals were made at ATM

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machines located at 500 SW 177th Avenue. Your affiants observed that this was the same

address on the check STEFANO deposited into her personal account back in June 2019 that

was drawn on an account from Miccosukee Indian Gaming. Your affiants further observed

that three of the ATM withdrawals were made from machines located at 1 Seminole Way,

the location of the Seminole Hard Rock Hotel & Casino in Ft. Lauderdale. The total amount

withdrawn from casinos located at Indian gaming locations exceeded $19,300, your affiants

found. Your affiants observed a pattern of multiple withdrawals on the same dates and

locations, suggestive of gambling behavior. In all instance ATM transaction fees of

approximately $5 per withdrawal were applied to the transactions for the Foundation's main

account.

It was observed by your affiants, moreover, that on the date that Stefano received a

payout of more than $20,000 from Miccosukee Indian Gaming (June 25, 2019), a review of

the Foundation's bank account shows that an ATM cash withdrawal of more than $300 was

made on that date at the Miccosukee casino location, 500 SW 177 th Avenue. In fact, the June

2019 statement for the Foundation reflects no fewer than four such ATM transactions at the

Miccosukee location, totaling more than $700 plus related ATM transaction fees.

Additionally, the June 2019 statement for the Foundation ending in (#1506) reflects

that $750 was transferred into Stefano's business checking account for Creativepro LLC.

30. Your affiants' review of Foundation bank account records (Wells Fargo

account ending #1506) further reflected transfers of $3,750 to an account in the name of

Creativepro LLC business checking (ending #2670). Account records for the Creativepro

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with Wells Fargo Bank show that the account was opened by STEFANO. State corporation

records show that STEFANO created a company named Creativepro LLC in 2009 and that

the firm was administratively dissolved in 2011. Your affiants further learned that

STEFANO states on her personal Facebook page that she is a "Former owner of Creativepro,

LLC."

Lily Stefano

Five

31. On Sept. 22, 2021, VEGA responded to the Miami-Dade County State

Attorney's Office and provided your affiants with a sworn statement. He said that STEFANO

would routinely visit the Miccosukee Tribe's casino located at 500 SW 177 th Avenue. He said

Stefano would often go to the casino after the conclusion of food give-away events outside

the Foundation's warehouse at 8250 NW South River Drive in Medley. VEGA said that

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while he was a volunteer working for STEFANO and for the Foundation, he would observe

paying customers such as the La Esperanza clinic and different religious organizations pick

up pallets of food in the morning, while Medley residents would show up to receive free food

later in the afternoon and evenings. He said STEFANO would frequently visit the casino in

the company of her mother (Nancy Stefano) and another volunteer, Medley resident Carlos

Gonzalez.

32. On Sept. 16, 2021, your affiants contacted SANTANA T. MOSS (hereinafter

"MOSS") by telephone as MOSS resides in the Washington, D.C., area. MOSS stated he has

had no recent involvement with the Foundation. He said he was surprised to learn that the

Foundation remained active. "I'm not in the loop at all," MOSS said. He further stated that he

was not aware that he was still an officer in the Foundation, as reflected in State of Florida

business records. He said that he had not been involved with the Foundation since he stopped

playing professional football seven or eight years ago. MOSS stated that he did not have any

knowledge relating to the sale of donated food items by STEFANO or the Foundation. He

likewise advised that he was not aware of how any of the proceeds of these sales were being

spent as he did not have any control over of the Foundation's operational account. "This is all

news to me. I'm clueless." He said he had not spoken to STEFANO since last year after he

became aware of reports involving the Foundation and that STEFANO assured him there was

nothing wrong and that "it's politics." MOSS said he wanted to emphasize that he was in no

way aware of or involved with any wrongdoing being carried out by STEFANO through the

Foundation.

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 33. Based on the forgoing, your affiants respectfully request an arrest warrant be

issued for ANA LILIA STEFANO for violation of Florida Statutes Organized Scheme to

Fraud in violation of Fla. Stat. 817.034(4)(a)1, a first-degree felony (1 count), and Grand

Theft in the Second Degree in violation of Fla. Stat. 812.014(2)(b)1, a second-degree felony

(1 count) as the findings of this investigation establish that STEFANO used a charitable

organization to defraud FSF out of donated food items worth approximately $1 million per

year and that, moreover, STEFANO misused the proceeds of these fraudulent transactions

for illicit purposes unrelated to the mission of the Moss foundation that she was entrusted

with managing.

SAYETH NOT

Det. Eric Rodriguez, Police Badge #41524

City of Miami Police Department Internal Affairs Section
Assigned to the Miami-Dade County State Attorney's Office
Multi-Agency Public Corruption Task Force

Karl Ross, COE Badge #29

Investigator/ Forensic Accountant
Miami-Dade County Commission on Ethics and Public Trust

SWORN TO AND SUBSCRIBED ON THIS DAY OF NOVEMBER 2021.

Circuit Court Judge

Eleventh Judicial Circuit of Florida

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 ROBERT T WATSON
CHRCUåT COURT JUDGE

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