United States v. YOHANA N ELIGOOLA, Southern District of New York (Apr. 17, 2024) — Complaint

AUSAs: Micah Fergenson, Kevin Mead 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 
UNITED STATES OF AMERICA 
v. 
YOHANA
N ELIGOOLA, 
Defendant. 
      COMPLAINT 
      V
iolation of 18 U.S.C. § 1956(h)  
      COUNTY OF OFFENSE: 
      NEW YORK 
SOUTHERN DISTRICT OF NEW YORK, ss.: 
LARISSA MONTES, being duly sworn, deposes and says that she is a Special Agent with 
the Federal Bureau of Investigation (“FBI”), and charges as follows: 
COUNT ONE 
(Money Laundering Conspiracy) 
1.From at least in or about June 2022 up to and including in or about April 2024, in
the Southern District of New York and elsewhere, YOHANAN ELIGOOLA, the defendant, and 
others known  and  unknown,  willfully  and  knowingly  combined,  conspired,  confederated,  and  
agreed together and with each other to commit money laundering, in violation of Title 18, United 
States Code, Section 1956(a)(3)(B). 
2.It  was  a  part  and  an  object  of  the  conspiracy  that  YOHANAN  ELIGOOLA, the
defendant,  and  others  known  and  unknown,  with  the  intent  to  conceal  and  disguise  the  nature,  
location,  source,  ownership,  and  control  of  property  believed  to  be  the  proceeds  of  specified  
unlawful activity, to wit, narcotics trafficking, in violation of Title 21, United States Code, Section 
841,  would  and  did  conduct  and  attempt  to  conduct  a  financial  transaction,  which  transaction  
affected interstate and foreign commerce and involved the use of a financial institution which was 
engaged  in,  and  the  activities  of  which  affected,  interstate  and  foreign  commerce,  involving  
property  represented  to  be  the  proceeds  of  specified  unlawful  activity,  to  wit,  the  proceeds  of  
narcotics trafficking, in violation of Title 21, United States Code, Section 841, in violation of Title 
18, United States Code, Section 1956(a)(3)(B). 
(
Title 18, United States Code, Section 1956(h).) 
Summary 
3.YOHANAN  ELIGOOLA,  the  defendant,  arranged  to  launder  money  for  an
individual he understood to be working on behalf of drug cartels in South America, who was, in 
truth  and  in  fact,  an  undercover  agent  with  the  FBI  (“UC-1”).    Specifically,  UC-1 gave 
ELIGOOLA large  amounts  of  cash,  and  ELIGOOLA  transferred  the  funds  back  to  UC-1 via 
cryptocurrency  and  bank  wires.    ELIGOOLA  specifically  asked UC-1 if  the  money  constituted  
24 MAG 1517

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drug proceeds, and UC-1 said yes.  ELIGOOLA laundered over half a million dollars represented 
by UC-1 to be narcotics proceeds. 
 
4. In  addition  to  laundering  what  he  understood  to  be  drug  money,  YOHANAN 
ELIGOOLA,  the  defendant,  agreed  to  sell  UC-1 a  number  of  military-grade munitions.    Those  
included rifles, grenades, “kamikaze drones,” rocket-propelled grenades, anti-tank weapons, and 
surface-to-air  missiles.    YOHANAN  ELIGOOLA  even  provided  UC-1 with a  spreadsheet  
cataloging his available inventory and prices.   
 
YOHANAN ELIGOOLA’s Initial Conversations with FBI Undercover Officers 
 
5. In or about June 2022, UC-1 began communicating with YOHANAN ELIGOOLA, 
the  defendant,  by  phone.
1
    UC-1  and  ELIGOOLA  discussed  UC-1  transferring  money  to  
ELIGOOLA.   
 
6. On or about January 17, 2023, YOHANAN ELIGOOLA, the defendant, and UC-1 
met in person.  That meeting was consensually recorded.  Based on my review of the recording 
and my discussions with other law enforcement officers, I know that the following, in substance 
and in part, took place at the meeting:  
 
a. ELIGOOLA discussed how he could receive any amount of cash and could 
transfer it back to UC-1 within five days. 
 
b. ELIGOOLA  said  that  if  he  received  cash  from  UC-1  in  New  York  and  
transferred it back to a New York bank account, he would charge a rate of 10 to 12 percent. 
 
c. ELIGOOLA said that an individual working for him would pick up the cash 
from UC-1. 
 
d. ELIGOOLA said that UC-1 should tell him what ELIGOOLA should tell 
his bank about why he was wiring the money to UC-1. 
 
e. ELIGOOLA said another individual would pick up the cash from UC-1.   
 
f. ELIGOOLA  asked  if  the  cash  that  UC-1  planned  to  give  him  was  “from  
drugs.”    UC-1  said  yes,  that  the  money  was  from  drugs,  and  that  he  was  “dealing  with  
Colombians.” 
 
g. ELIGOOLA told UC-1 he would charge a lower fee if UC-1 would accept 
cryptocurrency in exchange for his cash.   
 
h. ELIGOOLA   told   UC-1   that   they   should   use   encrypted   messaging   
applications to discuss their transactions. 
 
 
1
 The communications involving FBI undercover agents were recorded, and I know about those 
communications from reviewing the recordings and reports summarizing the recordings. 

3 
 
i. ELIGOOLA   told   UC-1   that   when   UC-1   received   the   wires   from   
ELIGOOLA, “the bank will never ask you a question.” 
 
7. On or about February 14, 2023, YOHANAN ELIGOOLA, the defendant, and UC-
1 met in person in New York, New York.  That meeting was consensually recorded.  Based on my 
review of the recording and my discussions with other law enforcement officers, I know that the 
following, in substance and in part, took place at the meeting: 
 
a. ELIGOOLA told UC-1 that he could launder up to $1 million in cash per 
day if ELIGOOLA could transfer the money back to UC-1 in the form of cryptocurrency. 
 
b. ELIGOOLA  told  UC-1  that  he  owned  a  factory  that  manufactured  rifles, 
that  he  manufactured  .50-caliber  firearms  and  “suicide  drones,”  and  that  “I  control  35%  of  the  
[country name omitted] defense industry.” 
 
c. ELIGOOLA showed UC-1 pictures of M4 rifles and told UC-1 that he could 
give UC-1’s contacts in South America a good price on M4 rifles. 
 
d. UC-1 offered to hand ELIGOOLA $28,000 in cash at the meeting, in order 
for ELIGOOLA to launder that cash, but ELIGOOLA told UC-1 that the amount of money was 
too small, and he would not accept less than $50,000 in cash at a time. 
 
e. UC-1 and ELIGOOLA discussed that UC-1 would shortly transfer cash to 
ELIGOOLA, and that ELIGOOLA would return the money to him in the form of cryptocurrency 
and a bank wire. 
 
f. ELIGOOLA and UC-1 discussed what they would tell the bank about the 
wire  transfers.    In  that  context,  ELIGOOLA  told  UC-1  to  tell  him  what  UC-1’s  company  was  
doing.  I understand from my training and experience and my involvement in this investigation 
that  ELIGOOLA  asked  this  question  in  order  to  effectively  deceive  the  bank  when  he  made  a  
money laundering transfer to UC-1’s company. 
 
The First Money-Laundering Transaction of $60,000 
 
8. On or about March 22, 2023, a coconspirator not named herein (“CC-1”) met with 
UC-1.  That meeting was consensually recorded.  Based on my review of the recording and my 
discussions  with  other  law  enforcement  officers,  I  know  that  the  following,  in  substance  and  in  
part, took place at the meeting: 
 
a. UC-1 and CC-1 met at a restaurant.  Shortly after meeting UC-1, CC-1 had 
a short video call with YOHANAN ELIGOOLA, the defendant.   
 
b. After the call, UC-1 confirmed that CC-1 was “familiar with everything.”  
UC-1 explained that he had “60” on him—i.e., $60,000 in cash—which was part of an “initial test” 
to see “how fast” ELIGOOLA would return the laundered funds.   
 

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c. UC-1  requested  that,  in  addition  to  cryptocurrency,  part  of  the  laundered  
funds  be  returned  via  a  bank  wire.    UC-1  stated  that  his  “friend  in  South  America”  was  also  
interested in bank wires.  CC-1 replied that this arrangement should not be a problem.   
 
d. UC-1 said he would also discuss the arrangement with ELIGOOLA, but did 
not like talking about such things over the phone.  CC-1 stated he would tell ELIGOOLA what 
UC-1 told him.  UC-1 said he would also send ELIGOOLA a note.  
 
e. UC-1 then handed CC-1 a bag containing approximately $60,000 in cash.  
After  receiving  the  bag,  CC-1 left  for  approximately  ten  minutes  to  count  the  cash.    CC-1 then 
returned and confirmed to UC-1 that it was all there. 
 
9. Based  on  my  review  of financial  records  and  my  discussions  with  other  law  
enforcement officers, I know that, several days after the March 22, 2023 meeting between UC-1 
and CC-1,  UC-1  received  approximately  $45,000  in  cryptocurrency  and  a  bank  wire  for  
approximately  $9,000  into  accounts  that  UC-1  had  provided  to YOHANAN  ELIGOOLA,  the  
defendant, from an account held in the name of another individual. These transfers reflected that 
ELIGOOLA had taken a fee of approximately 10% of the $60,000 that ELIGOOLA laundered on 
UC-1’s behalf.     
 
The Second Money-Laundering Transaction of $100,000  
 
10. On or about April 27, 2023, a coconspirator not named herein (“CC-2”) met with 
an  additional  FBI  undercover  agent  (“UC-2”)  for  a  money  exchange  that  had  been  arranged  by  
UC-1  and  YOHANAN  ELIGOOLA,  the  defendant.   The   meeting  was  consensually  recorded.    
Based on my review of the recording and my discussions with other law enforcement officers, I 
know that the following, in substance and in part, took place at the meeting:   
 
a. UC-2 handed CC-2 approximately $100,000 in cash.   
 
11. Based  on  my  review  of financial  records  and  my  discussions  with  other  law  
enforcement  officers,  I  know  that,  several  days  later,  UC-1  received  approximately  $50,000  in  
cryptocurrency and a bank wire for approximately $41,000 into accounts that UC-1 had provided 
to  YOHANAN  ELIGOOLA,  the  defendant.    UC-1  therefore  paid  ELIGOOLA  a  fee  of  
approximately 9% of the $100,000 that ELIGOOLA laundered on UC-1’s behalf. 
 
The Third Money-Laundering Transaction of $116,000  
 
12. On or about May 22, 2023, CC-1 met with UC-2 for a money exchange that had 
been  arranged  by  UC-1  and  YOHANAN  ELIGOOLA,  the  defendant.    The meeting  was  
consensually recorded.  Based on my review of the recording and my discussions with other law 
enforcement officers, I know that the following, in substance and in part, took place at the meeting: 
 
a. Upon  meeting  CC-1 in  UC-2’s  car,  UC-2  apologized  for  being  late,  and  
explained that UC-2 “had to meet up with our other cartel guys here to get the money.” 
 
b. UC-2 handed CC-1 a white plastic bag containing approximately $116,000 
in cash.  While still in UC-2’s car, CC-1 proceeded to count the $116,000 in cash.
             

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13. Based  on  my  review  of  financial  records  and  my  discussions  with  other  law  
enforcement  officers,  I  know  that,  several  days  later,  UC-1  received  approximately  $60,000  in  
cryptocurrency and a bank wire for approximately $45,000 into accounts that UC-1 had provided 
to  YOHANAN  ELIGOOLA,  the  defendant.    UC-1  therefore  paid  the  defendant   a  fee  of  
approximately 9% of the $116,000 that the defendant laundered on UC-1’s behalf. 
 
The Fourth Money-Laundering Transaction of $120,000 
 
14. On  or  about  May  31,  2023,  YOHANAN  ELIGOOLA,  the  defendant,  messaged 
UC-1  an  unsigned  “Affiliate  Marketing  Agreement”  between  a  company  associated  with  
YOHANAN ELIGOOLA (the “Eligoola Company”) and a company associated with UC-1 (“UC-
1  Company”).    The  agreement  stated,  in  substance  and  in  part, that  the  UC-1  Company  would  
make  sales  on  behalf  of  the  Eligoola  Company,  and  the  Eligoola  Company  would  then  pay  the  
UC-1 Company a commission.  Based on my training and experience and my involvement in this 
investigation, I believe that the purpose of this agreement was to create a document that could be 
used as a cover for the money laundering payments. 
 
15. On or about June 14, 2023, YOHANAN ELIGOOLA, the defendant, and UC-1 met 
in person in New York, New York.  That meeting was consensually recorded.  Based on my review 
of the recording and my discussions with other law enforcement officers, I know that the following, 
in substance and in part, took place at the meeting: 
 
a. UC-1 handed ELIGOOLA approximately $120,000 in cash.   
 
b. ELIGOOLA   and   UC-1   discussed   the   potential   sale   of   munitions.  
ELIGOOLA said that he could arrange for munitions to be transported to South America by plane. 
 
c. ELIGOOLA  said  he  would  accept  payment  for  munitions in  cash  or  
cryptocurrency, but refused to accept payment in cocaine. 
 
d. ELIGOOLA told UC-1 that he was disappointed that UC-1 was transferring 
such small amounts of cash to him, and said that he had expected to be receiving $1 million per 
week from him. 
 
16. Based  on  my  review  of  financial  records  and  my  discussions  with  other  law  
enforcement  officers,  I  know  that  several  days  later,  UC-1  received  approximately  $100,000  in  
cryptocurrency and a bank wire for approximately $8,000 into accounts that UC-1 had designated 
to  YOHANAN  ELIGOOLA,  the  defendant.    UC-1  therefore  paid  ELIGOOLA  a  fee  of  
approximately 9% of the $120,000 that ELIGOOLA laundered on UC-1’s behalf. 
 
The Fifth Money-Laundering Transaction of $150,000 and YOHANAN ELIGOOLA’s 
Plan to Sell Surface-to-Air Missiles to the Undercover FBI Agents 
 
17. On or about July 20, 2023, YOHANAN ELIGOOLA, the defendant, and UC-1 met 
in person in Miami, Florida.  That meeting was consensually recorded.  Based on my review of 

6 
 
the recording and my discussions with other law enforcement officers, I know that the following, 
in substance and in part, took place at the meeting: 
 
a. ELIGOOLA implied that he was transferring the cash UC-1 provided him 
out of the United States via diplomatic pouch. 
 
b. ELIGOOLA said that he made a profit of approximately 150 to  200% when 
he sold munitions. 
 
c. ELIGOOLA  said  that  some  of  the  munitions  he  sold  to  other  customers  
were marked up approximately 500% because they were “black market.” 
 
18. On  or  about  July  21,  2023,  YOHANAN  ELIGOOLA,  the  defendant,  UC-1,  and  
other  undercover  FBI  agents  met  in  person  in  Miami,  Florida.    That  meeting  was  consensually  
recorded.  Based on my review of the recording and my discussions with other law enforcement 
officers, I know that the following, in substance and in part, took place at the meeting: 
 
a. UC-1 handed ELIGOOLA approximately $150,000 in cash.   
 
b. The undercover agents said that they “have issues with aircraft,” referred to 
“the  fucking  helicopters,”  and  asked  for  “stingers.”    Referring  to  helicopters,  YOHANAN 
ELIGOOLA asked, “why’d you take them down,” and the undercover agents said, “you take one 
down, the others start scattering.”  Based on my training and experience and my involvement in 
this investigation, I know that the undercover agents, who represented that they worked for a South 
American drug cartel, meant that government helicopters had been interdicting the operations of 
the  cartel.    I  further know based  on  my  training  and  experience  and  my involvement  in  this 
investigation  that  the  undercover  agents  requested  Stinger  missiles,  which  are  a  man-portable 
surface-to-air  missile  systems  that  are  effective  in  shooting  down  helicopters,  in  order  to  shoot  
down government helicopters that were interfering with the drug cartel’s operations. 
 
c. ELIGOOLA showed UC-1 pictures of various military-grade munitions. 
 
d. ELIGOOLA  told  the  undercover  agents  to  send  him  a  list  of  the  types  of  
munitions they wanted to purchase. 
 
e. ELIGOOLA told the undercover agents that they could visit him in other 
countries to see the munitions firsthand. 
 
19. Based  on  my  review  of  financial  records  and  my  discussions  with  other  law  
enforcement  officers,  I  know  that,  several  days  after  the  July  21,  2023, meeting  between  
YOHANAN ELIGOOLA, the defendant, UC-1, and other undercover FBI agents, UC-1 received 
approximately $90,000 in cryptocurrency and two bank wires totaling approximately $45,000 into 
accounts that UC-1 had designated to YOHANAN ELIGOOLA.  UC-1 therefore paid ELIGOOLA 
a fee of approximately 9% of the $150,000 that ELIGOOLA laundered on UC-1’s behalf. 
 
20. On or about July 28, 2023, UC-1 sent YOHANAN ELIGOOLA, the defendant, a 
message containing a list of munitions he wished to purchase, which included, “2 Stinger missiles.”   
On or about August 7, 2023, ELIGOOLA messaged UC-1 a response in which he identified the 

7 
 
requested munitions he could provide, certain alternative munitions he could provide, the number 
of each type of munition he could provide, and the unit price of each type of munition.  A copy of 
the list ELIGOOLA sent to UC-1 is below: 
 
N DESCRIPTION ALTERNATIVE 
QUANTITY 
(PCS) 
UNIT PRICE 
($) 
1 
M4 Carabine (including 6 magazines, cleaning 
kits, red dot optics) 
Supplied by DRD 
2 
Barrett .50 cal rifle with 4x32 optics and 5/10-
rd magazine 
M93 Black Arrow Long-range 
rifle 
10 25.500 
3 M67 fragmentation grenades M75 fragmentation grenade 100 100 
4 Claymore Mine   50 TBC 
5 RPG-7 Grenade Launcher   25 13.500 
6 
40 mm RPG-7 Rounds (Anti-Personnel) OG-
7V 
  250 1.725 
7 40 mm RPG-7 Rounds (Anti-Armor) PG-7V   250 2.025 
8 AT4   25 TBC 
9 
Carl Gustaf 8.4 cm recoilless rifle with 20 
rounds per rifle 
  3 TBC 
10 Javelin missile 
SABRE ER (Tube Missile, 
Command Launch System, Indor 
& Field Training Simulators, Test 
Equipment) 
  6,563,000 
SABRE MR (Tube Missile, 
Command LaunchUnit, Indor & 
Field Training Simulators, Test 
Equipment) 
  6,190,000 
11 Stinger missile 
FN-6 Manpad (5 Missile in Tube, 
1 Firing Unit, 10 Ground Power & 
Gas Supply Unit, 1 Optical Sight) 
2 1,790,700 
FN-16 Manpad (5 Missile in 
Tube, 1 Firing Unit, 10 Battery & 
Cooling Unit, 1 Optical Sight, 1 
Thermal Sight) 
2 2,405,400 
12 Kamikaze drone 
FH-901A Loitering Missile 
System (10 missiles, 1 Portable 
Ground Control Equipment) 
2 2,521,950 
13 
XR-1 (24 units of UAV, 1 Mobile Guidance 
System, 1 Ground Station, 1 Launcher) 
  1 9,930,700 
14 5.56 round   5.000 TBC 
15 .50 cal round   2.000 TBC 
 
21. Based  on  my  training  and  experience  and  communications  with  other  law  
enforcement  officers,  I  have  learned  the  following  about  the  munitions  offered  for  sale  by 
YOHANAN ELIGOOLA, the defendant: 
 
a. As to row 1, the “M4 Carbine” is an assault rifle 
 
b. As to row 2, the “Barrett .50 cal rifle” is a sniper rifle. 

8 
 
 
c. As to row 3, the “M67” is a grenade. 
 
d. As to row 4, the “Claymore Mine” is an anti-personnel land mine. 
 
e. As to row 5, the “RPG-7” is an acronym for “rocket-propelled grenade.” 
 
f. As  to  row  6,  ”40  mm  RPG-7  Rounds  (Anti-Personnel)”  are a  type  of  
ammunition for the RPG-7, designed for use against individual targets. 
 
g. As  to  row  7,  ”40  mm  RPG-7  Rounds  (Anti-Armor)”  are  a  type  of  
ammunition for the RPG-7 designed for use against armored targets. 
 
h. As to row 8, the “AT4” is a shoulder-fired anti-tank weapon. 
 
i. As to row 9, the “Carl Gustaf 8.4 cm recoilless rifle”   is a shoulder-fired anti-
tank weapon. 
 
j. As to row 10, the “SABRE ER” and “SABRE MR” javelin missiles are each 
anti-tank missiles. 
 
k. As  to  row  11,  the  “FN-6”  and  “FN-16”  stinger  missiles  are  man-portable 
surface-to-air missile systems.  In particular, each of these weapons are “an explosive or incendiary 
rocket or missile that is guided by any system designed to enable the rocket or missile to seek or 
proceed toward energy radiated or reflected from an aircraft or toward an image locating an aircraft 
or otherwise direct or guide the rocket or missile to an aircraft, or a device designed or intended to 
launch or guide such a rocket or missile. 
 
l. As to row 12, the “FH-901A” is a drone aircraft designed to fly into a target 
and detonate. 
 
m. As to row 13, the “XR-1” is an unmanned aerial vehicle (UAV) system. 
 
n. As  to  row  14,  “5.56 round[s]”  refers  to  a  type  of  ammunition  frequently  
used for assault rifles. 
 
o. As to row 15, “.50 cal round[s]” are a type of rifle ammunition frequently 
used for sniper rifles. 
 
The Final Undercover Meeting and the Defendant’s Arrest 
 
22. On or about April 15, 2024, YOHANAN ELIGOOLA, the defendant, UC-1, and 
other undercover FBI agents met in person at a restaurant in New York, New York.  That meeting 
was consensually recorded.  Based on my review of the recording and my discussions with other 
law  enforcement  officers,  I  know  that  the  following,  in  substance  and  in  part,  took  place  at  the  
meeting: 
 

9 
 
a. The undercover  agents  told  ELIGOOLA  that  they  wanted  “Javelins”  and  
“Stingers”—which I know, based on my training and experience, are anti-aircraft missiles. 
 
b. After   ELIGOOLA   called   another   individual,   ELIGOOLA   told   the   
undercover agents, in substance and in part, that he had eight missiles.  ELIGOOLA further stated, 
in  substance  and  in  part,  that  he  could  not  be  exact  about  timing,  because  “paperwork”  would  
require time.   ELIGOOLA also, in substance and in part, invited the undercover agents, or someone 
they trusted, to view the “merchandise” (which I understand, based on the context of the call, to 
be a reference to the missiles) in a foreign country. 
 
c. As  a  downpayment,  the  undercover  agents  provided  ELIGOOLA  with  
$690,000 in cash, as depicted below: 
 
 
 
d. After ELIGOOLA accepted the bag of cash and the meeting concluded, FBI 
agents arrested ELIGOOLA.   
 
23. After  YOHANAN  ELIGOOLA,  the  defendant,  was  arrested,  law  enforcement  
conducted  a  search  of  his  cellphone  pursuant  to  a  judicially  authorized  warrant.    Based  on  my  
review of that cellphone, I have learned the following regarding ELIGOOLA’s communications 
with a coconspirator (“CC-3”) regarding the sale of surface-to-air missiles: 
 

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a. In or about September 2023, ELIGOOLA messaged CC-3 a version of the 
spreadsheet  he  had  sent  UC-1  on  or  about  August  7,  2023,  and  ELIGOOLA  and  CC-3  had  the  
following exchange: 
 
Sender Message 
ELIGOOLA [sends spreadsheet that  includes  original request  for  Stinger  
missiles  and  alternative  offer  of  FN-6  and  FN-16  surface-to-air 
missiles] 
ELIGOOLA We need to finalize 
ELIGOOLA My rifles cost please put 2100$ 
CC-3 What do you mean 
CC-3 This list is for? 
ELIGOOLA [voice note] Part of the list, which one we sent about one months 
and a half ago, to one of my customers, I told you.  Look, they just 
want to start with these products and continue with the big one. 
CC-3 Yes but they must show you the money without that it’s water if 
the time 
ELIGOOLA [voice note] If you agree with all the details they send us, this is 
what they send us today.  I want to know if it is OK so I can start, 
not to show the money, to ask them to put the money 
CC-3 
• Proof of funds 
• When  we  are  sure  that  there  is  amount  then  we  start  the  
procedure 
• I already sold that items to Africans it’s done 
• When  the  funds  will  be  confirmed  then  I’ll  start  the  new  
procedures for getting the items 
ELIGOOLA But I can tell that we can supply 
CC-3 Yes but let’s not waste our time 
CC-3 Seirously – if  they  need  to  get  the  info  from  us  they  can  use  the  
Wikipedia or yellow pages 
 
b. Call  records  show  that  ELIGOOLA  repeatedly  attempted  to  call  CC-3 
during the April 15, 2024 with the undercover agents. 
 

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WHEREFORE, I respectfully request that a warrant be issued for the arrest of YOHANAN 
ELIGOOLA, the defendant, and that he be arrested, and imprisoned or bailed, as the case may be. 
 
      
______________________________ 
        LARISSA MONTES 
Special Agent 
        Federal Bureau of Investigation 
 
 
Sworn to before me, this 16th day of April, 2024. 
 
___________________________________ 
THE HON. KATHARINE H. PARKER 
United States Magistrate Judge 
Southern District of New York