Case 3:25-mj-00237 Document 1 Filed 08/23/25 Page 1 of 1

AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

for the
District
__________ of Oregon
District of __________

United States of America )

v. )
) Case No. 3:25-mj-00237
CRISTIAN RAVOLALES )
)
)
)
Defendant(s)
CRIMINAL COMPLAINT
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I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of August 21, 2025 in the county of Multnomah in the
District of Oregon , the defendant(s) violated:

Code Section Offense Description

21 U.S.C. § 841(a)(1) and Distribution of Fentanyl, a Schedule II controlled substance; and,
841(b)(1)(C)
Possession with Intent to Distribute Fentanyl, a Schedule II controlled
substance.

This criminal complaint is based on these facts:

See attached affidavit of Federal Bureau of Investigation (FBI) Special Agent Bobby Gutierrez.

✔ Continued on the attached sheet.

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/s/ By Phone
Complainant’s signature

Bobby Gutierrez, Special Agent, FBI

Printed name and title

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7:45 pm
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Date: 08/23/2025
Judge’s signature

City and state: Portland, Oregon Hon. Youlee Yim You U.S. Magistrate Judge
Printed name and title
 Case 3:25-mj-00237 Document 1-1 Filed 08/23/25 Page 1 of 10

3:25-mj-00237
DISTRICT OF OREGON: ss. AFFIDAVIT OF BOBBY GUTIERREZ

Affidavit in Support of a Criminal Complaint

I, Bobby Gutierrez, being first duly sworn, hereby depose and state as follows:

Introduction and Agent Background

1. I am a Special Agent with the Federal Bureau of Investigation and have been since

January 2021. I am currently assigned to the FBI’s Portland Division and am part of the

Transnational Organized Crime and Violent Gang Squad. I presently work a variety of criminal

and national security matters, including the investigation of violent crimes, gangs and narcotics, in

addition to the apprehension of federal fugitives. During my 21-week training at the FBI

Academy, Quantico, Virginia, I received training in a variety of investigative and legal matters,

including the topics of Fourth Amendment searches, the drafting of search warrant affidavits, and

probable cause. In my current area of responsibility, I work with law enforcement officers who

have experience and training in investigating coded communication involving the distribution of

controlled substances and gang affiliations. I have used this training and experience, as well as the

training and experience of other law enforcement officers familiar with this investigation, to

demonstrate how these criminal enterprises plan, organize and carry out criminal activity.

2. Prior to being employed with the FBI, I was a Licensed Master Social Worker

(LMSW) in the state of Arizona for approximately six years. As a LMSW, I was responsible for

creating and implementing target treatment plans for court-ordered criminal offenders with a

chronic history of substance use disorders, domestic violence, and child abuse. In addition to my

employment as an LMSW, I was a behavioral health consultant for Medicare/Medicaid and

oversaw medical and mental health treatment for patients residing in assisted living homes and

Affidavit of Special Agent Bobby Gutierrez Page 1

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skilled nursing facilities. As a consultant, I was responsible for auditing medical treatment plans,

levels of care, and medications to include psychotropic and Schedule II narcotic pain medications.

3. This affidavit is based upon a joint investigation conducted by the Portland Police

Bureau (PPB) Central Neighborhood Response Team (NRT) and Bike Squad, PPB Narcotics and

Organized Crime Unit (NOC), United States Attorney’s Office (USAO), the Clackamas County

Interagency Task Force (CCITF), and the Federal Bureau of Investigation (FBI) (the

Investigators).

Purpose of Affidavit

4. This affidavit is submitted to support a criminal complaint and arrest warrant for

Cristian RAVOLALES, a Hispanic male, date of birth 02/xx/1998 (hereinafter referenced as

“RAVOLALES”) for committing the felony crimes of:

• Distribution of Fentanyl, a Schedule II controlled substance, in violation of

Title 21, United States Code, Section 841(a)(1) and 841(b)(1)(C); and,

• Possession with Intent to Distribute Fentanyl, a Schedule II controlled

substance, in violation of Title 21, United States Code, Section 841(a)(1)

and 841(b)(1)(C).

5. I have obtained the facts set forth in this affidavit through my personal participation

in the investigation described below; from oral and written reports of other law enforcement

officers; and, from records, documents and other evidence obtained during this investigation. I

have obtained and read official reports prepared by law enforcement officers participating in this

investigation and in other related investigations.

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Confidential Informant

6. This investigation involves the use of a Confidential Informant (CI) who provided

the information by his/her own free will. CI is working with Investigators and provided actionable

information to law enforcement in exchange for consideration on their pending federal criminal

controlled substances charges. No promises or guarantees were made by investigators to gain CI’s

cooperation. CI has previously been arrested for Domestic Assault/Strangulation,

Stalking/Intimidation, Harassing Communications, Possession of a Controlled Substance and

Paraphernalia with the intent to use, Possession of Controlled Substances with the Intent to

Distribute, and Theft. CI is specifically aware of the methods of packaging and the prices of the

controlled substances because CI has used and/or has had associates who use these and other types

of illegal drugs and has accurately described this information to Investigators. CI has provided

information that led to arrests and seizure of contraband. Based on CI’s ability to conduct

recorded, drug-related phone calls with a target individual, and observations of physical

surveillance that corroborate CI’s ability to order narcotics from a target individual, Investigators

believe the information CI has provided to be credible and reliable.

Summary of Probable Cause

7. Since the beginning of 2024, Investigators have conducted ongoing operations

targeting fentanyl dealers working primarily in the area of downtown, Portland, Oregon, to include

neighboring communities. These missions have been aimed at reducing the amount of fentanyl in

downtown Portland, Oregon, as well as the neighboring communities. These same missions in

return, have helped contribute to a reduction in drug overdoses and the criminal activity associated

to the sales of narcotics, to include a reduction in gun violence, within downtown Portland. On

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August 21, 2025, National Fentanyl Prevention and Awareness Day, Investigators ran another

fentanyl enforcement mission in downtown Portland.

8. In August of 2025, Investigators met with the CI who provided information on a

male fentanyl dealer operating in Portland, Oregon by the name “Christian.” CI informed

Investigators that “Christian,” later identified as RAVOLALES, was actively selling fentanyl in

downtown Portland, Oregon. CI provided the telephone number (510) 850-2166 (Target

Cellphone) for “Christian” in which to contact him to place an order for fentanyl.

9. On August 21, 2025, Investigators met with the CI for the purpose of placing an

order for narcotics, specifically fentanyl powder, from “Christian.” At the direction of

Investigators, the CI texted the Target Cellphone and spoke with “Christian” who agreed to sell a

predetermined amount of fentanyl powder to the CI. After agreeing on the amount and time,

“Christian” provided an address near W Burnside & SW 13th Portland, Oregon in which to

complete the deal, and the CI agreed.

10. Prior to providing the CI with buy funds, I retrieved one of the $100 bills and stuck

a clear piece of tape with the message, “Fetty Killz 217” and mixed it with the other buy funds

with the goal of retrieving it later and being able to help confirm the transaction with the target. 1

Below is an image of that $100 bill:

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1 According to the Center for Disease Control, in 2023, an average of 217 people died each
day from an opioid overdose. Per the Drug Enforcement Administration *DEA), 2 milligrams of
fentanyl is considered a potentially lethal dose. For perspective, one gram of fentanyl, equivalent
in size to a sugar packet, has the potential to kill up to 500 people. The term “Fetty” is a common
street code name used by fentanyl dealers to disguise the sales of fentanyl.
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11. After the above narcotics deal was agreed on, Investigators setup near the deal

location in an attempt to identity “Christian.” Prior to the deal and at the consent of the CI,

Investigators searched the CI for weapons, money, and narcotics. None of the previous items were

located. While Investigators waited for “Christian” to arrive, the CI called the Target Cellphone

to inform “Christian” they had arrived. The CI, who was under audio and visual surveillance, was

heard making phone contact with an unknown male who advised the CI they were near a bus stop.

Shortly thereafter, the CI was greeted by a Hispanic male and Investigators witnessed a hand-to-

hand exchange occur. The CI and the unknown male then parted ways.

12. Once the CI confirmed the narcotics deal, Investigators wearing their law

enforcement placards, announced their presence and detained the unknown male, later identified as

Cristian RAVOLALES. On RAVOLALES, Investigators seized bulk U.S. Currency and

prepackaged baggies containing a white powdery substance consistent with the appearance of

fentanyl. Below is an image of the seized items:

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13. The seized suspected narcotics was taken to PPB’s Central Precinct to weigh and

field test. Investigators tested a sample of the suspected fentanyl powder using a MobileDetect test

kit and received a presumptively positive (+) result for fentanyl, a Schedule II controlled

substance. I have found MobileDetect to be a reliable way to field test controlled substances with

subsequent forensic analysis regularly confirming the initial results. In summary, the CI bought

approximately 12.2 grams of fentanyl from RAVOLALES and Investigators seized an additional

approximately 33.7 grams of fentanyl from RAVOLALES, for a combined approximate weight of

45.9 grams of fentanyl powder to include packaging. Below is an image of the purchased fentanyl,

test results, as well as a picture of all of the seized fentanyl:

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14. Investigators also seized approximately $579.00 in U.S. Currency from

RAVOLALES which was believed to be proceeds from the sales of narcotics. I assisted in

counting this seized currency and discovered that it contained the $100 bill that I had marked prior

to the deal with RAVOLALES as the bill had the same clear tape with my writing. Below is an

image of this recovered $100 bill with the message, “Fetty Killz 217”:

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15. While Investigators processed the evidence, RAVOLALES was held in a detention

cell to be interviewed. I was then asked to interview RAVOLALES in the Spanish language as I

am native Spanish speaker. I then advised RAVOLALES of his Miranda rights in Spanish using

FBI form FD-395.15 “Notification De Derechos” in the presence of another Investigator.

RAVOLALES acknowledged his Miranda rights and agreed to answer questions. Below is a

summary of what RAVOLALES provided:

• RAVOLALES was from Tegucigalpa, Honduras and was now living in

Portland, Oregon.

• I advised RAVOLALES the reason for his arrest and my experience

investigating downtown fentanyl dealers and asked him why he was selling

fentanyl knowing that dealers in downtown Portland would get federally

prosecuted. RAVOLALES told Investigators he sold out of necessity.

• I asked RAVOLALES where he had obtained the fentanyl and who his

supplier was and he told Investigators he had obtained it from someone the

day prior but could not recall who.

• Investigators also asked what his phone number was, and he provided the

number 510-850-2166, known to Investigators as the Target Number.

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16. Shortly thereafter, Investigators terminated the interview. I then called the Target

Cellphone and noticed that the phone that was seized from RAVOLALES began to ring and light

up. RAVOLALES was subsequently lodged at the Multnomah County Detention Center on

federal charges.

17. I very familiar with how fentanyl dealers operate, and I know that fentanyl

traffickers are increasingly selling both fentanyl powder and counterfeit M30 prescription pills

manufactured with fentanyl, a Schedule II controlled substance. I know that fentanyl powder is

typically a white to off-white powder. I also know drug dealers selling powdered fentanyl, which

they will often possess in larger amounts, will often possess additional packaging materials to

repackage the drugs they are selling to their customer. Depending on their level of addiction, I

know that a user of powdered fentanyl will typically buy it in quantities of less than a gram and

use it in quantities of much less than 1/10 of a gram. I know that dealers of powdered fentanyl will

often buy fentanyl in larger quantities and then break off and sell it in smaller qualities of a gram

or less. I know that a person possessing approximately more than 10 grams of fentanyl powder

does not possess it for personal use but rather such a quantity clearly indicates that it is possessed

for purposes of further distribution.

Conclusion

18. Based on the foregoing, I have probable cause to believe, and I do believe, that

Cristian RAVOLALES has committed the felony crimes of:

• Distribution of Fentanyl, a Schedule II controlled substance, in violation of

Title 21, United States Code, Section 841(a)(1) and 841(b)(1)(C); and,

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• Possession with Intent to Distribute Fentanyl, a Schedule II controlled

substance, in violation of Title 21, United States Code, Section 841(a)(1)

and 841(b)(1)(C).

I therefore request that the Court issue a criminal complaint and arrest warrant for

RAVOLALES.

19. Prior to being submitted to the Court, this affidavit, the accompanying complaint,

and the arrest warrant were all reviewed by Assistant United States Attorney Scott Kerin. AUSA

Kerin advised me that in his opinion the affidavit and complaint are legally and factually sufficient

to establish probable cause to support the issuance of the requested criminal complaint and arrest

warrant.

By phone pursuant to Fed R. Crim. P. 4.1

Bobby Gutierrez, Special Agent
Federal Bureau of Investigation

Subscribed and sworn in accordance with the requirements of Fed. R. Crim. P. 4.1 by
telephone at 7:41 pm. on August23 , 2025.
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___________________________________
HONORABLE YOULEE YIM YOU
UNITED STATES MAGISTRATE JUDGE

Affidavit of Special Agent Bobby Gutierrez Page 10