Case Document 1 Filed in TXSD on 12/18/13 Page 1 of 3 A0 91 (Rev. 11/11) Criminal Complaint UNITED STATES DISTRICT COURT for the Southern District of Texas clerk of Court United States of America v. - CaseNo. . Rebecca Gonzalez Defendant(s) CRIMINAL COMPLAINT 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 November 6. 2012 in the county of Hidalgo in the Southern District of Texas the defendant(s) violated: Code Section O??ense Description 42 U.S.C. 1973i(c) Whoever knowingly or willfully gives false information as to his name, address or period of residence in the voting district for the purpose of establishing his eligibility to register or vote, or conspires with another individuai for the purpose of encouraging his false registration to vote or illegal voting, or pays or offers to pay or accepts payment either for registration to vote or for voting in a Federal election shall be ?ned not more than $10,000 or imprisoned not more than ?ve years, or both. This criminal complaint is based on these facts: Please see attached Af?davit. if Continued on the attached'sheet. g% 3. Lee i Ail/Ir?! I A Complainant?s signature Brandon Cook, Special Agent, FBI Printed name and title Sworn to before me and signed in my presence. pillsij ban, Judge ?3 signature City and state: McAnen, Texas Hon. Dorina Ramos, U.S. Magistrate Judge Printed name and title Case 7:14-cr-00071 Document 1 Filed in TXSD on 12/18/13 Page 2 of 3 AFFIDAVIT IN SUPPORT OF COMPLAINT I, Brandon Cook, being duly sworn, hereby depose and state: 1. lam a Special Agent of the Federal Bureau of Investigation and have been so employed since July 2010. I am currently assigned to work public corruption to include election crimes investigations within the San Antonio, Texas Division. 2. Since joining the FBI, I have received law enforcement training in the investigation of criminal violations of federal law within the jurisdiction of the FBI, and have received specialized training and gained experience in arrest procedures, search warrant applications, the execution of search and seizures, and various other criminal laws and procedures. 3. I make this affidavit in support of the issuance of a complaint and arrest warrant for subject Rebecca Gonzalez (Gonzalez). 4. The statements contained in this affidavit are based upon my investigation, information provided by other law enforcement officers, and on my own experience and training as a Special Agent of the FBI. Because the affidavit is being submitted for the limited purpose of securing a complaint, I have not included each and every fact known to me concerning the investigation. I have set forth only the facts that I believe are necessary to establish probable cause to believe that Gonzalez violated 42 U.S.C. 1973i(c). 5. Based upon information gathered during the course of this investigation, including some of the information set forth below, it is believed that Gonzalez worked as a politiquera during the 2012 Primary Election and November 2012 General Election. Federal candidates were on the ballot for these elections. Based upon my knowledge and experience, a politiquera is a person who works for a candidate to encourage people to vote, to bring voters to the polls, to ensure that voters select the appropriate candidate, and to pay voters for their votes. 6. On December 17-18, 2012, FBI agents interviewed three witnesses. Witness 1 stated that s/he was paid $10 by Gonzalez to vote for specific candidates during the November 2012 General Election. After voting, Gonzalez paid Witness 1 in Gonzalez' car. Witness 2 stated that Witness 2 and Witness 2?s sister were picked up by Gonzalez to vote in the 2012 General Election and that Gonzalez promised to pay each ofthem $10 if they voted for specific candidates. Witness 3 stated that Gonzalez paid Witness 3 $10 to vote for specific candidates in the November 2012 General Election. These witnesses are all familial relations to Gonzalez, and are all related to each other. 7. I have reviewed voter rolls from the precinct in which the witnesses stated that they voted. The voter rolls confirm that Witnesses 1, 2 and 3 cast a vote in the 2012 General Election. 8. On February 15, 2013, FBI agents interviewed Gonzalez at the FBI office in Texas, where she appeared voluntarily. Gonzalez stated that she worked as a politiquera for candidates in the 2012 Primary Election, and for candidates for the Donna Independent School Board in the 2012 General Election. Gonzalez stated that during the 2012 Primary Election, 1 Case Document 1 Filed in TXSD on 12/18/13 Page 3 of 3 she was paid approximately $40 on multiple occasions by a campaign manager to pay voters to vote for a particular candidate. Gonzalez and others were told by a campaign manager to pay voters $5 to $10 for their vote. Gonzalez further stated that the candidates for the Donna Independent School Board election instructed Gonzalez to pay $5 to $10 per voter in exchange for their votes in the 2012 General Election.