Case 7:17-cr-01686 Document 1 Filed in TXSD on 10/16/17 Page 1 of 2

 

 

A0 91 (Rev. 08/09) Criminal Complaint Katie? ?353.11
ri?es
UNITED STATES DISTRICT COURT 
for the 1 6 2017
Southern District of Texas
.Chl'kofceatt
United States of America 
Jonathan Riley YOB: 1995, 000: US 3 Case No i 1 8 Licf 



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 October 14, 2017 in the county of Hidalgo in the
Southern District of Texas the defendant(s) violated:
Code Section Offense Description

21 USC 952 Knowingly and intentionally attempt to import into the United States from Mexico
approximately 21.98 kilograms of liquid methamphetamine, a Schedule ll

21 USC 841 controlled substance, and did knowingly and intentionally possess with the
intent to distribute approximately 21.98 kilograms of liquid methamphetamine, a

21 USC 846 Schedule II controlled substance. Furthermore, the defendant(s) did knowingly

and unlawfully conspire to possess with intent to distribute the above listed
controlled substances.

This criminal complaint is based on these facts:

Continued on the attached sheet.

nee/z

57 Complainant?ssignature

 

Gerardo Mercado, HSI Special Agent
i i 5 7 Printed name and title

Sworn to before me and signed in my presence. .

Date: 10l16/2017

 

 

Judge?s signature

City and state: McAlien, Texas US. Magistrate Judge Dorina Ramos

Printed name and title

Case 7:17-cr-01686 Document 1 Filed in TXSD on 10/16/17 Page 2 of 2

II.



IV.

ATTACHEMENT A

On October 14, 2017, at approximately 5:05 US. Customs
and Border Protection Of?cers (CBPOs) encountered Jonathan
Riley LUNSFORD driving a black Nissan sedan (hereinafter
referred to as ?Subject Vehicle?) as he presented himself for entry
inspection from Mexico into the United States at the Progreso,
Texas Port of Entry (POE).

At the primary inspection area, the inspecting CBPO questioned
LUNSFORD regarding his recent travel itinerary. LUNSFORD
claimed he had visited Mexico from Dallas, Texas to celebrate his
birthday. LUNSFORD provided the CBPO with a negative
customs declaration to any contraband. The CBPO referred the
Subject Vehicle and LUNSFORD to the secondary inspection for
further inspection.

At the secondary inspection area, a CBP certi?ed-Canine Team
conducted a systemic search of the Subject Vehicle which yielded a
positive alert indicating to the trunk area of the Subject Vehicle.
CBPOs discovered numerous plastic labeled containers within the
trunk of the Subject Vehicle.

Subsequently, CBPOs noticed that the plastic labeled containers
were filled with a liquid substance inconsistent with the actual
labeled product. CBPOs conducted a ?eld test of the liquid
substance which yielded positive for characteristics of
methamphetamine. A total of approximately 21.98 kilograms of
liquid methamphetamine were seized from within the Subject
Vehicle.

In a post-Miranda interview, LUNSFORD stated to Homeland
Security Investigations (HSI) Special Agents (SAs) that he was
promised monetary compensation to smuggle the liquid narcotics
found within the Subject Vehicle. LUNSFORD indicated he
traveled from the Dallas, Texas area to Reynosa, Mexico with
intent to smuggle liquid narcotics from Mexico into the United
States. LUNSFORD admitted he was aware it was unlawful to
smuggle the liquid narcotics from Mexico into the United States.

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