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llase Document 125-1 Filed 09/28/18 Page 1 of 3 Page ID #:111( 

NICOLA T. HANNA
United States Attorney
LAWRENCE S. MIDDLETON
Assistant United States Attorney
Chief, Criminal Division
VICTORIA A. DEGTYAREVA (Cal. Bar No. 284199)
Assistant United States Attorney
OCDETF Section
1400 United States Courthouse
312 North Spring Street
Los Angeles, California 90012
Telephone: (213) 894-7635
Facsimile: (213) 894-0142
E?mail: Victoria.Degtyareva@usdoj. gov

Attorneys for Plaintiff
UNITED STATES OF AMERICA

UNITED STATES DISTRICT COURT
FOR THE CENTRAL DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA,
Plaintiff,
Case Number: ED CR GB

DECLARATION OF ASSISTANT
DIRECTOR MATTHEW c. ALLEN

vs.
SLAVCO IGNJATOV, et al.,

Defendants.



 

I, Matthew C. Allen, declare as follows:

1. I am the Assistant Director (AD) for the Domestic Operations Division within the
US. Department of Homeland Security (DHS), US. Immigration and Customs Enforcement?s
(ICE) Homeland Security Investigations (HSI). I have occupied this position since 2018. From
2007 to 2008, I was the Deputy Assistant Director (DAD) of the Narcotics, Financial and Public
Safety Division. From 2006 to 2007 I was the DAD and acting DAD for the Critical Infrastructure

and Fraud Division in the ICE, Of?ce of Investigations. Before that position, I served as

DECLARATION OF ASSISTANT DIRECTOR MATTHEW C. ALLEN
CASE NO. PAGE 1 of 3

 

 

 



I?l u?a h?l i?n v?I'v?A t?O


 

 

llase Document 125-1 Filed 09/28/18 Page 2 of 3 Page ID #:111'

Headquarters Unit Chief for the Contraband Smuggling Unit and previously served as the
Resident Agent in Charge in Nogales, Arizona, where I was responsible for managing 
investigative activities within the Nogales geographic area.

2. In my current position, I am responsible for managing, directing and coordinating
all investigative activities of the various domestic ?eld of?ces. These responsibilities include
ensuring implementation and adherence to policies, procedures, guidelines, and directives
governing investigative activities. The Domestic Operations Division ensures the implementation
of investigative activities and programs in conformance with national priorities. The
Division is also responsible for monitoring and evaluating productivity of the various ?eld of?ces
and ensuring prompt communication of signi?cant activity from ?eld components to appropriate
headquarters management.

3. I am aware of the proceedings and underlying investigation associated with the
above-captioned case. I submit this declaration to describe longstanding practices and
procedures on the use of GPS tracking devices in HSI investigations. The statements I make
herein are based on my personal knowledge and on facts and information provided to me in the
course of my of?cial duties.

4. H81 exercises its border-search authority for the purpose of protecting national
security and revenue of the United States. Pursuant to this authority, it is policy that a
customs officer may install a GPS tracking device on a vehicle at the United States border without
a warrant or individualized suspicion. HSI limits warrantless GPS monitoring to 48 hours, with
the exception of airplanes, commercial vehicles, and semi-tractor trailers, .which have a 
signi?cantly reduced expectation of privacy in the location of their vehicles. It is position
that such policy is consistent with the U.S. Supreme Court?s decisions in United States v. Jones,
565 U.S. 400 (2012), and United States v. Flores-Montana, 541 U.S. 149 (2004).

5. position on the use of GPS tracking devices was developed, in consultation

with the Department of Justice, in response to the 2012 Jones decision, and is found in HSI

DECLARATION OF ASSISTANT DIRECTOR MATTHEW C. ALLEN
CASE NO. l7-cr-00222-JGB PAGE 2 of 3

 





12

A

and correct and that this declaration was executed on September 24, 2018.



 

Matthew C. Allen

DECLARATION OF ASSISTANT DIRECTOR MATTHEW C. ALLEN
CASE NO. 

 

 

Ease Document 125-1 Filed 09/28/18 Page 3 of 3 Page ID 

policies and procedures, as well as trainings regularly provided to HSI personnel, all of which

were in place throughout the pendency of this case and the underlying investigation.

I declare under penalty of perjury under the laws of the United States that the foregoing is true

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