Case Document 1 Filed in TXSD on 12/15/18 Page 1 of 3 A0 91 (Rev. 02/09) Criminal Complaint UNITED STATES DISTRICT COURT for the Southern District of Texas McAllen Division United States of America v. 4- Ser io Eduardo an YOB 1962, . . Mexico) Case No. \8 W55 2. 560 ?Z'Faustino (YOB 1972, Mexico) 3- Carlos (YOB 1965, Mexico) Defendant 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 of December 14,. 2018 in the county of Hidalgo in the Southern District of Texas ,the defendant violated 18 U. S. C. 554(a) an offense described as follows: It shall be unlawful for any person to fraudulently or knowingly export or send from the United States, or attempt to export or send from the United States, any merchandise, article, or object contrary to any law or regulation of the United States, or receive, conceal, buy, sell, or in any manner facilitates the transportation, concealment, or sale of such merchandise, article or object, prior to exportation, knowing the same to be intended for exportation contrary to any law or regulation of the United States, to wit: One thousand (1,000) rounds UMC 9mm ammunition, three hundred ?fty (350) rounds Blazer Brass .380 caliber ammunition, two hundred (200) rounds Federal .243 caliber ammunition, and twenty (20) rounds Winchester .270 caliber ammunition. This criminal complaint is based on these facts: See Attachment A. IZI Continued on the attached sheet Michael Venegas Complainant 's signature Michael Venegas, HSI Task Force Of?cer Printed name and title Sworn to before me and signed in mv presence. Submitted by reliable electronic means, sworn to and attested to electronically per Fed. R. Cr. P. 4. found on and probable cause Date: December 15, 2018 9?:ch A . Judge ?8 signature City and state: McAllen, Texas Juan F. Alanis, U.S. Magistrate Judge Case 7:18-mj-02560 Document 1 Filed in TXSD on 12/15/18 Page 2 of 3 Attachment A The facts establishing the foregoing issuance of a criminal complaint are based on the following: 1, Homeland Security Investigations (HSI) Task Force Of?cer (TFO) Michael Venegas, Af?ant, do hereby depose and state the following: On December 14, 2018, United States Customs and Border Protection Of?cers (CBPOs) were working the outbound travel lane at the Hidalgo International Bridge Port of Entry (POE) in Hidalgo, Texas when CBPOs observed a silver Honda Ridgeline and a blue Ford F-250 truck enter the outbound travel lanes. A CBPO identi?ed the driver of the Ford as Faustino and the driver of the Honda Ridgeline as Sergio Eduardo PEREZ-Barragan. An additional passenger in the Honda Ridgeline was identi?ed as Carlos Ledezma. A CBPO took a negative declaration from VELAZQUEZ, PEREZ, and CASANOVA for being in possession of any ammunitions and referred the Honda Ridgeline and Ford F-250 for a secondary inspection. During the secondary inspection packages were discovered in the Ford F-250 containing one thousand (1,000) rounds of UMC 9mm ammunition, three hundred ?fty (350) rounds of Blazer Brass .3 80 caliber ammunition, two hundred (200) rounds of Federal .243 caliber ammunition, and twenty (20) rounds of Winchester .270 caliber ammunition. HSI Special Agents (SAs) and HSI TFOs arrived at the Hidalgo International Bridge POE and conducted interviews of VELAZQUEZ, PEREZ, and CASANOVA. VELAZQUEZ stated the ammunition found in the Ford F-250 was given to VELAZQUEZ by CASANOVA at a Wal?Mart parking lot in Hidalgo County. VELAZQUEZ further stated VELAZQUEZ was to be paid in ammunition by CASANOVA once VELAZQUEZ success?illy smuggled the ammunition into Mexico from the United States. CASANOVA stated the ammunition found in the Ford F-250 was purchased by PEREZ on December 14, 2018 in Cameron and Hidalgo Counties, Texas. CASANOVA further stated CASANOVA and PEREZ did not want to export the ammunition purchased by PEREZ into Mexico from the United States because neither had a license to export amrhunition and both knew it was a violation of United States Law to do so without a license. CASANOVA stated CASANOVA and PEREZ went to a Wal?Mart in Hidalgo County, Texas and transferred the one thousand (1,000) rounds of UMC 9mm ammunition, three hundred ?fty (350) rounds of Blazer Brass .380 caliber ammunition, two hundred (200) rounds of Federal .243 caliber ammunition, and twenty (20) rounds of Winchester .270 caliber ammunition to VELAZQUEZ who was to smuggle the Case Document 1 Filed in TXSD on 12/15/18 Page 3 of 3 Attachment A I ammunition via the Hidalgo International Bridge POE to Mexico. CASANQVA stated once in Mexico, CASANOVA and PEREZ were to meet with VELAZQUEZ to retrieve the ammunition from Ford F-250. VELAZQUEZ and CASANOVA admitted to knowing that smuggling ammunition from the United States was contrary to United States Law. Ammunition cannot be exported outside of the United States without a license in accordance with Title 22, United States Code Section 2778 and Title 22 of the Code of Federal Regulations. VELAZQUEZ, PEREZ, and CASANOVA do not have a license to export ammunition. Michael Venegas Complainant?s Signature Michael Venegas. HSI TFO Printed Name and Title Sworn to before me and signed in my presence. Submitted by reliable electronic means, sworn to and attested to electronically per Fed. R. Cr. P. 4.1, and probable cause found on Date: December 15. 2018 ?92744. Judge?s Signature Juan F. Alanis. Magistrate udge City and state: McAllen TX Printed Name and Title