A0 91 (Rev 3 . United States District Court - DISTRICT OF SOUTHERN . MCALLEN DIVISION UNITED STATES OF AMERICA v. CRIMINAL COMPLAINT Paola Zaleta-Hernandez PRINCIPAL Case Number: YOB: 1990 Mexico M-19-0076-M Gerson Moises Bprjas-Garcia CO-PRINCIPAL YOB: 1997 Honduras Sergio AImazan?Soto YOB: 1989 Mexico Mario Alberto Torres-Bolanos CO-PRINCIPAL YOB: 1986 Mexico (Name and Address of Defendant) I, the undersigned complainant being duly sworn state the following is true and correct to the best of my knowledge and belief. On or about January 9, 2019 in Hidalgo County, 1n the Southern District of Texas defendants(s) did, (Track Statutory Language of Offense) knowing or in reckless disregard of the fact that Kenia Maricela Medina-Carrasco, citizen of Honduras and Hadey Abigail Gomez-Chavez, citizen of El Salvador, along withfifty-five (55) other undocumented aliens, for a total of fifty-seven (57), who had entered the United States in violation of law, concealed, harbored or shielded from detection or attempted to conceal, harbor, or shield from detection such aliens in any place, including any building or means of transportation, to-wit: a residence located in Edinburg, Texas; in violation of Title 8 i United States Code, Section(s) FELONY I further state that I am a(n) US. Senior Border Patrol Agent and that this complaint is based on the following facts: On December 12, 2018, Border Patrol Agents (BPA) received information of a suspected stash house in Edinburg, Texas. I I On January 9, 2019 BPAs conducted surveillance on the targeted house and observed several subjects in the rear of the house. Shortly after, a black sports utility vehicle (SUV) was seen arriving to the property. One male subject exited the house and boarded the the vehicle then drove away from the house. Agents then requested assistance from the Hidalgo County Sheriff?s Of?ce. A Deputy responded and observed the driver of the black SUV make a traf?c violation and proceeded to conduct a traf?c stop on the SUV. SEE ATTACHED i Continued on the attached sheet and made a part of this complaint: Gerard 'i 7' ontalvo Senior Patrol Agent Sworn to before me and subscribed in my presence, Printed Name of Complainant January 11, 2019' at McAllen, Texas . Date . 3 7 Juan F. Alanis . U. S. Magistrate Judge Name and ?Title of Judicial Officer case Page 2 of 6 SOUTHERN DISTRICT OF TEXAS TEXAS ATTACHMENT To CRIMINAL COMPLAINT: M-19-0076-M RE: Paola Zaleta-Hernandez Gerson Moises Borjas-Garcia Se'rgio Almazan-Soto Mario Alberto Torres-Bolanos CONTINUATION: BPAs arrived on scene and approached the occupants of the vehicle. The driver was identi?ed as Paola Zaleta?Hernandez and the passenger, Gerson Moises Borjas?Garcia. Agents identi?ed themselves as Border Patrol Agents and questioned both subjects regarding the harboring of illegal aliens (IA). Both subjects freely admitted to being in the United States illegally and admitted they had knowledge of illegal aliens being housed in the stash house. Both occupants were read their Miranda Rights and placed under arrest; Borjas told Agents he resided in the stash house and granted written consent to search his property. Borjas stated there was sixty (60) or more [As currently being harbored at the house. Borj as also stated he left the house in charge to a brush guide he called ?Venado?. Borjas stated ?Venado? had the remote to access the property gate. With the consent from Borjas, Agents and Deputies proceeded to enter the house and encountered ?fty-eight (58) subjects inside the stash house. All subjects were determined to be illegally present in the United States. The subjects were asked if they had knowledge of the remote access for the gate and one subject named Sergio Almazan?Soto, later identi?ed as ?Venado?, told Agents he knew where it could be found. Almazan told Agents that Borjas had handed him the remote. All subjects were transported to the Rio Grande Valley Centralized Processing Center for processing. After interviewing the principals and material witnesses from this case, it was determined that there was another man in?ch'arge as the main coordinator, later identi?ed as Mario Alberto Torres?Bolanos (also known as ?Camaron?T Borjas con?rmed who ?Camaron? was through a photograph in his phone. Agents obtained the address of andther stash house location - where ?Camaron? could be found. On January 10, 2019, Agents conducted surveillance on the suspected stash house and observed a vehicle depart the location. Agents requested assistance from the Hidalgo County Sheriff?s Of?ce. A Deputy responded and observed the driver of the vehicle make a traf?c violation and proceeded to conduct a traf?c stop. The passenger of the vehicle was identi?ed as Mario Alberto Torres-Bolanos (also known as ?Camaron?), a citizen of Mexico illegally present in the United States. ?Camaron? was placed under arrest and was transported to the Border Patrol Station for processing. Page 2 Case Page 3 of 6 SOUTHERN DISTRICT OF TEXAS I TEXAS ATTACHMENT TO CRIMINAL COMPLAINT: M-19-0076-M Paola Zaleta-Hernandez Gerson Moises Borjas-Garcia Sergio Almazan-Soto Mario Alberto Torres-Bolanos CONTINUATION: PRINCIPAL STATEMENTS: Mario Alberto Torres-Bolanos, PaolaZaleta-l?Iernandez, Gerson Moises Borjas-Garcia, and Sergio Almazan-Soto, and were read their Miranda Rights. They understood their rights and each provided a sworn statement. - PRINCIPAL Torres, a citizen of Mexico stated he had been smuggling aliens for about two months. Torres claims that he smuggled undocumented aliens to the house where Border Patrol Agents apprehended 50 to 60 undocumented aliens. Torres admitted he transported the undocumented aliens and took . food to the stash house With the help of a woman. Torres admitted that the woman also transported the aliens and would take food to the stash house. Torres told Agents he had a caretaker at the stash - house and was trying to ?nd guides to walk the undocumented aliens ?irther north. Torres identi?ed Paola, through a photo lineup, as the woman that helped him transport the aliens and take food to the stash house. Torres identi?ed Almazan, through a photo lineup, as the brush guide he transported to the stash house. Torres identi?ed Borjas, through a photo lineup, as the caretaker of the stash house. PRINCIPAL Paola, a citizen of Mexico, stated she illegally entered the United States about three years ago. Paola was asked how she got. involved in alien smuggling and stated that a Mexican man named ?Camaron? offered her ajob to take food to illegal aliens. Paola accepted the offer. in exchange for a free trip to Tennessee that would normally cost $2,500 USD. Paola stated she picked up illegal aliens from ?Camaron? about ten times. Paola admitted she took a total of ?fteen illegal alienstto the stash house. Paola stated ?Camaron? would instruct her to take away the alien?s cell phones. ?Cameron? would give her $150 USD to buy food and would keep $25 USD to put gas in her vehicle. Paola stated shetook food to the illegal aliens at least ?fteen different times. Paola stated that a man by. the name of "Place? would grab the food and take it inside. Paola also stated that "Flaco" would write the names of illegal aliens in a notebook. Paola stated that "Place? was staying at that house and that "Camaron" was renting it. Paola also stated that a foot guide named "El Venado" was going to take the group up north. Page 3 Case 719?? Page 4 0f 6 SOUTHERN DISTRICT OF TEXAS . TEXAS ATTACHMENT TO CRIMINAL COMPLAINT. M- 19- 0076- Paola Zaleta-Hernandez Gerson Moises Borjas-Garcia Sergio Almazan-Soto Mario Alberto Torres-Bolanos CONTINUATION: Paola identi?ed Gerson Moises Borjas-Garcia, through a photo lineup, as ?Flaco? and as the person who would care for the illegal aliens. Paola identi?ed Sergio Almazan Soto, through a photo 11neup, as the brush guide for the illegal aliens. PRINCIPAL Borjas, a citizen of Honduras, stated he illegally entered the United States about three months ago. Borjas stated he was taken to a house where he met Paola. Borjas stayed at Paola?s home for about a month. During his time at the stash house, Borjas stated he started working for Paola and would assist her in taking food to the illegal aliens (1A5) and would also accompany Paola in transporting illegal aliens. Borjas admitted to being paid $200 or $300 USD several times by Paola. Borjas stated he was then offered ajob as a caretaker by ?Camaron?, the man that would take undocumented aliens to Paola. Borjas accepted the job and was taken to the stash house. Borjas stated ?Camaron? paid him $100 USD. At the stash house, Borjas kept a ledger with the names of the undocumented aliens. Borjas stated ?Camaron? and Paola would drop off 1A5 and food at the stash house. Borj as would also accompany Paola to purchase the food. Borjas stated that foot guides would go to the house as well to walk groups further north; he further stated that this time around, ?Camaron? dropped off a foot guide, which he identi?ed as Almazan. Borjas identi?ed Paola Zaleta-Hernandez, through a photo lineup, as the woman that would bring food and transport aliens to the house. .. Borjas identi?ed Sergio Almazan- Soto, through a photo lineup, as the brush guide for the illegal aliens. Page 4 Case Page 5 0f 6 SOUTHERN DISTRICT OF TEXAS TEXAS ATTACHMENT TO CRIMINAL M-19-0076-M RE: Paola Zaleta-Hernandez Gerson Moises Borjas-Garcia Sergio Almazan-Soto Mario Alberto Torres-Bolanos CONTINUATION: PRINCIPAL Almazan, a citizen of Mexico, stated he crossed illegally into the United States. Almazan claims his brother paid $1,800 USD and made his smuggling arrangements. He crossed the river along with ?ve others and were guided using a cell phone. They were eventually picked up and transferred into a Tundra pickup truck driven by a man named ?Camaron?. Once they got to the stash house, ?Camaron? called a man by the name of laco?, later identified as Borjas, to open the property?s gate. Almazan stated Borjas was the caretaker and told them to go inside and not make too much noise. Almazan obserVed Borj as leave with a woman that dropped off food to the house. Almazan admitted that Borjas showed him where the remote for the gate was located so he could Open it. Almazan claimed he used to be a foot guide but no longer guided groups since his last apprehension. Almazan also stated he told others in the house he used to be foot guide. Almazan identi?ed Gerson Moises Borjas- -Garcia, through a photo lineup, as the caretaker of the stash house. Almazan identi?ed Paola Zaleta?Hernandez, through a photo lineup, as the woman that would take food and pickup Borjas. MATERLAL WITNESS STATEMENTS: Hadey Abigail Gomez-Chavez and Kenia Maridela Medina-Carrasco were read their Miranda Rights. Both understood their rights and each provided a sworn statement. Gomez,- a citizen of El Salvador, stated she crossed illegally into the United States. Her family made the smuggling arrangements and paid $5,000 USD. After crossing the river, Gomez stated she was transported to the stash house in a pickup truck driven by a male subject. At the stash house, the driver told them to get off and go inside the house with him. Gomez stated there was about 80 illegal aliens in the house when she first got-to the house. A man, identified as Borjas, wrote down their names in a ledger. Gomez also observed a woman, identi?ed as Paola, take food to the house. Gomez also stated she heard there was a foot guide in the house nicknamed ?El Venado?. Gomez 1 also stated there was another man that would take only females to another house. The man asked Gomez if she wanted to go with him but she refused. Page5 Case. Page 6 ?5 SOUTHERN DISTRICT OF TEXAS TEXAS 7 ATTACHMENT TO CRIMINAL COMPLAINT: M-19-0076-M RE: Paola Zaleta?Hernandez Gerson Moises Borjas-Garcia Sergio Almazan-Soto .. Mario Alberto Torres-Bolanos CONTINUATION: 7 Gomez identi?ed Gerson Moises Borjas-Garcia, through a photo lineup, as the person in charge of the stash. house that wrote names in a ledger. Gomez identi?ed Paola Zaleta?Hernandez, through a photo lineup, as the person that would take people and bring food to the house. Medina, a citizen of Honduras, stated. she crossed illegally into the United States. After crossing the river, a woman, identi?ed as Paola, picked her up and took her to the stash house. Paola told her to get off the vehicle and go inside the house with her. Medina saw Paola several times when she dropped off food at the house. Medina claims that a Mexican man, identi?ed as Borjas, was in charge of the house. Medina stated Borjas would let them know when they were going to bring food and possessed the entry gate remote control. Medina stated a man nicknamed ?Camaron? wrote down her name in a ledger. ?Camaron? also told her that a person nicknamed ?El Venado? was the brush guide that would be taking her on the next group that left. When Venado? arrived, he told them that he would guide them. Medina identi?ed Gerson Moises Borjas-Garcia, through a photo lineup, .as the) caretaker of the stash house. Medina identi?ed Paola Zaleta-Hernandez, through a photo lineup, as the woman that tranSported aliens to the stash house and Would drop off food. . Medina identi?ed Sergio Almazan-Soto, through a photo lineup, as the brush guide. Page 6