Case Document 1 Filed on 12/10/18 in TXSD Page 1 of 2

A0 91 (Rev. 11." 1 1) Criminal Complaint

UNITED STATES DISTRICT COURT

 

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for the 
Southern District of Texas DEC 1} 
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YOB: 1988 (MEX) 3 Case NO- I 9 5! 







Defendant(s)
CRIMINAL COMPLAINT

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 04t03/2018
Southern District of Texas
Code Section
the county of

the defendant(s) violated:

Webb in the

 

O??e?nse Description

Conspiracy to Possess with the intent to Distribute and Possession with
Intent to Distribute Methamphetamine, approximately 18.5 kilograms, a

schedule ll controlled substance, and Cocaine, approximately 5.25 kilograms,
a schedule ll controlled substance.

This criminal complaint is based on these facts:

(See Attachment 

i Continued on the attached sheet.

Wee?7

/I?s/020 

Sworn to before me and signed in my presence.

. City and state: Texas

 

51/8/11

Complainant '5 signature

 

Christopher Donahue, DEA Special Agent

Printed name and title



I Judge ?5 Signature

 

 

Peter U.S. Magistrate Judge

Printed name and title

 

Case Document 1 Filed on 12/10/18 in TXSD Page 2 of 2

ATTACHMENT I

1. During March 2018, a Drug Enforcement Administration Task Force Of?cer, acting
in an undercover capacity (hereafter, UC) began negotiations with Christian REYNA-
RODRIGUEZ (hereafter, REYNA) to transport narcotics from the Rio Grande
Valley area of Texas to Atlanta, Georgia. REYNA subsequently told the UC that the
UC would be picking up four (4) to ?ve (5) parts (narcotics) in Laredo, Texas.

2. On April 03, 2018, the UC telephonically spoke with REYNA and advised REYNA
that the UC was in Laredo, Texas and was ready to receive the narcotics. REYNA
subsequently told the UC that his associates were in route to the location to
make the delivery to the On this same day, two (2) Hispanic males delivered
four (4) tractor trailer batteries to the UC which were to be transported to Atlanta,
Georgia. Later on this same day, REYNA told the UC that the UC would be paid after
successfully delivering the narcotics. I

3. On April 04, 2018, the UC telephonically spoke with REYNA. During the
conversation, REYNA provided the UC with the telephone number of a person to
contact in order to deliver the four (4) batteries.

4. On April 05, 2018, agents opened the four (4) batteries which revealed eighteen
bundles of suspected narcotics. Twelve (12) bundles, weighing approximately 185
kilograms, tested positive for the characteristics and properties of methamphetamine.
Six (6) bundles, weighing approximately 5.25 kilograms, tested positive for the I
characteristics and properties of cocaine. The suspected narcotics were removed from
the four (4) batteries and substituted with simulated narcotics.

5. On April 05, 2018, the UC called the phone number provided to the UC the previous
day by REYNA. The UC subsequently spoke with a Drug Traf?cking Organization
(DTO) member and provided the DTO member with the location in Atlanta,
Georgia. On this same day, a DTO member arrived at the location and took
Custody of the four (4) batteries from the UC. The DTO member then provided the
UC with $25,500 US. currency and departed the meeting location. Shortly after
delivering the batteries to the DTO member, the UC telephonically spoke with
REYNA. During the subsequent conversations, REYNA and the UC discussed the
logistics of delivering the narcotics to Atlanta, Georgia.