Case 7:17-cr-OO431 Document 1 - Filed on 02/22/17 in TXSD Page 17 of 3

A0 91 (Rev. 02/09) Criminal Complaint

 
  

 

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UNITED STATES DISTRICT COURT
forthe FEB 12.5? 

Southern District of Texas 
aw? Bmdier. Clerk

Case No. &3 

United States of America
V.
Kerena 
YOB: 1970
COBzMeXico



 

Defendant

 


CRIMINAL COMPLAINT

I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
From on or about December 2014 to February 2017, in the county of Harris in the SOuthern District of Texas,
The defendant Violation Title 18 United States Code, 1341 and 1349, an offense described as follows

did willfully, that is, with the intent to further the objects of the conspiracy, and
knowingly combine, conspire, confederate, and agree with each other and with persons
known and unknown to knowingly and with the intent to defraud, devise, and intend to
devise a scheme and artifice to defraud and to obtain money and property from others by
means of materially false and fraudulent pretenses, representations, and promises, and
knowingly cause to be delivered certain mail matter by the United States Postal Service
and by private commercial interstate carrier for the purpose of executing the scheme.

This criminal complaint is based on these facts:

See Attachment A

?ip-wag 1'3 all: 73:94 Lam-:9

Continued on the attached sheet

 

 

m? signature
Gustavo nzal ,Special Agent 
P?Mme and title

Sworn to before me and signed in my Drese?nce.

Date: 102112212017 5 cue-v 

Judge? signature
City and state: MCAllen, Texas Peter E. U. S. Magistrate

Printed name and title

 

 

 

 

Case 7:17-cr-OO431 Document 1 Filed on 02/22/17 in TXSD Page 2 of 3

I Attachment A

In early 2014, the undersigned learned of a group identifying itself as the Yamassee tribe,
also the Yamassee Native American Association Of Indians. This tribe is not a federally
recognized Indian tribe. Members of the tribe were claiming that tribal citizenship,
available for purchase, would grant tribe members the ability to work, live, and drive in
the United States, no matter the member?s immigration status. In Texas, the Yamassee
tribe primarily targeted undocumented aliens for recruitment.

011 March 17, 2015, Humberto REVELES entered a plea of guilty to 18 United States

Code (USC) Sections 1341 and 1349 for his role in the Yamasee Naturalizatioandoption
fraud scheme. 

Evidence discovered during the REVELES investigation led to the identification of
ALMEIDA. ALMEIDA is herself an undocumented alien from Mexico who enrolled as a
Yamassee tribal member on March 29, 2014. In December 2014, ALMEIDA applied and
began paying to be a Chief of the Yamassee tribe in the Houston, Texas, area.

Evidence obtained through this investigation indicates ALMEIDA collects application,
processing, and other fees from her victims and sends a signi?cant portion of the fees to
other YamaSsee tribal leaders. Tribal applications, documents, and other literature would
be sent to and via U.S. Postal Service and Federal Express from various
locations in and Nevada. Additionally, ALMEIDA would send completed 
?tribal identification cards? and other documents to individuals out of state via U.S. 
Postal Services and Federal Express.

Based on information obtained during the execution of federal search warrants in email
addresses associated with this investigation, ALEMIDA corresponded with a known co-
conspirator on January 29, 2016, and advises the co?conspirator that she was aware
REVELES had been convicted criminally for his role and participation in the Yamassee
fraud and naturalization scheme. In this email correspOndence, ALMEIDA expresses
concern about being accused of fraud herself.

On December 02, 2015, ALMEIDA was present in federal court as an enrolled Yamassee
tribal member and previously deported alien pled guilty to 8 USC Section 1326, illegal
reentry. ALMEIDA witnessed that the individual was still deportable despite tribal
membership. 

On October 12, 2016, Homeland Security Investigations (HSI) special agents (SA)
monitored a meet between an undercover (UC) agent and Kerena 
ALMEIDA met with the UC agent, posing as an undocumented alien from Mexico, to
enroll and obtain money from the UC agent in exchange for adoption and? or membership
into the Yamassee Native American Association of Indians. ALMEIDA claims this
membership and its documents allow a person be in the United States legally.

A follow-up undercover meeting with ALMEIDA is currently scheduled for February-23,
2017.

Case 7:17-cr-OO431 Document 1 Filed on 02/22/17 in TXSD Page 3 of 3

Attachment A 

Despite claims, Yamassee documents and/or tribal membership cannot
legitimately be used as a lawful basis to reside, work, or drive in the United States for
those unlawfully present in the United States.

 

Gustavo Gonzalez, Special Agent
Immigration Customs Enforcement

Sworn to before me and signed in my presence on February 22, 2017, in McAllen, Texas.

 

Peter E. . .
United States Magistrate Judge