Case 1:20-mj-00339 Document 1 Filed on 04/18/20 in TXSD Page 1 of 3 A0 91 (Rev. 11/] 1) Criminal Complaint Fm IV UNITED STATES DISTRICT COURT United States District Court for the Southern District or Texas APR 1 8 2020 Southern District of Texas United States of America i case David J. Bradley, Clerk of Court Edgardo SERRANO Dakar/0mm CRIMINAL COMPLAINT l, 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 April 17, 2020 in the county of Hidalgo in the Southern District of Texas, the defendant(s) violated: Code Section Q?'ense Description Title2l, United States Code, Section 846, Title 1-8, USC ConSpiracy to possess with intent to distribute 75 kilograms of 1956 cocaine, a Schedule II controlled substance conducted or attempted to conduct a ?nancial transaction, knowing the preperty involved in the ?nancial transaction represents the proceeds of some unlawful activity, knowing the transaction was designed to conceal the nature, ofthe proceeds. This criminal complaint is based on these facts: SEE ATTACHMENT Continued on the attached sheet. Compiaitmnt's Signature Zackary Rhinehart Special Agent Printer! name and title Submitted by reliable electronic means, sworn to and signature attested as per Fed. Rules Cr. Proc. 4.1 April 18, 2020 Date 's 'igr Brownsville, Texas Ignacio Telteya U.S. Magistrate Judge ity and tale Pri?ted name and title Case 1:20-mj-00339 Document 1 Filed on 04/18/20 U'rliife?hesiagebbtsinet ham Southern District of Texas . - ruse B-20-MJ-339 - 2020 ATTACHMENT A David. J. 'Iradley, Clerk of Court- 1. On April 15, 2020, HSI Special Agents and Task-Force Of?cers (TFOs) seized 59 kilograms of cocaine in Hidalgo County Texas and encOuntered one subject (source of information? SOI) pursuant to a. probable cause traf?c stop. During a mirandiz?ed interview, the 80] stated the cocaine was part of a bigger load that was to be taken to a ?Cuban? truck driver who would bring bulk cash drug proceeds in the form of United States currency to the Rio Grande Valley to purchase?the cocaine. The $01 stated the - cocaine was intended to be delivered Friday, April 17, 2020 to a location in Hidalgo County, Texas. The SOI stated the tractor truck would be white or black and had a compartment in the fuel tank on the passenger sideof the truck and it would not have a trailer. . 2. On April 16, 2020, under the direction and supervision of law enforcement, the SOI met with multiple subjects in Hidalgo County, Texas and was given an additional 41.30 kilograms of cocaine to store until Friday for the ?Cuban?. 3. In the evening of April 16, 2020, during a consensually monitored conversation, the SOI was instructed via telephone to help load 75 of the kilograms of cocaine obtained on the 15?h and 16th in the tractor truck of the Cuban. The 801 was told the exchange would occur at- Hidalgo, Texas. The SCI told agents he/she has used this location on several occasions to help the Cuban load the cocaine into compartment and offload the bulk cash drug proceeds. 4. The $01 also told agents the Cuban is present when the cocaine is delivered. The 801 stated ?the Cuban? of?oads bulk cash from the fuel tank compartment and loads the cocaine into the fuel tank compartment with the assistance of others. The 801 further stated a small trailer or mobile home located on the edge of the carport was used to count the currency that the Cuban delivered. 5. On April 17, 2020, during a consensually monitored conversation, the SQI was told by another individual who was at the lot, that the Cuban was present. ApprOximately one hour later, law enforcement of?cers arrived at Hidalgo, Texas and executed a search warrant that had been obtained foftWand vehicle. 6. During the search, agents observed a tractor truck similar to the truck previously described; a White tractor truck, with no trailer. It was parked besides the trailer described by the SOI and inside the trailer, agents found a money counter and large bags of rubber . bands, consistent with items needed to count and organize large quantities of bulk cash. 7. Subjects on the location were identi?ed and photographed. The 801 identi?ed Edgardo SERRANO from a photograph as ?the Cuban? that the 801 has helped with loading Cocaine into the tractor and the same Cuban the 801 helped to off-load bulk cash drug proceeds. The 801 further stated SERRANO was the intended recipient for the kilograms that law enforcement seized in paragraphs 1 and 2. The SCI told law enforcement he has delivered to Edgardo SERRANO cocaine in amounts of more than 5 kilograms on more Case DocumentI Filed on 01718720 In IXSD Page's than one occasion in Hidalgo, County, Texas at the instructions of others, and the same individuals instructed the $01 to deliver the cocaine he picked up on" April 15 and 16, 2020 to Edgardo SERRANO. SERRANO was at the place by the tractor relayed to the SOI for the intended delivery of cocaine. The 801 also con?rmed that in the prior deliveries of cocaine to SERRANO, SERRANO knew where the US. Currency was concealed and transferred to the SOI'and others the bulk cash drug proceeds when the SOI delivered the cocaine. 301 further con?rmed the bulk cash drug proceeds were always concealed in the gas tank when of?caded in the 8013 presence at the time of the exchange of the bulk cash for the cocaine. The 801 had done this on more than one occasion in the past in Hidalgo County with SERRANO and that the SOI knew that SERRANO was coming from out of state to deliver the concealed bulk cash in exchange for the cocaine and would be returning out of state to deliver the cocaine to others. SERRANO was at the place, by the vehicle at the time given by those instructing the 801, with the money in the gas tank, corroborating the 801?s information 'of knowledge of the cocaine delivery and bulk cash exchange. SERRANO was asked which vehicle Was his and he stated he did not have any vehicles on the location. SERRANO later stated the white truck was his and he was the owner. 9. Agents utilized a currency on the truck which alerted for the odor of currency. A closer search of the tractor truck revealed a hidden compartment in the truck?s passenger side ?emjus?gg described'by the SOI. Inside the compartment, agents found forty- four bundles of US cmrency. There were numbers indicating amounts on each bundle. According to the markings already on the bundles, it is estimated the currency is approximately 1.7 million US dollars. (AGENT NOTE: The of?cial count is pending) 10. SERRANO was placed under arrest and transported to the H81 Of?ce for processing. At the of?ce, SERRANO was advised of his rights and he requested an attorney. 11. Federal prosecution was accepted for SERRANO for Violation of 18 USC l956?Money Laundering (B) and 21 USC 846-Conspiracy to possess a schedule II-controlled substance, more than ?ve kilograms. Homeland Security Investigations Submitted by reliable electronic means, sworn to and signature attested as per Fed. Flules Cr. Proc. 4.1 0 Date: April 18, 2020 Ignacio Ll United tates Southern Dis or of Texas