Case 3:17-mj-00778-MDD Document 1 Filed 03/15/17 PageID.1 Page 1 of 2
BLANCA QUINTERO )(
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, Plaintiff, v. Jose Emiliano AGUILAR, Defendants.
) ) ) ) ) ) ) ) )
17MJ0778
Magistrate Case No. _ _ _ _ _ __ COMPLAINT FOR VIOLATION OF
Title 8, U.S.C., Section 1324(a)(2 )(B )(iii)Bringing in Unlawful .tjUJJ;.UJA}-----::----, Without Presentation
FIlED MAR 15{ 2017
The undersigned complainant being duly sworn states:
CU.:HK us DIS 1HIC1 COUf-lT . SOUTHf:.HN DISTRICT OF CALIFORNIA BY DEPUTY
On or about March 14, 2017, within the Southern District of California, Defendant, Jose Emiliano AGUILAR, with the intent to violate the immigration laws of the United States, knowing and in reckless disregard of the fact that aliens, namely, Fenjiao FENG, Yuanzhang LIN, Lingling TANG and Yiming WANG had not received prior official authorization to come to, enter and reside in the United States, did bring to the ,United States said aliens, and upon arrival did not bring and present said aliens immediately to an appropriate immigration officer at a designated port of entry; in violation of Title 8, United States Code, Section 1324(a)(2)(B)(iii). And the complainant states that this complaint is based on the attached statement of facts, which is incorporated erein by refer nce. ,
OF COMPLAINANT Victor Renteria, CBP Officer U.S. Customs and Border Protection Sworn to before me and subscribed in my presence, this 15 th day of March, 2017.
TED STATES MAGISTRATE JUDGE
Case 3:17-mj-00778-MDD Document 1 Filed 03/15/17 PageID.2 Page 2 of 2
PROBABLE CAUSE STATEMENT The complainant states that Fenjiao FENG, Yuanzhang LIN, Lingling TANG, and Yiming WANG are citizens of a country other than the United States; that said aliens have admitted they are deportable; that their testimonies are material; that it is impractical to secure their attendance at trial by subpoena; and that they are material witnesses in relation to this criminal charge and should be held or admitted to bail pursuant to Title 18, United States Code, Section 3144. On March 14, 2017, at approximately 5:46 P.M., Jose Emiliano AGUILAR (Defendant), a United States citizen, entered the United States from Mexico via the San Ysidro, California Port of Entry. Defendant was the driver of a 2014 Chrysler 200 bearing California license plates with P.LC.J as a passenger. Upon inspection before a United States Customs and Border Protection Officer, Defendant identified himself with his United States Passport card while P.L.C.J. identified herself with her Border Crossing Card (DSP-150). Defendant stated they were going to San Diego, California and had nothing to declare from Mexico. During primary inspection, a canine unit conducting pre-primary roving operations, alerted to the vehicle's trunk. After Defendant unlocked the trunk the CBP canine officer inspected it and saw several people hidden inside. Defendant and passenger were secured and escorted to secondary inspection along with the vehicle. In secondary, responding CBP Officers assisted and removed four people from the trunk. The individuals, later identified as Fenjiao FENG (MWl), Yuanzhang LIN (MW2), Lingling TANG (MW3) and Yiming WANG (MW4), were determined to be Chinese citizens without lawful documents to enter or reside in the United States and were held as Material Witnesses. During a video recorded interview, the Material Witnesses admitted they are citizens of China without lawful documents to enter the United States. Each Material Witness said they made their own smuggling arrangements and agreed to make a payment ranging from $3,000.00 to $60,000.00 if they successfully entered the United States. Two Material Witnesses said they were going to Los Angeles, California and two said they were going to New York, New York.