Case 3:15-mj-00792-ATB Document 1 Filed 03/18/15 Page 1 of 2

AO 91 (Rev. 11/11) Criminal Complaint

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UNITED STATEr1STRICT COURT

Western District of Texas

United States of America

V.

Case No.

Aifredo SANCHEZ

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Defendant(s)

CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best

On or about the date(s)

Western

of

District of

March 17, 2015

Texas

in the county of

and belief.

El Paso

inthe

the defendant(s) violated:

Offense Description

Code Section
Title 21 U.S.C. 841(a)(1).

of my knowledge

Defendant did knowingly and intentionally possess with the intent to distribute
0.22 kilograms (gross weight) of Heroin, a Schedule Controlled Substance.
I

Title 21 U.S.C. 952(a).

Defendant did knowingly and intentionally attempt to import 0.22 kilograms

(gross weight) of Heroin, into the United States.

This criminal complaint is based on these facts:

See attached affidavit.

I1 Continued on the attached sheet.

Complainant's signature

Omar Chavarria, HSI Special Agent

Printed name and title
Sworn to before me and signed in my presence.

Date:

03/18/2015
Judge 's signature

City and state:

El Paso, TX

Anne T. Berton
Printed name and title

Case 3:15-mj-00792-ATB Document 1 Filed 03/18/15 Page 2 of 2

AFFIVADIT

On March 17, 2015, at approximately 7:21 AM, Aifredo SANCHEZ was encountered at
the primary inspection lane of pedestrian crossings at Ysleta, Port of Entry (POE),
located in El Paso, TX. SANCHEZ presented a State of Florida identification card
bearing his name and photo. Customs and Border Protection Officer (CBPO) conducted
records checks on SANCHEZ. Records checks yielded a Treasury Enforcement
Communications System (TECS) look out for narcotics trafficking. SANCHEZ was
referred to Passport Control Secondary (PCS) for further inspection.
During a secondary inspection, a pat down of SANCHEZ was conducted and a narcotics
identifying K-9 inspection was conducted. The K-9 inspection of SANCHEZ' person
was negative. But during the pat down, a CBPO felt and heard an abnormality under the
buttocks area SANCHEZ' pants. SANCHEZ was handcuffed and questioned as to
whether he was in the possession of narcotics, to which he responded he did not. A more
in depth pat down was requested and conducted on SANCHEZ. During this inspection, s
CBPO observed an object with a white rubber tip inserted in SANCHEZ' rectum.
SANCHEZ continued to deny he was in possession of any narcotics. SANCHEZ then
consented to an X-ray and medical exam.
At approximately 9:00 AM, SANCHEZ was transported to the University Medical Center
(UMC). UMC personnel asked SANCHEZ for consent to conduct rectal exam, at which
time, SANCHEZ admitted to possessing narcotics.
At approximately 11:13 AM, SANCHEZ removed a cylindrical shaped bundle from his
rectum in the presence of CBP officers. The bundle contained a brown tar substance
which field tested positive for the properties of heroin and had an aggregate weight of
0.22 kgs/.048 lbs.
The CBP officers notified Homeland Security Investigations (HSI) Special Agent Juan
Ortiz of the seizure. SA Ortiz responded to Ysleta POE.

At approximately 3:46 PM, SA Ortiz in the presence of Department of Public Safety

(DPS) Special Agent Daniel Martinez read SANCHEZ his Miranda Rights. SANCHEZ
advised he understood his rights and agreed to speak with the agents without an attorney
present.
SANCHEZ explained he is a heroin addict that needs to maintain his habit. SANCHEZ
stated he was approached by a subject only known as "STEVE" to pick up an unknown
amount of heroin from an unknown female in Mexico and smuggle the heroin to El Paso,
Texas. SANCHEZ stated he was going to be paid with one or two grams Of heroin.
The case was presented to, and accepted for federal prosecution by AUSA Steve
Armstrong.