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UNITED STATES DISTRICT COURT
FILED
2 FEB 1 2 201b
SOUTHERN DISTRICT OF CALIFORN
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4 UNITED STATES OF AMERICA, Case No.:
5 Plaintiff,
COMPLAINT FOR VIOLATION OF
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v. Title 21 U.S.C. § 952 and 960
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Importation of a Controlled Substance
8 Eduardo SAIS-Peinado, (Felony)
9 Defendant.
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H----------------~ 18MJ0626
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12 The undersigned complainant being duly sworn states:
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On or about February 10, 2018, within the Southern District of California,
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The complainant states that this complaint is based on the attached Statement o
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23 Facts incorporated herein by reference.
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25 Special Agent Michael R. Baxter
Homeland Security Investigations
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SWORN TO BEFORE ME AND SUBSCRIBED IN MY PRESENCE, THIS _12th_
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4f=-~ -
DAY OF February 2018.
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ANDREW G. SCHOPLER
Case 3:18-mj-00626-AGS Document 1 Filed 02/12/18 PageID.2 Page 2 of 4
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I, Homeland Security Investigations (HSI) Special Agent Michael R. Baxter,
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9 the United States from Mexico through the San Ysidro (SYS), CA, Port of Entry
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(POE) in vehicle lane #12. SAIS-PEINADO was the driver and sole occupant of a
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At approximately 1822 hours, Customs and Border Protection Officer
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(CBPO) Joshua Quilici was conducting roving operations in pre-primary when he
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19 was driving to Chula Vista, CA. CBPO Quilici asked SAIS-PEINADO if he had
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anything to declare. SAIS-PEINADO stated he did not. SAIS-PEINADO told
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CBPO Quilici the vehicle was his and only his girlfriend uses the vehicle. CBPO
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23 Quilici began to inspect the vehicle. CBPO Rey assisted Quilici. According to
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CBPO Rey's K910B buster, the doors of the vehicle were reading high. CBPO
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2 Manis and her dog responded to a call for assistance to screen the Jeep Liberty.
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CEO Manis' assigned canine alerted to the vehicle's door. CEO Manis advised
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16 the vehicle's rear door. CBPO Vasquez probed one of the packages and extracted
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a white-powdery substance. The substance was tested and resulted in a positive
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The combine (approximate) total weight of the cocaine was 17.58 kilograms
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(38.75 pounds).
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Case 3:18-mj-00626-AGS Document 1 Filed 02/12/18 PageID.4 Page 4 of 4
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Michael R. Baxter, HSI Special Agent
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On the basis of the facts presented in this probable cause statement
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consisting of 3 pages, I find probable cause to believe the defendant, EDUARDO
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