Free Redacted Document - District Court of Delaware - Delaware

Case 1:07-cr—OOO58—JJF Document 2 Filed O4/17/2007 Page 1 of 3
AD 91 lHav.5$5l Crlmtnal Comnlalnt O ‘ I _ p
. Qgrcrteit C§tatza QB ratrtrt (Haart
` `_ . orsnucr or ELA“ARE I - .
1 UNITED STATES OF AMERICA
V. _ ‘ 1 .
CRIMINAL COMPLAINT
vmncmtira VILLALOBOS RODRIGUEZ ‘
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I IPJIQU MS`? agi
i Le. { 'C.1,
ptquuaammsolwmnra t A as .. ..1"'t K,} L1__]1__,/{ -
I. the undersigned complainant being duly_ swom state the following is true and correct to the best of mi
knowledge and belief. On or about in ......_........._......_.. - county, in tm
.......;........... District of d¤fBrldant(s) dld, nm: enum umm erormml
see Attachment A U I
` n 8 ’ 1325 (a) (1)
18 911, l5£t6Ea; and 1028(a) (el)
in violation of Title .£......._. United States Code, Section(s)
l further state that l am atn) and that this complaint is based on the following
facts; AFFIDAVIT attached. `
I p I rim;
E A _ APH 1 7 2007
i I 1 i
g 115. 0¤st0YEt”'EGLTé`%“t"`°I"] 3
. r E
E Continued on the attached sheet and made a part hereot: x Yes I] No ‘ ‘
. Signature. ot Complainant
David B. Yeary g
Swom to before me and subscribed in my presence, égigigeggig HOD and
Eg; at Wilmington, Delaware I . l
‘ Date Clty and State `
Honorable Mary Pai: Thynge A
United States Magistrate Judge _ . · · _ _
p Name lt 11tle ol Judicial Otlicer - 9 atura rclal Ctlicar

Case 1 :07-cr—OOO58—JJF Document 2 Filed O4/17/2007 Page 2 of 3
- AF FIDAVIT U A
1, David B. Yeary, being duly sworn, depose andsay:
I ‘ 1. I am a Special Agent with the United States Department of Homeland Security, Bureau of
Immigration & Customs Enforcement (ICE), Dover Delaware. I have been employed as a
Special Agent since January 25, 2003, when I was employed by the INS. The INS was
transferred to the U.S. Department of Homeland Security as the Bureau of Immigration &
Customs Enforcement in March 2003. p
` s 2. This investigation is based on information developed through an ongoing ICE
P investigation, INS/ICE database queries, and my own observations and interviews.
· 3. On or about April 13, 2007, at approx 1100 hrs a Federal Search Warrant was executed
_ at 1 ;, Blades Delaware 19973. At this residence one Vicente VILLALOBOS s
_ Rodriguez (VILLALOBOS) was encountered. He was asked his citizenship and status in the
United States, and he claimed to be a Mexican citizen and an illegal alien. -
4. On April 16, 2007, an interview of VILLALOBOS was done with Special Agent William
‘ Horn interpreting. During the interview VILLALOBOS stated that he worked at
Mountaire Poultry Plant in Selbyville, DE. VILLALOBOS stated that he worked under the
name Luis Angel N AVARR0 Vasquez. VILLALOBOS stated that he presented a Social P
Security Card and an Ohio State Identilication card to obtain employment at Mountaire
_ Poultry Plant in_Selbyville, DE. · . ‘ A
`5. A. copy of the U.S. Department of .Iustice Employment Eligibility Verification (Form I-9)
" was obtained from Mountaire Poultry Plant in Selbyville, DE. The Form 1-9 was shown to
. VILLALOBOS. He stated that he signed this form and that the copy of the Ohio ID and
Social Security Card are what he presented. On the 1-9 VILLALOBOS checked the box
stating that he was a Citizen or a national ofthe United States. The I-9 Form was signed
and dated on 08!20/2004. ‘ .
6. A Sworn Statement was taken with the assistance of special Agent William Horn. In this l
statement VILLALOBOS stated that he had entered the United States without Inspection . `
i at./near Douglas AZ, on/about 04/14/2004. A review of the ICE Central Index System ‘ -
_ database does not reveal any evidence of a legal entry into the United Sates. ·
WHEREFORE, your afiiant avers that there is probable cause to believe that
r VILLALOBOS is in violation of 8 U.S.C. 1325; 18 U.S.C. 1028, 1546 and 911; and 42
_ U.S.C. 408(a)(7)(B). --`A -
_. _ David B Yeary A ‘ p ` `.‘e I
· s Special Agent · A y
` _ U.S. Immigration & C stems Enforcement - s. _ `

Case 1 :07-cr—OOO58—JJF Document 2 Filed O4/17/2007 Page 3 of 3
i ' I _ B. Attachment A
_ On or about April 14, 2004, the defendant, an alien and subject of Mexico, did knowingly
and unlawfully enter the United States from Mexico at a point in Arizona, at a time and place that
. was then and there other than as designated by Immigration officials of the United States for the
entrance of immigrants into the United States, and the defendant was apprehended in the District of
Delaware, in violation of 8 U.S.C. § l325(a)(l) and 1329. ·
On or August 20, 2004, in the District of Delaware, the defendant falsely and willfully
represented himself to be a citizen of the United States when applying for a job and submitting an
Immigration Fonn 1-9, in violation of 18 U.S.C. § 911. — · "
On or about August 20,_ 2004, in the District of Delaware, the defendant knowingly did
possess, utter, and use a Social Security card, a document proscribed by statute and regulation as _ ‘
evidence of authorized employment in the United States, knowing the documents were unlawfully
' I obtained, in violation of 18 U.S.C. § 1546(a). .
On or about August 20, 2004, in the- District of Delaware, the defendant knowingly did
r possess, utter and use a Social Security card and a State driver’s license, neither document lawfully `
issued to the defendant, with the intent that such documents be used to defraud the United States V
Immigration and Customs Enforcement, an agency of the United States, in violation of 18 U.S.C. V
§ l028(a)(4). , p ‘
I I On or about August 20, 2004, in the District of Delaware, the defendant willfully and A
_ knowingly, and with intent to obtain employment by deception, did falsely represent that a particular
Social Security account number had been assigned to him by the Social Security Administration,
when in fact, the defendant knew the Social Security number had not been assigned to him, in
violation of 42 U.S.C. § 408(a)(7)(B). A A