Free Exhibit List - District Court of Delaware - Delaware

Case 1:07-cr-00021-JJF Document 13 Filed 01/24/2007 Page 1 0f 4
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Case 1 :07-cr-00021-JJF Document 13 Filed 01/24/2007 Page 2 of 4
Case 1:07-mj—00od9-MPT Document 2 Filed O1/18/2007 Page 1 of 3
United States District Court R --j - I
DISTRICT (JF DELA.WAR.E f} _
UNITED STATES OF AMERICA
v.
RICARDO ZANELAQASTELAN
Criminal Complaint
- I I i _A I I CASE NUMBER: 07- QQBA
(Name and Address ¤|'Defe·ndant)
I, the undersigned complainant, being duly svvom, state the following is true and correct to the best of my knowledge and belief.
On or about January I7, 2007, in New Castle County, in the State and District of Delaware, Defendant Ricardo Zanela-Castelan, a citizen and
national of Mexico, lcnowing and in reckless disregard of the fact that certain aliens had come to, entered and remained in the United States in
violation of law, did transport, move, and attempt to transfer and move such aliens within the United States by means of transportation and
otherwise, in furtherance of such violation oflaw, for the purpose ofcornmercial advantage and private financial gain.
All in violation ofTitle 8, United States Code, Section l324(a)(l)(A)(ii) & (a)(i)(B)(i).
I further state that I am a(n) Special Agent Department of Homeland Securig ICE,and that this complaint is based
` Onicial Title
on the following facts:
See attached Affidavit.
Continued on the attached sheet and made a part hereof: Yes X
I l W S l .
Signature ofComplainant r— L-- A _ - -—-- -· ~ -
William O. Horn j _; i _
Special Agent, '...., . .. .. , . ....,........ -.. I ,
Swom to before me and subscribed in my presence, ` "
at Wiimm ton pa _... 2 ____- 53, `Y '·ti {fig,
Date City and s
Honorable Mary Pat Thynge , I /
United States Magistrate Judge _ _
Namaa rm: eriuaicaai otnw n gaatiite O eel · {

1 Case 1 :07-cr-00021-JJF Document 13 Filed 01/24/2007 Page 3 of 4
Case 1:07-mj-00ou9—l\/1PT Document 2 Filed 01/18/2007 Page 2 of 3
AFFIDAVIT
I, William O. Horn, being duly sworn, depose and say:
1. I am a Supervisory Special Agent with the United States Department of Homeland Security,
Bureau of Immigration & Customs Enforcement (ICE), Dover, Delaware. I have been employed
as a Supervisory Special Agent since October 1, 1997, 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.
2. This investigation is based on information provided by State of Delaware government agencies,
INS/ICE records, and my own observations and interviews.
3. On January 17, 2007, ICE Wilmington received notitication from the Delaware State Police that
a van had been stopped on 1-95 and that the van contained 17 persons who s/poke little or no
English. The truck was driven by an individual claiming to be Pedro HERNANDEZ-Sanchez,
born on , 1976, in Mexico. During questioning of the occupants, the front-—seat passenger,
Ricardo ZANELA—Castelan, was identified by them as another driver ofthe van.
4. On January 17, 2007, your aftiant advised ZANELA of his rights, in Spanish. Once advised of
his rights, ZANELA signed a waiver of his rights and agreed to speak with your aftiant. In a
sworn statement, he admitted that his true and correct name is Ricardo ZANELA-Castelan, and
that he was bom on September 19, 1973, in Mexico. ZANELA stated that he had entered into an
agreement with the alien smugglers who had smuggled him into the United States to share driving
duties in exchange for a 50% reduction in the fees he had to pay for his own smuggling. Whereas
he would have had to pay $1,600, he only had to pay $800.
5. All 17 persons in the van were interviewed by ICE Agents, and all were foand to be in the
United States illegally. ZANELA stated, under oath, that he knew that the passengers in the truck
were illegal aliens and that they had entered together.
WHEREFORE, your aftiant avers there is probable cause to believe that Ricardo ZANELA-
Castelan, a citizen and national of Mexico, knowing that 16 other aliens had come into, entered, or
remained in the United States in violation of law, transported, or attempted to transport, such
aliens within the United States by means of transportation or otherwise, in furtherance of such
violation oflaw, in violation ofTitle 8, United States Code, 1324(a)(1)(A)(ii) & (B)(i).
William O. Horn
Special Agent
U.S. Immigration & Customs Enforcement

Case 1 :07-cr-00021-JJF Document 13 Filed 01/24/2007 Page 4 of 4
Case 1:07-mj-00009-MPT Document 2 Filed 01/18/2007 Page 3 of3
Subscribed and sworn to before me this jfkday oflanua 99 .
P I `
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The Ho Mary Pat - _
United tates Magistrat .' • e