Free Redacted Document - District Court of Delaware - Delaware

Case 1 :07-mj-00009-lVI PT Document 2 Filed 01/18/2007 Page 1 of 3
United States District Court
DISTRICT OF DELAWARE
UNITED STATES OF AMERICA
v.
RICARDO ZANELA-CASTELAN
Criminal Complaint
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I Ji r · Q I-M tl.: I Ii NUMBER: 07- [Vt
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(Name and Address of Defendant)
I, the undersigned complainant, being duly sworn, state the following is true and correct to the best of my knowledge and belief.
On or about January 17, 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 of law, for the purpose of commercial advantage and private financial gain.
All in violation of Title 8, United States Code, Section 1324(a)(l)(A)(ii) & (a)(l)(B)(i).
I further state that I am a(n) Special Agent, Department of Homeland Securig, ICE,and that this complaint is based
Official Title
on the following facts:
See attached Affidavit. /‘
Continued on the attached sheet and made a part hereof: Yes X 3
Signature ofComplainant [— - -— --7-- _ · -j_—···;······—····:
William o. Hom [ E- [ i-;_ ij j
Special Agent, ICE {—— -— —---— ————--·-——-—- 1 E
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Sworn to before me and subscribed in my presence, i W l ` _ _` J i
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Januagy 18, 2007 at Wilrriin ton DE 4; ' l`i'_'__{';-nf: _________ ‘
nate City and s / ,
Honorable Mary Pat Thynge , I
United States Magistrate Judge ` .
Name & Title of Judicial Officer alurc cer {

Case 1:O7—mj-OO0O9—IV|PT Document 2 Filed O1/18/2007 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,
INSfICE records, and my own observations and interviews.
3. On January 17, 2007, ICE Wilmington received notification from the Delaware State Police that
a van had been stopped on I—95 and that the van contained 17 persons who spoke little or no
English. The truck was driven by an individual claiming to be Pedro I-IERNANDEZ—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 of the 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 afiiant. In a
sworn statement, he admitted that his true and correct name is Ricardo ZANELA—Ca.stelan, and
that he was born 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 found 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 of law, in violation of Title 8, United States Code, 1324(a)(1)(A)(ii) & (B)(i).
C 7; Q Q ___
William O. Hom
Special Agent
U.S. Immigration & Customs Enforcement

Case 1:07-mj—OOOO9-MPT Document 2 Filed O1/18/2007 Page 3 of 3
Subscribed and sworn t0 before me this gf day cf Januar 99
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The H0 Mary Pat - A
United tates Magistrat .' •‘;