Free Redacted Document - District Court of Delaware - Delaware

Case 1 :07-mj-00008-lVI PT Document 2 Filed 01/18/2007 Page 1 of 3
United States District Court
DISTRICT OF [DELAWARE
UNITED STATES OF AMERICA
v.
PEDRO HERNANDEZ—SANCHEZ
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i it if I/Ll as ‘ rl `1Crlm1nal Complaint
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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 Pedro Hernandez-Sanchez, a citizen and
national of Mexico, knowing 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 l324(a)(l)(A)(ii) & (a)(1)(B)(i).
I fiuther 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. ta
Continued on the attached sheet and made a part hereof: Yes X ;
Signature ofComplainant -. l _ _____ __ _ _ _ _ A
William O. Horn l [C ; _ ._ '
Special Agent, ICE !...L...-i- .,__ ;__f" _ X I
Swom to before me and subscribed in my presence, .
i "I ‘ . :1 '
Januag 18, 2007 at Wilmington, DE I · " A- · lr.
H bl M P tTh /
onora e ary a ynge »
United States Magistrate Judge ...4. ""T
Name & Title ofJudicial Officer Signature 0 Ju ir:1 ficer V

Case 1:O7—mj-OO0O8—lV|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,
INS/ICE 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 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.
4. On January 17, 2007, your affiant advised HERNANDEZ of his rights, in Spanish. Once
advised of his rights, I-IERNANDEZ signed a waiver of his rights and agreed to speak with your
affiant. In a sworn statement, he admitted that his true and correct name is Pedro HERNANDEZ—
Sanchez, and that he was bom on June 06, 1976, in Mexico. HERNANDEZ 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. VVhereas he would have had to pay $1,500, he only had to pay $750.
5. All 17 persons in the van were interviewed by ICE Agents, and all were found to be in the
United States illegally. HERNANDEZ 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 Pedro HERNANDEZ-
Sanchez, 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).
William O. Horn
Special Agent
U.S. Immigration & Customs Enforcement

Case 1:07-mj—OOOO8-MPT Document 2 Filed O1/18/2007 Page 3 of 3
Subscribed and swom t0 before me this {Z day 0f Janua H

The Mar * hynge
Unit States Magis ate Judge