Free Redacted Document - District Court of Delaware - Delaware

Case 1:08-cr-00049-GMS
AD 91 (Rev. 12/93) Criminal Complaint IE

Document 2

Filed 02/25/2008

Page 1 of 5

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United States District Court

DISTRICT OF DELAWARE

UNITED STATES OF AMERICA Criminal Complaint
v.

PEDRO ALTATENCO-LUNA

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CASE NUMBER:

08-

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1, the undersigned complainant, being duly sworn, state the following is true and correct to the best of ffij knowledge and belief On or about defendant did knowingly:
(I) possess documents prescribed by statute or regulation for the entry into or as evidence of authorized stay OJ employment in the United States, knowing that such documents were produced without lawful authority, in violation 0: Title 18, United States Code, sections I 546(a);

February 22, 2008 in New Castle

County, in the District of Delaware

(2) possess false identification documents, knowing that such documents were produced without lawful authority, witl the intent to defraud the United States, in violation of Title 18, United States Code, sections 1028(a)(4) and 1028(b);
(3) possess a document-making implement knowing that it would be used in the production of a false identification
document, in violation of Title 18, United States Code, sections 1028(a)(5) and 1028(b).


1 further state that 1 am a(n)

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and that this complaint is based
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Official Title . on the following facts: See attached Affidavit . c,.ontinlJed onth~ att1l9hed sheet and made a part here~
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Signature of Complainant Patrick M. McCall Special Agent, ICE my presence, at Wilmington, DE City and State

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StV to ll'afOfHu;;.r '-"'''IiJfuhscrib om __. _ . ".~u\S
February 25. 2008 Date Honorable Mary Pat Thynge United States Magistrate Judge Name & Title of Judicial Officer

Case 1:08-cr-00049-GMS

Document 2

Filed 02/25/2008

Page 2 of 5

UNITED STATES v. Pedro ALTATENCO-LUNA AFFIDAVIT

Your affiant is a Special Agent of the United States Immigration and Customs Enforcement (ICE) at Philadelphia, Pennsylvania and has been so employed for approximately twenty (20) years. Being duly sworn, your affiant deposes and says as follows: 1. On February 22, 2008, a Federal Express package from Phoenix, Arizona was intercepted by the Delaware State Police, Special Investigations Unit, during parcel inspections at the Federal Express Facility in New CastlecDelaware. The package was addressed to Oscar SANCHEZ, Castle, Delaware from Juan Marin T., , New Phoenix, Arizona. This

package was suspected as being a possible parcel containing narcotics based on several characteristics. This included the fact that the package was a pre-paid box and that the recipient in New Castle, Delaware (Oscar SANCHEZ) listed a contact number
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with a Phoenix area code. Based oR.the suspicious nature of the packagecand the' potential that the parcel contained narcotics, it was opened by Federal Express officials. The package was found to contain approximately 401 fraudulent document laminates including approximately 199 1-551 Resident Alien card laminates and 198 Mexican drivers' license laminates.

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Case 1:08-cr-00049-GMS

Document 2

Filed 02/25/2008

Page 3 of 5

2. On February 22, 2008, your affiant, in conjunction with the Delaware State Police-Special Investigations Unit, conducted a "knock and talk" at the address located at " New Castle, Delaware. At this time,

Pedro ALTATENCO-LUNA, a native and citizen of Mexico, was encountered leaving in a 2000 Nissan Altima. ALTATENCO-LUNA was questioned as to his alienage, citizenship and right to be in the United States. ALTATENCO-LUNA admitted to being a native and citizen of Mexico and residing at , New Castle, Delaware. ALTATENCO-LUNA further admitted to entering the United States illegally on or about June of 2001 at Calexico, California.

3. ALTATENCO-LUNA waived his Miranda rights and agreed to speak to your affiant without the presence of an attorney. ALTATE NCO-LUNA also provided a written Consent to Search his residence and vehicle. ALTATENCO-LUNA stated that he was involved in the sale and manufacture of fraudulent documents, including Resident Alien cards, Social Security cards, driver's licenses, and Mexican Identification cards. These ·. '. . ",. , ':",documents were said for pFires ranging frQllilr.$.2.0.00 to -$50.00 and were manufactured via a computer in "his bedroom. This computer was purchased by ALTATENCO-LUNA for $500.00 with the programs to print and manufacture the documents. ALTATENCO LUNA further admitted to using the name Oscar SANCHEZ and wiring $400.00 the previous week to contacts in Arizona for the laminate needed to complete the documents contained in the seized Federal Express package.

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Case 1:08-cr-00049-GMS

Document 2

Filed 02/25/2008

Page 4 of 5

4. A search of the residence located at , New Castle, Delaware resulted in the location of approximately 500 pieces of blank plastic laminate, forty-two (42) completed and blank social security cards, three (3) completed Resident Alien cards, numerous completed Ohio and Pennsylvania driver's licenses, and Mexican identification cards. Numerous poloroid photographs, pieces of paper with biographic information for individuals having documents made, and ledgers for completed documents were found. The search also revealed a computer, scanner, laminator, and camera used to ma.nufacture the documents.

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Case 1:08-cr-00049-GMS

Document 2

Filed 02/25/2008

Page 5 of 5

Your affiant avers that there is probable cause to believe that on or about February 22, 2008, in Wilmington, Delaware, in the District of Delaware, that Pedro ALTATENCO LUNA, a native and subject of Mexico, did knowingly: (1) possess documents prescribed by statute or regulation for the entry into or as evidence of authorized stay or employment in the United States, knowing that such documents were produced without lawful authority, in violation ofTitle 18, United States Code, sections 1546(a); (2) possess false identification documents, knowing that such documents were produced without lawful authority, with the intent to defraud the United States, in violation of Title 18, United States Code, sections 1028(a)(4) a~d 1028(b); (3) possess a document-making implement knowing that it would be used in the production of a false identification document, in violation of Title 18, United States Code, sections 1028(a)(5) and 1028(b).

PATRICK M. MCCALL Special Agent d.n"..· ··l,lS. Imllliligration and Customs Enforcement (ICE)

Sworn to and subscribed in my presence thi&;i.lday 2008

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