UNITED STATES DISTRICT COURT JUL 05 2019

SOUTHERN DISTRICT OF CALIFORNI Magistrate Dockét'No.

MOMS 2785COMPLAINT FOR VIOLATIONOF:Title 8, USC 1324(a)(1 (A)Transporation ofGoins Aloas forFinancial Gain

UNITED STATES OF AMERICA,

Plaintiff,

v.

Byron Damefl LAW TL,David Javier SALAZAR~Quintero,

Defendants.

Theundersigned complainant being, duly sworn, states:On orabout July 03, 2019, within the Southern District ofCalifornia, defendant Byron DarnellLAWi and David Javier SALAZAR-Quintero, with the intent to violate the immigration lawsofthe United States, knowing or in reckless disregard ofthe fact that certain aliens, namely,Samuel ADAME-Saldana, Sandra AVENDANO-Miguel, and Virginio Roberio AVENDANO-Rosales, had come to, entered and remainedin the United States in violation oflaw, didknowingly transport and move, said aliens within the United States in fisrtherance ofsuchviolation of law, and which was done for the purpose ofcommercial advantage ot privatefinancial gain;in violation ofTitle 8, United States Code, Section 1324(a)(1)(A(ii).

Andthe complainant further states that this complaint is based on the attached statement offacts, whichis incorporated herein by reference.

a‘SIGNATURE OFCOMPLAINANTPaul J. Clouthier

Border Patrol Ageat

SWORN TG BEFORE ME AND SUBSCRIBEDIN MY PRESES

THIS Sth DAY July. 2019.

ala

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CONTINUATION OF COMPLAINT:Byron Darnell LAW IL,David Javier SALAZAR-Quintero.

PROBABLE CAUSE STATEMENT

The complainantstates that Samuel ADAME-Saldana, Sandra AVENDANO-Migucl, and

Virginio Roberto AVENDANO-Rosales,arecitizens of a country other than the United States:

‘thatsaid aliens have admitted that they are deportable; that their testimony is material, that it is

impracticable to secure their attendance at thetrial by subpoena, and they are material witnesses

in relationto this criminal charge and should be held or admitted to bail pursuantto Title 18,

United States Code, Section 3144.

OnJuly 3, 2019, Border Patrol Agents C. Anderson, and E. Pepe, were conducting assignedduties in the Boulevard Border Patrol Station’s area ofresponsibility. At approximately 10:00

AM,Agent Anderson was onfoot checking layup spots along Interstate 8 near while otheragents were tracking footprints of suspected illegal aliens south ofhis position. Agent Andersonnoticed a smallblack car pull over onto a dirt tumaroundfrom Interstate 8. Agent Anderson.

believed this could be a vehicle looking to pick up the suspected illegal aliens he was searching,

for. Agent Anderson attempted to get a better look at the vehicle, but before he could get inPosition the vehicle pulled back on toInterstate 8. Agent Anderson went to the spot where hehad scen the vehicle and noticed fresh footprints leading to where the vehicle was momentarily

parked. Agent Anderson relayed this information to other Agents in the area.

Agent E.Pepe spotted a black vehicle which matched the description that Agent Anderson hadrelayed. AgentPepe activated his emergency equipment in order to puill the vehicle over and thevehicle yielded. This areais located approximately seven miles north ofthe United States/Mexicointernational Border, and approximately 20 miles east ofthe Tecale, California Port ofEntry. Agent Pepe approached the vehicle, identified himselfasa Border Patrol agent andconducted an immigration inspection on thefive individualsin the vehicle

The driver, later identified as defendant Byron Damell LAW II, andthefantpassenger, fateridentified as defendant David Javier SALAZAR-Quintero,stated to be United States citizens.All three back seat passengers, later identified as material witness SamuelADAME-Saldana,Sandra AVENDANO-Miguel, and Virgino Roberto AVENDANORosales.stated they arecitizens of Mexico without any immigration documents that would allowtheas to enter or

remainin the United States legally. At approximately 10:17 AM_ AgeatPepeplaced all fivesubjects underarrest,

LAWwasadvised of his Miranda Rights. AW stated he understood hissigies and was willing1 answerquestions without an attorney present. LAWstated that he isamently an active duty

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CONTINUATION OF COMPLAINT:

Byron Darnell LAW II,

David Javier SALAZAR-Quintero

Marine stationed out of the Marine Corps Base Camp Pendleton. LAW claimedthat co-

passenger, David Javier SALAZAR-Quintero,was the individual responsible for organizing theevent. LAWstated that last night, SALAZARcalled and asked him ifhe waswilling to make

$1000.00 USDpicking up an illegalalien. On July 2, 2019, at approximately 10:30 PM, LAWand SALAZAR traveled to Jacumba, California and were being guided via cell phoneinstructions from an unknown Mexico number.

LAWstated that SALAZARwasthe one on the cell phone receiving directions from the southside spotter due to being proficient in the Spanish language. LAW stated they picked up asingle illegal alien af the Jacumba Exit on the eastbound lanes of Interstate 8 andhim to a McDonald's parking lot in Del Mar. They met with an individual whoarrived in a blueNissan Murano. LAWclaimed they were never paid for the event andtraveled back to baseafter the exchange.

‘On today's date, at approximately 9:00 AM, LAWstated that SALZARagain called him foranotherjob,this time guarantecing they would get paid for todays and last nights eventin cash.Asthey passed up the Jacumba HotSpringsexit, they were instructed totum around at thenearest emergency turnaroundalong the median on Interstate 8. As theycontinued traveling on1-8; now westbound, they were instructed to pull over at the Jacumba Hat Springs next exitsign. Within a few seconds, LAW stated that three illegal aliens emesged from the northernshoulderof1-8 and enter his vehicle.

SALAZARwasadvised of his Miranda Rights. SALAZAR stated he understood his rights and

was willing to answer questions without an attorney present. SALAZARstated he was

originally introduced to smuggling by Byron Dame! Law I (Co-Principal)who introduced himto a manthatrecruited him. SALAZAR stated that the recruiter drivesanalder blue Nissan

Rogue. SALAZARstated he has met with the recruiter on several differeatoccasions. Rojasstated they have met at the Between the Sheets Plaza in Solano Beach factual location is DelMar, CA) and at an apartment complex where the recruiter resides.

SALAZAR admitted t coming to Tacumba to pick up on fourdifferentaceasions. SALAZARstated that the first time he did not pick anyone up and wastold te retuna The second occasionhe picked upat the “Jacumha 1 Mile." SALAZARbroughthis 2017 Toyata Corolla for that

event. SALAZARstated he was going to be paid $500 but hasn't heempaid. SALAZARstatedhe camelast night, July 2, 2039. SAI_AZAR was with Law 1] ina blackBMW. SALAZAR.admilled 19 picking up threeillegal aliens and toak them 16 Solana Brack,CAL

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CONTINUATION OF COMPLAINT:

Byron Darnell LAW II,

David Javier SALAZAR-Quintero

Material witnesses Samue! ADAME-Saldana, Virginio Roberto AVENDANDO-Rosales,

Sandra AVENDANO-Miguel were interviewed, all admitted to making smuggling

arrangements. All material witnesses stated they were picked up by a black car andthat they

were instructed via cell phoneto get into the car. They also stated the passenger opened the

door for them. AVENDANO-Rosales and AVENDANO-Miguelstated they were going to pay

$8,000 USD,to be smuggled into the United States. With destinations to New Jersey and Los

Angeles. All three material witnesses were presented with a photographic lineup and were able

to identify the driver as Byron LAW II.