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BLANCA QUINTERO
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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF CALIFORNIA
17MJ0778
UNITED STATES OF AMERICA, ) Magistrate Case No. _ _ _ _ _ __
)
Plaintiff, ) COMPLAINT FOR VIOLATION OF
)
v. ) Title 8, U.S.C., Section
) 1324(a)(2 )(B )(iii)
Jose Emiliano AGUILAR, ) Bringing in Unlawful .tjUJJ;.UJA}-----::----,
Defendants.
)
)
Without Presentation FIlED
MAR 15{ 2017
The undersigned complainant being duly sworn states: CU.:HK us DIS 1HIC1 COUf-lT .
SOUTHf:.HN DISTRICT OF CALIFORNIA
BY DEPUTY
On or about March 14, 2017, within the Southern District of California,
Defendant, Jose Emiliano AGUILAR, with the intent to violate the immigration laws
of the United States, knowing and in reckless disregard of the fact that aliens,
namely, Fenjiao FENG, Yuanzhang LIN, Lingling TANG and Yiming WANG had
not received prior official authorization to come to, enter and reside in the United
States, did bring to the ,United States said aliens, and upon arrival did not bring and
present said aliens immediately to an appropriate immigration officer at a designated
port of entry; in violation of Title 8, United States Code, Section 1324(a)(2)(B)(iii).
And the complainant states that this complaint is based on the attached
statement of facts, which is incorporated erein by refer nce.
,
OF COMPLAINANT
Victor Renteria, CBP Officer
U.S. Customs and Border Protection
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TED STATES MAGISTRATE JUDGE
Case 3:17-mj-00778-MDD Document 1 Filed 03/15/17 PageID.2 Page 2 of 2
The complainant states that Fenjiao FENG, Yuanzhang LIN, Lingling TANG, and
Yiming WANG are citizens of a country other than the United States; that said
aliens have admitted they are deportable; that their testimonies are material; that it
is impractical to secure their attendance at trial by subpoena; and that they are
material witnesses in relation to this criminal charge and should be held or
admitted to bail pursuant to Title 18, United States Code, Section 3144.
In secondary, responding CBP Officers assisted and removed four people from the
trunk. The individuals, later identified as Fenjiao FENG (MWl), Yuanzhang LIN
(MW2), Lingling TANG (MW3) and Yiming WANG (MW4), were determined to
be Chinese citizens without lawful documents to enter or reside in the United
States and were held as Material Witnesses.
During a video recorded interview, the Material Witnesses admitted they are
citizens of China without lawful documents to enter the United States. Each
Material Witness said they made their own smuggling arrangements and agreed to
make a payment ranging from $3,000.00 to $60,000.00 if they successfully entered
the United States. Two Material Witnesses said they were going to Los Angeles,
California and two said they were going to New York, New York.