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FILED
UNITED STATES DISTRICT COURT
APR I 0 2017
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COUNT ONE
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On or about April 5, 2017, within the Southern District of California, Daniel
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GOMEZ-Florez did knowingly and intentionally import approximately and 21.66
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kilograms (4 7. 7 5 pounds) of Methamphetamine, a Schedule II Controlled
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Substance, into the United States from a place outside thereof; in violation of Title
21, United States Code, Sections 952 and 960.
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a~
Homeland Security Investigations
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SWORN TO BEFORE ME AND SUBSCRIBED IN MY PRESENCE, THIS
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lOTH DAY OF April, 2017.
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25 JILL L BURKHARDT
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Case 3:17-mj-01023-WVG Document 8 Filed 04/10/17 PageID.11 Page 2 of 6
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On April 5, 2017, at approximately 4:52 a.m., defendant Daniel GOMEZ-
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Flores ("GOMEZ"), a United States citizen, applied for permission to enter into
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the United States from Mexico through the Otay Mesa, California, Port of Entry in
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vehicle lane # 10. GOMEZ was the driver, sole occupant, and registered owner of
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a 2005 Chrysler Seabring bearing California license plates 7KVK658 ("the
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vehicle").
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Customs and Border Protection Officer ("CBPO") Teegarden conducted the
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primary inspection of GOMEZ. GOMEZ told CBPO Teegarden that he was
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traveling to the United States to go to work and he gave two negative customs
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declarations to CBPO Teegarden. CBPO Teegarden inspected GOMEZ's vehicle
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and noticed the spare tire, in the trunk of the vehicle, was not a normal weight for
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a spare tire and had hard spots when he pushed down on it. CBPO Teegarden
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referred the vehicle to secondary inspection for further investigation.
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CBPO Rodriguez, assigned as the Z-portal X-ray operator, conducted an X-
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ray of the vehicle. CBPO Rodriguez observed anomalies in the spare tire of the
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vehicle. CBPO Rodriguez escorted GOMEZ to the security office and referred the
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vehicle for further inspection.
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CBPO Haynes conducted the secondary inspection of the vehicle. During
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the secondary inspection, CBPO Haynes discovered the spare tire in the truck of
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the vehicle. CBPO Haynes observed that the spare tire was unusually heavy.
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CBPO Haynes cut the spare tire open and discovered brown wrapped packages
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concealed within the spare tire, CBPO Haynes discovered twenty-three packages,
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wrapped in clear plastic wrap, carbon paper, cardboard, and packing tape. CBPO
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Haynes probed one of the packages. The package contained a clear crystal like
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substance that field-tested positive for methamphetamine. The combined weight
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of the packages was approximately 12.76 kilograms (28.13 pounds). At
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approximately 5:55 a.m. CBPO Haynes notified Sector of the discovery.
Case 3:17-mj-01023-WVG Document 8 Filed 04/10/17 PageID.12 Page 3 of 6
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Case 3:17-mj-01023-WVG Document 8 Filed 04/10/17 PageID.13 Page 4 of 6
MICHAEL DESHONG
xct~ qo f FILED
UNITED STATES DISTRICT COUR~ ~ -APR 0 5 2017
2 SOUTHERN DISTRICT OF CALIFORNfAE~~~_.
~~
~ ~~:; ~>.!~r~cc~Rr
~ ~~-:rCR\:'> ,#- ....
-----..._-...-.....,.,._ C: P ~ T
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Substance, into the United States from a place outside thereof; in violation of Title
21, United States Code, Sections 952 and 960.
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18 Special Agent
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Homeland Security Investigations
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SWORN TO BEFORE ME AND SUBSCRIBED IN MY PRESENCE, THIS 51H
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DA.Y OF April, 2017.
22 WILLIAM V. GALLO
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U.S. MAGISTRATE JUDGE
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Case 3:17-mj-01023-WVG Document 8 Filed 04/10/17 PageID.14 Page 5 of 6
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On April 5, 2017, at approximately 4:52 a.m., defendant Daniel GOMEZ-
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Flores ("GOMEZ"), a United States citizen, applied for permission to enter into
5
the United States from Mexico through the Otay Mesa, California, Port of Entry in
6
vehicle lane #10. GOMEZ was the driver, sole occupant, and registered owner of
7
a 2005 Chrysler Seabring bearing California license plates 7KVK658 ("the
8
vehicle").
9
Customs and Border Protection Officer ("CBPO") Teegarden conducted ,the
10
primary inspection of GOMEZ. GOMEZ told CBPO Teegarden that he was
11
traveling to the United States to go to work and he gave two negative customs
12
declarations to CBPO Teegarden. CBPO Teegarden inspected GOMEZ's vehicle
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and noticed the spare tire, in the trunk of the vehicle, was not a normal weight for
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a spare tire and had hard spots when he pushed down on it. CBPO Teegarden
15
referred the vehicle to secondary inspection for further investigation.
16
CBPO Rodriguez, assigned as the Z-portal X-ray operator, conducted an X-
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ray of the vehicle. CBPO Rodriguez observed anomalies in the spare tire of the
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vehicle. CBPO Rodriguez escorted GOMEZ to the security office and referred the
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vehicle for further inspection.
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CBPO Haynes conducted the secondary inspection of the vehicle. During
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the secondary inspection, CBPO Haynes discovered the spare tire in the truck of
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the vehicle. CBPO Haynes observed that the spare tire was unusually heavy.
23
CBPO Haynes cut the 'spare tire open and discovered brown wrapped packages
24
concealed within the spare tire, CBPO Haynes discovered twenty-three packages,
25
wrapped in clear plastic wrap, carbon paper, cardboard, and packing tape. CBPO
26
Haynes probed one of the packages. The package contained a clear crystal like
27
substance that field-tested positive for methamphetamine. The combined weight
28
of the packages was approximately 12.76 kilograms (28.13 pounds). At
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approximately 5:55 a.m. CBPO Haynes notified Sector of the discovery.
Case 3:17-mj-01023-WVG Document 8 Filed 04/10/17 PageID.15 Page 6 of 6
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