Case 2:14-cr-01219-AM Document 1 Filed 08/04/14 Page 1 of 2

F IL ED

A0 91 (Rev. 02/09) Criminal Complaint

UNITED STATES DISTRICT COURT
for the
Western District of Texas

AUG 04

2014

CLERK, U.S. DIS1RICT COURT
WESTERN DISTRICT OF TEXAS

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United States of America

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V.

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CaseNo.

Juliette RAM IREZ
Noe RAMIREZ

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Defendant

CRIMINAL COMPLAINT
I, the

complainant in this case, state that the following is true to the best of my knowledge and belief.

On or about the date of 08/02/20 14 in the county of

Texas
, the defendant violated
an offense described as follows:

Title 18

Vat Verde

U.S.C.

in the

Western

District of

554

did knowingly and unlawfully export and attempt to export, from the United States, any merchandise, article, or object,
including but not limited to thirty six (36) United States Military grade sub-munitions, which are defense articles as
defined under Category five of the United States Munitions List, contrary to any law or regulation of the United States,
in that the Defendant had not obtained a license or written authorization for such export, in violation of Title 22, United
States Code, Sections 2778(b)(2) & 2778(c) and Title 22, Code of Federal Regulations, Parts 121, 123, & 127, all in
violation of Title 18, United States Code, Section 554(a).

This criminal complaint is based on these facts:

See Attachment A

Continued on the attached sheet.

"

/

Cplainant 's signature

Omar Pedraza,

1-ISI

Special Agent

Printed name and title

Sworn to before me and signed in my presence.

Date:

08/04/20 14
Judge's signá

City and state:

Del Rio, Texas

Collis White, U.S. Magistrate Judge
Printed name and title

Case 2:14-cr-01219-AM Document 1 Filed 08/04/14 Page 2 of 2

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Attachment A
On August 2, 2014, CBP Officers at the Del Rio Port of Entry (POE) were conducting an
outbound inspection operation. At approximately 2250 hours, CBP Officers selected
Juliette RAMIREZ for inspection as she was attempting to walk into Mexico. CBP
Officers discovered what appeared to be one explosive device hidden inside the backpack
Juliette RAMIREZ was carrying. Juliette RAMIREZ did not have official pennission or
documentation to export the device from the United States to the Republic of Mexico.
Officers placed Juliette under arrest and left the suspected explosive device under watch
outside where Juliette RAMIREZ was encountered as she was headed outbound into
Mexico. Del Rio CBP officers shut down the POE and contacted the Laredo, Texas
Bomb Disposal Unit.

During a post Miranda interview with HSI Del Rio Special Agents, Juliette Ramirez
stated she was exporting the explosive into Acuna Mexico and there were 35 more
similar explosive devices at another location. Juliette RAMIREZ claimed she was going
to be paid $2,000.00 to transport all 36 "grenades" to Acuna, Mexico. During a
subsequent investigation, HSI Special Agents were able to determine that the remaining
suspected explosives were being stashed at 227 Sunset Street Apartments, Unit D, in Del
Rio, Texas. Based on this information HSI Del Rio Special Agents conducted a "knock
and talk" at the apartment in question. The residents gave Agents consent to conduct a
search. During the search of the apartment, Special Agents discovered 35 additional
suspected explosives hidden in a childts bedroom closet where Noe RAMIREZ was
staying. Noe RAMIREZ voluntarily admitted that he brought the suspected explosives
into the residence and hid them in the bedroom closet.

Agents placed both Juliette Ramirez and Noe Ramirez under arrest and charged with
18USC554 with the concurrence of AUSA Matthew Watters. The suspected explosives
were turned over to the Laredo Texas bomb disposal unit for safeguarding, testing and
disposal.
The Laredo Texas Bomb Disposal Unit preliminarily identified the suspected explosive
devices as United States military-grade sub munitions, which are defense articles as
defined under category five of the United States Munitions List.