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Case 2:15-mj-02864-CW Document 1 Filed 04/09/15 Page 1 of 2

A0

91

(Rev.

li/Il)

FILED

Criminal Complaint

APR

UNITED STATES DISTRICT COURT

United States of America

2015

Ct.ERK. U.S. DISTRICT CLERK


VESTERN DISTRICT OF TEXAS
/2d.1
BY
DEPU1Y

for the
Western District

of Texas

)
)

V.

Eduardo Hinojosa (DOB 1/18/1968)


Jose Carlos Mendoza-Hernandez (DOB 3/16/1973)
Elizabeth Cervantes-Mateos (DOB 7/11/1991)
GUy Ajin-Cordova (DOB 8/24/1 990)

Case No.

R/5 _-)..8lJ,Lfr(_o/, oZ,D31O']

)
)

Defendant(s)

CRIMINAL COMPLAINT
1,

the complainant in this case, state that the following is true to the best

On or about the date(s)

Western

of

District of

7.2015

Texas

and belief.

Maverick

in the county of

in the

the defendant(s) violated:

Offense Description

Code Section
18

of my knowledge

Smuggling goods from united States

usc 554

This criminal complaint is based on these facts:


On April 07, 2015, Homeland Security Investigations (HSI) Special Agents from Eagle Pass received information that a
White Dodge Pickup was involved in smuggling weapons from the Mendoza & Hernandez (M&H) business located on
Highway 57 in Eagle Pass, Texas. Agents observed a 2006 White Dodge Ram bearing MX LP# EX-57-154, a 2007
Ford Explorer bearing MX LP# FHM-41-46 and a 2014 White Audi A5 bearing MX LP # FGZ-29-73 at the M&H

Continued on the attached sheet.

Complainant's

re

Rick Bazan, Special Agent, HSl


Printed name and title

Sworn to before me and signed in my presence.

Date:

City and state:

<i7L

o
/

el Rio, Texas

Printed name and title

Case 2:15-mj-02864-CW Document 1 Filed 04/09/15 Page 2 of 2


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business parking lot. A male individual later identified as Eduardo HINOJOSA, a United States
citizen, was observed loading boxes into the Ford Explorer. Maverick County Sheriffs Office
(MCSO) later initiated a traffic stop on the 2007 ford Explorer due to the vehicle not signaling
during a lane change. The Ford Explorer was occupied by Gily Natividad AJIN Cordova the
driver and a passenger Elizabeth CERVANTES-Mateos both Mexican citizens. AJIN gave
verbal consent to search the vehicle. During the consent to search of the Ford Explorer deputies
discovered a 243 Rifle Winchester, a Beretta 12 Gauge Shotgun and 1088 rounds of various
calibers of ammunition. During surveillance, agents observed HINOJOSA and Jose MENDOZA
Hemandez unloading boxes into a storage facility in Eagle Pass, TX. Agents maintained
surveillance on H1NOJOSA and MENDOZA as they left the storage facility. HINOJOSA was
observed driving in a White Dodge Ram to the Wal-Mart in Eagle Pass where a traffic stop was
initiated by MCSO for running a red light at the traffic light on Bibb at the Wal-Mart entrance.
HSI Special Agents responded to the scene of the stop and advised HINOJOSA verbally of his
Miranda Rights and HINOJOSA waived his rights. HINOJOSA admitted that he left the storage
facility where he had dropped off ammunition. HINOJOSA gave consent to agents to search the
storage facility where 3 boxes of shot gun shells were found. Customs and Border Protection
Officers encountered the White Audi driven by MENDOZA at the outbound lanes of Port of
Entry #2 in Eagle Pass. HSI Special Agents responded and advised MENDOZA of his Miranda
Rights which MENDOZA waived and gave a statement to agents. MENDOZA stated he knew
the 243 rifle and 4 boxes of ammunition were being exported to Mexico and had a friend
purchase the weapon. MENDOZA stated he knew it was illegal to take weapons into Mexico.
HJNOJOSA stated he tasked AJIN and CERVANTES into taking the guns into Mexico and
knew it was illegal to cross the weapons into Mexico. AJIN stated she knew there were weapons
in the vehicle and knew it was illegal to export weapons to Mexico. CERVANTES stated she
had knowledge of ammunition being present in the vehicle and knew it was illegal to take it to
Mexico.