A0
91
(Rev.
02/09) Criminal Complaint
F
IL
ED
UNITED
STATES
DISTRICT
COURT
AUG
04
2014
for the
CLERK,
U.S.
DIS1RICT
COURT
Western District
of
Texas
WESTERN
DISTRICT
OF TEXAS
ctE
United States
of
America
)
V.
Juliette
RAM
IREZ
Noe
RAMIREZ
Defendant
CaseNo.
c5fV(OI)
OL
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
Vat
Verde in the
Western
District
of
Texas
,
the defendant violated an offense described
as
follows:
Title 18
U.S.C.
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. Sworn to before me and
signed
in my presence. Date: 08/04/20
14
City and
state:
Del Rio,
Texas
/
Cplainant
's
signature
Omar
Pedraza,
1-ISI
Special Agent
Printed
name
and
title
Judge's
signá
Collis
White, U.S.
Magistrate
Judge
Printed
name
and
title
Case 2:14-cr-01219-AM Document 1 Filed 08/04/14 Page 1 of 2
iq54'
-0 )
OL
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.
Case 2:14-cr-01219-AM Document 1 Filed 08/04/14 Page 2 of 2
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