I!

U.S. DISTRICT COURT

MIDDLE DISTRICT OF TENN

OA091 (Rev. 12/03) Criminal Complaint

JUL

UNITED STATES DISTRICT COURT

Middle DISTRICT OF Tennessee

2'9

2016

BY
DEPUTY CLERK

UNITED STATES OF AMERICA

V.
RONALD EDWARD STRICKLAND
4238 Columbia Pike, Franklin, Tennessee

16 M J-1 U 9 7

Case Number:

(Name and Address of Defendant)

I, the undersigned complainant state that the following is true and correct to the best of my
in

July 18, 2016

knowledge and belief. On or about

Williamson

County, in

(Date)

Middle

the

Tennessee

District of

defendant(s) did,

(Track Statutory Language of Offense)

knowingly and unlawfully transport and harbor an illegal alien within the United States.

in violation of Title

1324(a)(1)(A)((ii)

United States Code, Section(s)

Special Agent HSI

I further state that I am a(n)

and that this complaint is based on the

Official Title

following facts:
See attached affidavit of HSI Special Agent Bryna Warnock.

Continued on the attached sheet and made a part of this complaint:

X Yes

No

Signature of Comp arrant

Bryna Warnock
Printed Name of Complainani

..

Sworn to before me and signed in my presence,

"u
Date

,Z1 ZZ

at

g'

Nashville, ToRrje
to

Ci
l

Barbara D. Holmes
Name of Judge

Magistrate Judge
Title of Judge

r6ofJudge

Case 3:16-mj-01097 Document 3 Filed 07/29/16 Page 1 of 4 PageID #: 3

AFFIDAVIT IN SUPPORT OF COMPLAINT

The affiant herein is Special Agent Bryna Warnock of the U.S. Department of Homeland
Security (DHS), U.S. Immigration and Customs Enforcement (ICE), Homeland Security
Investigations (HSI), who being first duly sworn states as follows:
I am a federal law enforcement officer and Special Agent (SA) for the Department of
Homeland Security, U.S. Immigration and Customs Enforcement (ICE), Homeland Security
Investigations (HSI), so employed since March of 2003. Prior to March of 2003, I served as a
Special Agent with the United States Customs Service beginning in October of 2001. My duties
include the investigation of the transporting and harboring illegal aliens in violation of Title 8
U.S.C. 1324 (bringing in and harboring aliens).
This application seeks the issuance of a federal Criminal Complaint and Arrest Warrant.
The facts set forth herein are based on investigation by federal agents, law enforcement
officers with the State of Tennessee and elsewhere, and consensual interviews. I have not
included details of every aspect of this investigation, but rather only those necessary to establish
probable cause for an arrest for violation(s) of Title 8 U.S.C. 1324. Where statements are
related herein, they are related in substance and in part rather than verbatim.
On July 22, 2016, at approximately 3:45pm, I and other agents responded to Ronald
Edward STRICKLAND's residence to further an investigation that originated with a tip of
suspected human smuggling. HSI agents located a twenty-two-year-old Honduran female named
Rosa Idalia Osorto-Osorto at the residence who admitted to being smuggled across the border
and picked up in Houston, Texas, by STRICKLAND approximately four to five days prior to
July 22, 2016. STRICKLAND then transported Osorto-Osorto to Nashville, Tennessee. The
Honduran female was administratively arrested by HSI Nashville, interviewed, and turned over
to ICE Enforcement and Removal Operations for removal proceedings.
During the investigation, agents were invited inside the residence on two separate
occasions by STRICKLAND. At which time, within approximately one hour of each other,
agents observed, in plain view, a large number of Western Union receipts and what appeared to
be a "love note" addressed to Osorto-Osorto. Without disturbing them, a photo of one of the
Western Union receipts was taken and later reviewed. It listed MTCN 353-819-1316 and a WU
Gold Card Number of 451139983. Agents also took a photo of the "love note" written in the
Spanish language. The note, when translated to English, reads, "Rosa, I'll be back soon. Went to
the store to get bread. I love you with all my heart." Agents observed no indication of anyone
else living inside the residence.
Agents also observed STRICKLAND get very nervous, even visibly frustrated, when
agents tried to speak to Osorto-Osorto without him being present. On one occasion, an officer

Case 3:16-mj-01097 Document 3 Filed 07/29/16 Page 2 of 4 PageID #: 4

had to physically step in front of STRICKLAND to prevent him from entering the garage where
agents were speaking with Osorto-Osorto. Additionally, agents observed Osorto-Osorto retrieve
her valid Honduran passport and identity document from a dresser drawer located in a room that
agents believed to be the master bedroom of the residence and STRICKLAND's primary
bedroom. The first time agents saw Osorto-Osorto, she was sleeping in this room. A check of
HSI records confirms that Osorto-Osorto is not in the United States legally.
Subsequent to her administrative arrest for immigration violations, agents interviewed
Osorto-Osorto about how she arrived at the residence. Osorto-Osorto stated that she traveled by
bus and train from Honduras across Mexico where she eventually crossed over a river and into
the United States. Osorto-Osorto stated that once she arrived in Houston, Texas, she waited and
hid by a garbage dumpster in a parking lot of a gas station for STRICKLAND to pick her up,
which he eventually did in his red truck. Osorto-Osorto stated that she stayed in telephonic
contact with STRICKLAND during her journey to the United States from Honduras so that he
would know when she arrived in Houston, Texas. Osorto-Osorto stated that she used a Honduran
phone chip until she got to Mexico, then she bought a Mexican phone chip that worked until she
arrived in Houston, Texas. Osorto-Osorto told agents that she informed STRICKLAND as far
back as a year ago that she was coming into the United States illegally because it has always
been her dream to come to the United States. Osorto-Osorto stated that STRICKLAND was a
friend of her family in Honduras, and had been for approximately four years. She denied being in
a romantic relationship with STRICKLAND.
During the course of the investigation on July 22, 2016, agents had several consensual
conversations with STRICKLAND. During those encounters, STRICKLAND confirmed that
he travels regularly to Honduras, and has an apartment there. He also admitted to traveling to
Houston, Texas, to pick Osorto-Osorto up as soon as she called him and told him she had
arrived. STRICKLAND admitted to bringing Osorto-Osorto back to Tennessee and to the
residence, and to purchasing her Honduran passport for her. He also admitted to utilizing the
Facebook cellular application "WhatsApp" to communicate with Osorto-Osorto.
STRICKLAND also feely admitted to sending money to Osorto-Osorto's family in Honduras
because she told him they needed help.
A review of Western Union transactions indicated that the receipt observed in
STRICKLAND's residence (MTCN 353-819-1316) correlates with a transaction on July 20,
2016, in which STRICKLAND sent $100.00 to Deysi Delila Osorto in Choluteca, Honduras.
The payment was disbursed on July 21, 2016. Osorto-Osorto identified Deysi Delila Osorto as
her sister during her administrative immigration processing.
Further review of Western Union records indicated that since September of 2011,
STRICKLAND has sent an aggregate total of approximately $29,803.00 to Guatemala,
Honduras, or Mexico. Of that $29,803.00 aggregate total, approximately $27,873.00 was sent to

Case 3:16-mj-01097 Document 3 Filed 07/29/16 Page 3 of 4 PageID #: 5

Honduras. An approximate total of $6,652.00 was sent to Osorto-Osorto, and approximately

$3,398.00 was sent to her sister Deysi Delila Osorto.
On the afternoon of July 27, 2016, I along with other law enforcement officers executed a
federal search warrant on STRICKLAND's residence located at 4238 Columbia Pike, Franklin,
Tennessee.
STRICKLAND was home when the warrant was executed. STRICKLAND stated at the
beginning of the warrant execution that he did not wish to answer any questions without having
his lawyer present. While agents were preparing to leave the residence at the conclusion of the
search warrant, STRICKLAND made unsolicited statements to agents in which he restated what
he had stated before about having transported Osorto-Osorto from Houston, Texas. He further
stated that he had informed Osort-Osorto that if she could get across the border, he would come
pick her up.
Based on my experience, education, conversations with other law enforcement officers,
and the information described herein, I believe that there is probable cause that STRICKLAND
and others yet unknown are involved in the unlawful transporting and harboring of illegal aliens
into the United States in violation of Title 8 U.S.C. 1324.
It is therefore respectfully requested that a warrant be issued authorizing arrest of Ronald
Edward STRICKLAND for violations of Title 8 U.S.C. 1324. It is further requested that the
complaint and warrant be maintained under seal pending further order of the Court as public
disclosure would jeopardize the investigation

Bryna Warnock
Special Agent
Homeland Security Investigations
Sworn to and subscribed before me
this`&y,

, 2016

y
i

B*ara D:fIolmes
United States Magistrate Judge

Case 3:16-mj-01097 Document 3 Filed 07/29/16 Page 4 of 4 PageID #: 6