Case 3:18-mj-00626-AGS Document 1 Filed 02/12/18 PageID.

1 Page 1 of 4

1
UNITED STATES DISTRICT COURT
FILED
2 FEB 1 2 201b
SOUTHERN DISTRICT OF CALIFORN
3
4 UNITED STATES OF AMERICA, Case No.:
5 Plaintiff,
COMPLAINT FOR VIOLATION OF
6
v. Title 21 U.S.C. § 952 and 960
7
Importation of a Controlled Substance
8 Eduardo SAIS-Peinado, (Felony)
9 Defendant.
10
H----------------~ 18MJ0626
11
12 The undersigned complainant being duly sworn states:
13
On or about February 10, 2018, within the Southern District of California,
14

21
The complainant states that this complaint is based on the attached Statement o
22
23 Facts incorporated herein by reference.
24
25 Special Agent Michael R. Baxter
Homeland Security Investigations
26
SWORN TO BEFORE ME AND SUBSCRIBED IN MY PRESENCE, THIS _12th_
27

4f=-~ -
DAY OF February 2018.
28

U.S. MAGISTRATE JUDGE

ANDREW G. SCHOPLER
 Case 3:18-mj-00626-AGS Document 1 Filed 02/12/18 PageID.2 Page 2 of 4

PROBABLE CAUSE STATEMENT

2

3
I, Homeland Security Investigations (HSI) Special Agent Michael R. Baxter,
4

5 declare under penalty of perjury the following to be true and correct:

6
On February 10, 2018, at approximately 1822 hours, defendant EDUARDO
7
SAIS-PEINADO ("SAIS-PEINADO"), a Mexican citizen, applied for entry into
8

9 the United States from Mexico through the San Ysidro (SYS), CA, Port of Entry
10
(POE) in vehicle lane #12. SAIS-PEINADO was the driver and sole occupant of a
II

12 2007 Jeep liberty bearing MX/Baja CA license plates ("the vehicle").

13
At approximately 1822 hours, Customs and Border Protection Officer
14
(CBPO) Joshua Quilici was conducting roving operations in pre-primary when he
15

16 observed SAIS-PEINADO. CBPO Quilici approached the vehicle and conducted a

17
field interview. SAIS-PEINADO presented his border crossing card and stated he
18

19 was driving to Chula Vista, CA. CBPO Quilici asked SAIS-PEINADO if he had

20
anything to declare. SAIS-PEINADO stated he did not. SAIS-PEINADO told
21
CBPO Quilici the vehicle was his and only his girlfriend uses the vehicle. CBPO
22

23 Quilici began to inspect the vehicle. CBPO Rey assisted Quilici. According to
24
CBPO Rey's K910B buster, the doors of the vehicle were reading high. CBPO
25

26 Quilici again asked SAIS-PEINADO if he had anything to declare. SAIS-

27 PEINADO stated he did not.

28
1
 Case 3:18-mj-00626-AGS Document 1 Filed 02/12/18 PageID.3 Page 3 of 4

At approximately 1822 hours, Canine Enforcement Officer (CEO) Laura

2 Manis and her dog responded to a call for assistance to screen the Jeep Liberty.
3
CEO Manis' assigned canine alerted to the vehicle's door. CEO Manis advised
4

5 CBP personnel of her findings.

6
At approximately 1826 hours, CBPO Nicholas Pierce, Z-Portal Operator,
7
conducted an x-ray on the Jeep Liberty. CBPO Pierce observed anomalies in both
8

9 passenger-side doors. CBPO Pierce advised CBP personnel of his findings.

10
At approximately 1900 hours, CBPO Jose Vasquez was assigned to conduct
11

12 a seven-point inspection on the Jeep Liberty. During the inspection, CBPO

13
Vasquez located 11 packages concealed inside the vehicle's front and rear-side
14
passenger doors. Additionally, five additional packages were found situated inside
15

16 the vehicle's rear door. CBPO Vasquez probed one of the packages and extracted
17
a white-powdery substance. The substance was tested and resulted in a positive
18

19 reaction for cocaine.

20
The combine (approximate) total weight of the cocaine was 17.58 kilograms
21
(38.75 pounds).
22

23 SAIS-PEINADO was arrested and scheduled to be booked into MCC, San

24
Diego, CA.
25

26

27

28
2
 Case 3:18-mj-00626-AGS Document 1 Filed 02/12/18 PageID.4 Page 4 of 4

Executed on February 11, 2018, at 2:30 a.m.

3
Michael R. Baxter, HSI Special Agent

6
On the basis of the facts presented in this probable cause statement
7

8
consisting of 3 pages, I find probable cause to believe the defendant, EDUARDO

9 SAIS-PEINADO, named in this probable cause statement, committed the offense

10
on February I 0, 2018, in violation of Title 21 USC 952 and 960, Unlawful
II

Importation of a Controlled Substance.

13

9:13AM, Feb 11, 2018

14
Date/Time
15
United States Magistrate Judge
16 Hon. ANDREW G. SCHOPLER
17

18

19

20

21

22

24

25

26

27

28
3