Criminal Complaint — United States v. Ismael Lopez Sanchez, 1:25-mj-00217

Summary

A Criminal Complaint, Document 1 in Case 1:25-mj-00217-DJS, filed 07/28/25, in the U.S. District Court for the Northern District of New York, against Ismael Lopez Sanchez. It charges a violation of 8 U.S.C. § 1326(a) on or about July 28, 2025, in the County of Saratoga, New York. The attached statement of Special Agent Derrick Zalewski of HSI states that Lopez Sanchez was stopped as a passenger in a vehicle on Route 9 in Saratoga Springs, was arrested, and was previously removed from the United States on June 13, 2024. It states that records show no express consent to reapply for admission. The Hon. Daniel J. Stewart, U.S. Magistrate Judge, acknowledges telephone attestation on July 28, 2025.

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Case 1:25-mj-00217-DJS Document1 Filed 07/28/25 Page1of3

AO Y1 (Kev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

for the
Northern District of New York

UNITED STATES OF AMERICA )

) Case No. 1:25-mj- avy (DJS)
ISMAEL LOPEZ SANCHEZ, )
)
)
)
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 July 28, 2025, in the County of Saratoga, New York in the Northern District of New York, the
defendant violated:

Code Section Offense Description

8 U.S.C. § 1326(a) Ismael Lopez Sanchez, an alien, native and citizen of Guatemala,
being an alien who has been denied admission, excluded, deported,
or removed, or has departed the United States while an order of
exclusion, deportation, or removal is outstanding, entered and was
thereafter found in the United States without the Attorney General of
the United States, or her successor, the Secretary of Homeland
Security, having expressly consented to his reapplication for
admission to the United States.

This criminal complaint is based on these facts:

& Continued on the attached sheet.

Complainant 's signature
Derrick Zalewski, Special Agent, HSI

Printed name and title

Attested to by the affiant in accordance with Rule 4.1 of thé Federal\Rules of Criminal Procedure.

City and State: Albany, New York Hon. Daniel J. Stewart, U.S. Magistrate Judge

Printed name and title
Case 1:25-mj-00217-DJS Document1 Filed 07/28/25 Page 2 of 3

I am a Special Agent with the U.S. Immigration and Customs Enforcement Office of
Homeland Security Investigations (HSI) and have been since 2018. In this role, I have participated
in a number of investigations involving violations of the Immigration and Nationality Act.

On July 28, 2025, Albany Immigration Customs Enforcement and Removal Operations
(“ICE-ERO”) officers conducted targeted surveillance at an address known to those officers on
Western Avenue (“Western Avenue”) in Albany, NY. An individual matching the physical
characteristics of an ICE fugitive residing at the Western Avenue address was observed exiting the
residence and entering a white cargo van (“vehicle”) that was parked. The vehicle was surveyed
by officers who initiated a vehicle stop on Route 9 in Saratoga Springs, NY. Officers approached
the vehicle and identified themselves to the occupants. Ismael] LOPEZ SANCHEZ was a
passenger in the front seat of the vehicle. LOPEZ SANCHEZ provided his identification card
from Guatemala and did not initially answer any questions, but later during the traffic stop stated
that he was in the United States for approximately two years and crossed the U.S. border by
himself. LOPEZ SANCHEZ was placed under arrest and transported back to the ICE-ERO office
for processing. Lopez Sanchez’s fingerprints were entered into IDENT and yielded a positive
match for a previously removed alien and fingerprint identification number.

According to these records, LOPEZ SANCHEZ is a citizen of Guatemala and was removed
from the United States pursuant to immigration proceedings in June 2024. In particular, on June
7, 2024, LOPEZ SANCHEZ was arrested by the United States Border Patrol near Santa Teresa,
New Mexico. On June 8, 2024, LOPEZ SANCHEZ was ordered removed a designated official.
On June 13, 2024, LOPEZ SANCHEZ was removed from the United States via ICE ERO Air
Charter Operations departing from El Paso, TX.

A records check revealed that LOPEZ SANCHEZ has not obtained the express consent of
Case 1:25-mj-00217-DJS Document1 Filed 07/28/25 Page3of3

the Attorney General of the United States or her successor, the Secretary of Homeland Security,
to reapply for admission to the United States. Based on the foregoing, there is probable cause to
believe that on July 28, 2025, LOPEZ SANCHEZ violated 8 U.S.C. §1326(a), which prohibits
aliens who have been denied admission, excluded, deported, or removed, or have departed the
United States while an order of exclusion, deportation, or removal is outstanding, from entering
and being found in the United States unless the Attorney General of the United States, or her
successor, the Secretary of Homeland Security, has expressly consented to their reapplication for

admission to the United States.

Attested to by the affiant.

Detrick Zalewski

HSI Special Agent

I, the Honorable Daniel J. Stewart, United States Magistrate Judge, hereby acknowledge that this
affidavit was attested to by the affiant by telephone on July 28, 2025, in accordance with Rule 4.1
of the Federal Rules of Criminal Procedure.


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