Affidavit for Probable Cause — United States v. Guadalupe Martinez-Sanchez, 2:19-mj-00023

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An Affidavit for Probable Cause for a Complaint and Arrest Warrant, pages 2 and 3 of Document 1 in Case 2:19-mj-00023-MTP, filed 08/13/19, in the Southern District of Mississippi. Special Agent Brent Druery of Homeland Security Investigations swears that the affidavit supports a criminal complaint against Guadalupe MARTINEZ-Sanchez for violating Title 8, United States Code, Sections 1326(a)(1) and (2), reentry of removed alien. It states that on August 7, 2019 Immigration and Customs Enforcement executed seven criminal and administrative search warrants at chicken processing company locations, and that record checks revealed one prior removal on or about November 28, 2014. The affidavit concludes that probable cause exists.

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Case 2:19-mj-00023-MTP Document1 Filed 08/13/19 Page 2 of 3

AFFIDAVIT FOR PROBABLE CAUSE FOR
A COMPLAINT AND ARREST WARRANT

I, Brent Druery, being duly sworn, do hereby depose and state the following:

INTRODUCTION AND AGENT BACKGROUND

1. I am employed as a Special Agent with Homeland Security Investigations
(“HSI”), assigned to the Resident Agent in Charge in Jackson, Mississippi. I have been so
employed since November of 2002. I have received training and been assigned to conduct
investigations of criminal violations of the United States Code as enumerated in Titles 8, 18, 19,
21, 22, 31 and various other federal statutes.

2. I submit this affidavit based on information known to me personally from the
investigation, as well as information obtained from others who have investigated the matter or
have personal knowledge of the facts herein. This affidavit is being submitted in support of a
criminal complaint against Guadalupe MARTINEZ-Sanchez, and, as such, does not include all
the information known to me as part of this investigation, but only information sufficient to
establish probable cause for the issuance of a criminal complaint against Guadalupe
MARTINEZ-Sanchez for violating Title 8, United States Code, Sections 1326(a)(1) and (2),
reentry of removed alien.

PROBABLE CAUSE

3. On August 7, 2019, Immigration and Customs Enforcement (ICE) executed seven
criminal and administrative search warrants at chicken processing company locations across the
Southern District of Mississippi. During the execution of the search warrant at Peco Foods, 95
Commerce Drive, Bay Springs, Mississippi 39338, ICE officials encountered Guadalupe
MARTINEZ-Sanchez (Alien # XXXXX1829), an illegal alien from Mexico. Record checks for

MARTINEZ-Sanchez revealed one prior removal by U.S. immigration officials. On or about
Case 2:19-mj-00023-MTP Document1 Filed 08/13/19 Page 3 of 3

November 28, 2014, MARTINEZ-Sanchez was encountered by U.S. immigration officials in
Arizona and was processed as an Expedited Removal. She was thereafter removed to Mexico
from Douglas, Arizona, on or about November 28, 2014. Queries within ICE databases revealed
Guadalupe MARTINEZ-Sanchez has not received consent from the Attorney General of the
United States or Secretary of Homeland Security to apply for readmission, or to re-enter into the
United States.

CONCLUSION

is Based on these underlying facts and circumstances, as set forth above, it is my
belief that probable cause exists showing that Guadalupe MARTINEZ-Sanchez, is a citizen and
national of Mexico, who reentered and was found in the United States after deportation and
removal without having first obtained the express consent of the Attorney General of the United
States or the Secretary of the Department of Homeland Security, in violation of Title 8, United
States Code, Section 1326(a)(1) and (2).

Respectfully submitted,

Brent Druery C-

Special Agent
Homeland Security Investigations

aw
SWORN to before me on this 3 day of August, 2019.

Lee tal

UNITED STATES MAGISTRATE JUDGE


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