Durante eso una conferencia de prensa el día de hoy, los
I, Patrick Cunningham, Special Agent, HSI, declare under penalty of perjury, the
following in support of the complaint:
On or about October 3, 2013, HSI agents received information from a confidential
source (hereinafter "CS") that an individual later identified as Jose Gabriel
Orendain was involved in the construction of a subterranean cross-border tunnel
and that Orendain acquired multiple items including four demolition hammer drills
during a 45-day period, beginning in August 2013 to September 2013. Orendain
told the CS that these drills were being used to construct a tunnel. Federal agents
determined through recent crossing records that Orendain drove a GMC pickup,
bearing Baja California, license plates BP94034 ("GMC pickup"). On October 16,
2013, Orendain, who was driving the same GMC pickup, crossed the border with
Julian Velasquez-Lopez.
October 25, 2013
On Friday, October 25, 2013, agents observed Orendain at the SIEMPRE VIVA
WAREHOUSE.
October 26, 2013- Seizure of 3 tons of marijuana
On Saturday, October 26, 2013, Orendain was again observed near the SIEMPRE
VIVA WAREHOUSE.
At one point, box truck-2 left and was stopped by Chula Vista
Police for traffic violations. Agents found approximately three tons of marijuana
inside box truck-2.
October 28 and 29, 2013 Surveillance
On October 28, 2013, agents saw the white Nissan Sentra at the SIEMPRE VIVA
WAREHOUSE.
October 30, 2013 – Seizure of Cocaine
On October 29, 2013, agents observed several suitcases being transferred from the
SIEMPRE VIVA WAREHOUSE to a panel van that was parked outside.
Defendant Juan Pena-Osuna then drove the panel van away from the SIEMPRE
VIVA WAREHOUSE but parked nearby.
Defendant
Juan Pena-Osuna who was driving his white Nissan Sentra in tandem with the
panel van was also stopped and arrested.
Defendant Roman Ramos Romero was driving
box truck-1. He was the sole occupant ofbox truck-1. Agents found
approximately 2,868.6 kilograms (6,310.92 pounds) of marijuana inside the box
truck-1.
On October 30, 2013, federal search warrants were executed at two locations: (1)
the warehouse located at 9163 Siempre Viva Road, Suite F, San Diego, California
(hereinafter "SIEMPRE VIVA WAREHOUSE"); and (2) the warehouse located at
1675 Brandywine Avenue, Suite C, Chula Vista, California (hereinafter
"BRANDYWINE WAREHOUSE").
Inside the SIEMPRE VIVA WAREHOUSE on October 30,
20 13, federal agents found a narcotics tunnel, spanning the international border
from Mexico into the United States, and approximately 997.2 kilograms (2,193.84
pounds) of marijuana.
The BRANDYWINE WAREHOUSE
II
I
was the stash location or secon~~o £ r the drug trafficking organization.
