AO 91 (Rev. L111) Ceiminl Complaint
UNITED STATES DISTRICT COURT
for the
Southern District of Indiana
United States of America )
v. )
) Case No.
> 1:18-mj-00113
MANUEL ORREGO-ZAVALA )
alk/a Manuel Orrego-Savala )
ee )
‘Defendant
CRIMINAL COMPLAINT
J, the complainant in this ease, state that the following is true to the best of my knowledge and belief.
Onorabout the date(s) of ___February 4, 2018 in the county of Marion inthe
Southem _ District of Indiana the defendant(s) violated:
Code Section Offense Description
Title 8, United States Code, Section Illegal reentry of a previously deported alien
1326(@)
This criminal complaint is based on these facts:
See attached affidavit,
& Continued on the attached sheet.
ea
ao Us =
q@ Complainant/Axignature
n Rodriguez, Special Agent, HSI
Printed name and title
‘Swom to before me and signed in my presence.
Date: o2/06/2018 NY = mK
Tide's signature
City and state: Indianapolis, Indiana Tim A. Baker, U.S, Magistrate Judge
a ~~ Printed namie and tteAFEIDAVIT
Your Affiant, Jason C. Rodriguez, is employed by the Homeland Security Investigations,
United States Department of Homeland Security. I have been so employed for approximately
(17) years. Prior to my employment as a Special Agent, I was employed as an Inspector with the
Immigration and Naturalization Service on the International border at the San Luis, AZ port of
entry,
1. _ Tam a swom Federal agent empowered under the laws of the United States to
investigate violations of Federal firearm and Immigration laws and have focused attention on the
detection and apprehension of individuals violating both Federal and State laws.
2. Your Affiant is currently involved in an investigation regarding illegal re-entry of
a previously deported alien by Manuel ORREGO-Zavala (“ORREGO-Zavala”) aka Manuel
ORREGO-Savala, aka Manuel Savala Orrego, aka Alex G. Cabrera, who is an alien illegally or
unlawfully in the United States. Based upon this investigation, your Affiant has probable cause
to believe ORREGO-Zavala violated Title 8, United States Code, Section 1326(a), illegal re-
entry of a previously deported alien
3. Your Affiant’s probable cause is based on the information set forth in the
following paragraphs which is either known personally to your Affiant, or has been related to
your Affiant by law enforcement personnel within the Indianapolis Metropolitan Police
Department (IMPD) and Immigration and Customs Enforcement-Enforcement and Removal
Operations (ICE-ERO).
4, On February 4, 2018, ORREGO-Zavala was encountered by law enforcement in
Indianapolis, Indiana, when ORREGO-Zavala was attested after being involved in a motor
vehicle accident on Interstate 70,5. ORREGO-Zavala was arrested under the name of Alex Cabrera,
6. On February 5, 2018, your Affiant reviewed ORREGO-Zavala’s alien file, AOS,
263 807. ORREGO-Zavala is a citizen and national of Guatemala by birth in Guatemala City,
Guatemala on July 25, 1980. On October 27, 2006, ORREGO-Zavala, was arrested by ICE-
ERO, San Francisco, California and processed for removal proceedings. On December 20, 2006,
ORREGO-Zavala was ordered removed from the United States to Guatemala at Eloy, Arizona,
On January 17, 2007, ORREGO-Zavala was removed from the United States to Guatemala at
Phoenix, Arizona. At the time of his removal to Guatemala, ORREGO-Zavala was served form
1-296 (Notice to Alien Ordered Removed/Departure Verification). This form notified ORREGO-
Zavala was prohibited from entering, attempting to enter, or being in the United States for a
period of 10 years from the date of removal from the United States. On! March 26, 2009,
ORREGO-Zavala was arrested by ICE-ERO, San Francisco, California and processed for
removal proceedings. On May 12, 2009, ORRE
)-Zavala was removed from the United States
to Guatemala at Phoenix, Arizona. At the time of his removal to Guatemala, ORREGO-Zavala
was served form 1-296 (Notice to Alien Ordered Removed/Departure Verification). ‘This form
notified ORREGO-Zavala was prohibited from entering, attempting to enter, or being in the
United States for a period of 20 years from the date of removal from the United States,
7. On February 6, 2018, HST Task Force Officer (TFO) Wilkerson obtained
ORREGO-Zavala’s fingerprints from the February 4, 2018 arrest in Indianapolis, Indiana from.
the IMPD identification and Records Branch, Your Affiant scanned and submitted ORREGO-
Zavala’s fingerprints in a Department of Homeland Security database.
8. The database search resulted in a fingerprint match to ORREGO-Zayala’s January
17, 2007 and May 12, 2009 removals from the United States to Guatemala,9. Department of Homeland Security records show that ORREGO-Zavala did not
have permission from the Attorney General of the United States, or his successor, the Secretary
of Homeland Security, or any designee, to renter the United States following his deportation,
United States Department of Homeland Security,
Homeland Security Investigations
Subscribed and sworn to me before this 6" day of February 2018, at Indianapolis, Indiana,
Na) BL
Tim A. Baker
United States Magistrate Judge
Souther District of Indiana