UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA 

Case No. 22-8401-WM 

UNITED STATES OF AMERICA 

v. 

ISAIAS PEREZ-BARTOLOME, 

Defendant. 

I --------------

CRIMINAL COVER SHEET 

1. Did this matter originate from a matter pending in the Northern Region of the United States 

Attorney's Office prior to August 8, 2014 (Mag. Judge Shaniek Maynard)? _Yes _{_ No 

2. Did this matter originate from a matter pending in the Central Region of the United States 

Attorney's Office prior to October 3, 2019 (Mag. Judge Jared Strauss)? Yes I No 

Respectfully submitted, 

JUAN ANTONIO GONZALEZ 

UNITED STATES ATTORNEY 

BY: ~ /u¢uu:uu: 

Rinku Tribuiani 

ASSIST ANT UNITED STA TES ATTORNEY 

Florida Bar No. 0150990 

500 South Australian Avenue, Suite 400 

West Palm Beach, Florida 33401 

Tel: (561) 820-8711 

Fax: (561) 820-8777 

Email: RTribuiani@usa.doj .gov 

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AO 91 (Rev. 08/09) Criminal Complaint 

UNITED STATES DISTRICT COURT 

United States of America 

V. 

ISAIAS PEREZ-BARTOLOME, 

Defendant(s) 

for the 

Southern District of Florida 

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Case No. 22-8401-WM 

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(s) of August 14, 2022 in the county of Palm Beach 

Southern District of Florida , the defendant(s) violated: 

Code Section Offense Description 

Title 8 U.S .C. 1326(a) and (b)(1) Illegal re-entry into the United States after deportation or removal 

This criminal complaint is based on these facts: 

See Attached Affidavit 

~ Continued on the attached sheet. 

TFO Andy Korzen, HSI 

Printed name and title 

Sworn and Attested to me by Applicant by Telephone (FaceTime) pursuant to Fed. R. Crim. P. 4(d) and 4.1 

Date: 

Judge 's signature 

in the 

City and state: West Palm Beach FL William Matthewman, U.S. Magistrate Judge 

Printed name and title 

September 13, 2022

KJZ Sep 13, 2022 West Palm Beach

Case 9:22-cr-80151-AMC Document 1 Entered on FLSD Docket 09/13/2022 Page 2 of 5
AFFIDAVIT OF ANDY KORZEN 

UNITED STATES DEPARTMENT OF HOMELAND SECURITY 

IMMIGRATION AND CUSTOMS ENFORCEMENT 

I, Andy Korzen, being duly sworn, depose and state as follows: 

l. I am a Task Force Officer (TFO) with the Homeland Security 

Investigations (HSI), and I am also Deportation Officer with the Immigration and 

Customs Enforcement (ICE) and have been so employed for over nineteen years. I am 

currently assigned to the HSI, West Palm Beach, Florida. My duties and responsibilities 

include enforcing criminal and administrative immigration laws of the United States. I 

have also conducted and participated in investigations of this nature. 

2. This affidavit is based upon my own knowledge as well as information 

provided to me by other law enforcement officers. This affidavit does not set forth every 

fact known to me regarding the investigation but only those facts necessary to establish 

probable cause to believe that Isaias PEREZ-BARTOLOME committed the offense of 

illegal re-entry after removal, in violation of Title 8, United States Code, Sections 

1326(a) and (b)(l). 

3. On or about August 14, 2022, Isaias PEREZ-BARTOLOME was arrested 

in Palm Beach County, Florida for the offenses of driving under the influence, driving 

without driver license, and willfully refusing to sign/accept summons. He was booked 

and detained at the Palm Beach County Jail. 

4. A review of the immigration records show that Isaias PEREZBARTOLOME is a native and citizen of Guatemala. Records further show that on or 

about June 4, 2010, Isaias PEREZ-BARTOLOME was ordered removed. The Order of 

Case 9:22-cr-80151-AMC Document 1 Entered on FLSD Docket 09/13/2022 Page 3 of 5
Removal was executed on or about June 16, 20 I 0, whereby Isaias PEREZBARTOLOME was removed from the United States and returned to Guatemala. 

5. Records further show that on or about March l 7, 20 I 0, in the Criminal 

Division of the Circuit Court of the Fifteenth Judicial Circuit of Florida, in and for Palm 

Beach County, Isaias PEREZ-BARTOLOME was convicted of the felony offense of 

child abuse and the misdemeanor offense of domestic battery, in case number 

2009CF0I 6156. 

6. Isaias PEREZ-BARTOLOME's fingerprints taken in connection with his 

August 14, 2022, arrest in Palm Beach County were scanned into the IAFIS system. 

Results confirmed that scanned fingerprints belong to the individual who was previously 

removed from the United States, that is, Isaias PEREZ-BARTOLOME. 

7. A record check was performed in the Computer Linked Application 

Informational Management System to determine iflsaias PEREZ-BARTOLOME filed an 

application for permission to reapply for admission into the United States after 

deportation or removal. After a search was performed in that database system, no record 

was found to exist indicating that Isaias PEREZ-BARTOLOME obtained consent from 

the Attorney General of the United States or from the Secretary of Homeland Security, 

for re-admission into the United States as required by law. 

8. Based on the foregoing, I submit that probable cause exists to believe that, 

on or about August 14, 2022, Isaias PEREZ-BARTOLOME, an alien who was previously 

deported and removed from the United States, was found in the United States without 

having received express consent from the Attorney General or the Secretary of the 

2 

Case 9:22-cr-80151-AMC Document 1 Entered on FLSD Docket 09/13/2022 Page 4 of 5
Department of Homeland Security for re-admission into the United States, in violation of 

Title 8, United States Code, Sections 1326(a) and (b)(l). 

And~ 

Task Force Officer 

Homeland Security Investigations 

Sworn and Attested to me by Applicant by Telephone (Facetime) pursuant to Fed. R. 

Crim. P. 4(d) and 4.1 this ___ day of September 2022. 

WILLIAM MA TTHEWMAN 

UNITED STATES MAGISTRATE JUDGE 

3 

13th

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