AO 91 (Rev. 08/09) Criminal Complaint 

UNITED STATES DISTRICT COURT 

forthe 2020 APR20 3O 

Western District of Texas 

United States of America ) j. 

v. ) 

Ludwig ARMENDARIZ ) Case No. //, 

ltzel Alicia HAYASHI-ITO ER L 

Defendant(s) 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 in the county of El Paso in the 

Western District of Texas , the defendant(s) violated: 

Code Section Offense Description 

21 usc 960 & 952 On or about April 17, 2020, in El Paso county, in the Western District of 

Texas defendant(s) did, knowingly and intentionally conspire to import with 

the intent to distribute approximately 19.24 kilograms (gross weight) of 

marijuana, a Schedule I Controlled Substance; and knowingly and 

intentionally imports with the intent to distribute approximately 19.24 

kilograms (gross weight) of marijuana, a Schedule I Controlled Substance. 

This criminal complaint is based on these facts: 

Please see attached affidavit. 

Continued on the attached sheet. 

Sworn to before me and signed in my presence. 

Date: 04/20/2020 

Francisco Zubia Jr., Special Agent 

Printed name cmdtlll>/ 

Judge signature 

City and state: El Paso, Texas Robert F. Castaneda, U.S. Magistrate Judge 

Printed name and title 

Oath TeephotiaUY Sworn 

At I :UU_pt,q 

Fed .R.Crirn..P.4.1 (bX2XA) 

Case 3:20-mj-02230-RFC Document 1 Filed 04/20/20 Page 1 of 2
Affidavit 

On Friday, 17, 2020, at approximately 8:53 pm, Itzel Alicia HAYASHI-ITO and Ludwig 

ARMENDARIZ, attempted to make entry into the United States utilizing the Bridge of Americas 

(BOTA) Port of Entry (POE) located in the Western District of Texas, driving a 2008 Ford Focus 

red in color in color with Mexican plates A38SBB2. Custom and Border Protection Officers 

(CBPO) conducted an inspection of the vehicle and revealed approximately 19.24 kilograms of 

marijuana concealed inside the rear bumper, Glove box, and front right quarter panel of the 

vehicle. 

CBPO obtained a negative declaration from ARMENDARIZ. CBPO asked ARMENDARIZ 

where he was coming from and his purpose of going to Juarez, Mexico which ARMENDARIZ 

replied that he was coming from visiting family. CBPO asked ARMENDARIZ who the vehicle 

belonged and for how long which ARMENDARIZ replied that it was uncles and that he is the 

only one that drives it for the last two months. CBPO stated that he then swiped HAYASHI -ITO 

passport, a computer-generated mandatory referral appeared and referred the vehicle for 

secondary. 

CBPO at secondary obtained a second negative declaration from ARMENDARIZ. CBPO stated 

that ARMENDARIZ continued to look back at the vehicle while a K9 was conducting a search. 

CBPO advised that the he was advised of a positive alert by K9 officer. 

At approximately 1:22 am. HAYASHI-ITO was readvised of her Miranda Warnings by Special 

Agent (SA) Francisco Zubia and witnessed by Task Force Officer (TFO) Aaron Fierro which 

HAYASHI-ITO waived her rights and was willing to continue to speak to agents. The interview 

was conducted in English. 

SA Zubia asked HAYASI-II-ITO what she was smuggling, how much she was getting paid and 

where was she taking the vehicle. HAYASHI-ITO stated that she did not know what type of 

drugs she was taking but knew it was narcotics, was going to get paid $3,000 U.S. currency, and 

was going to receive a text of where to take the narcotics. 

At approximately 1:55 am. ARMENDARIZ was readvised of his Miranda Warnings by Special 

Agent (SA) Francisco Zubia and witnessed by Task Force Officer (TFO) Aaron Fierro which 

ARMENDARIZ waived his rights and was willing to continue to speak to agents. The interview 

was conducted in English. 

SA Zubia asked ARMENDARIZ what he was smuggling into the U.S., how much was he getting 

paid and where he was taking the narcotics. ARMENDARIZ stated that he was smuggling 

"Reggie" which he explained to be low grade marijuana, was getting paid $2,400 U.S. currency. 

ARMENDARIZ stated that he was going to remove the marijuana at his residence and delver it 

to an unknown person at the outlet malls located at 7051 S. Desert Blvd, Canutillo, Texas 79935. 

Case 3:20-mj-02230-RFC Document 1 Filed 04/20/20 Page 2 of 2