AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

for the

__________ District of __________

United States of America )

)

)

)

)

)

)

v.

Case No. 3:22-MJ-323-BK

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 in the

District of , the defendant(s) violated:

Code Section Offense Description

This criminal complaint is based on these facts: 

u Continued on the attached sheet.

Complainant’s signature

Printed name and title

$JHQWVZRUQDQGVLJQDWXUHFRQILUPHGYLDUHOLDEOHHOHFWURQLFPHDQVSXUVXDQWWR)HG5&ULP3

Date:

Judge’s signature

City and state:

Printed name and title

Northern District of Texas

Jesus Alexander Perez Fuentes 

March 30, 2022 Dallas

Northern Texas

21 USC 841 Possession with Intent to Distribute a Schedule II controlled 

substance.

See attached affidavit of DEA TFO Christopher Biggs

✔

Christopher Biggs, TFO DEA

Dallas, Texas RENÉE HARRIS TOLIVER, U.S. Magistrate Judge

March 31, 2022

FILED

KAREN MITCHELL

CLERK, U.S. DISTRICT 

COURT March 31, 2022

Case 3:22-cr-00156-K Document 1 Filed 03/31/22 Page 1 of 6 PageID 1
Affidavit in Support of Criminal Complaint - Page 1 

Affidavit in Support of Criminal Complaint 

I, Christopher Biggs, a Task Force Officer with the Drug Enforcement 

Administration (DEA), being duly sworn, deposes and states: 

1. I am a Task Force Officer with the United States Department of

Justice Drug Enforcement Administration (DEA). I have been a deputized Task 

Force Officer assigned to the Drug Enforcement Administration (DEA) since 

December 2018. I am assigned to the Dallas Field Division Office to investigate 

violations of federal drug statutes. I have conducted and participated in previous 

investigations of violations of the United States’ drug laws, including violations of 

21 U.S.C. §§ 841(a)(1), and 846. I am a United States law enforcement officer as 

defined in 18 U.S.C. § 2510(7), and I am empowered by law to conduct criminal 

investigations and to make arrests for federal felony offenses. I have been employed 

by my parent agency, Lancaster Police Department, for over five years. I am 

currently certified as a Master Peace Officer by the Texas Commission on Law 

Enforcement. As a law enforcement officer, I have used a variety of methods 

investigating drug related crimes, including, but not limited to, visual surveillance, 

witness interviews, the use of search warrants, confidential informants and 

undercover agents. I have personally participated in the investigation below, and I 

am familiar with the facts and circumstances through my personal participation, 

from discussions with other DEA agents and law enforcement officers, and from 

reviewing records and reports relating to the investigation. 

Case 3:22-cr-00156-K Document 1 Filed 03/31/22 Page 2 of 6 PageID 2
Affidavit in Support of Criminal Complaint - Page 2 

1. This affidavit is made for the limited purposes of establishing 

probable cause that Jesus Alexander Perez Fuentes violated Title 21, United States 

Code, Section 841(a) and (b)(1)(C), that is, possession with intent to distribute a 

Schedule II controlled substance. 

2. The information contained in this affidavit is based on my personal 

knowledge and experience, my personal participation in this investigation, and 

information obtained from other law enforcement officers and/or agents involved in 

this investigation. 

3. Since this affidavit is being submitted for the limited purpose of 

securing an arrest warrant, I have not included each and every fact known to me 

concerning this investigation. I have set forth only the facts that I believe are 

necessary to establish probable cause to believe that a violation of 21 U.S.C. § 

841(a) and (b)(1)(C), has been committed by Jesus Alexander Perez Fuentes. 

PROBABLE CAUSE 

4. In March 2022, ATF TFO Walden contacted DEA Dallas HIDTA 

Group 3 Agents in regards to information that he received from a confidential 

source1

 that Jesus Alexander Perez Fuentes was distributing counterfeit 

Oxycodone M30 tablets in the Dallas, Texas area. 

5. It has become common for drug dealers to sell blue tablets stamped 

with the letter “M” and the number “30”, that look like prescription Oxycodone 

1

 The confidential source is providing information in consideration of criminal charges and is not being 

compensated. 

Case 3:22-cr-00156-K Document 1 Filed 03/31/22 Page 3 of 6 PageID 3
Affidavit in Support of Criminal Complaint - Page 3 

M30 tablets, but which in fact contain Fentanyl and are being sold as counterfeit 

Oxycodone M30 tablets. 

6. On March 30, 2022, Agents received information that Perez Fuentes 

would be at the Galleria Mall in Dallas, Texas, which is in the Dallas Division of 

the Northern District of Texas. Agents also had information that Perez Fuentez 

would have well over a thousand M30 pills. Agents set up surveillance at the 

Galleria Mall and located Perez Fuentes’s vehicle, a white Dodge pickup, which 

ATF TFO Walden had previously identified as Perez Fuentes’s vehicle. The white 

Dodge pickup was bearing Texas license plate PMB8383, which showed to be 

registered to Perez Fuentes. Agents observed Perez Fuentes and an unknown 

female enter the Galleria Mall. Agents maintained surveillance of Perez Fuentes’s 

pickup while Perez Fuentes was inside of the Galleria Mall. Agents observed 

Perez Fuentes and the unknown female exit from the Galleria Mall and get into 

Perez Fuentes’s pickup with Perez-Fuentes being the driver. Perez Fuentes 

departed the Galleria Mall and Agents followed him as he traveled onto Interstate 

635 towards Mesquite, Texas. Texas DPS Troopers Mack and Sloan stopped Perez 

Fuentes in the area of Interstate 635 and US Highway 80 for traffic infractions. 

Trooper Mack made contact with Perez Fuentes and advised that he could smell 

the strong odor of marijuana emitting from within Perez Fuentes vehicle. Dallas 

PD K9 Officer Millard and her K9, “Z”, arrived to assist the Troopers on their 

traffic stop. Dallas PD K9 Officer Millard utilized K9 Z to conduct an exterior air 

sniff of Perez Fuentes’s pickup and K9 Z showed a positive alert for narcotics in 

Case 3:22-cr-00156-K Document 1 Filed 03/31/22 Page 4 of 6 PageID 4
Affidavit in Support of Criminal Complaint - Page 4 

Perez Fuentes’s pickup. Trooper Mack conducted a search of Perez Fuentes’s 

pickup and located a Glock 30 (.45 caliber), Serial #BSRT487, in the center 

console of the pickup and it had 10 rounds in the magazine. Trooper Mack then 

located a black backpack under the driver’s side backseat that contained two clear 

plastic bags of blue tablets with the marking’s “M” and “30”, which TFO Biggs 

believes to be counterfeit Oxycodone M30 tablets, based on training and 

experience. There were hundreds of the M30 pills.2

 I know based on my training 

and experience that this is a distributable amount. Also, inside of the black 

backpack was a large amount of an undetermined amount of U.S. currency that 

was wrapped with multiple rubber-bands. 

7. Agents attempted to speak to Perez Fuentes but he advised that he 

did not want to speak to Agents. Although Perez Fuentes did not want to speak to 

Agents, he stated to Agents that everything that was located inside of his pickup 

belonged to him. 

8. Based on the foregoing, together with my training and experience, I 

believe that there is sufficient probable cause to believe that Perez Fuentes was 

possessing with intent to distribute a Schedule II controlled substance, namely 

counterfeit Oxycodone M30 tablets containing fentanyl, in violation of 21 U.S.C. 

§ 841(a) and (b)(1)(C). I respectfully request a warrant be issued for the arrest of 

Perez Fuentes.

2

 Agents conducted a field test of one of the pills and it was presumptively positive for fentanyl. 

Case 3:22-cr-00156-K Document 1 Filed 03/31/22 Page 5 of 6 PageID 5
Affidavit in Support of Criminal Complaint - Page 5 

_________________________________ 

Christopher Biggs 

Task Force Officer 

Drug Enforcement Administration 

Agent sworn and signature confirmed via reliable electronic means on 

March____, 2022, pursuant to Fed. R. Crim. P. Rule 4.1 

___________________________________ 

RENEE HARRIS TOLIVER 

United States Magistrate Judge

31st

Case 3:22-cr-00156-K Document 1 Filed 03/31/22 Page 6 of 6 PageID 6