= CRIMINAL COMPLAINT

United States District Court DISTRICT of ARIZONA
United States of America DOCKET NO.
: v.
Dmitriy Borisovich Razmyslovich
DOB: 1998; U.S. Citizen; . MAGISTRATE'S CASE NO.
James Michael Nowak :
DOB: 1998; US. Citizen; 17-O05960MS
Complaint for violation of Title 8 United States Code § 1324(a)(1)(A)(ii), 1324(a)(1)(B)(@), and
1324(a)(D( AYO

COMPLAINANT'S STATEMENT OF FACTS CONSTITUTING THE OFFENSE OR VIOLATION:

On or about November 5, 2017, at or near Tombstone in the District of Arizona, Dmitriy Borisovich
Razmyslovich and James Michael Nowak, named herein as defendants and conspirators, did knowingly
and intentionally combine, conspire, confederate, and agree with each other and other persons, known and
unknown, to transport a certain illegal alien, namely Daniel Garcia-Pena, and did so for the purpose of private
financial gain; in violation of Title 8, United States Code, Sections 1324(a)(1)(A)(ii), 1324(a)(1)(B)@), and
1324(a)(I(A\W)@.

BASIS OF COMPLAINANT'S CHARGE AGAINST THE ACCUSED:

On or about November 5, 2017, at or near Tombstone, in the District of Arizona, United States Border Patrol
Agents (BPA) encountered a grey 2010 Honda Accord at the Highway 80 Immigration Checkpoint. As the
vehicle approached the pre-primary inspection area, a K-9 alerted to the vehicle. The vehicle was driven by
Dmitriy Borisovich Razmyslovich and James Michael Nowak was the front seat passenger. While BPA
was performing an immigration inspection of the vehicle, the K-9 alerted to the vehicle again. The BPA
handler notified the inspecting officer to send the vehicle to secondary. During secondary, BPA discovered
Daniel Garcia-Pena inside the truck. Garcia-Pena is not a citizen or national of the United States and does
not possess any documentation that would allow him to enter or remain in the United States legally.

After Miranda, Razmyslovich admitted that he and his friend Nowak saw an ad on Snap Chat asking if|
anyone would like to pick-up someone for $600, to which they both agreed. Razmyslovich further admitted
that Nowak knew the person they were working with and his name is “Willie”. After driving for two hours,
Razmyslovich and Nowak waited at a Burger King for an additional two hours, where they were given
further instructions to drive to Purdy Lane. They picked up an unknown person waiting in the brush. They
received instructions to put the person in the trunk of the car. Razmyslovich pulled over and Nowak placed
him in the trunk.

Garcia-Pena stated that he arranged to be smuggled into the United States in exchange for money. He further
stated that after entering the United States illegally, he received instructions to wait at what looked like an
apartment building and a house. He was only there for 5 minutes before he was picked up by two males in
a sedan. About 30 minutes later, the car pulled off the road and the passenger ordered him to get in the
trunk of the car. ;

MATERIAL WITNESSES IN RELATION TO THE CHARGE: Daniel Garcia-Pena

DETENTION REQUESTED SIGNAT. OF COMPLAINANT
Being duly sworn, I declare that the foregoing is
true and correct to the best of my knowledge.

Ww ASOFFICIAL TITLE
UTHORIZED BY: AUSA RW US Border Patrol Agent
Sworn to before me and subscribed in my presence.

SIGN. [AGISTRATE jes orn DATE: November 6, 2017

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