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GARY M. RESTAINO 

United States Attorney 

District of Arizona 

JARED KREAMER HOPE 

Assistant U.S. Attorney 

State Bar Number: 025575 

ASHLEY ENDERLE

Assistant U.S. Attorney 

State Bar Number: 030798 

United States Courthouse 

405 W. Congress Street, Suite 4800 

Tucson, Arizona 85701 

Telephone: 520-620-7300 

Attorneys for Plaintiff 

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF ARIZONA 

United States of America, 

 Plaintiff, 

 vs. 

Maria Mendoza-Mendoza, 

 Defendant.

CR 18-00078-3-RCC 

GOVERNMENT’S SENTENCING 

MEMORANDUM 

The United States of America, by and through its undersigned attorneys, hereby 

submits the following Sentencing Memorandum. Sentencing is currently set for April 2, 

2024. 

Guideline Calculation: 

The government concurs with the PSR’s calculation of a base offense level of 12, a 

total offense level of 32 and the defendant’s placement in criminal history category I. This 

would result in a guideline range of 121 to 151 months, but the plea stipulates to a guideline 

range of 96 to 120 months, and the government requests the Court accept the plea and 

impose a sentence within the stipulated plea range.1

1 This stipulation in the plea also provides benefit to the defendant, as the statutory maximum for money laundering is 20 years, and the plea caps the defendant’s exposure at 

10 years. Further, Counts 9 and 10 would have potential to be run consecutively and the 

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Investigation Overview: 

In October 2016, Homeland Security Investigations (HSI) received information 

about an alien smuggling organization (ASO) moving thousands of people to stash houses 

across the United States/Mexico border to stash houses in Phoenix, Arizona. The ASO 

recruited and coordinated load drivers, collected fraudulent documents from smuggled 

undocumented non-citizens (UNCs), received buy-outs from the families of smuggled 

UNCs via cash and wire transfer, and provided the smuggling proceeds and fraudulent 

documents to other members of the ASO both in the United States and in Mexico. Through 

further investigation, HSI agents were able to identify the main United States-based 

coordinator of the ASO as Audias Sanchez-Colin. 

HSI utilized numerous law enforcement techniques, including toll analysis, geolocation of cellular devices, vehicle tracking warrants, indices checks, and physical 

surveillance and interdicted 24 alien smuggling loads in 12 states, involving 140 UNCs. 

Based on information obtained throughout the investigation, HSI estimates that over 1,000 

UNCs have been moved from Mexico into the United States by the ASO, all through the 

District of Arizona. HSI identified two residences and several motels in the District of 

Arizona that the ASO utilized as stash houses where the UNCs were held until they (or 

their family) completed payment for their smuggling journey. After payment, the ASO 

smuggled the UNCs to their final destination. The ASO utilized numerous funnel accounts 

to collect millions of dollars in smuggling fees deposited across the United States and 

withdrawn primarily in the Phoenix, Arizona area. 

In January 2018, 27 co-defendants, including Sanchez-Colin and MendozaMendoza, were indicted in this matter. Their roles include: United States-based 

coordinators, coordinators based in other countries, money launderers, funnel account 

current plea provides benefit to the defendant by avoiding that potential and dismissing 

those counts. 

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holders, accountants, stash house owners, stash house coordinators, recruiters, and load 

drivers for this ASO. 

 Specific to the identification of Maria Mendoza-Mendoza, an authorized wiretap on 

Sanchez-Colin’s cell phones beginning in October 2017 revealed that a female who goes 

by the moniker “Guera” was the Honduras-based smuggler for the ASO. Per the intercepted 

communications, Guera was responsible for supplying Central American and Mexican 

UNCs to smugglers operating in and around Altar and Sasabe, Sonora, Mexico. Guera also 

employed foot guides and money launderers, and smuggled aliens into the United States to 

work for Sanchez-Colin as load drivers and stash house caretakers. HSI agents met with 

Border Patrol agents to aid in identifying “Guera.” Border Patrol agents disclosed that 

during the past several years, numerous apprehended UNCs identified a Honduran female 

known as “La Guera” as the leader of the ASO that made the arrangements to smuggle 

them into the United States. Border Patrol agents believed this female to be Maria 

Mendoza-Mendoza, who also goes by the name Roxana Guadalupe Hernandez de Paz, and 

created a 6-pack photo lineup with Mendoza-Mendoza’s picture. More than 10 UNCs 

positively identified Mendoza-Mendoza as “Guera”. Agents also acquired additional 

identification evidence from passports, social media and witness interviews corroborating 

that Mendoza-Mendoza was “Guera”. 

A warrant issued for Mendoza-Mendoza on January 18, 2018. She was subsequently 

arrested while attempting to travel to Guatemala and finally extradited from Honduras to 

the United States on June 22, 2023. 

The government also respectfully requests the court incorporate the facts and 

evidence in the government’s detention memorandum (Doc. # 890). 

Defendant’s Involvement: 

The government concurs with the PSR’s assessment that the defendant was a leader 

or organizer in this alien smuggling organization, which involved more than five 

participants. The defendant’s role is evident from her communications with the primary 

U.S. coordinator, Audias Sanchez-Colin. The defendant’s authority is clear in her ability 

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to assess punitive sanctions to organization members who have made mistakes. Attachment 

A, p. 101-102. Her organization included obtaining passports for smuggled persons and 

receiving money for the smuggled persons. Attachment B, p. 165-166. She aggressively 

executed this leadership with threats against the smuggled persons. Attachment C, p. 385-

389. As the PSR notes, her aggressive control permeates the wire intercepts in this case, 

with statements about bleeding out members of the organization and enforcement of 

payments. (PSR ¶ 80).2

The defendant led the most concerning aspects of the organization. As a Honduras 

based coordinator, she acquired a high volume of work for the organization. Attachment 

B, p. 161. This work is reflected in ledgers seized from Sanchez-Colin, which repeatedly 

reference this defendant as the coordinator for certain people. Attachment D. This also 

resulted in significant money to the organization. Id. The defendant also posted social 

media videos displaying this money. Attachment E. 

In addition to the significant volume of people smuggled, the defendant’s 

discussions are replete with references to smuggling children. In intercepted 

conversations, she references a smuggled child being sick (Bates # 253-54), delivery of a 

child to “Carlos” (Bates #821), Sanchez-Colin smuggling a 10-11 year old (Bates #1045), 

discussion of a smuggled “kid” urinating blood (Bates 1507-1508), and the incident 

referenced in the PSR where Sanchez relayed her instructions to drop off 5 people and 2 

kids at a stash house (Bates 1934). (PSR ¶ 103).

This defendant also led an organization that posed significant risk to the people 

smuggled. As the PSR states, a person was killed at a stash house and firearms and 

2 Despite stipulating to a leadership role in her plea, the defendant appears to partially deny a leadership role or receiving money. This is not a dispute the court need resolve, as the proposed enhancements are supported by substantial evidence and the plea stipulates to any variance needed to reach the range the parties have agreed upon. The 

parties do not seek to withdraw from the plea and as such, unless the defendant specifically objects or attempts to controvert the facts in the PSR, the court can rely on the evidence noted by the PSR and government. United States v. Saeteurn, 504 F.3d 1175, 1181 (9th Cir. 

2007).

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ammunition were found during search warrants. (PSR ¶ 104). As stated above, the 

defendant herself directly made threats against organization members and smuggled 

migrants. Further, she repeatedly references people potentially being killed during actions 

in the smuggling organization. (Bates 801, 1003, 1036, 1051, 2318). The defendant’s 

responses to such violence are cold, as she recounts a co-conspirator saying “they’re going 

to kill me here, they’re going to lynch me in Guatemala,” and says she replied “I told him 

‘if they lynch you, I don’t care.’” (Bates 2318). 

In short, the government concurs this defendant was a primary leader of an 

extensive, high-dollar, smuggling organization that realized substantial revenue by 

smuggling migrants (often children) in dangerous ways. 

Sentencing Recommendation: 

The government concurs with the PSR’s recommendation of 120 months. This 

sentence is consistent with the application of the sentencing factors outlined in 18 U.S.C. 

§ 3553(a). It takes into consideration the defendant’s characteristics, reflects the 

seriousness of the defendant’s conduct, promotes respect for the law, and provides a just 

punishment that would afford adequate deterrence while protecting the public from further 

crimes of Defendant. Further, such a sentence would be proportional within the case, as 

the primary U.S. coordinator, Sanchez-Colin, received a sentence of 120 months. (Docket 

# 689). A 120 month sentence is appropriate for a leader of an extensive, dangerous 

organization. 

/// 

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Respectfully submitted this 19th day of March, 2024.

GARY M. RESTAINO

United States Attorney District of Arizona

s/Jared Kreamer Hope

JARED KREAMER HOPE

Assistant U.S. Attorney

s/Ashley Enderle

ASHLEY ENDERLE

Assistant U.S. Attorney

Copy of the foregoing served electronically or by other means this 19th day of March, 2024, to:

All ECF Participants

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