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ELIZABETH A. STRANGE F IL E D
First Assistan tant United States Attorney

istrict 0: na . .
LORIL. PRICE org 2018 MAR -7 PM 3:48

CLERK US DISTRICT COURT
Assistant U.S. Attorneys
Tnited States Courthouse ISTRICT OF ARIZONA
405 W. Congress § Street, Suite 4800
Tucson, Arizona 8
Telephone: 330°620-7300
Jul

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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF ARIZONA
United States of America,
. INDICTMENT
Plaintiff,
Violations:
vs. 18 U.S.C. § 1542
€ ‘alse Statement in Application and
se of Passport)
Marco Antonio De La Garza, Jr., Counts 1,2
aka Marco Antonio De La a Garza Campos,
aka Marco Antonio Delagarza, Jr., 18 U.S.C. § 1001
‘alse Statements)
Defendant. ‘ount 3
THE GRAND JURY CHARGES:
COUNT 1

On or about October 16, 2017, at or near the Cochise County Superior Court, within
the District of Arizona, the defendant, MARCO ANTONIO DE LA GARZA, JR., aka
Marco Antonio De La Garza Campos, aka Marco Antonio Delagarza, Jr., knowingly and
willfully made a false statement in an application for a passport with intent to induce and
secure for his own use the issuance of a passport under the authority of the United States,
contrary to the laws regulating the issuance of such passports and the rules prescribed
pursuant to such laws, in that while making an application for United States passport, the
defendant stated that:

(1) he was a United States citizen,

(2) he was born in Brownsville, Texas, and



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(3) he was born on December 21, 1980,
when he well knew those statements were false, all in violation of Title 18, United States
Code, Section 1542.

COUNT 2

On or about November 25, 2017, at or near Hereford, Arizona, within the District
of Arizona, the defendant, MARCO ANTONIO DE LA GARZA, JR., aka Marco Antonio
De La Garza Campos, aka Marco Antonio Delagarza, Jr., knowingly and willfully made a
false statement in an application for a passport with intent to induce and secure for his own
use the issuance of a passport under the authority of the United States, contrary to the laws
regulating the issuance of such passports and the rules prescribed pursuant to such laws, in
that while making an application for United States passport, the defendant completed a
supplemental questionnaire to determine entitlement for a U.S. passport and stated:

(1) he was a United States citizen,

(2) he was born in Brownsville, Texas,

(3) he was born on December 21, 1980,

(4) he had not attended formal or official schools in Mexico,

(5) his biological father was rarely in his life, and

(6) no one would hire him to work in Mexico,
when he well knew those statements were false, all in violation of Title 18, United States
Code, Section 1542.

COUNT 3

On or about October 24, 2016, in the District of Arizona, while employed as a
Customs and Border Protection (CBP) officer at the Douglas Port of Entry (POE), the
defendant, MARCO ANTONIO DE LA GARZA, JR., aka Marco Antonio De La Garza
Campos, aka Marco Antonio Delagarza, Jr., knowingly and willfully made a materially
false, fictitious, and fraudulent statement and representation in a matter within the
jurisdiction of the executive branch of the Government of the United States, by stating on
his Electronic Questionnaires for Investigations Processing (e-QIP) five-year background

United States of America v. De La Garza
Indictment Page 2 of 3



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check Request #xxxx1376 for his continued employment as a CBP officer that:

(1) he was a United States citizen,

(2) he was born in Brownsville, Texas, and

(3) he was born on December 21, 1980,
when, in fact, he knew those statements were false, all in violation of Title 18, United States
Code, Section 1001.

A TRUE BILL
/S/

Presiding Juror
ELIZABETH A. STRANGE
First Assistant United States Attorney
District of Arizona ,

IS/ REDACTED FOR

Assistant U.S. Attorney PUBLIC DISCLOSURE
Dated: March 7, 2018

United States of America v. De La Garza
Indictment Page 3 of 3