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![The sworn affidavit submitted in support of the Criminal Complaint in this matter tells a
very different—and largely fictional—story. For example, Special Agent Steven Fuentes of ICE,
HSI, and the Department of Homeland Security (DHS) swore to the following:
On June 20, 2025, [HSI, ICE-ERO, and TxDPS] were conducting
surveillance at a residence on Benrus, in San Antonio, Texas, in the Western
District of Texas. Database checks indicated that Jaime Albert
QUINTANILLA-Chavez, with a Final Order of Removal from an
Immigration Judge, was residing at the above address. At approximately
0715 a.m., QUINTANILLA exited the residence and entered a white Dodge
Ram. The Dodge Ram was towing a trailer containing construction
equipment. Both license plates for the truck and trailer were expired.
ECF No. 1 ¶ 2 (emphasis added). Fuentes also swore that (1) the Defendant refused to “follow any
commands”; (2) after the Defendant was blocked in between the officers’ vehicles, he was given
“multiple verbal commands to exit the vehicle”; and (3) the Defendant “fought the law
enforcement officers.” Id. ¶¶ 3–4. Fuentes further testified at the preliminary hearing that the
Defendant was surveilled (and taken into custody) because he was subject to a Final Order of
Removal from an Immigration Judge. See ECF No. 12, 6/26 Preliminary Hr’g Tr. at 4:20–25.
Despite HSI’s sworn statement to the Magistrate Judge that the vehicle was stopped
because of expired license plates, the Assistant U.S. Attorney conceded at a bond hearing in July
2025 that Fuentes had “misrepresented what was going on.” ECF No. 29, 7/10 Hr’g Tr. at 8:12–](https://cdn.bsky.app/img/feed_thumbnail/plain/did:plc:bbp2b224lro3bfnzcqwwnkfo/bafkreie6x3oqkmgiyywtsyowz35tyuqw2ra27hpaxj2h2npzdlaskrurjm@jpeg)
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Kristi Noem: "No American citizens have been arrested or detained. We focus on those who are here illegally. And anything you would hear or report that would be different than that is simply not true and false reporting."
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