Elias Casiano Statement Of Facts

8/2/2019 Elias Casiano Statement Of Facts

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IN THE UNITED STATES D ISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA

Alexandria Divis ion

UNITED STATES OF AMERICA

CRIMINAL NO. 1 :12CR66

•fl£0

INOPEN COW

CUPK,'. . STRICT COURT

ELIAS CASIANO, JR.,

a/k/a "DICE,"

Defendant.

The Hono ra bl e Leoni e M . B ri nk ema

STATEMENT OF FACTS

Were this matter to go to trial, the United States of America would prove the following

facts beyond a reasonable doubt with admissible and credible evidence:

1. On or about December 17, 2011, within the Eastern District of Virginia, the

defendant, ELIAS CASIANO, JR., unlawfully, knowingly, and intentionally imported into the

United States from a place outside thereof, one (I ) kilogram or more of a mixture and substance

containing a detectable amount of heroin, a Schedule I controlled substance, in violation of Title

21, United States Code, Section 952.

2. On or about December 17, 2011, the defendant entered the United States at Dulles

International Airport, within the Eastern District ofVirginia, after arriving on a flight originating

from Bolivia. During the course of a customs inspection, an officer with Customs and Border

Patrol noted that a foreign object was concealed within a small soccer team banner inside the

defendant's suitcase. Upon further inspection, the officer determined that the foreign object was

a package of heroin. Further examination of the defendant's suitcase revealed four pairs of

soccer-style pants and two pairs of soccer-style shorts, which also contained packages of heroin

Case 1:12-cr-00066-LMB Document 25 Filed 03/14/12 Page 1 of 3 PageID# 59



sewn within their linings. In total, twenty-seven packages of heroin were recovered from inside

the defendant's suitcase, weighing 3.842 kilograms.

3. The acts taken by the defendant in furtherance of the offense charged in this case,

including the acts described above, were done willfully and knowingly with the specific intent to

violate the law. The defendant acknowledges that the foregoing Statement of Facts does not

describe all of the defendant 's conduct relating to the offense charged in this case nor does it

identifyall of the persons with whom the defendant may have engaged in illegal activities.

Respectfully submitted,

Neil H. MacBride

United States Attorney

By:

Kara Mart in Traster

Special Assistant United States Attorney




Defendant's Stipulation and Signature

After consultingwith my attorney, I hereby stipulate that the above Statement of Facts is

true and accurate, and that had the matter proceeded to trial, the United States would have proved

the same beyond a reasonable doubt.

ELIAS CASIANO, JR .

Defendant

Defense Counsel 's Signature

I am the attorney for ELIAS CASIANO, JR. I have carefully reviewed the above

Statement of Facts with him. To my knowledge, his decision to stipulate to these facts is

informed and voluntary.

(-£k&)kMJVO>Shannon Quill, Esq

Counsel fo r the Defendan t


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Elias Casiano Statement Of Facts