Case 1:12-cr-00066-LMB Document 25

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IN OPEN COW

IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA Alexandria Division
CUPK,'. . STRICT COURT

UNITED STATES OF AMERICA CRIMINAL NO. 1:12CR66

ELIAS CASIANO, JR., a/k/a "DICE,"

Defendant.

The Honorable Leonie M. Brinkema

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 of Virginia, 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

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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

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

Respectfully submitted,
Neil H. MacBride

United States Attorney

By:
Kara Martin Traster

Special Assistant United States Attorney

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Defendant's Stipulation and Signature

After consulting with 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.

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Shannon Quill, Esq
Counsel for the Defendant