Case 1:11-mj-01014-IDD Document 2

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IX
UNITED STATES DISTRICT COURT FOR THE JjJ I DEC I 9 2011
EASTERN DISTRICT OF VIRGINIA
Alexandria Division

, clb^T^^

UNITED STATES OF AMERICA

Criminal No. 1:11MJ1014

ELIAS CASIANO, JR.

a/k/a"DICE"
Defendant.

AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT

Your Affiant, Julie Hilario, being duly sworn, deposes and states:
Introduction

1.

I am a Special Agent of the United States Department of Homeland Security

(DHS), U.S. Immigration and Customs Enforcement (ICE), Homeland Security Investigations
(HSI) and have been so employed since December 2006. I am currently assigned to the

Washington, D.C. Special-Agent-in-Charge (SAC/DC) office and am assigned to the Washington Dulles International Airport. My duties as a Special Agent with HSI include, but
are not limited to, the investigation of federal laws governing the importation of controlled

substances into the United States (21 U.S.C. 952). I have received training in general law

enforcement, including training in Title 21, United States Code, and I am a graduate of the
Federal Law Enforcement Training Center in Glynco, Georgia.

2.

The facts set forth in this affidavit are based on my personal knowledge and

review ofrecords, documents, and other physical evidence obtained during this investigation, as

well as information conveyed to me by other law enforcement officials and private persons. All

observations referenced in this affidavit that were not made by me were related to me by the
1

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person who made such observations. Unless specifically indicated, all conversations and

statements described in this affidavit are related in substance and in part only and are not
intendedto be a verbatim recitation of such statements.

3.

This affidavit is submitted in support of a criminal complaint charging Elias

CASIANO, Jr. (hereafter CASIANO) with the importation of a controlled substance into the
United States, in violation of 21 U.S.C. 952.

4.

Since this affidavit is being submitted for the limited purpose of obtaining a

criminal complaint, it does not include each and every fact observed by me or known to the
government. I have set forth only those facts necessary to support afinding ofprobable cause.
Probable Cause

5.

On or about December 17, 2011, CASIANO entered the United States at

Washington Dulles International Airport, within the Eastern District of Virginia, after arriving on Aerosur Flight 700 from Santa Cruz, Bolivia. After arriving at the U.S. Customs checkpoint,
CASIANO was selected for secondary examination. CASIANO presented his United States
Passport and Customs Declaration to an officer with the United States Customs and Border

Protection (CBP). CASIANO informed the CBP officer that he had nothing to declare.
6. CASIANO was then instructed to place his luggage on the examination belt.

CASIANO stated to the CBP officer that the luggage belonged to him. CASIANO further stated

that he had gone to Santa Cruz, Bolivia for seventeen days to visit friends. During the baggage

examination, CASIANO displayed signs of nervousness by providing short answers, hesitating,

and avoided eye contact. The CBP officer discovered a small soccer team banner within CASIANO's suitcase and noticed there was a foreign object concealed within the banner. At

that time, CASIANO began to exhibit additional signs of nervousness, specifically that he was

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looking around and shifting his weight.

7.

The CBP officer removed the foreign object from the banner and probed the

package, revealing a brown powdery substance that field-tested positive for heroin. Further

examination of CASIANO's luggage revealed four pair of soccer-style pants and two pair of
soccer-style shorts, which also contained concealed packages sewn within their inner linings. A
total of twenty-seven packages containing suspected heroin were extracted from CASIANO's

luggage, weighing a total ofapproximately 4.4595 kilograms.

Conclusion

8.

Based on the foregoing, there is probable cause to believethat CASIANO

unlawfully, knowingly and intentionally imported one (1) kilogram or more of a mixture and

substance containing a detectable amount ofheroin, a Schedule I controlled substance, into the United States from a place outside the United States, in violation of 21 U.S.C. 952.

Julie/E. HilarioJJpecial Agent Homeland-Security Investigations

Sworn to and subscribed before me

th\s/9jh day of December, 2011.

M.
Ivan D. Davis

United States Magistrate Judge