Stalin Anthony Asenjo Indictment

8/17/2019 Stalin Anthony Asenjo Indictment

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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA

CASE NO. 15-601 IZ-CR-ZLOCH

M AGISTRATE JUDGE HUNT

UN ITED STATES OF AM ERICA

,

Plaintiff,

STALIN ANTONIO ASENJO

,

Defendant.

/

ls STALIN ANTONIO ASENJO

,

hereby state the following:

l am knowledgeable and personally aware of the factual matters summari

zed

throughout this Stipulated Statement of Facts

.

I have consulted with my attorney regarding the factual assertions described in the

pages which follow.

1 hereby acknowledge, adopt

,

admit and confirm to be true and correct

,

as

evidenced by my signature appearing at the end of this document

,

the factual assertions set forth

herein.

4. l understand that this statement is being signed and supplied by me p

ursuant to

Fed. R. Crim. P. 1 1(b)(3) with the understanding that I will be pleading guilty to the single count

of the lnformation which has been filed in the case of United States v

.

Stall'n Antonio Asenjo,

Case 0:15-cr-60112-WJZ Document 20 Entered on FLSD Docket 06/24/2015 Page 1 of 6


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Case No. 15-601 IZ-CR-ZLOCH

,

and which charges me with the offense of wire fraud in

violation of Title 1 8

,

Uhited States Code, Section l 343 as a consequence of the offense co

nduct

described below.

On February 27, 2012

,

defendant Stalin Antonio Asenjo

(hereinafter 6 Asenjo''), a stock Sipromoter'' whose services were retained by

certain businesses seeking to generate public intertst in the purchase of th

eir

stock, met with an FBl undercover confidential source (hereinafter the i CS'')

along with a second individual

During the course of the ensuing meeting

,

which took place in the Orlando area

,

a fraudulent microcap stock market

manipulation proposal that had been the subject of earlier conversations

between the CS and the other individual

,

but which had not involved Asenjo,

was discussed in Asenjo's presence.

During the February 27

s

2012 meetings in which Asenjo

participated, the CS claimed that he had in place an organized çdbuyin

g

group'' which could be called upon to purchase so-called ikpenny stock'' in

certain microcap companies through contrived market transactions

. The CS

further stated that his iibuying group'' would engage in all of the neces

sary

contrived trading transactions upon a ddfour-to-one basis

,

'' meaning that the

Sdbuying group'' would be paid one dollar for evel'y four dollars of stock which

they would purchase on the open market

.

These purchases would be made

for the purpose of fraudulently generating trade volume and bidding u

p the

market price of the particular Cûpenny stock'' which would be the object of any

.



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such schtme. These statements by the CS were part of the undercover

scenario.

In April, 20l 2, approximately five weeks after the February 27

,

2012 Orlando meeting, Asenjo initiated an unsolicited telephone contact with

the CS in the Southern District of Florida

,

wherein Asenjo was recorded

asking the CS whether the CS and the CS' iibuying group'' could ttfront-run'' a

forthcoming news release concerning a promotion which Asenjo had been

hired to dissem inate during the following week

.

The term Ssfront-run'' in this

context referred to a process wherein the CS's idbuying group'' was asked to

initiate some contrived volume-generating buying activity shortly before the

press release was to be dissem inated so that it would appear as though there

had been interest in the stock by investors even before the press release was

disseminated.

The penny-stock in question with respect to

ikfront-run'' proposal to the

Asenjo's

CS was Blackbird International Corporation

(symbol ikBBRD''), an SEc-delisted company which was very thinly traded

upon an over-the-counter basis through the so-called S'Pink Sheets'' database

.

In response to Asenjo's solicitation, the CS replied that he would engage in

the proposed difront run'' as Iong as the CS and the CS' ûdbuying group''

received advance copies of the actual press release from Asenjo before it was

scheduled to run. In response

,

Asenjo agreed to prematurely reveal the

contents of the press release to the CS, since Asenjo was destined to receive



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an advance copy from BBRD which had ret

ained Asenjo's services as a

promoter.

On April 24, 2012

,

Asenjo engaged in a Skype conversation

with the CS and was overheard reading thr

ee Blackbird lnternational

Corporation prtss rtleases to the CS

.

Thereafter. on April 25

,

2012, FB1

agents, posing as members of the CS' Sibuying group

,

'' and with the previous

consent the SEC, bought 40

,

000 shares of Blackbird lnternational

Corporation.

three different undercover purchases conducted over a

n electronic

This was done from the Southern District of Florida th

rough

trading

platform that utilized interstate wire

purchases.

communication to effectuate these

A11 three purchases were made on the morning of April 24

,

2012 and the first of the three press releases previously read by Asenjo to the

CS was officially disseminated to the public at noon on that day

,

while a

second press release was issued on April 27

,

2012.

to get on Skype.

While on Skype, Asenjo asked the CS if the CS and his group would

Sdfront-run'' the news on another promotion that Asenjo planned upon

initiating the following Monday regarding Sutimco lnternational (symbol

On M ay l 6, 201 2

,

Asenjo texted the CS

SUTI), an SEC non-reporting company on the Pink Sheets

After the CS agreed

,

Asenjo advised that the news release

would be disseminated the following Monday (May 21

, 2012), but that he



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*

would read the contents

following day (Thursday May

of the press release to the CS over Skype on th

e

17, 2012) and wanted the CS and the CS'

buying group to start buying that same morni

ng. This schedule was later

moved back by one day

.

such that the buying and press release dissemination

actually took place on Friday

,

M ay l 8, 2012.

On M ay 1 8, 2012

,

Agents of the FBI

,

posing as the CS's

tsbuying group,'' bought shares through matched trades

which were essentially

orchestrated for no purpose other than to pump up volume and

market price.

As with BBRD scheme

,

the FBI bought shares on four separate occasions on

M ay 18, 2012.

On June l9, 2012

,

Asenjo again contacted the CS via Skype

and requested the CS' and his isbuying group's'' assistance in conducti

ng yet

another d'front-run'' scheme

,

this time with respect to Far Vista Petroleum

Corporation, a Pink Sheets OTC stock which was non

-

registered with the SEC

and traded under the symbol CSFVSTA

.

'' Again, the CS agreed

. Thereaûer,

Asenjo read to the CS the contents of five proposed press releases

s

one of

which related to FVSTA

.

On June 2 1, 20l 2, the FB1 purchased shares of FVSTA on one

occasion. Later that sam e day

,

the press release in question was

disseminated.

posing as the CS'

iibuying group'' in each of the aforementioned dsfront run'' sche

m es w as

k.

The total expenditure by the FBI

,

while

5



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*

approximately 2 1,706.93.

STALIN ANTO O ASENJO

Dcfendant

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PETER B. OUTERBRIbG .

'QSSISTANT U

.

S. ATTORNEY

X-a z - .,M-

Date

ttop: 22, 2&ïo

Date

Ikolgôtç

Date


Stalin Anthony Asenjo Indictment

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