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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,
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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
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PETER B. OUTERBRIbG .
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S. ATTORNEY
X-a z - .,M-
Date
ttop: 22, 2&ïo
Date
Ikolgôtç
Date
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