Case 1:11-cr-00260-LO Document 3-1 Filed 04/27/11 Page 1 of 10

IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA

Alexandria Division CLERX US- DISTRICT cr „!"

AULJCAVKUV VIRGIN!*-

UNITED STATES OF AMERICA, UNDER SEAL

v. 1:11MJ336
)
ALONSO BRUNO CORNEJO ) Hon. Ivan D. Davis
ORMF.NO, also known as "CASPER" )

Defendant.

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

I, Richard M. Baer, Special Agent of the Federal Bureau of Investigation (hereafter

"FBI"), being duly sworn, do depose and state that:

1. I am a Special Agent of the FBI and have been employed as such since October

2006. I am currently assigned to a squad that investigates violent gangs, criminal enterprises,

and the corresponding criminal offenses that these groups commit, out of the Northern Virginia

Resident Agency of the Washington, D.C. Field Office of the FBI. I have been assigned to this

squad since August 2008. During the course of my participation in criminal investigations, I

have testified in grand jury and trial proceedings.

2. I have attended classes and courses conducted by the FBI and other government

agencies regarding various criminal activities by persons and/or groups who are gang members.

I have participated in a number of criminal investigations conducted by the FBI, Immigrations

and Customs Enforcement (hereafter "ICE"), and other law enforcement agencies that resulted in

the arrest of numerous subjects, the recovery of weapons, and the identification and interviewing

of bothjuvenile and adult victims. In addition, as a result of my training and experience, I am

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familiar with how persons who are members of violent gangs use various criminal enterprise

schemes, including prostitution and sex trafficking, to generate income and obtain influence

within a particular geographic area.

3. I have become knowledgeable with the enforcement of state and federal laws

pertaining to gang participation, offenses against persons, and property offenses.

4. This affidavit is made in support of an arrest warrant and criminal complaint

charging ALONSO BRUNO CORNEJO ORMENO ("CORNEJO ORMENO"), also known as

"Casper," with knowingly, in or affecting interstate or foreign commerce, recruiting, enticing,

harboring, transporting, providing, obtaining, and maintaining by any means a person, knowing,

or in reckless disregard of the fact, that the person had not attained the age of 18 years and would

be caused to engage in a commercial sex act, in violation of Title 18, United States Code, Section

1591(a)(1).

5. The facts and information contained in this affidavit are based upon my personal

knowledge and information obtained from other federal and state law enforcement officers. All

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

person who made such observations.

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

criminal complaint and arrest warrant, it is not intended to include each and every fact observed

by me or known to the government. I have set forth only those facts necessary to support

probable cause.

7. CORNEJO ORMENO is a self-admitted associate of Mara Salvatrucha 13

(hereafter "MS-13"). MS-13 is a violent international gang with members located across the

United States and throughout Central and North America. At present, CORNEJO ORMENO
 Case 1:11-cr-00260-LO Document 3-1 Filed 04/27/11 Page 3 of 10

resides at an address in Fairfax, Virginia that is known to law enforcement.

8. On February 25, 2011, Detective Anthony Erway of the Fairfax County Police

Department and I interviewed an incarcerated, self-admitted memberof MS-13, CW 1. CW 1

provided reliable information that has been corroborated by other witnesses and independent

evidence. CW 1 stated that prior to his incarceration, he was a close associate of CORNEJO

ORMENO and witnessed CORNEJO ORMENO prostitute at least five different juvenile

females. According to MSWl, CORNEJO ORMENO extensively prostituted VI, a sixteen year

old female. CW 1 also witnessed CORNEJO ORMENO advertise his prostitution business,

through word of mouth, to groups of predominantly Hispanic men that did not speak English.

9. CW 1 stated that CORNEJO ORMENO would often rent hotel rooms to facilitate

his prostitution business as well as deliver prostitutes directly to his clients' residences.

According to CW 1, a particular motel in Falls Church, Virginia, gave CORNEJO ORMENO a

discount on rooms because CORNEJO ORMENO's prostitution business made him such a

frequent customer.

10. CW 1 stated that CORNEJO ORMENO explained the rules to the clients

governing sex with his prostitutes. According to CW 1, CORNEJO ORMENO instructed the

clients that they had to wear condoms at all times, had a maximum of thirty minutes with a

prostitute, and oral sex required additional payment. CW 1 explained that CORNEJO ORMENO

shared the prostitution proceeds with his prostitutes, but kept a larger percentage for himself.

CW 1 observed that CORNEJO ORMENO provided his prostitutes with Trojan brand condoms

as well as food and clothing.

11. CW 1 stated that CORNEJO ORMENO set up approximately six to seven

prostitution appointments a day and generally profited $400-500 on weekdays and $800-900
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during a weekend day. CW 1 observed that CORNEJO ORMENO used a black Honda CRX to

transport his prostitutes and that CORNEJO ORMENO also kept a small .22 caliber handgun

under the driver's seat for protection.

12. On January 22,2011, your affiant participated in the interview of an FBI

confidential source (hereafter "CS 1"), who is a self-admitted member of MS-13. CS 1 has been

a reliable source of information and the information CS 1 provided has been corroborated by

other witnesses and independent evidence. CS 1 advised that in the previous few months he

received multiple phone calls from CORNEJO ORMENO asking about potential clients for

CORNEJO ORMENO's prostitutes. CS 1 advised that he visited CORNEJO ORMENO at a

rented hotel room. CORNEJO ORMENO, who was using illicit pills, was at the hotel with three

girls, one of which was seventeen years old. CORNEJO ORMENO asked CS 1 if he wanted to

sleep with the girls.

13. On a separate occasion during the summer of 2009, CORNEJO ORMENO called

CS 1 and advised him that he had rented a room at a Super 8 Hotel in Manassas, Virginia.

CORNEJO ORMENO informed CS 1 that he had girls they could "fuck" for only $50. During

that same conversation, CORNEJO ORMENO told CS 1 that he would give him a discount if he

could find another prostitution client.

14. On April 7, 2011, your affiant participated in the interview of an incarcerated,

self-admitted MS-13 member, CW 2. CW 2 provided reliable information that has been

corroborated by other witnesses and independent evidence. CW 2 recently pled guilty to two

counts of Title 18, United States Code, Section 1591, and admitted to running a prostitution

business involving juvenile females. During the interview, CW 2 stated that CORNEJO

ORMENO ran an extensive prostitution business that included a large number of clients.
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15. CW 2 reported that he first met CORNEJO ORMENO a few years ago and

personally observed CORNEJO ORMENO run a prostitution business that utilized juvenile

females. According to CW 2, CORNEJO ORMENO had an extensive list of prostitution clients

who lived in the Alexandria, Fairfax, and Woodbridge areas of Northern Virginia as well as

some clients who lived in Maryland. CW 2 stated that CORNEJO ORMENO also utilized his

mother's house for prostitution appointments. According to CW 2, CORNEJO ORMENO

maintained client lists within his cellular phone and used his cellular phone to run his prostitution

business.

16. CW 2 also stated that CORNEJO ORMENO advised him on how to conduct his

own prostitution activities, which CW 2 referred to as "the rules." These rules included how to

get clients, how much money to charge, and how much time to give a client with a prostitute.

CORNEJO ORMENO advised CW 2 that the prostitutes had to make the clients "feel like a

king" and if the clients wanted oral sex then the prostitutes should inform the clients that it would

cost an extra $20. CW 2 also heard CORNEJO ORMENO inform his prostitutes that all of the

clients had to wear a condom. CW 2 observed that CORNEJO ORMENO supplied condoms to

his prostitutes, and specifically used Ultra Thin or Trojan brand condoms.

17. CW 2 advised that in November 2009, CORNEJO ORMENO told CW 2 that he

had four girls working for him as prostitutes and that all four were juveniles. CW 2 stated that

CORNEJO ORMENO broughtthese fourjuvenile girls to his apartment during this time period.

18. CW 2 stated that in October2010, he utilized two juvenile females as prostitutes.

Around this time, CORNEJO ORMENO asked CW 2 about utilizing both girls for his

prostitution business. For approximately two weeks after CORNEJO ORMENO approached him

about his two juvenile prostitutes, CW 2 attempted to develop his own set of male clients, but he
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was ultimately unsuccessful. Consequently, CW 2 allowed CORNEJO ORMENO to utilize his

two juvenile prostitutes with the understanding that CW 2 would receive a portion of the

prostitution proceeds earned by his two prostitutes. CORNEJO ORMENO ended up only

utilizing one of CW 2's juvenile prostitutes, hereafter referred to as V2. According to CW 2,

CORNEJO ORMENO would take V2 to various locations throughout Northern Virginia as well

as occasionally to Maryland. CW 2 stated that CORNEJO ORMENO utilized V2 from

approximately October to November of 2010.

19. CW 2 recalled two separate occasions where he accompanied CORNEJO

ORMENO and V2 to a prostitution appointment along Route 50 in Fairfax County, Virginia.

CW 2 added that when he and CORNEJO ORMENO would take V2 to see clients, CW 2 would

wait in the car with CORNEJO ORMENO while V2 engaged in sexual intercourse in exchange

for money. CW 2 stated that CORNEJO ORMENO informed his clients that V2 was a juvenile

because many clients would pay a premium to have sex with an underage girl. CW 2 estimated

that CORNEJO ORMENO utilized V2 approximately three days a week and that he, CW 2,

received approximately $150 a day for "loaning" V2 to CORNEJO ORMENO.

20. During the course of this investigation, I obtained phone records for cellular

phones used by CW 2 and CORNEJO ORMENO. Toll analysis was conducted and it has been

determined that between December 12, 2009 and November 18,2010, a phone number used by

CW 2 was in contact with a phone number used by CORNEJO ORMENO. Specifically, during

this frame, CW 2's phone number received 660 phone calls from CORNEJO ORMENO and CW

2's phone number placed 202 phone calls to CORNEJO ORMENO.

21. On March 31,2011, Special Agent Charles Knowles, Jr. of the FBI and I

interviewed V2, a seventeen year old female. V2 stated that she ran away from home several
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months earlier and that while she was on the run she stayed with members and affiliates of MS-

13. V2 admitted that she engaged in prostitution during the time she was away from her home.

She explained that she started as one of CW2's prostitutes, but later CORNEJO ORMENO

became primarily responsible for booking her prostitution appointments and transporting her to

those appointments.

22. On April 14, 2011, your affiant participated in the interview of an incarcerated,

self admitted member of MS-13, CW 3. CW 3 provided reliable information that has been

corroborated by other witnesses and independent evidence. CW 3 stated that he has known

CORNEJO ORMENO for over seven years. CW 3 stated that during the last twenty-four months

he was present with CORNEJO ORMENO on a daily basis while CORNEJO ORMENO ran his

prostitution business. CW 3 stated that he would receive small amounts of money from

CORNEJO ORMENO, but claimed that he was not involved in the prostitution operation and

that CORNEJO ORMENO gave him the money because they were friends.

23. CW 3 observed CORNEJO ORMENO transport prostitutes to the Four Mile Run

area of Arlington as well as to Manassas and Woodbridge, Virginia. According to CW 3,

CORNEJO ORMENO's prepaid phone rang constantly with clients calling for prostitution

appointments.

24. CW 3 stated that CORNEJO ORMENO started his prostitution business by

"pimping" a Caucasian female, V3. According to CW 3, V3 actually told both CW 3 and

CORNEJO ORMENO that she was sixteen years old at the time she was being utilized as a

prostitute. CW 3 explained that CORNEJO ORMENO drove V3 to prostitution appointments

and made it a point to tell potential clients that she was young, specifically advertising her as a

"high school girl" and "fresh out the box."

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25. According to CW 3, CORNEJO ORMENO recruited another girl into his

prostitution business, V4. CW 3 witnessed CORNEJO ORMENO take V4 to a hotel for the

purposes of prostitution. CORNEJO ORMENO charged clients $100 to have sex with V4

because CORNEJO ORMENO advertised her as a "young girl." CW 3 was present when V4

informed CORNEJO ORMENO that she was a juvenile. According to CW 3, he and CORNEJO

ORMENO knew the ages of all of the female prostitutes CORNEJO ORMENO was using

because each prostitute had told CORNEJO ORMENO their age.

26. CW 3 observed CORNEJO ORMENO go to CVS or Rite Aid and buy large

boxes of condoms for his prostitution business. CW 3 recalled one occasion where a client's

condom broke while he was having sex with one of CORNEJO ORMENO's juvenile prostitutes

and CORNEJO ORMENO provided the prostitute with the "day after pill."

27. According to CW 3, CORNEJO ORMENO also provided his prostitutes with

drugs and alcohol so the prostitutes could be drunk or high during their appointments. CW 3

also heard CORNEJO ORMENO instruct his prostitutes to "fuck their clients' brains out and

moan really loud so they will nut faster." All of this was in an attempt to move onto the next

client more quickly.

28. CW 3 advised that in addition to taking the prostitutes to areas throughout

Northern Virginia, he and CORNEJO ORMENO would also take the prostitutes to Washington,

D.C. and Maryland. On one particular occasion, CW 3 and CORNEJO ORMENO transported a

juvenile prostitute to a house on Georgia Avenue in Washington, D.C. There CORNEJO

ORMENO charged $160-$ 180 to have sex with the juvenile female. The appointment lasted

approximately one hour.

29. On April 19, 2011,1 interviewed a V4. V4 is a juvenile female. V4 advised that
 Case 1:11-cr-00260-LO Document 3-1 Filed 04/27/11 Page 9 of 10

she first met CORNEJO ORMENO after a middle school dance in 2009 and first hung out with

him at Triste's house. According to V4, CORNEJO ORMENO provided V4 with alcohol at

Triste's house. V4 stated that she became intoxicated and had sex with CORNEJO ORMENO in

a bathroom. V4 advised that although she was drunk, the sex was consensual.

30. According to V4, after four months of hanging out, she started prostituting for

CORNEJO ORMENO. Prior to engaging in prostitution for CORNEJO ORMENO, V4

informed CORNEJO ORMENO that she was only 15 years old. According to V4, CORNEJO

ORMENO charged her clients $95 to $100 for sexual intercourse with V4. V4 stated that

CORNEJO ORMENO would negotiate with the client and collect the prostitution fee before she

had sex with the client.

31. According to V4, if CORNEJO ORMENO knew the prostitution client,

CORNEJO ORMENO waited in the car while V4 had sex with the client. If CORNEJO

ORMENO did not know the customer, CORNEJO ORMENO waited in the living room of the

residence or hotel. On one occasion, CORNEJO ORMENO told V4 to hide in some bushes

because the client was white and CORNEJO ORMENO wanted to make sure he was not a law

enforcement officer.

32. V4 stated that CORNEJO ORMENO always supplied her with condoms, which

were usually Trojan brand. CORNEJO ORMENO also bought V4 alcohol, cigarettes, food,

toiletries, and clothes. V4 advised that she worked for CORNEJO ORMENO for about two to

three months and that her cut of the prostitution proceeds was approximately $2,000.

33. V4 advised that CORNEJO ORMENO transported her to prostitution

appointments in Falls Church, Arlington, Annandale, Chirilagua (Alexandria), Little River

Turnpike, Woodbridge, and Manassas, Virginia. V4 was not aware of CORNEJO ORMENO
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bringing her to appointments outside of the Commonwealth of Virginia.

34. According to V4, potential customers would call CORNEJO ORMENO on his

cellular telephone to request prostitution appointments.

35. Through independent research, I discovered that no commercially available

condoms, including Trojan brand condoms, are manufactured in the Commonwealth of Virginia.

36. Based on the foregoing, there is probable cause to believe that on or about June

2009 through November 2010, in the Eastern District of Virginia, ALONSO BRUNO

CORNEJO ORMENO, also known as Casper, did knowingly, in or affecting interstate or foreign

commerce, recruit, entice, harbor, transport, provide, obtain, and maintain by any means a

person, knowing, or in reckless disregard of the fact, that the person had not attained the age of

18 years and would be caused to engage in a commercial sex act, in violation of Title 18, United

States Code, Section 1591(a)(1).

FURTHER THIS AFFIANT SAYETH NOT.

Richard M. Bacr
Special Agent
Federal Bureau of Investigation

Sworn to and deposed to me thisc3^r^ day of April, 2011.

At Alexandria, Virginia

/s/
Ivan D. Davis
United States Magistrate Judge

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