Case 1:11-mj-00289-TCB Document 3 Filed 04/08/11 Page 1 of 11

IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA

Alexandria Division APR - 8 ^n

UNITED STATES OF AMERICA

v.

EDGAR GEOVANI PEREZ-SUNIGA,

aka "Rapidito,"
Criminal No.
VAHELO ALAY ESCOBAR,

SERFIDO TRINIDAD PEREZ FLORIAN,

ESTANISLAO RAMOS PEREZ,

aka "Armando Palma Alonzo,"

Defendants.

AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT

I, James E. Christie, being duly sworn, depose and state as follows:

1. I am a duly appointed Special Agent of the Federal Bureau of Investigation (FBI)

and have been employed assuch since August 1999. I am currently assigned to a squad which

investigates violent crimes out ofthe FBI's Violent Crimes Task Force ofthe Washington, D.C.
Field Office. I have been assigned to this squad since October 2008. Prior to being appointed to

the FBI, I served as an officer with the Philadelphia Police Department for one year and as a

patrol trooper and a criminal investigator with the Pennsylvania State Police for three years.
Through myemployment with the FBI, I have gained knowledge in the use of various

investigative techniques, including, but notlimited to, the utilization of physical surveillance,
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cooperating witnesses, and investigative interviews.

2. This affidavit is made in support of a criminal complaint charging that the

defendants, EDGAR GEOVANI PEREZ-SUNIGA, also known as "Rapidito," VAHELO ALAY

ESCOBAR, SERFIDO TRINIDAD PEREZ FLORIAN, and ESTANISLAO RAMOS PEREZ,

also known as "Armando Palma Alonzo," knowingly and unlawfully combined, conspired,

confederated and agreed togetherand with others to obstruct, delay and affect, commerce and the

movement of articles and commodities in such commerce, by robbery, in violation of Title 18,

United States Code, Section 1951.

3. The facts and information contained in this affidavitare based on personal

knowledge, as well as on the observations of other agents and officers involved in this

investigation. This affidavit contains information necessary to support probable cause and is not

intended to include each and every fact and matter observed by me or known to the government.

The August 22,2010 Robbery of La Disperensa Latina

4. On August 22,2010, at 8:40 p.m., three Hispanic males ("Subject #1," "Subject

#2," and "Subject #3"), two of whom were brandishing handguns, entered La Disperensa Latina,

located at4120 Dale Boulevard, Woodbridge, Virginia, within the Eastern District ofVirginia,

and demanded money. La Disperensa Latina isa small grocery store that services primarily the

Latino community in eastern Prince William County, selling groceries and other items. The store

also provides money transfer services for its customers. Subject #1 and Subject #2 went to the

back of the store while Subject #3, who was carrying a handgun, stayed with the cashier. Two

store employees were in the back office of the store counting money when Subject #1 and

Subject #2 entered. Subject #2 pulled a gun from his waistband, racked the slide to chamber a
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round, then pointed the gun at one of the employees, saying words to the effect of "don't look at

my face or move or I will shoot you." When the employee attempted to get up, Subject #2

kicked the employee in the upper thighs and grabbed her hair pushing the employee to the

ground. Subject #1 demandedrepeatedly for the employees to surrender the money. The

employee handed the money to Subject #1. Subject #1 also took the employee's cellphone.

5. Then, Subject #1 and Subject #2 left the office and went toward the front of the

store where Subject #3 had been waiting. Subject #1 asked Subject #3 if he had taken the money

from the cash register. Subject #1 approached a customer and demanded the customer's wallet

and phone, and then handed these items over to Subject #3. Subject #1 then had another store

employee open the register.

6. During the course of the robbery, the subjects took approximately $32,066.60 and

two cellphones. The robbers then fled the scene. As the robbers were fleeing, the owner of the

store who was at a nearby restaurant came outside into the parking lot and yelled to Subject #3,

and told a waitress to retrieve the owner's gun. Subject #3 racked the slide on this gun, pointed it

at the owner, and said "you're going to die." The owner ducked behind a car. A witness to the

robbery observed three robbers enter a light green or silver-colored Nissan Xterra which was

parked outside the store. The witness provided a partial tag of 2352 or 2532 for the Nissan

Xterra. Law enforcement queried Virginia Department of Motor Vehicles for all Nissan Xterra

sport utility vehicles, green or silver in color, with similar tag combinations to 2352 and 2532

registered in Prince William County. The results were narrowed to a single vehicle, a green

Nissan Xterra, Virginia license plate XKZ-2535, that was registered to an owner with an address

in the vicinity of the August 22,2010 robbery.

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The September 26,2010 Robbery of La Azteca Latina

7. On September 26, 2010, at 10:50 p.m., two Hispanic males ("Subject #1" and

"Subject #2") entered La Azteca Latina store, located at 2928 Dale Boulevard, in Prince William

County, Virginia. Both were armed with handguns. Theowner/manager was sitting in the front

office, which has a door openingnear the cash register. As Subject #1 enteredthe store, he went

toward the front office. The owner/manager heard a noise outside the office. As he turned, he

observed Subject #1 pointing a handgun with a red laser light towards the chest of a child. The

owner/manager moved the child behind him. Subject #1 then pointed the laser from the gun at

the owner/manager's head and then at his chest, and demanded money, in Spanish. The

owner/manager handed over the cash that the owner/manager had been counting. Subject #1

then demanded money from the cash register located outside the front office. The

owner/manager opened the cash register, removed the money, and placed it into a plastic

shopping bag that Subject #1 was holding. Meanwhile, Subject #2 walked toward the back of the

store, encountering three employees. Subject #2 made each of them lie on the floor and took the

cellphonesthat two of the employees were carrying.

8. Subsequently, both suspects exited the store, got into an older model silver SUV

parked in the fire lane nearthe business, and fled the scene. During the course of the robbery, the

robbers stole approximately $12,680 in cash and two cellphones.

February 7,2011 Robbery of Steven's Shop

9. On February 7, 2011, three Hispanic males ("Subject #1," "Subject #2," and

"Subject #3") entered Steven's Shop, located at 6178 Arlington Boulevard, Falls Church,

Virginia, within the Eastern District of Virginia. An employee was handling transactions at the
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front of the store when the three subjects entered the store. Subject #1 stated "Don't move" and

pointed a revolver at the employee and told the employee to open the display drawer. Subject #1

came around the counter with Subject #2, who pointed a pistol at the employee's head and told

the employee to get on her knees and to open the safe. The employee complied. Subject #3

stood bythe door of the store, serving as a lookout. The robbers took approximately $40,000 in

U.S. currency from the safe and placed it in a bag. The robbers also took checks. Subject #3

took trays ofjewelry. After taking these items, the robbers sprayed the employee in the face with

pepper spray or mace, and fled the scene.

10. Steven's Shop is a small store that services primarily the Latino community in

Fairfax County, selling clothing, DVDs, and other items. Steven's Shop also conducts money

transfers and provides check cashing services.

February 11,2011 Robbery of Dollar City Plus

11. On February 11, 2011, at approximately 11:14 p.m., two Hispanic males ("Subject

#1" and "Subject #2"), displaying handguns, entered Dollar City Plus store and ordered the

customers and employees to lieonthe floor. The two subjects proceeded to rob the Dollar City

Plus store, which is located at 13817 Foulger Square, Dale City, Virginia, within the Eastern

District of Virginia. The robbery was captured on surveillance footage. The footage shows
Subject #1 enter the store priorto the robbery and purchase a phone card in cash. When the

employee turned to give Subject #1 his change, Subject #1 placed the phone card onthe counter

and walked outofthe store. Approximately two minutes later, Subject #1 returned to the store

with Subject #2 and they were both carrying guns. Subject #2 went around the counter, placed

his gun against an employee's head and forced the employee to open the cash register. The
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suspects stole approximately $600 cash and a cellular telephone from an employee. Subject #1

was described as a light-skinned Hispanic male, clean-shaven with a mohawk.

12. Dollar City Plus can be described as a convenience store in eastern Prince William

County, selling groceries and other items. The store also provides money transfer services for its

customers.

March 2011 Planned Robbery of Pennsylvania Bank and D.C. Drug Dealer

13. On March 3, 2011, at approximately 4:21 p.m., undercover officers with the

Metropolitan Police Department of the District of Columbia met with two Hispanic males who

were known as Rapidito, later identified as EDGAR GEOVANI PEREZ-SUNIGA, and Luis,

later identified as Luis Fernando Balderas, who told the undercover officerthat he had previously

committed robberies and burglaries. The undercover officers discussed with PEREZ-SUNIGA

whether they (Balderas and PEREZ-SUNIGA) were interested in committing a home invasion

and robberies. PEREZ-SUNIGA and Balderas said they were interested, and PEREZ-SUNIGA

wanted to know when the robberies were going to occur.

14. On March 4, 2011, at approximately 7:00 p.m., the undercover officers again met

with Balderas and one unidentified Hispanic male at a location in the District of Columbia.

Balderas, the unidentified Hispanic male, and the undercover officers discussed possible

robberies they could conduct. During the meeting, Balderas stated that he andthe group were

planning to rob a bank in Pennsylvania. The undercover officers offered to assist and Balderas

said that he needed the undercover officers to provide eight vehicles, four with Pennsylvania

license plates and four with Maryland license plates, and guns for the robbery. According to

Balderas, he and the group with whom he was associated knew where some of the bank
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employees who possessed keys to the bank lived.

15. On March 5,2011, at approximately 8:00 p.m., the undercover officers met with

Balderas at a location in the District of Columbia. Balderas and the undercover officers

discussed working together on future robberies, including the robbery of the bank in

Pennsylvania. Balderas stated that on the following day he could take the undercover officers to

see the bank in Pennsylvania that Balderas and the group were planning to rob. Balderas also

stated that he needed new or differentguns for the bank robbery in Pennsylvania, and that he

might sell to the undercover officers "old" guns that he and the group had used in armed

robberies they had recently committed in Virginia. Balderas agreed to meet the undercover

officers for them to see the bank in Pennsylvania that he and his group were planning to rob.

16. On March 7,2011, Balderas and a memberof the group named Juan, later

identified as SERFIDO TRINIDAD PEREZ FLORIAN, met with the undercover officers at a

restaurant parking lot in Hyattsville, Maryland, to discuss their plans to rob the bank in

Pennsylvania. FLORIAN requested assistance from the undercover officers in the form of

vehicles and guns. Duringthe meeting, FLORIAN, Balderas and the undercover officers agreed

to meet the following day (March 8, 2011), outside Philadelphia, Pennsylvania, to conduct

surveillance of the targeted bank.

17. Later that same evening, at approximately 11:00 p.m., the undercover officers met

with Balderas and a Hispanic male, later identified as Jose Martin Ruiz Cacho, at a restaurant in

Alexandria, Virginia. After talking inside the restaurant, two of the undercover officers left with

Balderas and Cacho and drove together to a car dealership. Balderas and Cacho describedthe

types of vehicles they needed for the bank robbery in Pennsylvania. In particular, Cacho said that
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they needed an SUV with a third row seat to toss the money bags in the rear and that the

windows needed to be heavily tinted. Cacho also stated that he was the driver for robberies the

group had previously committed and that he had conducted surveillance of the employees of the

targeted bank inPennsylvania. Balderas and Cacho further stated that they were ready to rob the

bank in Pennsylvania that week and agreed to meet with the undercover officers the following
day to go to Pennsylvania and conduct surveillance of the bank.

18. On March 8, 2011, the undercover officers met with Balderas and FLORIAN at a

hotel in Ridley Park, Pennsylvania. The undercover officers, Balderas, and FLORIAN left the

hotel, and the undercover officers followed Balderas and FLORIAN to the bank. Balderas

showed the undercover officers the bank they were planning to rob, which bank was located in

Horsham, Pennsylvania. While Balderas and FLORIAN waited, one of the undercover officers

entered the bank and returned outside. Shortly thereafter, the undercover officers met Balderas

and FLORIAN ina nearby parking lot. Balderas and FLORIAN viewed photographs that were
taken byone of the undercover officers. FLORIAN also said that if any of the individuals inside

the bank gave them problems, they would have to kill them one by one. FLORIAN and Balderas

asked whether the undercover officers could supply them with six bullet proof vests for the bank
robbery. The undercover officers replied that they would have to work on that request.
FLORIAN and Balderas agreed to meet the undercover officers in the Districtof Columbia to

obtain the guns and vehicles to use during the bank robbery in Pennsylvania that FLORIAN,
Balderas and their group would conduct later that same week.

19. In the late afternoon of March 9,2011, the undercover officers met with six

individuals, namely, Balderas, PEREZ-SUNIGA, FLORIAN, Cacho and two other members of

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the group who were subsequently identified as VAHELO ALAY ESCOBAR and ESTANISLAO

RAMOS PEREZ, for the purpose of discussing and planning the robbery of a person they

believed to be a drug dealer in the District of Columbia and to view and receive six guns from

the undercover officers that were going to be used during the robbery of the D.C. drug dealer and

the bank robbery in Pennsylvania.

20. PEREZ-SUNIGA, FLORIAN, ESCOBAR, ESTANISLAO RAMOS PEREZ,

Balderas and Cacho initially met with the undercover officers at a restaurant in the District of

Columbia to discuss the robbery of the D.C. drug dealer. Following that meeting, the six

conspirators gotinside three vehicles andfollowed the undercover officers to another building.

Upon arriving at that building, theyparked the three vehicles directly in front of the building, got

out of the vehicles, and went inside the building to further discuss their plans to rob the D.C.

drug dealer and the bank in Pennsylvania, and to obtain the six guns. When the six conspirators

were leaving the meeting location, members of the MPD Emergency Response Team

apprehended the defendants. Three of the six, PEREZ-SUNIGA, ESCOBAR, and

ESTANISLAO RAMOS PEREZwere armed with handguns which they had brought to the

location sight with them.

Pertinent Developments in the Investigation

21. Later that evening, law enforcement interviewed PEREZ-SUNIGA. Prior to the

interview, PEREZ-SUNIGA was advised of his Miranda rights, which he acknowledged and

waived. During the interview, PEREZ-SUNIGA admitted to his involvement in a robbery in

Northern Virginia in February 2011. Investigators learned that PEREZ-SUNIGA routinely

operated a light greenNissan Xterra bearing Virginia registration plate XKZ-2535, which was
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linked to the August 22,2010 robbery. Witnesses familiar with PEREZ-SUNIGA and the vehicle

indicated that he had access to operate this Nissan Xterra. Moreover, at the time of

PEREZ-SUNIGA's arrest on March 9,2011, he was in possession of a Glock semi-automatic

pistol with a "red dot" laser sighting system attached. During the robbery of La Azteca Latina in

Prince William County, a handgun with a "reddot" laser sighting system was used during the

commission of the robbery.

22. FLORIAN was also interviewed following his arrest. Prior to the interview

FLORIAN was advised of his Miranda rights, whichhe acknowledged and waived.

Investigators showed FLORIAN surveillance photographs from the armed robbery on September

26,2010, of LaAzteca Latina. FLORIAN positively identified himself as one of the subjects in

the surveillance photographs.

23. A latent fingerprint recovered after the robbery on February 7,2011, at Steven's

Shop was identified as ESCOBAR'S fingerprint. The latent print was recovered from a glass

display cabinet in close proximity to the cash register in which money was taken during the

course of the robbery.

24. Based onthe aforementioned factual information, your affiant respectfully

submits that there is probable cause to believe that the defendants, EDGAR GEOVANI

PEREZ-SUNIGA, also known as "Rapidito," VAHELO ALAY ESCOBAR, SERFIDO

TRINIDAD PEREZ FLORIAN, and ESTANISLAO RAMOS PEREZ, also known as "Armando

Palma Alonzo," knowingly and unlawfully combined, conspired, confederated and agreed
together and with others to obstruct, delay and affect, commerce and the movement of articles

and commodities in such commerce, by robbery, in violation of Title 18, United States Code,

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Section 1951.

Q^
Special Agent James E. Christie, Jr.
Federal Bureau of Investigation

Sworn and subscribed before me thisj^ day of April, 2011.

Is!
Theresa Carroll Buchanan
(^^ nited States Magistrate Judge
The Honorable Theresa Carroll Buchanan
United States Magistrate Judge

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