Case 1:11-cr-00217-LO Document 1
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WOPENRnilBT
IN THE UNITED STATES DISTRICT COURT F(|R T$E
EASTERN DISTRICT OF VIRGINIA Alexandria Division
MAY 1 2 2011
CLfcRK. U.S. UISIKICT COURT
UNITED STATES OF AMERICA
Criminal No: l:llcr217
Count 1: 18U.S.C. 371
Conspiracy
JOSE CIRO JUAREZ-SANTAMARIA,
aka "Sniper,"
Defendant.
Count 2: 18 U.S.C. 2423(a) and 2 Transportation of minor to engage in prostitution
Count 3: 18 U.S.C. 1591 and 2 Sex trafficking a child
INDICTMENT Mav 2011 Term - At Alexandria
Count One
(Conspiracy)
THE GRAND JURY CHARGES THAT:
Beginning in and around October2009, and continuing through in and around December
2009, within the Eastern District of Virginia and elsewhere, the defendant, JOSE CIRO JUAREZ-SANTAMARIA, also known as "Sniper," and an unindicted conspirator did unlawfully, knowingly and intentionally combine, conspire, confederate and agree together and with other persons known and unknown to the grand jury to commit the following offenses:
(1) To knowingly transport an individual, who has not attained the age of eighteen
years, in interstate commerce, with intent that the individual engage in prostitution, in violation
of 18 U.S.C. 2423(a); and
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(2)
To knowingly, in and affecting interstate commerce, recruit, entice, harbor,
transport, provide, obtain, and maintain by any means a person, knowing, and in reckless
disregard of the fact, that the person had not attained the age of eighteen years and would be caused to engage in a commercial sex act, in violation of 18 U.S.C. 1591.
WAYS. MANNER. AND MEANS TO ACCOMPLISH THE CONSPIRACY
The primary purpose of the conspiracy was to make money through prostitution. The ways, manner and means by which this purpose was carried out included the following:
1. It was part of the conspiracy that members of the conspiracy recruited a female
juvenile to work as a prostitute.
2. It was further part of the conspiracy that one of the members would arrange for clients
to have sex with the juvenile for money.
3. It was further part of the conspiracy that members of the conspiracy would transport
the juvenile from Maryland to Virginia and elsewhere to engage in prostitution.
OVERT ACTS
In furtherance of the conspiracy and to effect the objects thereof, the defendant and his
conspirator committed overt acts in the Eastern District of Virginia and elsewhere, including, but
not limited to, the following:
1. In and around October 2009, JOSE CIRO JUAREZ-SANTAMARIA recruited a
female juvenile, "G.T.," to work as a prostitute. 2. In and around October 2009, JOSE CIRO JUAREZ-SANTAMARIA provided "G.T."
with clothes and make up to wear when meeting with prostitution clients.
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3. Between in and around October 2009 and in and around December 2009, a member of
the conspiracy provided "G.T." with condoms to use when meeting with prostitution clients.
4. Between in and around October 2009 and in and around December 2009, JOSE CIRO
JUAREZ-SANTAMARIA and an unindicted conspirator used cellular telephones to arrange for
prostitution clients to meet with "G.T."
5. Between in and around October 2009 and in and around December 2009, JOSE CIRO
JUAREZ-SANTAMARIA and an unindicted conspirator transported "G.T." by vehicle between
the Eastern Districtof Virginia, the Districtof Columbia, and Maryland to engage in prostitution.
6. On or about December 19,2009, JOSE CIRO JUAREZ-SANTAMARIA traveled by
car to Washington, D.C. to pick up "G.T." after she met with a prostitutionclient.
(In violation of Title 18, United States Code, Section 371.)
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Count Two
(Interstate Transportation of Minor to Engage in Prostitution)
THE GRAND JURY FURTHER CHARGES THAT:
Between in and around October 2009 and in and around December 2009, in Alexandria,
Virginia, in the Eastern District of Virginia, the defendant, JOSE CIRO JUAREZ-
SANTAMARIA , also known as "Sniper," and an unindicted conspirator did unlawfully and
knowingly transport an individual, namely "G.T." a female juvenile who was at that time under
the age of eighteen years, in interstate commerce from Maryland to Virginia, with intent that
"G.T." engage in prostitution and any sexual activity for which any person could be charged with
a criminal offense.
(In violation of Title 18, United States Code, Sections 2423(a) and 2.)
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Count Three
(Sex Trafficking a Minor)
THE GRAND JURY FURTHER CHARGES THAT:
Between in and around October 2009, and in and around December 2009, in Alexandria,
Virginia within the Eastern District of Virginia, and elsewhere, the defendant, JOSE CIRO
JUAREZ-SANTAMARIA, also known as "Sniper," did unlawfully and knowingly, in and
affecting interstate commerce, recruit, entice, harbor, transport, provide, obtain, and maintain by
any means a person, namely "G.T.," a female juvenile, knowing, and in reckless disregard of the
fact, that "G.T." had not attained the age of eighteen years and would be caused to engage in a
commercial sex act.
(In violation of Title 18, United States Code, Sections 159 land 2.)
A TRUE BILL
the original ofthis page has been filed
Pursuant toihe E-GovemmentAct'
under acal intha Clerk's Office.
FOREPERSON
Neil H. MacBride
United States Attorney
Patricia T. Giles
Assistant United States Attorney
