Case 1:11-mj-00835-IDD Document 2

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IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA

Alexandria Division
UNITED STATES OF AMERICA,

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CRIMINAL NO. 1:11MJ835
Hon. John F. Anderson

RAMIRO ESPINOZA JAMAICA,

also known as "Criminal" and "Junior" Defendant.

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

I, Brian C. Dugan, Special Agent of the Federal Bureau of Investigation (hereafter "FBI"), Washington Field Office, Washington, D.C., being duly sworn, do depose and state that: 1. I am a Special Agent of the FBI and have been so employed since November

1998. Currently, I am assigned to the violent gangs and criminal enterprises squad of the

Northern Virginia Resident Agency of the Washington, D.C., Field Office of the FBI. In my more than 13 years of experience, I have participated in a number of drug trafficking, organized
crime, money laundering, gang, and prostitution investigations conducted by the FBI and other law enforcement agencies, which resulted in the arrest of numerous subjects, the seizure of
property, assets, and controlled substances. In the course of those investigations, I have

supervised, or participated in, numerous searches of residences and businesses for evidence of criminal activity.
2. I have also attended classes and courses conducted by the FBI and other

government agencies regarding the various criminal activities by persons and/or groups who are
gang members. In addition, as a result of my training and experience, I am familiar with how

persons who are members of violent gangs use various criminal enterprise schemes, including

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prostitution, to conduct their activities.

3.

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

pertaining to gang participation, offenses against persons, and property offenses. I have also
interviewed convicted gang members, who decided to cooperate with government officials, on numerous occasions. During these interviews, the gang members have explained their

organizational structure as well as their methods of operation.

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

charging that RAMIRO ESPINOZA JAMAICA ("JAMAICA"), also known as "Criminal" and
"Junior," 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).

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. JAMAICA is a citizen of the United States of America, and a self-admitted

member of SUR-13, Manassas Park Locos ("MPL"). SUR-13 is a violent, transnational gang, with members located across the United States and throughout Central and North America. At present, JAMAICA is incarcerated, on unrelated charges, at a correctional facility in Prince

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William County, Virginia. JAMAICA is the subject of the captioned investigation as it relates to
the following events: 8. The Prince William County Police Department made contact with a juvenile-

female, runaway, Jane Doe 1 ("JDl"). Prince William County Police had also received
information that JDl was being prostituted.

9.

On or about September 21,2011, the FBI interviewed JDl. At the outset, the FBI

confirmed that JDl was a juvenile. JDl stated that during the late winter and early spring of
2011, when she was only fourteen years old, she ran away from home and lived with JAMAICA.
She lived with JAMAICA at a rental apartment located on Clark Place, in Manassas, Virginia.

JDl, who knew JAMAICA through mutual friends, originally chose to live with JAMAICA because she believed she did not have anywhere else to go.
10. According to JD1, she told JAMAICA that she was only fourteen years of age.

One of JDl's friends also told JAMAICA that JDl was only fourteen years of age. 11. JDl explained that she lived with JAMAICA, and two other males, at the Clark

Place address for approximately three months. During this three month period, JAMAICA was physically abusive toward JDl. JD 1 stated that JAMAICA would hit her with a closed fist and once choked her to the point of unconsciousness. Toward the end of this three month period of cohabitation, JDl, JAMAICA, and two of JAMAICA'S friends ("Wl" & "W2") were all present
at the Clark Place apartment. The group was drinking and socializing. According to JDl, two

Hispanic males ("HM1" & "HM2"), whom she had never seen before, came to the apartment complex. After the two males arrived, JAMAICA explained to JDl that she was to have sex
with HM1 and HM2 for money and that she would get to keep half of what she earned.

12.

In preparation for the act of prostitution, JAMAICA supplied JDl with Hennessey

brand alcohol, Pepsi, and beer. At JAMAICA'S urging, JDl consumed the alcoholic drinks in an

attempt to dull her senses prior to engaging in the sexual intercourse that JAMAICA

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orchestrated.

13.

After HMl and HM2 got to the apartment complex, JDl explained that she and

JAMAICA entered HMl and HM2's vehicle. JDl recalls that as she was traveling in the car, JAMAICA, HMl, and HM2 discussed the price for having sex with her. JDl remembers the group driving to a nearby house, which they contemplated using for the prostitution act.

Apparently, the owner of the home, believed to be a relative of HMl or HM2, was home; consequently, HMl, HM2, JAMAICA, and JDl returned to JAMAICA'S apartment.
14. At the apartment, JDl observed JAMAICA counting money that she had not seen

him with earlier. When JDl questioned JAMAICA as to the origin of the money, JAMAICA told JDl that he had "sold her." Following this exchange, JDl entered JAMAICA'S bedroom

and observed HMl already inside of the room. HMl produced, and put on, a Trojan brand

condom and had sexual intercourse with JDl. After HMl climaxed, JDl got dressed and left the

room. Shortly after having sex with HMl, JDl told JAMAICA that she "never wanted to do that

again." JAMAICA responded by saying, "my other homegirls do it, why can't you."1
15. Following this incident, JAMAICA told his friends that JD 1 was a prostitute.

Specifically, JAMAICA told one of his fellow SUR-13 members ("SMI") that JDl was his (JAMAICA'S) prostitute. On another occasion, JAMAICA told SMI that he (JAMAICA) had sold JDl as a prostitute. SMI stated that he witnessed JAMAICA provide marijuana and Old
English brand beer to JDl in an effort to get her drunk so JAMAICA could have sexual
intercourse with her.

16.

In the fall of 2011, the FBI interviewed W1, who was also present with JD 1,

JAMAICA, and W2 the night the two Hispanic males came to the apartment and JDl had sexual

1Despite initially promising JDl half of the money from the prostitution activity, JAMAICA refused to provide any money to JDl for several days, despite repeated requests. Eventually, JAMAICA gave JDl $20, which JDl believed was less than half of what HMl had paid to have
sex with her.

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intercourse with HMl. Wl stated that on the night in question, Wl entered JAMAICA'S Clark Place apartment and observed JAMAICA drinking a 40 ounce bottle of beer and noted that there
was liquor in the refrigerator. JAMAICA told Wl that he was going to get JDl drunk so that she could make him (JAMAICA) some money. Wl then witnessed JAMAICA order JDl to drink

the rest of JAMAICA'S 40 ounce beer. Wl also observed an attempt by W2 to try and talk to JDl before any prostitution took place, but JAMAICA put a stop to this by yelling at W2 to "stay out of his business." Next, Wl overheard JAMAICA speaking to someone on the phone. Approximately 10-15 minutes later, Wl observed two unknown Hispanic males outside of the

apartment. According to Wl, JAMAICA, JDl, and the two unknown Hispanic males left the
apartment complex in a vehicle. After JAMAICA and JDl drove off with the two Hispanic
males, Wl and W2 left the apartment and traveled to McDonalds. When Wl returned to the apartment, JDl was in JAMAICA'S bedroom.

17.

In the fall of 2011, the FBI interviewed W2, who was also present with JD 1,

JAMAICA, and Wl the night the two Hispanic males came to the apartment and JDl had sexual

intercourse with HMl. On the night in question, W2 recalls that JAMAICA, JDl, and Wl were all present in the apartment. W2 remembers hearing JAMAICA and JDl arguing about sex. Following this argument, JAMAICA approached W2 and said that JDl "is going to do
something" tonight and requested that W2 leave the apartment. W2 refused to leave the

apartment. W2 observed JAMAICA provide JDl with alcohol. At this point, based upon W2's

observations, W2 believed that JDl was going to be prostituted. W2 attempted to speak to JDl,
but JAMAICA interrupted and did not allow W2 to talk with JDl. Later that same evening, W2
saw two Hispanic males arrive at the apartment complex and watched JAMAICA and JDl enter

their vehicle. W2 got into a vehicle with Wl and requested that Wl follow JAMAICA, JDl, and the two unknown Hispanic males. Wl was unable to track the other vehicle. After losing the
vehicle, Wl and W2 made a stop and returned to the apartment. Back at the apartment, W2

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observed JDl sitting on JAMAICA'S bed and when W2 asked JDl what happened, JDl did not
answer.

18.

In the summer of 2011, the FBI interviewed an individual with personal

knowledge of JAMAICA ("W3"). W3, who lived with JAMAICA at the Clark Place apartment,
observed JAMAICA living, and sleeping, with underage, female runaways. W3 identified a picture of JDl as one of these underage runaways that lived in JAMAICA'S room. At one time, in the early spring of 2011, W3 overheard JAMAICA speaking on the telephone and offering a female to another person for $100 for fifteen minutes. W3 indicated that he had asked

JAMAICA about the females he was having sex with and their status as juveniles. In response to
the question, JAMAICA said that he did not care and "all you have to do is get them drunk or
high and they will do whatever you want." 19. In the summer of 2011, the FBI interviewed another witness (W4). W4 has

known JAMAICA for over three years. While JAMAICA was incarcerated on local charges at the Prince William County Adult Detention Center, JAMAICA had telephonic communication with W4. During one call to W4, JAMAICA and W4 recount an incident where W4 wanted to yell at JDl, but JAMAICA protected JDl because JDl was "making me (JAMAICA) money." 20. Through independent research, I discovered that Trojan brand condoms cross

state lines prior to being sold in the Commonwealth of Virginia. It has also been found that Old

English malt liquor and Hennessy liquor are not manufactured within the Commonwealth of

Virginia. Finally, the renting of apartments and the subletting of rooms is part of commerce
between the states.

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21.

Based on the foregoing, I believe that there is probable cause that in the spring of

2011, in Manassas, Virginia, within the Eastern District of Virginia, RAMIRO ESPINOZA
JAMAICA, also known as Criminal and Junior, 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.

Special-Agent Federal Bureau of Investigation

Sworn to and deposed to me this _f__day of October, 2011.

At Alexandria, Virginia

JsL
John F. Anderson

United States Magistrate Judge