Case 0:15-cr-60112-WJZ Document 20 Entered on FLSD Docket 06/24/2015 Page 1 of 6

UN ITED STATES D ISTRICT CO URT

SOUTHERN D ISTRICT OF FLOR ID A
CA SE N O .15-601IZ-CR-ZLOCH
M AG ISTRA TE JUDGE HUN T
UN ITED STATES OF A M ERICA ,
Plaintiff,

STA LIN ANTON IO ASENJO ,

Defendant.
/

lsSTALIN A NTO NIO ASENJO , hereby state the following:

l am knowledgeable and personally aware of the factual matters sum marized

throughoutthis Stipulated Statem entofFacts.

Ihave consulted with my attorney regarding the factualassertions described in the

pageswhich follow .

1 hereby acknow ledge, adopt, adm it and confirm to be true and correct
,

as

evidenced by m y signature appearing atthe end ofthis document, the factualassertions setforth
herein.

4.

l understand thatthis statement is being signed and supplied by m e pursuant to

Fed.R.Crim.P.11(b)(3)withtheunderstandingthatIwillbepleadingguiltytothesinglecount
ofthe lnform ation which has been filed in the case of United States v.

Stall'
n Antonio Asenjo,

Case 0:15-cr-60112-WJZ Document 20 Entered on FLSD Docket 06/24/2015 Page 2 of 6

Case No. 15-601IZ-CR-ZLO CH , and which charges me w ith the offense of w ire fraud in
violation ofTitle 18, Uhited States Code,Section l343 as a consequence of the offense co
nduct
described below.
O n February 27, 2012, defendant Stalin Antonio Asenjo

(hereinafter6$Asenjo''),astock Sipromoter''whose serviceswere retained by

certain businesses seeking to generate public intertst in the purchase of their

stock,metwith an FBlundercoverconfidentialsource (hereinafterthei$CS'')

along w ith a second individual. During the course ofthe ensuing m eeting
,
which took place in the O rlando area, a fraudulent m icrocap stock m arket

manipulation proposalthat had been the subject of earlier conversations

between the CS and the other individual, butwhi
ch hadnotinvolved Asenjo,

wasdiscussedinAsenjo'spresence.
During the February 27s 2012 meetings in which Asenjo
participated, the CS claim ed that he had in place an organized dbuyin
g

group'' which could be called upon to purchase so-called ikpenny stock'' in

certain m icrocap com panies through contrived m arket transactions. The CS
further stated that his iibuying group''would engage in allof the neces

sary

contrived trading transactions upon a ddfour-to-one basis,''m eaning that the

Sdbuying group''would be paid one dollarforevel'
y fourdollarsof stock which
they w ould purchase on the open market. These purchases would be m ade
for the purpose of fraudulently generating trade volum e and bidding up the

marketpriceoftheparticularCpennystock''whichwouldbetheobjectofany

Case 0:15-cr-60112-WJZ Document 20 Entered on FLSD Docket 06/24/2015 Page 3 of 6

such schtm e. These statem ents by the CS were part of the undercover
scenario.

In April,20l2,approxim ately five w eeksafterthe February 27,

2012Orlandomeeting,Asenjo initiatedan unsolicitedtelephonecontactwith

the CS in the Southern D istrict of Florida, wherein Asenjo was recorded
asking the C S whetherthe CS and the CS'iibuying group''could ttfront-run''a

forthcoming newsrelease concerning a promotion which Asenjo had been

hired to dissem inate during the follow ing week. The term Ssfront-run''in this
contextreferred to a process wherein the CS's idbuying group''w as asked to
initiate som e contrived volum e-generating buying activity shortly before the
press release w as to be dissem inated so that itwould appearas though there
had been interest in the stock by investors even before the press release w as

dissem inated.
The penny-stock in question w ith respect to Asenjo's
ikfront-run'' proposal to the C S was Blackbird International Corporation

(symbolikBBRD''),an SEc-delisted company which was very thinly traded

upon an over-the-counter basisthrough the so-called S'Pink Sheets''database.

In response to Asenjo's solicitation,the CS replied thathe would engage in

the proposed difront run'' as Iong as the CS and the CS' dbuying group''

receivedadvancecopiesoftheactualpressreleasefrom Asenjobeforeitwas
scheduled to run. In response, Asenjo agreed to prematurely revealthe

contentsofthepressrelease to theCS,sinceAsenjo was destined to receive

Case 0:15-cr-60112-WJZ Document 20 Entered on FLSD Docket 06/24/2015 Page 4 of 6

an advance copy from BBRD which had ret

ained Asenjo's services as a

prom oter.
O n A pril24, 2012, Asenjo engaged in a Skype conversation

w ith the CS and w as overheard reading thr

ee Blackbird lnternational
Corporation prtss rtleases to the CS. Thereafter. on A pril 25
, 2012, FB1
agents,posing as m em bers ofthe CS'Sibuying group,''and w ith the previous
consent

the SEC, bought 40,000 shares of Blackbird lnternational

Corporation. This was done from the Southern District of Florida th

rough

three different undercover purchases conducted over an electronic

trading

platform that utilized interstate w ire com m unication to effectuate these

purchases.
A 11 three purchases were m ade on the m orning of A pril 24
,

2012andthefirstofthethreepressreleasespreviouslyreadbyAsenjoto the
CS was officially dissem inated to the public at noon on that day, while a
second pressrelease wasissued on April27, 2012.
On M ay l6, 2012, Asenjo texted the CS to get on Skype.

While on Skype, Asenjo asked the CS ifthe CS and his group would
Sdfront-run'' the news on another promotion that Asenjo planned upon
initiating the following M onday regarding Sutimco lnternational (symbol

SUTI),an SEC non-reporting com panyonthePink Sheets

.

A fter the CS agreed, Asenjo advised that the news release

would be disseminated the following M onday (M ay 21, 2012),butthat he

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*

w ould read the contents of the press release to the CS over Skype on th
e

following day (Thursday May 17,2012) and wanted the CS and the CS'
buying group to start buying that sam e m orni
ng. This schedule was later
m oved back by one day. such thatthe buying and press release dissem ination
actually took placeon Friday, M ay l8,2012.
O n M ay 18, 2012, A gents of the FBI, posing as the CS's

tsbuying group,''boughtsharesthrough m atched tradesw hich w ere essentially

orchestrated forno purpose otherthan to pum p up volum eand m arketprice.
As with BBRD schem e, the FBIboughtshares on four separate occasions on
M ay 18,2012.
O n June l9, 2012, Asenjo again contacted theCS vi
a Skype

and requested the C S'and his isbuying group's''assistance in conducting yet

another d'front-run'' schem e, this time w ith respect to Far V ista Petroleum

Corporation,a Pink Sheets OTC stock which wasnon- registered with the SEC

and traded under the sym bol CSFVSTA .'' A gain,the C S agreed. Thereaer,

Asenjo read to the CS the contentsoffive proposed pressreleasess one of

which related to FV STA .
k.

On June 21,20l2,the FB1purchased shares of FVSTA on one

occasion.

Later that sam e day, the press release in question was

dissem inated.
The total expenditure by the FBI, while posing as the CS'

iibuying group'' in each of the aforem entioned dsfront run'' schem es

5

w as

Case
0:15-cr-60112-WJZ Document 20 Entered on FLSD Docket 06/24/2015 Page 6 of 6
*

approximately$21,706.93.

STA LIN ANTO

Dcfendant
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O A SENJO

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