Case 1:11-cr-00235-GBL Document 20 Filed 05/18/11 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA
Alexandria Division

UNITED STATES OF AMERICA

v. CRIMINAL NO.: 1:11CR235

EDOBOR F. OKENWA The Honorable Gerald Bruce Lee

Defendant.

STATEMENT OF FACTS

Were this matter to go to trial, the United States of America would prove the following facts

beyond a reasonable doubt with admissible and credible evidence:

1. On or about March 24, 2011, within the Eastern District of Virginia, the defendant,

EDOBOR F.OKENWA, attempted to unlawfully, knowingly, and intentionally import into the United

States from a placeoutside thereof, one (I) kilogram or more of a mixture and substancecontaining a

detectable amount ofheroin, a Schedule II controlled substance, in violation ofTitle 21, United States

Code, Sections 952 and 963.

2. On or about March 24,2011, the defendant attempted to enter the United States at Dulles

International Airport, within the Eastern District ofVirginia, afterarriving on a flight originating from

Italy. During the course of a customs inspection, an officer with Immigration and Customs

Enforcement observed that the defendant was sweating profusely and appeared to be in pain. A search

of the defendant's belongings revealed Imodium and other anti-diarrheal medication. The officer

subsequently conducted a pat-down of the defendant's mid-section and detected a firmness in the

defendant's abdomen. The defendant was then transported to Reston Hospital Center. The defendant
 Case 1:11-cr-00235-GBL Document 20 Filed 05/18/11 Page 2 of 3

consented to an x-ray examination, which revealed the presence of foreign objects in the defendant's

abdomen. The defendant subsequently expelled eighty-eight (88) pellets from his rectum.

3. In total, the eight-eight (88) pellets contained 1.44 kilograms of a mixture or substance

containing a detectable amount of heroin.

4. This statement of facts includes those facts necessary to support the plea agreement

between the defendant and the government. It does not include each and every fact known to the

defendant or the government, and it is not intended to be a full enumeration of all of the facts

surrounding the case.

5. The actions of the defendant as recounted above were in all respects knowing and

deliberate, and were not committed by mistake, accident, or other innocent reason.

Respectfully submitted,

Neil H. MacBride
United States Attorney

By: J^JuATAfUJ^vCrA^fXa^
Kara Martin Traster
Special Assistant United States Attorney
 Case 1:11-cr-00235-GBL Document 20 Filed 05/18/11 Page 3 of 3

Defendant's Stipulation and Signature

After consulting with my attorney, I hereby stipulate that the above Statement of Facts is true

and accurate, and that had the matter proceeded to trial, the United States would have proved the same

beyond a reasonable doubt.

S~'fz-r/
EDOBOR F. OKENWA
Defendant

Defense Counsel's Signature

I am the attorney for EDOBOR F. OKENWA. I have carefully reviewed the above Statement

ofFacts with him. To my knowledge, his decision to stipulate to these facts is informed and voluntary.

Kenneth P.TlUCUuli; Esq.

Counsel for the Defendant