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v. YOMADE SAHEED ABORISHADE Defendant ) ) ) ) ) ) )

CRIMINAL NO.: 1:11CR259 The Honorable Gerald Bruce Lee

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 30, 2011, within the Eastern District of Virginia, the defendant,

YOMADE SAHEED ABORISHADE, unlawfully, knowingly, and intentionally imported into the United States from a place outside thereof, one (1) kilogram or more of a mixture and substance containing a detectable amount of heroin, a Schedule II controlled substance, in violation of Title 21, United States Code, Section 952. 2. On or about March 30, 2011, the defendant entered the United States at Dulles

International Airport, within the Eastern District of Virginia, after arriving on a flight originating from Ghana. Upon examination by Customs and Border Protection (CBP) Officers, defendant gave multiple and conflicting reasons for his travel. The defendant was then transported to Reston Hospital Center. The defendant consented to an x-ray examination, which revealed the presence of foreign objects in the defendants abdomen. The defendant subsequently expelled one hundred (100) pellets from his body. 3. The one hundred (100) pellets contained a gross weight of approximately 1.8 kilograms

of a mixture and substance containing a detectable amount of heroin.


The defendant is responsible for the importation of at least 1 kilogram, but less than

3 kilograms, of heroin. 5. 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. 6. 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


__________________________ Julie J. Allen Special Assistant United States Attorney Counsel for United States U.S. Attorneys Office Eastern District of Virginia 2100 Jamieson Avenue Alexandria, Virginia 22314 Direct: 703-299-3904 Fax: 703-299-3980

Defendants 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. ______________________________ YOMADE SAHEED ABORISHADE Defendant

Defense Counsels Signature I am the attorney for YOMADE SAHEED ABORISHADE. I have carefully reviewed the above Statement of Facts with him. To my knowledge, his decision to stipulate to these facts is informed and voluntary. _______________________________ Shannon Quill, Esq. Counsel for the Defendant