Consuelo Carreto Valencia's Part in the Carreto Family Sex Trafficking Ring

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					Case 1:04-cr-00140-FB Document 172-1

Filed 10/29/09 Page 1 of 34

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SMC:MER F.#2004R00374 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - -X UNITED STATES OF AMERICA - against CONSUELO CARRETO VALENCIA, Defendant. - - - - - - - - - - - - - - - -X 04-CR-140 (S-1) (FB)

THE GOVERNMENT’S TRIAL BRIEF

BENTON J. CAMPBELL United States Attorney Eastern District of New York GRACE CHUNG BECKER Acting Assistant Attorney General Civil Rights Division U.S. Department of Justice MONICA E. RYAN Assistant U.S. Attorney HILARY AXAM Special Litigation Counsel (Of Counsel)

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I.

Preliminary Statement The United States submits this trial brief to assist

the Court in the upcoming trial of the above matter, scheduled to begin July 21, 2008. In this brief, the government summarizes

salient aspects of its anticipated evidence and discusses the elements of and relevant case law interpreting the statute criminalizing sex trafficking, 18 U.S.C. § 1591. II. Procedural History On November 16, 2004, a federal grand jury returned a 27-count superseding indictment charging defendant Consuelo Carreto Valencia, along with co-defendants Josue Flores Carreto, Gerardo Flores Carreto, Daniel Perez Alonso, Eliu Carreto Fernandez and Maria de los Angeles Velasquez Reyes, with: (a) conspiracy to commit sex trafficking, in violation of 18 U.S.C. § 371; (b) sex trafficking, in violation of 18 U.S.C. § 1591; (c) attempted sex trafficking, in violation of 18 U.S.C. § 1594; (d) forced labor, in violation of 18 U.S.C. § 1589; (e) transportation in interstate or foreign commerce for the purpose of engaging in prostitution, in violation of 18 U.S.C. § 2421; (f) conspiracy to import aliens for immoral purposes, in violation of 18 U.S.C. § 371; (g) importation of an alien for immoral purposes, in violation of 8 U.S.C. § 1328; (h) alien smuggling, in violation of 8 U.S.C. § 1324(a)(1)(B)(i); and (i) alien smuggling for financial gain, in violation of 8 U.S.C. § 1324(a)(2)(B)(ii).
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2 Only defendant Consuelo Carreto Valencia will be tried on July 21, 2008. Co-defendants Josue Flores Carreto, Gerardo

Flores Carreto and Daniel Perez Alonso each pled guilty to the entire superseding indictment on April 5, 2005. On April 27,

2006, Josue Flores Carreto, Gerardo Flores Carreto and Daniel Perez Alonso were sentenced to terms of imprisonment of fifty years, fifty years and twenty-five years, respectively.1 Defendants Josue Flores Carreto, Gerardo Flores Carreto, Daniel Perez Alonso and Eliu Carreto Fernandez were arrested on January 5, 2004, when agents from the Bureau of Immigration and Customs Enforcement (“ICE”) raided apartments located at 104-56 41st Avenue and 37-71 104th Street in Queens, New York. Defendant Consuelo Carreto Valencia, who had been

previously incarcerated in Mexico on related charges, was extradited from Mexico to the United States on January 20, 2007 and was arraigned in the Eastern District of New York on March 2, 2007. Defendant Maria de los Angeles Velasquez Reyes, who was

also previously incarcerated in Mexico on related charges, is believed to be in Mexico and has not yet been located pursuant to government’s extradition request.

1 Co-defendant Eliu Carreto Fernandez pled guilty to a single count of sex trafficking on December 22, 2004, and was sentenced to an 80 month term of imprisonment on June 1, 2006.

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3 III. Statement of Facts A. Introduction Defendant Consuelo Carreto Valencia is the matriar
				
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Description: Consuelo Carreto Valencia, a member of the Carreto family sex trafficking ring that operated between Mexico and Queens, N.Y., was sentenced to 121 months in prison for benefitting financially from her participation in the organization, which transported young Mexican women to the United States and forced them into prostitution. The sentencing proceeding was held today before U.S. District Judge Frederic Block at the U.S. Courthouse in Brooklyn, N.Y.
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