t

IN THE CIRCUIT COURT FOR BALTIMORE CITY

STATE OF MARYLAND

v.

CHRISTOS VASILIADES
l0l N. Haven Street
Baltimore, Maryland 21224
D.O.B.: 0512611978

rrackingNumber: t7-7a24-0013s-0 1 t ? 143 00 2

(TRUE BILL)

GRAND JURY FOREPERSON

FILED: MAY 23,2017

CHARGES:

Conspitacy - Obstruction / Intimidation (Common Law; Maryland Criminal Law Article g9-305(a))

Intimidate Witness by Threat - Felony (Victim 1) (Maryland Criminal Law Articls $9-305(a))

Intimidate Vy'itness by Corrupt Means - Felony (Victim l) (Maryland Criminal Law Article g9-305(a)

Intimidate Witness by Threat - Felony (Victim 2) (Maryland Criminal Law Article g9-305(a)

Intimidate Witness by Corrupt Means - Felony (Victim 2) (Maryland Criminal Law Article g9-305(a))

Solicitation to Intimidate Witness - Felony (Victim 1) (Maryland Criminal Law Article g9-305(b)

Solicitation to Intimidate \itness - Felony (Victim 2) (Maryland Criminal Law Article $9-305(b))

Influence Victim to Withhold Testmony (Victim l) (Maryland Criminal Law Article g9-302(aXt))

Induce Victim to be Absent from Proceeding (Victim l) (Maryland Criminal Law Aticle g9-302(a)(2))
Influence Witness to Withhold Testimony (Victim 2) (Maryland Criminal Law Afticle g9-302(a)(l))

Induce Vy'itness to be Absent from Proceeding (Victim 2) (Maryland Criminal Law Afticle g9-302(a)(2)

Obstruction of Justice (Maryland Criminal Law Article $9-306)

 \VITNESSES:

Sgt Robert Velte (['-593)

Investigation Intelligence Section
Baltimore Police Department

Det. Anthony Sgambati (F-142)

Investigation Intelligence Section
Baltimore Police Department

Please issue a warrant and return for service to:

Katie l)orian
Assistant Attorney General
Chief, Organized Crime
4t0-576-6458
STATE OF MARYLAND ,r IN THE

v * CIRCUIT COURT

CHRISTOS VASILIADES * FOR BALTIMORE CITY

Defendant
* CASE NO: 1t?143008
INDICTMENT
The Grand Jurors for the State of Maryland for Baltimore City charge:

(couruox conffi ossrnucrJusrrcB

"n*
luo IxrrnTDATE A Vrcrrm AND \ryITNEss)

The Jurors of the State of Maryland for the body of the City of Baltimore, do on their oath
present that the aforesaid DEFENDANT, late of said City, in April and May of 2017, in Baltimore
City, did unlawfully conspire with others known and unknown, to obstruct justice and intimidate
witnesses in a pending felony rape case, through unlawlul criminal means including, but not
limited to, threatening to harm the witnesses with deportation, and offering to pay the witnesses to
not show up to court and to not testiff, with the intent to intimidate the witnesses out of performing
their official duties to testify in an ofnicial proceeding to which they had een subpoenaed and
summoned, and trying to induce the witnesses to withhold testimony in a pehding felony criminal
case, the offense being the commission of a crime of violence as described under Criminal Law
Article, Section 14-101, of the Maryland Code, to wit: rape, in violation of the Common Law of
Maryland as well as the Criminal Law Article, sections 9-305, 9-302, and 9-306, of the Maryland
Code, against the peace, govemment, and dignity of the State.

Overt Acts in Furtherance of the Conspiracy

l. On April 11,2017, Christos VASILIADES (a defense attorney who represents

Mario Aguilar-Delossantoso a defendant who is pending felony rape charges for allegedly raping
and Edgar Ivan RODRIGUEZ (an individual who works with
VASILIADES and who speaks both English and Spanish) together called husband,
and stated that his wife's case had become "more complicated,"
and asked I to meet to discuss the case.

2. Later that evening, VASILIADES and RODRIGUEZ arcived - at the meeting place
(a previously agreed upon restaurant) in Baltimore City, Maryland, and met with I and
both of whom are State's witnesses in the felony rape case against VASILIADES'
client. VASILIADES introduced himself as the attomey who represents the defendant in the case
in which was a victim, and RODRIGUEZ presented himself as VASILIADES'
interpreter (I and I both primarily speak Spanish, but I does
understand and speak some English).

-
 3. During the April ll,20l7 meeting, VASILIADES and RODRIGUEZwarnedf
I and I of the potential risk of being deported if they testify in court, and explained
that the U.S. Immigration and Customs Enforcement (ICE) would likely be present in the
courtroom for their client. VASILADES and RODRIGUEZ c,ited new federal laws and policies
and maintained that there is a high risk that I and I would be deported if they
testify in court.

4. During the April Ll,2017 meeting, VASILIADES and RODRIGUEZ toldf

I and I that the defendant in the pending rape case, in which I is the
victim, was very sorry and could offer compensation if they did not comp to court and testify
against him. VASILIADES and RODRIGUEZ indicated that the monetary compensation would
help ensure that I and would not get deported.

5. On May 15,2017, during a controlled and recorded phone call placed by I

-
(at the direction of law enforcement) to Christos VASILIADES wherein f said he had
been considering the offer and wanted to talk more about it, VASILIADES suggested an in-person
meeting and said he would call back at a later time to schedule it. On ll[ay 17 ,20 t 7, VASILIADES
called I and scheduled a meeting for the following evening.

6. On May 18,2017, around 6:30 in the evening, VASILIADES called I to

confirm that they were still meeting, and gave the meeting location. Around 7:30 that night,
VASILIADES and RODRIGUEZ met rift was wearing a recording device-
and I in an office space in Baltimore City, Maryland.

7. --who
At the beginning of the meeting on May 18,2017, VASILIADES ordered that
everyone place their cell phones on the desk in the lobby, and prohibited them from bringing the
phones with them into the office where they would be meeting. Upon everyone complying with
this instruction, VASILIADES led everyone into the office.

8. During the May I8,2017 meeting, VASILIADES and RODRIGUEZ explained

what they purported to be the current environment for immigrants in this country, citing recent
immigration arrest statistics, and explained that ICE is "looking at this case" for their client, and
again reiterated that there is a risk of deportation for I and Ishould they show
up and testify in the rape case. RODRIGUEZ stated, "You know how things are with Trump's
laws now; someone goes to court, and boom, they get taken away." After explaining that if they
go through with the trial ICE would show up for his client, VASILIADES said to I,
gesturing to III "And because she's there, you know, my guy's going to be like, '['m
ooThey're going to
here, but she is too!"' RODRIGUEZ followed up by explaining, ask, 'you have
your documents?o'o VASILIADES then stated, "Then everybody's flcked."

9. DuringtheMay 18,2A17 meeting,VASILIADESandRODRIGUEZinformedI

I and I that the defendant could provide them with $3,000 in cash if they did not
show up to court and the case got "thrown out." VASILIADES and RODRIUEZthen developed
and explained the following plan to I and I: On the upcoming trial date I
I and I should not show up to court and should instead wait outside the court house
with RODRIGIJEZ, who would be holding the cash, while VASILiADES would appear in court.
lf the case was then "thrown out" due to the fact that I and I did not show up,
VASILIADES would come out of the court house, give a "thumbs up" to RODRIGUEZ, and
RODRIGUEZ would hand and I the cash.

10. Throughout the May 18,2017 meeting, VASILIADES encouraged I and

I to, instead of testifying in court against his client, simply take the money and then
physically assault his client, who is ccused of raping VASILIADES said, among
other things, the following: "find him and wear him out"; "if we were back home where I'm from,
from Greece... we would go fxck him up, that's it, if you want to do that, that's fine"; *$3,000,
and then find him and kick his ass"; o'he's an asshole, I think you should find him and kick his ass,
-
personally"; and finally, after explaining that all they want is for I and I to not
come to court, VASILIADES stated, "I did my job, I did very good, and I can go home and go to
sleep, ok, and then you get something, and then you find him outside, brother, and you frck him
up, that's it."

11. At the conclusion of the May 18, 2017 meeting, VASILIADES explained that he
would call I after speaking to his client and securing the money. VASILIADES and
RODRIGUEZ offered to show the money to I and I the night before trial, to
prove that they in fact did have the money to give them. VASILIADES instructed I and
"Please, don't say nothing on the phones. Don't say nothing on the phones. For me
and for you."

Common Law; Annotated Code of Maryland, Criminal Lw Article fS 9-305(a)(c), 9-302, 9-306
-CJIS Code /,C0359

Couxr Two
(Inrrvrrolrn Wrrwsss By THRAT' Fnloxy Orrnxsn)

The Jurors of the State of Maryland for the body of the City of Baltimore, do on their oath
present that the aforesaid DEFENDANT, late of said City, in April and May of 2017, did by threat
try to influence, intimidate, and impede a witness, in the
performance of her official duties, the offense being a crime of violence as described under
Criminal Law Article, Section l4-101 of the Maryland Code, to wit: rape, in violation of Criminal
Law Article, Section 9-305(a) of the Maryland Code, against the peace, govemment, and dignity
of the State.

Annotated Code of Maryland, Criminal Law Article f 9-305(a)(c)

CJIS Code I-0359
Felony: 20 years
 Couur Tnnne
(IxrIutol'ru Wlrxnss nv Connupr Mnlxs - Fnloxy Ornnnso)
The Jurors of the State of Maryland for the body of the City of Baltimore, do on their oath
present that the aforesaid DEFENDANT, late of said City, in April and May of 2017, did by
corrupt means try to influence, intimidate, and impede a witness,
in the perfonnance of her official duties, the offense being a crime of violence as described under
Criminal Law Article, Section t4-101 of the Maryland Code, to wit: rape, in violation of Criminal
Law Article, Section 9-305(a) of the Maryland Code, against the peace, government, and dignity
of the State.

AnnotqtedCode of Maryland, Criminal Lw Article $ 9-305(a)(c)

CJIS Code I-0359
Felony: 20 years

Couxr Foun
(Ixrruroarn Wrrxnss By THREAT - FsLoNv Orrnnsn)

The Jurors of the State of Maryland for the body of the City of Baltimore, do on their oath
present that the aforesaid DEFENDANT, late of said City, in April and May of 2017, did by threat
try to influence, intimidate, and impede a witness in the
performance of his official duties, the offense being a crime of violence as described under
Criminal Law Article, Section 14-l0l of the Maryland Code, to wit: rape, in violation of Criminal
Law Article, Section 9-305(a) of the Maryland Code, against the peace, government, and dignity
of the State.

Annotated Code of Maryland, Crminal Law Article f 9-305(a)(c)

CJIS Code I-0359
Felony: 20 years

Couxr Frve
(Inrrrurnlre lVrness sy ConRupr Meaxs - FBr,oxy Orrensn)

The Jurors of the State of Maryland for the body of the City of Baltimore, do on their oath
present that the aforesaid DEFENDANT, late of said City, in April and May of 2017, did by corrupt
means try to influence, intimidate, and impede a witness in the
performance of his official duties, the offense being a crime of violence as described under
Criminal Law Article, Section 14-101 of the Maryland Code, to wit: rape, in violation of Criminal
Law Article, Section 9-305(a) of the Maryland Code, against the peace, government, and dignity
of the State.

Annotated Code of Maryland, Criminal Law Article g 9-305(a)(c)

CJIS Code l-0359
Felony: 20 yers
 Counr Srx
(Solrcrra'rroN To lurrmrnrrn Wrrxuss - FBloxy Orrnxsn)

The Jurors of the State of Maryland for the body of the City of Baltimore, do on their oath
present that the aforesaid DEFENDANT, late of said City, in April and May of 2017, did solicit
Edgar lvan RODRIGUEZ to, by threat and comrpt means try to influence, intimidate, and impede
a witness, in the performance of her official duties, the offense
being a crime of violence as desibed under Criminal Law Article, Section 14-101 of the
Maryland Code, to wit: rape, in violation of Criminal Law Article, Section 9-305(b) of the
Maryland Code, against the peace, government, and dignity of the State.

Annotated Code of Maryland, Criminal Lw Article S 9-305(b)(c)

CJIS Code l-0363
Felony: 20 years

Couxr Srvnx
(Sot IcrrnrroN To lxrrnnrorro WrrNEss - Fnlouv OrreNsn)

The Jurors of the State of Maryland for the body of the City of Baltimore, do on their oath
present that the aforesaid DEFENDANT, late of said City, in April and May of 2017 , did solicit
Edgar Ivan RODRIGUEZ to, by threat and comrpt means try to influence, intimidate, and impede
a witness in the performance of his official duties, the offense
being a crime of violence as described under Criminal Law Article, Section 14-101 of the
Maryland Code, to wit: rape, in violation of Criminal Law Article, Section 9-305(b) of the
Maryland Code, against the peace, govemment, and dignity of the State.

Annotated Code of Maryland, Criminal Law Article S 9-3A5@)

CJIS Code l-0363
Felony: 20 years

Couxr ErcH'r
(Ixrlunxce Vrcrrn ro Wrrnuot,D TESrrMoNy)

The Jurors of the State of Maryland for the body of the City of Baltimore, do on their oath
present that the aforesaid DEFENDANT, late of said City, in April and May of 2017, did threaten
to harm with the intent to influence the victim to withhold
testimony, the offense being the commission of a crime of violence as described under Criminal
Law Article, Section 14-101 of the Maryland Code, to wit: rape, in violation of Criminal Law
Article, Section 9-302(a)(l) of the Maryland Code, against the peace, government, and dignity of
the State.

Annotated Code of Marylond, Criminal Law Article SS 9-302(a)(l), 9-302(c)(2)

CJIS Code 1-0355
Felony: 20 years
 Couxr Nrnr
(Irouce Vrcrn ro Bn Asseir FRoM Orrrcrr, PnocnnorNc)

The Jurors of the State of Maryland for the body of the City of Baltimore, do on their oath
present that the aforesaid DEFENDANT, late of said City, in April and May of 2017, did threaten
to harm with the intent to induce the victim to be absent from an
official proceeding to which the victim has been subpoenaed and summoned, the offense being the
commission of a crime of violence as described under Criminal Law Article, Section i4-101 of
the Maryland Code, to wit: rape, in violation of Criminal Law Article, Section 9-305(a)(2) of the
Maryland Code, against the peace, government, and dignity of the State.

Annotated Code of Maryland, Criminal Lw Artcle $$ 9-302(a)(2), 9-302(c)(2)

CJIS Code 1-0355
Felony: 20 years

CounrTnu
(Ixnluoxcn Wrrxnss ro \ryrruuor,o Tusrruonv)

The Jurors of the State of Maryland for the body of the City of Baltimore, do on their oath
present that the aforesaid DEFENDANT, late of said City, in April and May of 2017, did threaten
to harm with the intent to influence the witness to withhold
testimony, the offense being the commission of a crime of violence as described under Criminal
Law Article, Section 14-101 of the Maryland Code, to wit: rape, in violation of Criminal Law
Article, Section 9-302(a)(1) of the Maryland Code, against the peace, goverment, and dignity of
the State.

Annotared Code af Maryland, Criminal Law Article $$ 9-302(a)(l), 9-302(c)(2)

CJIS Code 1-0355
Felony: 20 years

CouxrElpvnx
(Ixoucn Wrxsss ro BE Anspnr FRoM ORncrnl. Pnocenotnc)

The Jurors of the State of Maryland for the body of the City of Baltimore, do on their oath
present that the aforesaid DEFENDANT, late of said City, in April and May of 2017, did threaten
to harm with the intent to induce the witness to be absent from an
official proceeding to which the witness has been subpoenaed and summoned, the offense being
the commission of a crime of violence as described under Criminal Law Article, Section 14-101
of the Maryland Code, to wit: rape, in violation of Criminal Law Article, Section 9-302(a)(2) of
the Maryland Code, against the peace, government, and dignity of the State.

Annotated Code of Maryland, Criminal Law Article $$ 9-302(a)(2), 9-3A2k)(2)

CJIS Code I-0355
Felony: 20 years
 CouurTwer,vB
(Onsrnucrron or Jus'nce)

The Jurors of the State of Maryland for the body of the City of Baltimore, do on their oath
present that the aforesaid DEFENDANT, late of said City, in April and May of 20 I 7 , did by threat
and conupt means try to obstruct and impede the administration ofjustice in State of Marylandv.
Maro Aguilar-Delostantos, case number 116112002, in the Circuit Court for Baltimore City, in
violation of Criminal Law Article, Section 9-306 of the Maryland Code, against the peace,
government, and dignity of the State.

Annotated Code of Maryland, Criminal Law Article S 9-306

CJIS Code 2-5006
Misdemeanor : 5 years/$ I A,000

t",o^ f,od^ lqnt

BnrnNE. Fnoss I
Attomey General of Maryland

-b
Knrrp DoRleN fucuRno GresoN
Assistant Attorney General Special Assistant Attorney General
Chief, Organized Crime Major Investigations
Maryland Attomey General's Office Baltimore City State's Attorney's Office
200 Saint Paul Place 120 East Baltimore Street
Baltimore, Maryland 21202 Baltimore, Maryland 21242
(410) s76-64s8 (443) 984-6048