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AUSA, STEVEN J. DOLLEAR (312) 353-5359AUSA, MATTHEW MADDEN (312) 886-2050AUSA, JESSICA ROMERO (312) 353-4137AO 91 (REV.5/85) Criminal 4444444UNITED STATES DISTRICT COURTNORTHERNDISTRICT OFILLINOIS, EASTERN DIVISIONUNITED STATES OF AMERICAv.CRIMINAL COMPLAINTJUN YUN ZHANG,a/k/a “Lao Sze”and the defendants on the attached listCASE NUMBER:UNDER SEALI, the undersigned complainant being duly sworn state the following is true and correct to the best of myknowledge and belief. From in or about at least 2003, and continuing to the present, in the NorthernDistrict ofIllinois, Eastern Division, defendants herein,did knowingly and intentionally conspire with each other and others, to transfer, possess, or use, meansof identification, namely social security numbers of other persons which were issued by or under the authority ofthe United States, without lawful authority, with the intent to commit, or to aid or abet, or in connection with, anunlawful activity constituting a violation of federal law, namely, Title 42, United States Code, Section 408(a)(7)(B),and Illinois law, namely, 625 ILCS 5/6-302, contrary to Title 18, United States Code, Section 1028(a)(7),all in violation of Title 18 United States Code, Section 1028(f) and 2.I further state that I am a(n) Special Agent with the Federal Bureau of Investigationbased on the following facts:and that this complaint isSee Attached AffidavitContinued on the attached sheet and made a part hereof:XYesNoSignature of ComplainantDAVID A. PATCHSpecial Agent, Federal Bureau of InvestigationSworn to before me and subscribed in my presence,atChicago, IllinoisDateCity and StateMichael T. MasonU.S. MAGISTRATE JUDGESignature of Judicial Officer
2.JUN YUE ZHANG, a/ka “Lao San”;3.JUN XI ZHANG, a/k/a “Lao Wu”;4.JUN SHUN ZHANG, a/k/a “Mikey”;5.DONG DONG GUO, a/k/a “Xiao Zhang”;6.GUOQI ZHANG;7.TIANSHENG ZHANG;8.XIN LI WANG a/k/a “Tony”;9.MEIZHU WANG;10.YIYI SHI, a/k/a “YiYi” a/k/a “Huati”;11.SONG YAN SHI;12.WENYUAN ZHOU;13.YONGHUI WANG;14.ZHAOFA WANG;15.QIONG ZHOU;16.TIMOTHY T. JOHNSON JR.;17.JAMES M. HOWELL.
STATE OF ILLINOISCOUNTY OF COOK)))SSAFFIDAVITI, David A. Patch, hereinafter referred to as "Affiant," being duly sworn underoath, state as follows:I.PRELIMINARY MATTERS1.I am an investigative or law enforcement officer of the United States within themeaning of Title 18, United States Code, Section 2510(7), in that I am empowered by law to conductinvestigations and to make arrests for felony offenses as enumerated in Title 18, United States Code,Section 2516.2.I am a Special Agent ("SA") with the Federal Bureau of Investigation ("FBI"), UnitedStates Department of Justice and have been so employed for approximately ten years. I am currentlyassigned to the Asian/Eurasian Criminal Enterprise Squad of the Chicago Division of the FBI. Aspart of my official duties, I investigate criminal violations of federal laws, including, but not limitedto Title 18, United States Code, Sections 1028, 1543, 1544 and 1951, which prohibit, among otherthings, the manufacture, sale, and alteration of fraudulent personal identification documents as wellas interfering with commerce through extortion. I have received specialized training in theinvestigation and prosecution of Asian criminal enterprises and their involvement in the manufactureand sale of fraudulent identification documents. I have been involved in various types of electronicsurveillance, physical surveillance and in the debriefing of defendants, witnesses and confidentialsources, and have worked and spoken with other law enforcement officers who are knowledgeableabout Asian criminal enterprises which are involved in the illegal manufacture, sale, and distributionof altered and fraudulent personal identification documents.
3.This Affidavit is made for the limited purposes of establishing probable cause insupport of:a.A Criminal Complaint charging that defendants: JUN YUN ZHANG, a/k/a“Lao Sze”; JUN YUE ZHANG, a/k/a “Lao San”; JUN XI ZHANG, a/k/a “Lao Wu”; JUN SHUNZHANG, a/k/a “Mikey”;DONG DONG GUO, a/k/a “Xiao Zhang”; GUOQI ZHANG; TIANSHENGZHANG; XIN LI WANG a/k/a “Tony”; MEIZHU WANG; YIYI SHI, a/k/a “YiYi” a/k/a “Huati”;SONG YAN SHI; WENYUAN ZHOU; YONGHUI WANG; ZHAOFA WANG; QIONG ZHOU;TIMOTHY T. JOHNSON JR.; and JAMES M. HOWELL, did knowingly and intentionally conspirewith each other and others, to transfer, possess, or use, means of identification, namely socialsecurity numbers of other persons which were issued by or under the authority of the United States,without lawful authority, with the intent to commit, or to aid or abet, or in connection with, anunlawful activity constituting a violation of federal law, namely, Title 42, United States Code,Section 408(a)(7)(B), and of Illinois law, namely, 625 ILCS 5/6-302, contrary to Title 18, UnitedStates Code, Section 1028(a)(7), all in violation of Title 18 United States Code, Section 1028(f);b.Criminal Complaints charging that defendants LI WEN HUANG andRONG SI, did knowingly possess and use, without lawful authority, a means of identification ofanother person, namely social security numbers of other persons which were issued by or under theauthority of the United States, with the intent to commit, or to aid or abet, or in connection with,commission of a violation of federal law, namely, Title 42, United States Code, Section408(a)(7)(B), and Illinois law, namely 625 ILCS 5/6-302, all in violation of Title 18 United StatesCode, Section 1028(a)(7).2
c.Obtaining Search Warrants at the following locations (as more fullydescribed below and in referenced attachments):i.2734 S. Wentworth Avenue, Unit 310, Chicago, Illinois more fullydescribed in Attachment A-1;ii.2734 S. Wentworth Avenue, Unit 408, Chicago, Illinois, more fullydescribed in Attachment A-2;iii.260 West 24th Place, Unit 1-Rear, Chicago, Illinois, more fullydescribed in Attachment A-3; andiv.2925 South Wells Street, Chicago, Illinois, more fully described inAttachment A-4 (hereinafter, collectively referred to as “Search Residences”).4.The information in this Affidavit is based upon interviews of witnesses, my ownobservations and actions, information received from other law enforcement agents and officers, myexperience and training, and the experience of other agents and officers, information fromconfidential sources and undercover law enforcement officers, consensual recordings of telephonecalls and in-person meetings with subjects of the investigation, surveillance by law enforcementofficers of subjects of the investigation and records obtained during the course of the investigation.Further, the information in this Affidavit is also based upon a review of intercepted wirecommunications which were obtained pursuant to Court Order. Since this Affidavit is beingsubmitted for the limited purposes of securing Criminal Complaints and Search Warrants asindicated above, I have not included each and every fact known to me concerning this investigation.More specifically, I have set forth only the facts that I believe are necessary to establish a foundationof probable cause to support the requested Criminal Complaints and Search Warrants.II.OVERVIEW OF THE INVESTIGATION3
A.General Summary5.Based upon the investigation to date, my training, experience and involvement indebriefing defendants, witnesses, and confidential sources as well as my consultation with other lawenforcement officers who have conducted investigations of Asian criminal enterprises, I know thefollowing:a.Chinese criminal enterprises frequently establish well coordinated operationswhereby nationals from the People's Republic of China ("PRC") are smuggled, for a fee, into theUnited States ("U.S.") via a variety of different techniques. Upon entering the U.S., these Chinesenationals frequently seek out and prepare to reside in ethnically similar communities, namely thewell established "Chinatown" communities located in various large cities to include Atlanta, Boston,Chicago, Los Angeles, New York and San Francisco, among others. Although illegally residing inthe U.S., these Chinese nationals often attempt to obtain employment, housing, utility services,driver's licenses as well as credit card and banking accounts in furtherance of assimilating into lifein the U.S.b.Chinese nationals who are illegally residing in the U.S. often seek to obtainaltered or fraudulent personal identification documents, under alias identities, in furtherance ofavoiding detection by U.S. immigration authorities and in furtherance of obtaining employment,housing, utility services and credit card and banking services. Social security account cards areroutinely sought, due to the fact that many employers require a worker to possess a valid socialsecurity account number. Additionally, these Chinese nationals seek to utilize fraudulently obtainedsocial security account numbers for a variety of other purposes, to include applying for and openingcredit card and banking accounts as well as to support applications for state issued driver's licenses4
or identification cards.c.As part of a typical fraudulent document operation, an undocumented foreignnational "customer" will usually coordinate with a "broker"1 to obtain fraudulent personalidentification documents and, in furtherance of that process, will provide a personal passportphotograph to the broker. In turn, this broker will coordinate with a "manufacturer"2 who will altera counterfeit or authentic PRC passport to contain the customer's photograph and will manufacturea new biographical page for the passport to match the identity associated with an authentic socialsecurity account card for a third party. Further, these brokers and their associated "couriers"3provide instruction to customers relative to using an altered PRC passport, social security accountcard and a fraudulent bank statement, utility service statement or postmarked envelope4 to obtaina state issued driver's license or identification card.1The term "broker" is utilized to designate an individual that often advertises, viacustomer referrals or through published newspapers, his or her ability to obtain various forms ofaltered or fraudulent personal identification documents. Further, a broker will commonlycoordinate all arrangements with a prospective customer who is seeking to purchase suchdocuments. Typically, a broker will conduct all negotiations relative to the fees which are to bepaid by the customer.2The term "manufacturer" is utilized to designate an individual that has the knowledge andability to physically alter, produce or manufacture various forms of fraudulent personalidentification documents.3The term "courier" is utilized to designate an individual that, at the direction of a brokeror manufacturer, routinely transports customers from public transportation facilities, or otherlocations, to various locations in order to obtain passport photographs, altered and fraudulentdocuments as well as to state operated driver's license/identification card issuing facilities. Oftentimes, couriers quickly develop their own customers and essentially take on the role of a broker.4Such fraudulent bank statements, utility service statements or postmarked envelopes areutilized and commonly accepted as a means of demonstrating residency for the purposes ofobtaining a state issued driver's license or identification card. In some instances, the addressesutilized on these fraudulent proofs of residency will be valid, but often the addresses will befictitious.5
d.Commonly, brokers or couriers will advertise their ability to assist customerswith obtaining such fraudulent personal identification documents in regional or national foreignlanguage newspapers which are circulated within smaller ethnic communities.e.According to representatives of the Illinois Secretary of State, in the State ofIllinois, a foreign national may obtain a driver's license based upon presentation of a foreignpassport, social security account card, proof of residency, proof of insurance and upon successfulcompletion of the Illinois Secretary of State ("ISOS") Driver's License Written Examination and theISOS Vehicle Road Test as administered by ISOS employees at various ISOS Driver ServicesFacilities.B.Overview of the Investigation6.In approximately late 2005, the Chicago Division of the FBI and the Chicago PoliceDepartment ("CPD") initiated independent investigations into the manufacture and sale of alteredand fraudulent personal identification documents, to include passports from the PRC and socialsecurity account cards, within Chicago's Chinatown community. In approximately November of2007, these two investigations were merged into a joint investigation which also involved the IllinoisSecretary of State, Office of the Inspector General ("ISOS/OIG").7.As more fully set forth in this Affidavit, law enforcement has investigated a criminalenterprise which is involved with selling "identity sets" to predominately Chinese, Korean andIndonesian nationals who have been illegally smuggled into the U.S. An identity set essentiallyconsists of an altered PRC passport which is biographically matched to an authentic social securityaccount of a third party and also includes an authentic Illinois driver's license and/or identificationcard, also biographically matched to the PRC passport and social security card. In relation to the6
sale of these identity sets, this criminal enterprise makes extensive use of authentic social securityaccount cards which have account numbers that begin with the prefix, "586."5 Further investigationof the social security account cards utilized by this criminal enterprise has revealed that a largeportion of the cards were originally obtained, through legitimate means, by Chinese nationalstemporarily working in Saipan. Upon the return of these temporary workers to the PRC or whilesill in Saipan, their issued social security account cards were collected and transported in bulk to theU.S. for eventual use by this criminal enterprise. According to SSA-OIG, given that the originalholders of these social security account cards remain in the PRC, the illegitimate use of such cardsand their associated numbers is feasible within the U.S. without problems arising from having morethan one person utilizing a given social security account number.8.As part of this criminal enterprise's fraudulent document operation, manufacturers,to include, JUN YUN ZHANG and CO-CONSPIRATOR A, alter either counterfeit or authenticPRC passports to contain a customer's photograph as well as alter the passport's biographical pagein order to match the identity of an authentic social security account card of a third party. Afterpreparation of such documents, related brokers and couriers assist customers with using thesedocuments to fraudulently obtain Illinois driver's licenses or identification cards from various ISOSDriver Services Facilities. The following chart lists the general affiliation of brokers withmanufacturers, JUN YUN ZHANG and CO-CONSPIRATOR A:5Throughout the investigation, the Social Security Administration, Office of the InspectorGeneral ("SSA/OIG") has been consulted on numerous occasions. Based upon informationprovided by SSA/OIG, Affiant is aware that the "586" prefix is a designation indicating that thesocial security account card was issued in either American Samoa, Guam, Philippines or Saipan.Guam and Saipan are part of the Commonwealth of the Northern Mariana Islands and areconsidered U.S. territories.7
9.JUN YUN ZHANGCO-CONSPIRATOR AJUN YUE ZHANGJUN XI ZHANGJUN SHUN ZHANGDONG DONG GUOTIANSHENG ZHANGXIN LI WANGMEIZHU WANGWENYUAN ZHOUYONGHUI WANGZHAOFA WANGGUOQI ZHANGYIYI SHISONG YAN SHILI WEN HUANGRONG SIIn conjunction with assisting customers obtain Illinois driver's licenses, brokersaffiliated with this criminal enterprise provide instruction relative to an alpha-numeric memorizationscheme that will allow a non-English speaking/reading customer to be able to pass the Englishversion of the ISOS Driver's License Written Examination. This scheme is based upon having thecustomer memorize a series of rules which will allow a customer to correctly answer the multiplechoice style questions found on the ISOS Driver's License Written Examination. For example, theserules are based upon such factors as always selecting the multiple-choice answer that begins witha particular letter of the alphabet or selecting the answer that is the shortest, longest or that containsa particular number of words or letters. This memorization scheme takes into account the fact thatthere are multiple versions of the examination.10.Additionally, brokers will provide brief driving instruction to a customer infurtherance of helping the customer pass the ISOS Vehicle Road Test. However, at times, brokersaffiliated with this criminal enterprise have been able to establish relationships with several corruptISOS Public Service Representatives. Through these relationships, brokers have paid bribes to ISOSPublic Service Representatives, to include TIMOTHY JOHNSON and JAMES HOWELL among8
others, in furtherance of altering or forgoing the ISOS Vehicle Road Test.11.Upon successfully obtaining an Illinois driver's license and/or identification card, thecustomer is allowed to retain the social security account card, but has to return the PRC passport,unless additional money is paid. These returned PRC passports can then be re-used by amanufacturer in furtherance of the scheme by changing the picture and altering the biographicalpage of the passport. Typically, customers will pay between approximately 1,200 and 3,500 topurchase an identity set.12.This criminal enterprise obtains new customers through customer referrals, Chineseoperated employment agencies and driving schools as well as from advertisements which are oftenplaced in the World Journal.613.Based upon investigation, it is believed that JUN YUN ZHANG has been involved,in various capacities, with obtaining and selling fraudulent personal identification documents forapproximately the last ten years. Further, it is believed that around late 2003, JUN YUN ZHANG,CO-CONSPIRATOR A and their associated brokers began producing altered and fraudulentdocuments and selling such documents to larger numbers of customers. Between approximatelyMarch 2006 and December 2008, law enforcement conducted numerous controlled purchases ofaltered PRC passports, social security account cards and Illinois driver's license and identificationcards as arranged through JUN YUN ZHANG and various brokers. Based upon these controlledpurchases as well as other investigation, it is believed that in approximately late 2007 or early 2008,6The World Journal is a Chinese language newspaper distributed throughout the U.S. andCanada. The World Journal has regional versions to include editions published in Atlanta,Boston, Chicago, New York, San Francisco and Washington D.C., among others. The WorldJournal can also be accessed via the Internet at www.worldjournal.com.9
CO-CONSPIRATOR A became less involved in the criminal enterprise and that his/her duties weretaken over by other members.14.In September 2008, Court authorization was obtained to intercept wirecommunications of two mobile telephones utilized by JUN YUN ZHANG and QIONG ZHOU, whois a girlfriend of JUN YUN ZHANG. Pursuant to these interceptions and other investigation, it wasdetermined that in approximately the summer of 2008, JUN YUN ZHANG became concerned thathe was under law enforcement investigation and, therefore, he dramatically curtailed hisinvolvement in manufacturing and selling fraudulent personal identification documents.7 Moreover,as a result of illegally residing in the U.S., JUN YUN ZHANG made attempts to obtain legalresidency status out of fear that if he was arrested he would be deported from the U.S.15.As a result of JUN YUN ZHANG minimizi
ao 91 (rev.5/85) criminal complaint ausa, steven j. dollear (312) 353-5359 ausa, matthew madden (312) 886-2050 ausa, jessica romero (312) 353-4137 .
United States District Court District of Utah Pro Hac Vice Registration STEP 2 Enter your PACER Username and Password.Click Login. STEP 3 Click the Maintenance tab. STEP 4 Click the Attorney Admissions / E‐File Registration link. STEP 5 From the Court Type list, select U.S. District Courts.From the Court list, select Utah District Court - NextGen.
Mr.Justice Sh.Riaz Ahmed, HCJ Mr.Justice Munir A.Sheikh Mr.Justice Iftikhar Muhammad Chaudhry Mr.Justice Qazi Muhammad Farooq Mr.Justice Mian Muhammad Ajmal Mr.Justice Syed Deedar Hussain Shah Mr.Justice Hamid Ali Mirza Mr.Justice Abdul Hameed Dogar Mr.Justice Muhammad Nawaz Abbasi CONSTITUTION PETITION NO.15 OF 2002
UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO [Return to Table of Contents] I.SCOPE, PURPOSE, AND CONSTRUCTION D.C.COLO.LCivR 1.1 SCOPE OF THE LOCAL CIVIL RULES (a) Title and Citation. These rules shall be known as the Local Rules of Practice of the United States District Court for the District of Colorado - Civil. These rules
Justice David S. Wiggins Justice Daryl L. Hecht Justice Brent R. Appel Justice Thomas D. Waterman Justice Edward M. Mansfield Justice Bruce B. Zager In Memoriam Chief Justice W. Ward Reynoldson (Iowa Supreme Court 1971-1987) Justice James H. Carter (Iowa Supreme Court 1982-2006)
Table of Contents a. District 1 pg. 6 b. District 2 pg. 7 c. District 3 pg. 9 d. District 4 pg. 10 e. District 5 pg. 11 f. District 6 pg. 12 g. District 7 pg. 13 h. District 8 pg. 14 i. District 9 pg. 15 j. District 10 pg. 16 k. District 11 pg. 17 l. District 12 pg. 18 m. District 13 pg. 19 n. District 14 pg. 20
UNITED STATES OF AMERICA )) v. ) Criminal No. CR-05-86-P-H) CORDELL LOCHIN ) GOVERNMENT'S SUPPLEMENTAL SENTENCING MEMORANDUM NOW COMES the United States of America, by and through Paula D. Silsby, United States Attorney for the District of Maine, and Daniel J. Perry, Assistant United States Attorney, and
UNITED STATES BANKRUPTCY COURT EASTERN DISTRICT OF NEW YORK ECF NEWSLETTER . 14 (347) 394 "Go Live Day" January 19, 2021 . United States Bankruptcy Court . Eastern District of New York . Conrad B. Duberstein United States Bankruptcy Courthouse . 271-C Cadman Plaza East, Suite 1595 . Brooklyn, NY 11201-1800 -1700 press 6. United States .
court assignments, pooling, authorization of leave, and efficient service to the Court and litigants. Each official court reporter in this district shall prepare and submit to the Court Operations Supervisor the quarterly report AO 40A, Attendance and Transcripts of U.S. Court Reporters, listing hours and days in court and any transcript backlog.
