Kuang Hao Chou and Ling Yu Hsieh Indictment

8/7/2019 Kuang Hao Chou and Ling Yu Hsieh Indictment

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IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF VIRGINIAAlexandria Division

UNITED STATES OF AMERICA ) Criminal No. 1:11CTO?

RLEDIN OPEN COURT

KUANG HAO CHOU,Also known as Edwin Chou,LING YU HSIEH,Also known as Erica Hsieh,

Defendants.

MAR 1 7 2011

CLERK,U.S. DISTRICTCOURTALEXANDRIA, VIRGINIA

Count 1:18 U.S.C. 371 (Conspiracy toCommit ImmigrationFraud)Count 2: 18 U.S.C. 201(b)(1)(C) (Bribery

of a Public Official) and 2(Aiding andAbetting)Count 3: 18U.S.C. 1546(a)(Fraud

andMisuse of ImmigrationDocuments) and 2 (Aidingand Abetting)Count 4: 18U.S.C. 1425 (Procurement

ofCitizenship or NaturalizationUnlawfully), and 2 (AidingandAbetting)Count 5: 18U.S.C. 1030(a)(2)(B) Fraudand Related Activitywith

ComputersCount 6: 18 U.S.C. 1001 (False Statementin a SecurityClearance

Application)

INDICTMENT

March Term - At Alexandria

THE GRAND JURY CHARGES THAT:GENERAL ALLEGAT IONS

At al l t imes mater ia l to thi s indictment:

Case 1:11-cr-00144-LMB Document 1 Filed 03/17/11 Page 1 of 23


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1. Robert Schofield was a federal employee with the title ofSupervisory DistrictAdjudications Officer responsible for processing applications submitted by immigrantsrequesting adjustments to their United States immigration status. Prior to early2003,Schofield worked for the Immigration and Naturalization Service (INS). After early2003, Schofield worked for the newly formed Department ofHomeland Security (DHS)Citizenshipand ImmigrationServices (CIS).

2. Schofield,worked at the WashingtonDistrict Office located at 4420NorthFairfax Drive,Arlington, VirginiauntilNovember 2004,when the Washington DistrictOfficemoved to 2675 ProsperityAvenue,Fairfax,Virginia. Both federal governmentoffices are located within the Eastern District ofVirginia.

3. As a SupervisoryDistrict AdjudicationsOfficer, Schofield possessed aTemporary 1-551 Stampwiththe unique identificationWAS/IIO #13,whichwasassigned to him, andhad access to andusedat least threeother stamps, WAS/IIO #5, #9and#7785. ATemporary 1-551 Stampin an immigrant'spassport indicates that theimmigrant has been grantedLawful Permanent Resident(LPR)status. Someone whomaintains LPR status can also be considered a green card holder. A properly issuedTemporary 1-551 Stamppermits an immigrant to gainentryintoand remain in theUnitedStates. To obtainan LPR card or green card, an immigrant must file a Form1-485,Application to RegisterPermanent Residence or AdjustStatus, with CIS, andtheapplication mustbe properly adjudicated andapproved. To obtaina naturalizationcertificate, an immigrant must first be granted LPR status in the United States andgenerally mustmaintain that statusfor five years. The immigrant mustthen filewithCIS



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aForm N-400, Application for Naturalization, which must be properly adjudicated andapproved before a naturalization certificate may be issued.

4. Schofield was stationed at only the Washington District Office after hispromotion to aSupervisory District Adjudications Officer in 1998. The WashingtonDistrict Office only has jurisdiction to issue Advance Parole documents, Temporary I-551 Stamps, LPR cards and Naturalization Certificates to immigrant applicants residinginNorthern Virginia and Washington, D.C. Other federal offices handle immigrantsresiding in other sections ofthecountry.

5. Naturalization certificates are generated by computer within theWashingtonDistrict Office. Blank naturalization certificates aremaintained for those rare instanceswhere anerror has occurred in the computer generated certificate. These blanknaturalization certificates are prenumbered with individually assigned unique serialnumbers. A log book ismaintained to record the government employee who removes ablank certificate.

6. OnNovember 30,2006, Schofield pled guilty intheEastern District ofVirginia to Bribery ofaPublic Official and Procurement ofCitizenship or NaturalizationUnlawfully. As part ofhis plea agreement, Schofield admitted to fraudulently providingUnited States immigration documents, including naturalization certificates; Temporary I-551 stamps, which areevidence ofLPR ("green card") status; andAdvance Paroledocuments, to ineligible aliens in return forbribes. Schofield admitted thathe utilizedvarious brokers to bring the aliens to him who were willing to pay for falsely madeUnited States immigration documents.



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7. KUANG HAO CHOU a/k/a Edwin Chou is a Taiwanese national who enteredtheUnitedStateson or aboutAugust21,1996, as a nonimmigrant B-2 visitor forpleasure. CHOU obtained unlawfully issued immigration benefits from Schofield inreturn for money. CHOU used his unlawful immigration benefits to obtain a UnitedStatesPassportand to obtain jobs as a contractemployeeof the UnitedStatesDepartment of State(DOS) andUnited States government security clearances. CHOUalso brought and referred other foreign nationals to Schofield in order to obtain unlawfulimmigration benefits for these other aliens.

8. LING YU HSIEH a/k/a Erica Hsieh is a Taiwanese nat ional who entered theUnited States on or about April 11,1998, as a nonimmigrant B-2 visitor. HSIEHobtained unlawfully issued immigration benefits fromSchofield in returnformoney.HSIEH usedherunlawful immigration benefits to obtaina UnitedStatesPassport andaposition as a contractemployee of theDOS andUnited Statesgovernment securityclearances. HSIEHalso brought and referredother foreign nationals to Schofield inorder to obtain unlawful immigration benefits.

9. KUANG HAO CHOU and LING YU HSIEH are married and have beenmarried since 1991. Theyhave resided in Herndon,Virginia, within the Eastern DistrictofVirginia since 2001.

10. KUANG HAOCHOU andLING YUHSIEH used their fraudulentlyobtained United StatesNaturalizationCertificates to obtainUnitedStatesPassports. OnApril 28, 2003, CHOU applied for his United States Passport in Oakton, Virginia, withintheEastern District of Virginia. Afterreceiving his passport, CHOUsubsequently usedit



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seven times to leave andenter theUnited States on June 26 and July11,2005, July 11,2006, July 21 andAugust 13,2007,July15 andAugust, 1,2009. OnMarch 24,2005,HSIEH applied forherUnited States Passport inMerrifield, Virginia, within theEasternDistrict ofVirginia. After receiving her passport, HSIEH subsequently used it fifteentimes to leave and enter the United States on June26, July 19,December 14andDecember 24,2005, July 11,2006, July 21 and August 22,2007,February 11, March 3,December 4 andDecember15,2008, June26 andAugust 1,2009, andMarch25 andApril 8,2010.

11. KUANG HAO CHOU and LING YU HSIEH used theirfraudulentlyobtained United States Naturalization Certificates toobtain United States securityclearances and jobsworking ascontract employees with the United States Department ofState. On or about September 9,2005, CHOU submitted to the Office of PersonnelManagement (OPM) anElectronic Questionnaire for Investigations Processing (e-QIP)request number 165787, which contained aQuestionnaire for National Security Positions(SF86) in connectionwith his employmentas a contractor to the United StatesDepartment ofState. On or about September 14,2005, HSIEH submitted to the OfficeofPersonnel Management (OPM) anElectronic Questionnaire for InvestigationsProcessing (e-QIP) request number 172495, which contained a Questionnaire forNational Security Positions (SF86) in connection with heremployment as a contractor tothe United States Department of State.



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COUNT ONE

THE GRAND JURY FURTHER CHARGES THAT:

THE CONSPIRACY

1. The Grand Jury realleges and incorporates byreference the GENERALALLEGATIONS of this Indictment.

2. Between in or about April 18,1996 and August 5, 2010, in Fairfax County,Virginia, within the Eastern District ofVirginia, and elsewhere, the defendants, KUANGHAO CHOU and LING YU HSIEH, and others known and unknown to the Grand Jury,did unlawfully and knowingly combine, conspire, confederate and agree together andwith others known and unknown to the Grand Jury to commit the following offensesagainst the United States:

a) to knowingly forge, counterfeit and falsely make and utter, use, attempt to use,possess, obtain, accept and receive documents prescribed by statute and regulation forentry into and authorized stay in the United States, to wit, Temporary 1-551 Stampsplaced by Schofield in aliens' passports to permit those aliens to enter the United States,falsely reflecting Lawful Permanent Residence status intheUnited States aswell asUnited States passports obtained using naturalized United States citizenship statusknowing them to have been falsely made, to have been procured bymeans ofany falseclaim or statement, and otherwise procured by fraud and unlawfully obtained, a violationofTitle 18, United States Code, Section 1546(a);

b) to directly and indirectly, corruptly give, offer, and promise a thing ofvalue toSchofield, a senior public official, to induce such public official to do and omit todoan



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act in violation ofhis official duties, aviolation ofTitle 18, United States Code, Section201(b)(1)(C);

(c) to knowingly procure and obtain and attempt to procure and obtainnaturalization and citizenship and a certificate ofnaturalization for aliens not entitledthereto, in violation of Title 18, United States Code, Section 1425 (b).

MANNER AND MEANS OF THE CONSPIRACYThe purpose ofthe conspiracy was to acquire unlawfully issued immigration benefits and

to make money by permitting illegal aliens to come to, enter and reside in the United States byobtaining and providing them with an Temporary 1-551 Stamp, LPR card and NaturalizationCertificate, each ofwhich were falsely and fraudulently made. The manner and means by whichthe conspirators conducted the conspiracy included the following:

1. Itwas part of the conspiracy that the defendants, KUANG HAO CHOU and LINGYU HSIEH, and others known and unknown to the Grand Jury, acted as customers and brokers,obtaining immigration benefits to which they were not entitled for themselves and others whowere interested in obtaining and paying for Temporary 1-551 Stamps, LPR cards, NaturalizationCertificates, and United States Passports, collecting money from the illegal aliens, obtainingtheir foreign passport, photographs and personal information and providing these items to thecorrupt government official, Schofield.

2. Itwas further a part of the conspiracy that the brokers and others known andunknown to the Grand Jury translated the instructions and directions received fromSchofield and communicated these instructions and directions to the illegal aliens.



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3. It was further apart ofthe conspiracy that the defendants KUANG HAO CHOU andLING YU HSIEH, and others known and unknown to the Grand Jury, often accompanied theillegal aliens to the government office ofSchofield to facilitate obtaining EmploymentAuthorization and the placement ofthe falsely and fraudulently made Temporary 1-551 stamp inthe illegal alien's foreign passport.

4. It was further a part ofthe conspiracy that the defendants and others known andunknown to the Grand Jury remained in regular contact by telephone, mail, courier, the internetandby regular meetings.

5. Itwas further apart ofthe conspiracy that the defendants and others known andunknown to the Grand Jury collected money from each illegal alien and paid the coconspiratorsfrom these collected funds.

6. It was further part ofthe conspiracy that KUANG HAO CHOU and LING YUHSIEH used their addresses on immigration applications for individuals they brought or referredto Schofield, although the individuals did not reside with them but instead lived outside Virginia.

7. It was further part of the conspiracy that Schofield would issue EmploymentAuthorization, Temporary 1-551 Stamps, aLPR card andNaturalization Certificates to aliens notentitled to such immigration benefits and disguise this false and fraudulent issuance by eithercreating an "empty jacket" using an immigration file number that has never been assigned ordeleting any record of the alien and entering into the Central Index System's database an entryindicating the alien's file had been lost. By disguising his activities Schofield permitted theillegal aliens to avoid detection and allowed himselfand his coconspirators to profit from theissuance of illegal immigration documents.



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OVERT ACTS

In furtherance ofthe said conspiracy andto effect theobjects thereof, thedefendants andotherconspirators committed the following overtacts in the Eastern District ofVirginia and elsewhere, including, butnot limited to, the following:

1. Onor about April 18,1996, an individual known to thegrand jurywho acted as abrokerfor Schofield providedbiographic information aboutCHOU to Schofield in order tofacilitate the improper issuance of immigration benefits toCHOU in return for money.

2. Onor about August 29, 1996, CHOU received anEmployment AuthorizationDocument (also referred to as awork permit), valid for one year, fraudulently issued bySchofield. CHOU received this document at the INSWashington District Office in Arlington,Virginia, within the Eastern District ofVirginia. CHOU received this document, bearing alienregistration number A74 864 615, despite being ineligible to receive it. On orabout September1,1996, CHOU departed the United States and returned to Taiwan.

3. In orabout October 1996, CHOU referred T.S.L. to an individual known to the grandjury who acted as a broker for Schofield.

4. On orabout November 29,1996, CHOU received aTemporary 1-551 stamp,WAS#7785, inhis Taiwanese passport, valid for one year, fraudulently issued by Schofield.This stamp, referencing alien registration number A74 864 615, was purported evidence ofLPRstatus, although USCIS databases andCHOU's alien file (A file) reflect thatCHOU never filed aform 1-485, Application toRegister Permanent Residence orAdjust Status, which would havehad tobeproperly filed and adjudicated inorder for CHOU to legitimately obtain LPR status.CHOU also obtained from Schofield a Temporary 1-551 stamp, WAS#7785, intheTaiwanese



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passport ofhis minor son, C.C.C, despite knowing that his son was ineligible for aTemporary I-551 stamp.

5. On orabout January 6, 1997, CHOU received anLPR card (also referred to as a"green card"), bearing alien registration number A74 864 615, that Schofield fraudulently causedto be issued. CHOU obtained this card, purported evidence of LPR status, despite never havingapplied for LPR status and despite being ineligible for LPR status. CHOU also obtained anLPRcard for his minor son, C.C.C.

6. Inor about February 1997, CHOU referred W.M.L. to an individual known to thegrandjury who acted as a broker for Schofield.

7. On or about March 11, 1997, T.S.L. received aTemporary 1-551 stamp in hisTaiwanese passport, valid for one year, fraudulently issued by Schofield. This stamp,referencing alien registration numberA74 864 614, was purported evidence ofLPR status,although USCIS databases and T.S.L.'sAfile reflect that T.S.L. never filed a form 1-485,Application toRegister Permanent Residence orAdjust Status, which would have had to beproperly filed and adjudicated inorder for T.S.L. to legitimately obtain LPR status. T.S.L.'s Afile contains an incomplete and unadjudicated ETA 750, Application for Alien EmploymentCertification, reflecting CHOU's address at that time, 1012 Aponi Road SE, Vienna, Virginia22180.

8. On or about December 23,1998, HSIEH received aTemporary 1-551 stamp,WAS#7785, in herTaiwanese passport, valid for one year, fraudulently issued by Schofield.This stamp, referencing alien registration number A74 359 948, was purported evidence ofLPRstatus, although USCIS databases and HSIEH's Afile reflect no record ofHSIEH's adjustment

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of status from temporary visitor to LPR. HSIEH was issued alien registration number (A-number) A74 359 948 by Schofield, but there is no record of this A-number in USCIS systems.In HSIEH's administrative file maintained by USCIS, there is an un-adjudicated Form 1-485,Application to Register Permanent Residence or Adjust Status, which must be adjudicated inorder to obtain an LPR card.

9. In or about 1998, HSIEH offered to help Y.C.C. and Y.C.C.'s minor children obtainLPR status in the United States. HSIEH and CHOU subsequently made arrangements withSchofield to obtain unlawfully issued immigration benefits for Y.C.C. and Y.C.C.'s children.

10. On or about December 23, 1999, HSIEH received aTemporary 1-551 stamp,WAS#7785, in her Taiwanese passport, valid for one year, fraudulently issued by Schofield.This stamp, referencing alien registration number A74 359 948, was purported evidence ofLPRstatus, although USCIS databases and HSIEH'sAfile reflect that HSIEH was never an LPR andwas ineligible for LPR status.

11. On or about December 15,2000, HSIEH received aTemporary 1-551 stamp,WAS#7785, in her Taiwanese passport, valid for one year, fraudulently issued by Schofield.This stamp, referencing alien registration number A74 359 948, was purported evidence ofLPRstatus, although USCIS databases and HSIEH's Afile reflect that HSIEH was never an LPR andwas ineligible for LPR status.

12. On or about November 5, 2001, CHOU submitted aform N-400, Application forNaturalization, to USCIS. This application was submitted to the USCIS Vermont Service Centerwhich subsequently forwarded it to the USCIS Washington District Office for adjudication. Onthe Application for Naturalization, CHOU falsely represented himself to be aLPR. CHOU

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presented his authentic but falsely-obtained LPR card as evidence ofhis LPR status. By doingso, CHOU was able to apply for naturalization. Schofield had personally retained CHOU'soriginal administrative file containing all the documentary proofofCHOU's immigration statusand the lack ofthe appropriate application and review process. Therefore, the file was displayedas"lost"in immigration databases. OnCHOU's Application forNaturalization, CHOU marked"no" inresponse to the question, "Have you ever given false testimony for the purpose ofobtaining any immigrationbenefit?"

13. On orabout December 12,2001, HSIEH received aTemporary 1-551 stamp,WAS/IIO#9, in her Taiwanese passport, valid for one year, fraudulently issued by Schofield.This stamp, referencing alien registration number A74 359 948, was purported evidence ofLPRstatus, although USCIS databases andHSIEH'sA file reflect thatHSIEH was neveran LPRandwas ineligible for LPR status.

14. Inor about February 2002, HSIEH and CHOU arranged forY.C.C. to send Y.C.C.'sTaiwanese passport to HSIEH and CHOU in Virginia. HSIEH and CHOU brought the passportto Schofield.

15. On orabout February 8,2002, Schofield placed a fraudulently issued Temporary I-551 stamp, WAS/IIO#5, inY.C.C.'s Taiwanese passport, valid for one year. This stamp waspurported evidence of LPRstatus,although USCIS databases andY.C.C.'s A filereflectthatY.C.C. was never an LPR and was ineligible for LPR status. Schofield gave the passport ofY.C.C. toHSIEH and CHOU who mailed thepassport back to Y.C.C.

16. Onor aboutSeptember 25, 2002, CHOU appeared foran interview at theUSCISWashington District Office regarding his Application for Naturalization. During the interview,

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CHOU represented himself to be an LPR and failed to disclose that he had obtained his LPRstatus by paying a bribe to Schofield.

17. On or about November 14,2002, CHOU obtained United States Certificate ofNaturalization number 27429719 at the Washington District Office in Arlington, Virginia, withinthe EasternDistrict of Virginia.

18. Inor about January 2003, HSIEH and CHOU arranged forY.C.C. to send theTaiwanese passports ofY.C.C. and her son, W.H.W., to HSIEH and CHOU in Virginia. HSIEHand CHOUbrought the passports to Schofield.

19. On orabout January 29,2003, Schofield placed fraudulently issued Temporary 1-551stamps, WAS/IIO#13, in the Taiwanese passports ofY.C.C. and W.H.W. These stamps, whichwere valid for one year, were purported evidence ofLPR status, although USCIS databases andtheAfiles ofY.C.C. and W.H.W. reflect that neither Y.C.C. norW.H.W. were LPR's or eligibleforLPRstatus. Schofield gave the passports toHSIEH andCHOU whomailed thembacktoY.C.C.

20. On or about January 29, 2003, Schofield also placed aTemporary 1-551 stamp,WAS/IIO#13, valid for one year, in HSIEH's Taiwanese passport. This stamp, referencing alienregistration number A74 359 948, was purported evidence ofLPR status, although USCISdatabases and HSIEH's Afile reflect that HSIEH was never an LPR and was ineligible for LPRs tatus .

21. Inor about January 2004, HSIEH and CHOU arranged forY.C.C. to send theTaiwanese passports ofY.C.C. and W.H.W. toHSIEH and CHOU inVirginia. HSIEH andCHOU brought the passports to Schofield.

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22. On or about January 16, 2004, Schofield placed fraudulently issued Temporary 1-551stamps, WAS/IIO#13, in the Taiwanese passports of Y.C.C and W.H.W. These stamps, whichwere valid for one year, were purported evidence ofLPR status, although USCIS databases andtheAfiles ofY.C.C andW.H.W. reflect that neither Y.C.C. norW.H.W. were LPR's or eligiblefor LPR status. Schofield gave the passports to HSIEH and CHOU who mailed them back toY.C.C.

23. On or about January 16, 2004, Schofield also placed aTemporary 1-551 stamp,WAS/IIO#13, valid for one year, in HSIEH's Taiwanese passport. This stamp, referencing alienregistration number A74 359 948, was purported evidence ofLPR status, although USCISdatabases and HSIEH'sAfile reflect that HSIEH was never an LPR and was ineligible for LPRs ta tus .

24. In or about January 2005, HSIEH and CHOU arranged for Y.C.C to send theTaiwanese passports ofY.C.C,W.H.W., and Y.C.C.'s daughter, S.S.C, to HSIEH and CHOUin Virginia. HSIEH and CHOU brought the passports to Schofield.

25. On or about January 10, 2005, Schofield placed fraudulently issued Temporary 1-551stamps, WAS/IIO#13, in the Taiwanese passports of Y.C.C, W.H.W., and S.S.C. These stamps,which were valid for one year, were purported evidence ofLPR status, although USCISdatabases and theAfiles of Y.C.C, W.H.W., and S.S.C. reflect that none were LPR's or eligiblefor LPR status. Schofield gave the passports to HSIEH and CHOU who mailed them back toY.C.C.

26. On or about January 10,2005, Schofield also placed aTemporary 1-551 stamp,WAS/IIO#13, valid for one year, in HSIEH's Taiwanese passport. This stamp, referencing alien

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registration number A74 359 948, was purported evidence ofLPR status, although USCISdatabases and HSIEH'sAfile reflect that HSIEH was never an LPR and was ineligible for LPRs ta tus .

27. On or about March 24,2005, HSIEH received United States Certificate ofNaturalization number 28614969, affixed with alien registration number A74 359 948 in theWashington District Office ofUSCIS, located within the Eastern District ofVirginia. USCISrecord checks revealed that United States Certificate ofNaturalization number 28614969 did notexist in their database. In HSIEH's administrative file maintained by USCIS, there is not an N-400 (Application for Naturalization) form, which must be completed, signed, and adjudicated inorder to obtain naturalization. Additionally, Lawful Permanent Residence in the United States isarequirement for U.S. citizenship, though there is no record ofHSIEH having been an LPR.Schofield issued afalsely-made naturalization certificate to HSIEH, who never was an LPR,never took the naturalization test, and never applied for U.S. citizenship.

28. In or about 2005, CHOU contacted Y.C.C and told Y.C.C. to bring approximately$8,000 cash to an interview with Schofield in Virginia. CHOU brought Y.C.C to the interviewwith Schofield. Y.C.C did as instructed by CHOU and paid the money to Schofield at theinterview.

29. On or about April 13,2005, Schofield issued Y.C.C United States Certificate ofNaturalization number 28614975, affixed with alien registration number A77 511 458 in theWashington District Office ofUSCIS, located within the Eastern District ofVirginia. USCISrecord checks revealed that United States Certificate ofNaturalization number 28614975 doesnot exist in their database. In Y.C.C.'s administrative file maintained by USCIS, there is not an

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N-400 (Application for Naturalization) form, which must be completed, signed, and adjudicatedin order to obtain naturalization. Additionally, Lawful Permanent Residence in the United Statesis arequirement for U.S. citizenship, though there is no record of Y.C.C. having been an LPR.Schofield issued afalsely-made naturalization certificate to Y.C.C, who never was an LPR,never took the naturalization test, and never applied for U.S. citizenship.

30. On or about May 1,2006, Schofield issued W.H.W. United States Certificate ofCitizenship number A2222325, affixed with alien registration number A78 148 067, in theWashington District Office of USCIS, located within the Eastern District of Virginia.Certificates ofCitizenship are issued to individuals who derive United States citizenship throughaparent. USCIS record checks revealed that Certificate ofCitizenship number A2222325 doesnot exist in their database. W.H.W.'s administrative file maintained by USCIS contains aFormN-600, Application for Certificate of Citizenship, purportedly based on the U.S. citizenship ofhis mother, Y.C.C, that was not properly filed or adjudicated. W.H.W. was not eligible toreceive aCertificate ofCitizenship because his mother was not aU.S. citizen. The N-600 listsW.H.W.'s address as 2725 Robaleed Way, Herndon, VA, which is not the address ofW.H.W.but is the addressofHSIEHand CHOU.

31. On or about May 1,2006, Schofield issued S.S.C. United StatesCertificate ofCitizenship number A2222322, affixed with alien registration number A78 148 068, in theWashington District Office ofUSCIS, located within the Eastern District ofVirginia. USCISrecord checks revealed that United States Certificate ofCitizenship number A2222322 does notexist in their database. S.S.C's administrative file maintained by USCIS contains aForm N-600, Application for Certificate of Citizenship, purportedly based on the U.S. citizenship of her

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mother, Y.C.C, thatwas notproperly filed or adjudicated. S.S.C. wasnot eligible to receive aCertificate ofCitizenship because her mother was not a U.S. citizen. The N-600 lists S.S.C'saddress as 2725 Robaleed Way,Herndon, VA, which is not the address ofS.S.C. but is theaddress o fHSIEH and CHOU .

(Inviolation of Title 18,United StatesCode, Section371.)

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COUNT T W O

THE GRAND JURYFURTHERCHARGES THAT:

1. The Grand Jury realleges and incorporates the GENERAL ALLEGATIONS ofthisindictment.

2. Between on or about April 18, 1996 and November 30, 2006, in Fairfax County,Virginia, within the Eastern District ofVirginia, and elsewhere, the defendants, KUANG HAOCHOU and LING YU HSIEH, and others known and unknown to the Grand Jury, did directlyand indirectly, knowingly and unlawfully corruptly, give, offer, and promise athing ofvalue, toSchofield, at that time asenior public official, that is aSupervisory District AdjudicationsOfficer, in return for being induced to do and omit to do an act in violation of his official duties,that is, Schofield, in return for apromised payment and service, violated his official duties in thathe did falsely and fraudulently make, issue and provide aliens with Employment Authorizationdocuments, Temporary 1-551 Stamps, LPR status, and Naturalization Certificates to which theywere not entitled nor authorized to receive, based upon fraudulent, incomplete or nonexistentimmigrant applications, and by deleting any record of such actions on the government'scomputers, creating empty jackets utilizing alien numbers never issued, and by utilizing meansto disguise the defendant's unlawful actions.

(In violation of 18 United States Code, Sections 201(b)(2)(C) and 2.)

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COUNT THREE

THE GRAND JURY FURTHER CHARGES THAT:1. The Grand Jury realleges and incorporates the GENERAL ALLEGATIONS of this

indictment.

2. Between on or about April 18,1996 and April 8,2010, in Fairfax County,Virginia, within the Eastern District ofVirginia, and elsewhere, the defendants, KUANG HAOCHOU and LING YU HSIEH, and others known and unknown to the Grand Jury, did unlawfullyand knowingly falsely make, utter, use, attempt to use, possess, obtain, accept and receivedocuments and stamps prescribed by statute and regulation for entry into and authorized stay inthe United States, to wit, Temporary 1-551 Stamps in alien passports falsely reflecting LawfulPermanent Residence status in the United States, Lawful Permanent Residence cards and UnitedStates passports obtained using United States Naturalization Certificates, knowing them to havebeen falsely made, to have been procured by means ofany false claim or statement, andotherwise procured by fraud and unlawfully obtained.

(In violation ofTitle 18, United States Code, Sections 1546(a) and 2.)

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COUNT FOUR


1. The Grand Jury realleges and incorporates the GENERAL ALLEGATIONS ofthisindictment.

2. Between on or about April 18,1996 and November 30,2006, in Fairfax County,Virginia, within the Eastern District ofVirginia, and elsewhere, the defendants, KUANG HAOCHOU and LING YU HSIEH, and others known and unknown to the Grand Jury, did unlawfullyand knowingly, issue, procure, obtain and apply for and otherwise attempt to procure and obtainand apply for naturalization for aliens not entitled to Naturalization Certificates by creating falseapplications and false immigration files and no file at all in order to issue, procure and obtainnaturalized United States citizenship status knowing such status to have been falsely made, tohave been procured by means of any false claim or statement, and otherwise procured by fraudand unlawfully obtained. The Grand Jury realleges the five falsely and fraudulently madeNaturalization Certificates identified in Count One, including the certificates ofnaturalization,number 27429719 issued on or about November 14,2002, in the name ofKUANG HAO CHOU,also known as Edwin Chou, to which CHOU was not entitled and number 28614969 issued on orabout March 24,2005, in the name of LING YU HSIEH, also known as Erica Hsieh, to whichHSIEH was not entitled.

(In violation ofTitle 18, United States Code, Sections 1425(b) and 2.)

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COUNT FIVE


1. The Grand Jury realleges and incorporates the GENERAL ALLEGATIONS of thisindictment.

2. Between onoraboutApril 8,2010 andNovember 16, 2010, inHerndon, Virginia,within the Eastern District of Virginia, andelsewhere, the defendant, KUANG HAOCHOU,knowingly and intentionally accessed a computer without authorization and exceeded hisauthorized access andthereafter obtained information froma department and agency of theUnited States, to wit: CHOU accessed theUnited States Department of StateeMED databasewithout authorization and exceeding his authorized access andobtained information relating toapproximately250,000or moreUnited States DepartmentofState and other United Statesgovernment employees.

(In violation ofTitle 18United States Code 1030(a)(2)(B).)

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COUNT SIX


1. The Grand Jury realleges and incorporatesthe GENERALALLEGATIONS of thisindictment.

2. Onor about August 5,2010, in Herndon,Virginia,within the Eastern DistrictofVirginia, and elsewhere, the defendant, KUANG HAO CHOU, inamatter within the jurisdictionofthe Executive Branch of the Government of the United States, that is the Social SecurityAdministration and theDepartment of State, did knowingly, unlawfully and willfully make amaterially false, fictitious and fraudulent statement and representation, to wit: CHOU claimed tobe lawfully naturalized United States citizens when CHOU sought to renew his securityclearance he originally obtained towork as a contractor for the United States Department ofState,in orderto workwith the Social Security Administration, when in truthand in fact, asCHOU thenand therewell knewhe had paida bribefor his immigration benefits andwas noteligible to obtain oruse a security clearance inSeptember 9,2005, nor to renew itonAugust 5,2010. On or about August 5,2010, CHOUsubmitteda Questionnaire for Non-Sensitive

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Positions and a Declaration for Federal Employment submitted to the United States Office ofPersonnel Management to maintain his security clearance and reaffirming his false statement andrepresentation concerning his immigration status.

(In violation ofTitle 18, United States Code, Section 1001.)

A TRUE BILL:Pun&tartt to the F-Govemmcni Acitheoriginalof this pagehas been fi'-.iunder seal in the Cleik' Oflfc-;.FOREPERSON

By:

Neil H. MacBrideUnited States Attorney

Ronald L. Walutes, Jr.AssistantUnited States^Cttorney

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Kuang Hao Chou and Ling Yu Hsieh Indictment

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Transcript of Kuang Hao Chou and Ling Yu Hsieh Indictment