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IN THE UNITED STATES DISTRICT COURT

RLED IN OPEN COURT

FOR THE EASTERN DISTRICT OF VIRGINIA
Alexandria Division

MAR 1 7 2011
CLERK, U.S. DISTRICT COURT ALEXANDRIA, VIRGINIA

UNITED STATES OF AMERICA

)

Criminal No. 1:11CTO?

Count 1:18 U.S.C. § 371 (Conspiracy to
Commit Immigration Fraud)
KUANG HAO CHOU,

Also known as Edwin Chou,
LING YU HSIEH, Also known as Erica Hsieh,

Count 2: 18 U.S.C. § 201(b)(1)(C) (Bribery
of a Public Official) and §2 (Aiding and Abetting) Count 3: 18 U.S.C. §1546(a) (Fraud and Misuse of Immigration Documents) and §2 (Aiding and Abetting) Count 4: 18 U.S.C. §1425 (Procurement of Citizenship or Naturalization Unlawfully), and §2 (Aiding and Abetting)

Defendants.

Count 5: 18 U.S.C. §1030(a)(2)(B) Fraud and Related Activity with
Computers

Count 6: 18 U.S.C. §1001 (False Statement in a Security Clearance
Application)

INDICTMENT

March Term - At Alexandria

THE GRAND JURY CHARGES THAT:
GENERAL ALLEGATIONS

At all times material to this indictment:

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1. Robert Schofield was a federal employee with the title of Supervisory District

Adjudications Officer responsible for processing applications submitted by immigrants
requesting adjustments to their United States immigration status. Prior to early2003,
Schofield worked for the Immigration and Naturalization Service (INS). After early 2003, Schofield worked for the newly formed Department of Homeland Security (DHS)

Citizenship and Immigration Services (CIS). 2. Schofield, worked at the Washington District Office located at 4420 North

Fairfax Drive, Arlington, Virginia until November 2004, when the Washington District
Office moved to 2675 Prosperity Avenue, Fairfax, Virginia. Both federal government
offices are located within the Eastern District of Virginia.

3. As a Supervisory District Adjudications Officer, Schofield possessed a

Temporary 1-551 Stampwith the unique identification WAS/IIO #13, which was assigned to him, and had access to and used at least three other stamps, WAS/IIO #5, #9 and #7785. A Temporary 1-551 Stampin an immigrant's passport indicates that the
immigrant has been granted Lawful Permanent Resident (LPR) status. Someone who
maintains LPR status can also be considered a green card holder. A properly issued

Temporary 1-551 Stamp permits an immigrant to gain entry into and remain in the United
States. To obtain an LPR card or green card, an immigrant must file a Form 1-485,

Application to Register Permanent Residence or Adjust Status, with CIS, and the

application must be properly adjudicated and approved. To obtain a naturalization
certificate, an immigrant must first be granted LPR status in the United States and

generally must maintain that status for five years. The immigrant must then file with CIS

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a Form N-400, Application for Naturalization, which must be properly adjudicated and
approved before a naturalization certificate may be issued.

4. Schofield was stationed at only the Washington District Office after his

promotion to a Supervisory District Adjudications Officer in 1998. The Washington

District Office only has jurisdiction to issue Advance Parole documents, Temporary I551 Stamps, LPR cards and Naturalization Certificates to immigrant applicants residing

in Northern Virginia and Washington, D.C. Other federal offices handle immigrants
residing in other sections of the country.

5. Naturalization certificates are generated by computer within the Washington
District Office. Blank naturalization certificates are maintained for those rare instances

where anerror has occurred in the computer generated certificate. These blank

naturalization certificates are prenumbered with individually assigned unique serial
numbers. Alog book ismaintained to record the government employee who removes a
blank certificate.

6. OnNovember 30,2006, Schofield pled guilty in the Eastern District of

Virginia to Bribery ofa Public Official and Procurement ofCitizenship or Naturalization

Unlawfully. As part ofhis plea agreement, Schofield admitted to fraudulently providing United States immigration documents, including naturalization certificates; Temporary I551 stamps, which are evidence of LPR ("green card") status; and Advance Parole documents, to ineligible aliens in return for bribes. Schofield admitted that he utilized

various brokers to bring the aliens to him who were willing to pay for falsely made
United States immigration documents.

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7. KUANG HAO CHOU a/k/a Edwin Chou is a Taiwanese national who entered

the United States on or about August 21,1996, as a nonimmigrant B-2 visitor for
pleasure. CHOU obtained unlawfully issued immigration benefits from Schofield in return for money. CHOU used his unlawful immigration benefits to obtain a United

States Passport and to obtain jobs as a contract employee of the United States

Department of State (DOS) and United States government security clearances. CHOU
also brought and referred other foreign nationals to Schofield in order to obtain unlawful immigration benefits for these other aliens.
8. LING YU HSIEH a/k/a Erica Hsieh is a Taiwanese national who entered the

United States on or about April 11,1998, as a nonimmigrant B-2 visitor. HSIEH

obtained unlawfully issued immigration benefits from Schofield in return for money. HSIEH used her unlawful immigration benefits to obtain a United States Passport and a position as a contractemployee of the DOS and United States government security
clearances. HSIEH also brought and referred other foreign nationals to Schofield in
order to obtain unlawful immigration benefits.
9. KUANG HAO CHOU and LING YU HSIEH are married and have been

married since 1991. They have resided in Herndon, Virginia, within the Eastern District
of Virginia since 2001.

10. KUANG HAO CHOU and LING YU HSIEH used their fraudulently obtained United StatesNaturalization Certificates to obtain United States Passports. On
April 28, 2003, CHOU applied for his United States Passport in Oakton, Virginia, within

the Eastern District of Virginia. After receiving his passport, CHOU subsequently used it

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seven times to leave and enter the United States on June 26 and July 11,2005, July 11, 2006, July 21 andAugust 13,2007,July 15 andAugust, 1,2009. On March 24,2005, HSIEH applied for her United States Passport in Merrifield, Virginia, within the Eastern

District of Virginia. After receiving her passport, HSIEH subsequently used it fifteen
times to leave and enter the United States on June 26, July 19, December 14 and

December 24,2005, July 11,2006, July 21 and August 22,2007, February 11, March 3,
December 4 and December 15,2008, June 26 and August 1, 2009, and March 25 and
April 8,2010.

11. KUANG HAO CHOU and LING YU HSIEH used theirfraudulently

obtained United States Naturalization Certificates to obtain United States security
clearances and jobsworking as contract employees with the United States Department of
State. On or about September 9,2005, CHOU submitted to the Office of Personnel

Management (OPM) an Electronic Questionnaire for Investigations Processing (e-QIP) request number 165787, which contained a Questionnaire for National Security Positions
(SF86) in connection with his employment as a contractor to the United States
Department of State. On or about September 14,2005, HSIEH submitted to the Office

of Personnel Management (OPM) an Electronic Questionnaire for Investigations
Processing (e-QIP) request number 172495, which contained a Questionnaire for

National Security Positions (SF86) in connection with heremployment as a contractor to
the 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 GENERAL
ALLEGATIONS 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, KUANG

HAO CHOU and LING YU HSIEH, and others known and unknown to the Grand Jury,
did unlawfully and knowingly combine, conspire, confederate and agree together and

with others known and unknown to the Grand Jury to commit the following offenses
against 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 for

entry into and authorized stay in the United States, to wit, Temporary 1-551 Stamps

placed by Schofield in aliens' passports to permit those aliens to enter the United States,
falsely reflecting Lawful Permanent Residence status in the United States as well as

United States passports obtained using naturalized United States citizenship status knowing them to have been falsely made, to have been procured by means ofany false
claim or statement, and otherwise procured by fraud and unlawfully obtained, a violation
ofTitle 18, United States Code, Section 1546(a);

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

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act in violation ofhis official duties, a violation ofTitle 18, United States Code, Section
201(b)(1)(C);

(c) to knowingly procure and obtain and attempt to procure and obtain
naturalization and citizenship and a certificate of naturalization for aliens not entitled

thereto, in violation of Title 18, United States Code, Section 1425 (b).
MANNER AND MEANS OF THE CONSPIRACY

The 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 by
obtaining and providing them with an Temporary 1-551 Stamp, LPR card and Naturalization

Certificate, each of which were falsely and fraudulently made. The manner and means by which
the conspirators conducted the conspiracy included the following:
1. It was part of the conspiracy that the defendants, KUANG HAO CHOU and LING

YU 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 who

were interested in obtaining and paying for Temporary 1-551 Stamps, LPR cards, Naturalization

Certificates, and United States Passports, collecting money from the illegal aliens, obtaining
their foreign passport, photographs and personal information and providing these items to the
corrupt government official, Schofield.

2. It was further a part of the conspiracy that the brokers and others known and unknown to the Grand Jury translated the instructions and directions received from

Schofield 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 and

LING YU HSIEH, and others known and unknown to the Grand Jury, often accompanied the

illegal aliens to the government office of Schofield to facilitate obtaining Employment

Authorization and the placement ofthe falsely and fraudulently made Temporary 1-551 stamp in
the illegal alien's foreign passport.

4. It was further a part ofthe conspiracy that the defendants and others known and

unknown to the Grand Jury remained in regular contact by telephone, mail, courier, the internet
and by regular meetings.

5. Itwas further apart ofthe conspiracy that the defendants and others known and

unknown to the Grand Jury collected money from each illegal alien and paid the coconspirators
from these collected funds.

6.

It was further part ofthe conspiracy that KUANG HAO CHOU and LING YU

HSIEH used their addresses on immigration applications for individuals they brought or referred

to Schofield, although the individuals did not reside with them but instead lived outside Virginia.
7. It was further part ofthe conspiracy that Schofield would issue Employment
Authorization, Temporary 1-551 Stamps, a LPR card and Naturalization Certificates to aliens not

entitled to such immigration benefits and disguise this false and fraudulent issuance by either

creating an "empty jacket" using an immigration file number that has never been assigned or

deleting any record ofthe alien and entering into the Central Index System's database an entry
indicating the alien's file had been lost. By disguising his activities Schofield permitted the
illegal aliens to avoid detection and allowed himself and his coconspirators to profit from the
issuance of illegal immigration documents.

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OVERT ACTS

In furtherance of the said conspiracy and to effect the objects thereof, the
defendants and otherconspirators committed the following overtacts in the Eastern District of

Virginia and elsewhere, including, but not limited to, the following:
1. Onor about April 18,1996, an individual known to the grand jury who acted as a
broker for Schofield provided biographic information about CHOU to Schofield in order to

facilitate the improper issuance of immigration benefits to CHOU inreturn for money.
2. On or about August 29, 1996, CHOU received an Employment Authorization

Document (also referred to as a work permit), valid for one year, fraudulently issued by

Schofield. CHOU received this document atthe INS Washington District Office in Arlington,

Virginia, within the Eastern District ofVirginia. CHOU received this document, bearing alien
registration number A74 864 615, despite being ineligible to receive it. On or about September
1,1996, 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 grand
jury who acted as a broker for Schofield.

4. On orabout November 29,1996, CHOU received a Temporary 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 of LPR
status, although USCIS databases and CHOU's alien file (A file) reflect that CHOU never filed a

form 1-485, Application to Register Permanent Residence or Adjust Status, which would have had to beproperly filed and adjudicated in order for CHOU to legitimately obtain LPR status.
CHOU also obtained from Schofield a Temporary 1-551 stamp, WAS#7785, in theTaiwanese

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passport ofhis minor son, C.C.C, despite knowing that his son was ineligible for aTemporary I551 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 caused

to be issued. CHOU obtained this card, purported evidence of LPR status, despite never having
applied for LPR status and despite being ineligible for LPR status. CHOU also obtained an LPR
card for his minor son, C.C.C.

6. In or about February 1997, CHOU referred W.M.L. to an individual known to the
grand jury who acted as a broker for Schofield.

7. On or about March 11, 1997, T.S.L. received a Temporary 1-551 stamp in his

Taiwanese passport, valid for one year, fraudulently issued by Schofield. This stamp,
referencing alien registration number A74 864 614, was purported evidence ofLPR status,

although USCIS databases and T.S.L.'s Afile reflect that T.S.L. never filed aform 1-485,
Application to Register Permanent Residence or Adjust Status, which would have had to be

properly filed and adjudicated in order for T.S.L. to legitimately obtain LPR status. T.S.L.'s A

file contains an incomplete and unadjudicated ETA 750, Application for Alien Employment Certification, reflecting CHOU's address at that time, 1012 Aponi Road SE, Vienna, Virginia
22180.

8. On or about December 23,1998, 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 ofLPR

status, although USCIS databases and HSIEH's Afile reflect no record ofHSIEH's adjustment

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ofstatus from temporary visitor to LPR. HSIEH was issued alien registration number (Anumber) A74 359 948 by Schofield, but there is no record ofthis 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 in
order to obtain an LPR card.

9. In or about 1998, HSIEH offered to help Y.C.C. and Y.C.C.'s minor children obtain

LPR status in the United States. HSIEH and CHOU subsequently made arrangements with
Schofield 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 ofLPR
status, although USCIS databases and HSIEH's Afile reflect that HSIEH was never an LPR and
was 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 of LPR
status, although USCIS databases and HSIEH's Afile reflect that HSIEH was never an LPR and
was ineligible for LPR status.

12. On or about November 5, 2001, CHOU submitted aform N-400, Application for
Naturalization, to USCIS. This application was submitted to the USCIS Vermont Service Center

which subsequently forwarded it to the USCIS Washington District Office for adjudication. On
the Application for Naturalization, CHOU falsely represented himselfto be aLPR. CHOU

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presented his authentic but falsely-obtained LPR card as evidence of his LPR status. By doing
so, CHOU was able to apply for naturalization. Schofield had personally retained CHOU's

original administrative file containing all the documentary proofof CHOU's immigration status

and the lack ofthe appropriate application and review process. Therefore, the file was displayed
as "lost" in immigration databases. On CHOU's Application for Naturalization, CHOU marked

"no" inresponse to the question, "Have you ever given false testimony for the purpose of
obtaining any immigration benefit?"

13. On orabout December 12,2001, HSIEH received a Temporary 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 ofLPR
status, although USCIS databases and HSIEH's A file reflect that HSIEH was neveran LPR and
was ineligible for LPR status.

14. In or about February 2002, HSIEH and CHOU arranged for Y.C.C. to send Y.C.C.'s

Taiwanese passport to HSIEH and CHOU in Virginia. HSIEH and CHOU brought the passport
to Schofield.

15. On orabout February 8,2002, Schofield placed a fraudulently issued Temporary I551 stamp, WAS/IIO#5, inY.C.C.'s Taiwanese passport, valid for one year. This stamp was
purported evidence of LPR status, although USCIS databases and Y.C.C.'s A file reflectthat

Y.C.C. was never an LPR and was ineligible for LPR status. Schofield gave the passport of
Y.C.C. to HSIEH and CHOU who mailed the passport back to Y.C.C.
16. On or about September 25, 2002, CHOU appeared for an interview at the USCIS

Washington 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 LPR
status by paying a bribe to Schofield.

17. On or about November 14,2002, CHOU obtained United States Certificate of

Naturalization number 27429719 atthe Washington District Office in Arlington, Virginia, within
the Eastern District of Virginia.

18. In or about January 2003, HSIEH and CHOU arranged for Y.C.C. to send the

Taiwanese passports ofY.C.C. and her son, W.H.W., to HSIEH and CHOU in Virginia. HSIEH
and CHOU brought the passports to Schofield.

19. On orabout January 29,2003, Schofield placed fraudulently issued Temporary 1-551 stamps, WAS/IIO#13, in the Taiwanese passports ofY.C.C. and W.H.W. These stamps, which
were valid for one year, were purported evidence of LPR status, although USCIS databases and

the Afiles ofY.C.C. and W.H.W. reflect that neither Y.C.C. nor W.H.W. were LPR's or eligible
for LPR status. Schofield gave the passports to HSIEH and CHOU who mailed them back to
Y.C.C.

20. On or about January 29, 2003, Schofield also placed a Temporary 1-551 stamp,

WAS/IIO#13, valid for one year, in HSIEH's Taiwanese passport. This stamp, referencing alien
registration number A74 359 948, was purported evidence ofLPR status, although USCIS databases and HSIEH's Afile reflect that HSIEH was never an LPR and was ineligible for LPR
status.

21. In or about January 2004, HSIEH and CHOU arranged for Y.C.C. to send the

Taiwanese passports of Y.C.C. and W.H.W. to HSIEH and CHOU in Virginia. HSIEH and
CHOU brought the passports to Schofield.

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22. On or about January 16, 2004, Schofield placed fraudulently issued Temporary 1-551 stamps, WAS/IIO#13, in the Taiwanese passports ofY.C.C and W.H.W. These stamps, which
were valid for one year, were purported evidence ofLPR status, although USCIS databases and

the Afiles ofY.C.C and W.H.W. reflect that neither Y.C.C. nor W.H.W. were LPR's or eligible
for LPR status. Schofield gave the passports to HSIEH and CHOU who mailed them back to
Y.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 alien
registration number A74 359 948, was purported evidence ofLPR status, although USCIS

databases and HSIEH's Afile reflect that HSIEH was never an LPR and was ineligible for LPR
status.

24. In or about January 2005, HSIEH and CHOU arranged for Y.C.C to send the

Taiwanese passports of Y.C.C, W.H.W., and Y.C.C.'s daughter, S.S.C, to HSIEH and CHOU
in Virginia. HSIEH and CHOU brought the passports to Schofield.

25. On or about January 10, 2005, Schofield placed fraudulently issued Temporary 1-551

stamps, 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 USCIS

databases and the Afiles of Y.C.C, W.H.W., and S.S.C. reflect that none were LPR's or eligible
for LPR status. Schofield gave the passports to HSIEH and CHOU who mailed them back to
Y.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 USCIS

databases and HSIEH's Afile reflect that HSIEH was never an LPR and was ineligible for LPR
status.

27. On or about March 24,2005, HSIEH received United States Certificate of

Naturalization number 28614969, affixed with alien registration number A74 359 948 in the

Washington District Office ofUSCIS, located within the Eastern District ofVirginia. USCIS
record checks revealed that United States Certificate ofNaturalization number 28614969 did not
exist 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 in
order to obtain naturalization. Additionally, Lawful Permanent Residence in the United States is

arequirement 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 interview
with Schofield. Y.C.C did as instructed by CHOU and paid the money to Schofield at the
interview.

29. On or about April 13,2005, Schofield issued Y.C.C United States Certificate of

Naturalization number 28614975, affixed with alien registration number A77 511 458 in the

Washington District Office of USCIS, located within the Eastern District ofVirginia. USCIS
record checks revealed that United States Certificate ofNaturalization number 28614975 does

not 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 adjudicated in order to obtain naturalization. Additionally, Lawful Permanent Residence in the United States is 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 of

Citizenship number A2222325, affixed with alien registration number A78 148 067, in the

Washington District Office ofUSCIS, located within the Eastern District ofVirginia. Certificates ofCitizenship are issued to individuals who derive United States citizenship through
aparent. USCIS record checks revealed that Certificate ofCitizenship number A2222325 does

not exist in their database. W.H.W.'s administrative file maintained by USCIS contains aForm

N-600, Application for Certificate ofCitizenship, purportedly based on the U.S. citizenship of his mother, Y.C.C, that was not properly filed or adjudicated. W.H.W. was not eligible to
receive aCertificate of Citizenship because his mother was not aU.S. citizen. The N-600 lists W.H.W.'s address as 2725 Robaleed Way, Herndon, VA, which is not the address of W.H.W.
but is the address of HSIEH and CHOU.

31. On or about May 1,2006, Schofield issued S.S.C. United States Certificate of

Citizenship number A2222322, affixed with alien registration number A78 148 068, in the

Washington District Office ofUSCIS, located within the Eastern District ofVirginia. USCIS
record checks revealed that United States Certificate ofCitizenship number A2222322 does not
exist in their database. S.S.C's administrative file maintained by USCIS contains aForm N-

600, Application for Certificate ofCitizenship, purportedly based on the U.S. citizenship ofher

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mother, Y.C.C, that was not properly filed or adjudicated. S.S.C. was not eligible to receive a
Certificate of Citizenship because her mother was not a U.S. citizen. The N-600 lists S.S.C's address as 2725 Robaleed Way, Herndon, VA, which is not the address of S.S.C. but is the
address of HSIEH and CHOU.

(Inviolation of Title 18, United States Code, Section371.)

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COUNT TWO

THE GRAND JURY FURTHER CHARGES THAT:

1. The Grand Jury realleges and incorporates the GENERAL ALLEGATIONS ofthis
indictment.

2. Between on or about April 18, 1996 and November 30, 2006, in Fairfax County,
Virginia, within the Eastern District of Virginia, and elsewhere, the defendants, KUANG HAO

CHOU and LING YU HSIEH, and others known and unknown to the Grand Jury, did directly
and indirectly, knowingly and unlawfully corruptly, give, offer, and promise athing ofvalue, to
Schofield, at that time asenior public official, that is aSupervisory District Adjudications

Officer, in return for being induced to do and omit to do an act in violation ofhis official duties,
that is, Schofield, in return for apromised payment and service, violated his official duties in that he did falsely and fraudulently make, issue and provide aliens with Employment Authorization

documents, Temporary 1-551 Stamps, LPR status, and Naturalization Certificates to which they
were not entitled nor authorized to receive, based upon fraudulent, incomplete or nonexistent

immigrant applications, and by deleting any record of such actions on the government's
computers, creating empty jackets utilizing alien numbers never issued, and by utilizing means
to 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 ofthis
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 HAO

CHOU and LING YU HSIEH, and others known and unknown to the Grand Jury, did unlawfully
and knowingly falsely make, utter, use, attempt to use, possess, obtain, accept and receive

documents and stamps prescribed by statute and regulation for entry into and authorized stay in the United States, to wit, Temporary 1-551 Stamps in alien passports falsely reflecting Lawful
Permanent Residence status in the United States, Lawful Permanent Residence cards and United

States passports obtained using United States Naturalization Certificates, knowing them to have
been falsely made, to have been procured by means ofany false claim or statement, and
otherwise procured by fraud and unlawfully obtained.

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

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COUNT FOUR

THE GRAND JURY FURTHER CHARGES THAT:

1. The Grand Jury realleges and incorporates the GENERAL ALLEGATIONS ofthis
indictment.

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 HAO

CHOU and LING YU HSIEH, and others known and unknown to the Grand Jury, did unlawfully
and knowingly, issue, procure, obtain and apply for and otherwise attempt to procure and obtain

and apply for naturalization for aliens not entitled to Naturalization Certificates by creating false
applications and false immigration files and no file at all in order to issue, procure and obtain

naturalized United States citizenship status knowing such status to have been falsely made, to

have been procured by means of any false claim or statement, and otherwise procured by fraud
and unlawfully obtained. The Grand Jury realleges the five falsely and fraudulently made
Naturalization Certificates identified in Count One, including the certificates ofnaturalization,

number 27429719 issued on or about November 14,2002, in the name of KUANG HAO CHOU,
also known as Edwin Chou, to which CHOU was not entitled and number 28614969 issued on or

about March 24,2005, in the name of LING YU HSIEH, also known as Erica Hsieh, to which
HSIEH was not entitled.

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

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COUNT FIVE

THE GRAND JURY FURTHER CHARGES THAT:

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

2. Between on or aboutApril 8,2010 andNovember 16, 2010, in Herndon, Virginia,
within the Eastern District of Virginia, and elsewhere, the defendant, KUANG HAO CHOU,
knowingly and intentionally accessed a computer without authorization and exceeded his

authorized access and thereafter obtained information from a department and agency of the United States, to wit: CHOU accessed the United States Department of State eMED database

without authorization and exceeding his authorized access and obtained information relating to
approximately 250,000 or more United States Department of State and other United States
government employees.

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

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COUNT SIX

THE GRAND JURY FURTHER CHARGES THAT:

1. The Grand Jury realleges and incorporatesthe GENERAL ALLEGATIONS of this
indictment.

2. On or about August 5,2010, in Herndon, Virginia, within the Eastern District of

Virginia, and elsewhere, the defendant, KUANG HAO CHOU, in a matter within the jurisdiction

ofthe Executive Branch ofthe Government ofthe United States, that is the Social Security
Administration and theDepartment of State, did knowingly, unlawfully and willfully make a
materially false, fictitious and fraudulent statement and representation, to wit: CHOU claimed to

belawfully naturalized United States citizens when CHOU sought to renew his security

clearance he originally obtained to work as a contractor for the United States Department of
State, in order to workwith the Social Security Administration, when in truth and in fact, as CHOU then and there well knew he had paid a bribe for his immigration benefits and was not

eligible to obtain or use a security clearance in September 9,2005, nor to renew it onAugust 5,
2010. On or about August 5,2010, CHOU submitted a Questionnaire for Non-Sensitive

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Positions and a Declaration for Federal Employment submitted to the United States Office of

Personnel Management to maintain his security clearance and reaffirming his false statement and

representation concerning his immigration status.
(In violation of Title 18, United States Code, Section 1001.)

A TRUE BILL:
Pun&tartt to the F-Govemmcni Aci

the originalof this page has been fi'-.i
under seal in the Cleik'» Oflfc-;.

FOREPERSON

Neil H. MacBride

United States Attorney

By:
Ronald L. Walutes, Jr.

AssistantUnited States^Cttorney

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