AO 91 (Rev.

11/ll) Criminal Complaint FILED

UNITED STATES DISTRICT COURT JUN 1 7 2021
for the PETER A. MOORE. JR., CLERK
Eastern District of North Carolina US �:ff:COURT,��
BY

United States of America )

V. )
Ok Hwa LEE aka "Jenny" aka "Janey," ) Case No.
Shanyu SONG, ) 7:21-MJ-1165-RJ
0g Bun PARK aka "Hannah," )
XueJin BAI aka "Yoko," and )
Ming JI CAO aka "Amy" aka "Nana"
--- )
Defendanl(s)

AMENDED CRIMINAL COMPLAINT

I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date{s) of Augus.!_11, 2020 until May 26, 2021 in the county of _Wake and New Hanover in the
Eastern District of North Carolina , the defendant(s) violated:
Code Section Offense Description
18 u.s.c. § 371 Conspiracy to commit an offense against the United States

This criminal complaint is based on these facts:

See attached affidavit, incorporated as if fully restated herein.

� Continued on the attached sheet.

M.C. Glenn Covington, HSI Special

On this day, /"6 .C.., G&+,} � Printed name and lille
appeared before me vin reliable electronic me , was
placed under oath. and attested to the contents of this
Complaint.

City and state: Ra h North Carolina James E. Gates, U.S. Mag trate Judge
Printed name and tit/«

Case 7:21-mj-01165-RJ Document 24 Filed 06/18/21 Page 1 of 9

 IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA
SOUTHERN DIVISION

PROBABLE CAUSE AFFIDAVIT

I, M.C. Glenn Covington (Affiant), having been duly sworn according to law,
depose and state that:

INTRODUCTION AND AGENT BACKGROUND

1. I am a Special Agent with the Department of Homeland Security (DHS),

Homeland Security Investigations (HSI), currently assigned to Cary, North Carolina
and have been so employed since October 2009. I am responsible for investigations
child exploitation and sex trafficking which occur in the Eastern District of North
Carolina. I was previously employed as a United States Postal Inspector for five years
in Richmond, VA and was responsible for child exploitation investigations involving
the U.S. Mail.

2. I have participated in over 400 child exploitation and sex trafficking

investigations. I have received training in the area of child sexual exploitation and
sex trafficking investigations as well as specialized instruction on how to conduct
investigations of child sexual exploitation and sex trafficking crimes through the
United States Postal Inspection Service, the FBI, Department of Justice, and
Homeland Security Investigations. I have also received specialized training from the
Internet Crimes Against Children Task Force seminars and at the Dallas, TX
Advocacy Center's Crimes Against Children Training Conference.

3. As a result of my training and experience, I am familiar with federal

criminal laws and know that it is a crime to conspire to violate the laws of the United
States, including paying a bribe to a public official as defined in 18 U.S.C. § 201(a)(l)
in violation of 18 U.S.C. § 201(b)(l), all in violation of 18 U.S.C. § 371.

4. Information contained within this affidavit is based upon information

from my investigation, personal observations, training and experience, and
information relayed to me by other law enforcement officers and or agents.

5. Because this affidavit is being submitted for the limited purpose of

securing authorization for the requested arrest warrant, I have not included each and
every fact known to me concerning this investigation. Instead, I have set forth only
the facts that I believe are necessary to establish the necessary foundation for the
requested warrant.

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 PROBABLE CAUSE

The LEE Organization

6. Since August 2020, HSI has investigated Ok Hwa LEE aka "JENNY''
aka "JANEY'' and associates Shanyu SONG, Og Bun PARK aka "HANNAH," XueJin
BAI aka "YOKO," and Ming Ji CAO aka "AMY'' aka "NANA" for operating illicit, so-
called Asian massage parlors located in Cary, Durham, and Wilmington, North
Carolina, in the Eastern District of North Carolina and Middle District of North
Carolina. I will refer to this group as the LEE organization because investigation
indicates that LEE is the leader and manager for the other members.

7. Investigation has revealed that the LEE organization knowingly

operates massage parlors, where, in addition to massage, clients can obtain sexual
services (usually touching of the buttocks and/or groin followed by what's colloquially
known as a "happy ending" or a "hand job," that is, manual stimulation of the penis
generally to ejaculation). The LEE organization's illegal massage parlors include:

a. New Happy Spa, 115 S.W. Maynard Road, Cary, NC;

b. SuperRelax Chinese Spa, 2223 Highway 54, Suite J, Durham, NC;
c. VIP Spa, 6786 Market Street, Wilmington, NC; and
d. Comfort Asian Massage, 415 South College Road, Wilmington, NC.
e. Yucca Treatment Spa, 604 Shipyard Boulevard, Wilmington, NC;
and
f. King Spa, 3901 Market Street, Wilmington, NC.

8. In August 2020, a source of information introduced an HSI undercover

agent (UCA) posing as a corrupt HSI agent to members of the LEE organization. As
explained below, since then, the UCA has taken bribe payments from the LEE
organization in exchange for the UCA supposedly protecting the LEE organization's
illegal massage parlors from law enforcement scrutiny.

9. At all relevant times, the UCA was a "public official" as defined in 18

U.S.C. § 201(a)(l) because he was a sworn special agent of the Department of
Homeland Security - Homeland Security Investigations. As discussed below, he also
informed members of the LEE organization that he was a sworn federal agent.

10. In particular, on August 11, 2020, t h e source of information introduced

the UCA to Ok Hwa LEE and Shanyu SONG at a meeting in Wilmington, NC. The
UCA told LEE and SONG he was agent with Homeland Security and lifted his shirt
and showed them his gun and federal badge. The UCA and LEE discussed what
sexual services are provided at the illicit massage parlors. (LEE motioned her hand
up and down as to simulate a "hand job.").

11. LEE told the UCA she owned four businesses: 415 S. College Road,
Wilmington, NC; 6786 Market Street, Wilmington, NC; 115 S.W. Maynard Road,

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Cary, NC; and 2223 Highway 54, Suite J , Durham, NC. During the meeting, LEE
told the UCA that she would pay him $400 per location for a total of $1,600 per month.
LEE told the UCA that h e could pick up the money in Cary or Wilmington. LEE and
the UCA walked to SONG's Jeep Compass, and LEE gave the UCA a r ed bag that
contained $1,600 in U .S. currency.

12. Later that day, the source of information introduced the UCA, posing as
a corrupt HSI agent, to Ming Ji CAO aka "AMY' aka "NANA." He met "AMY' in the
parking lot of one of h er massage parlors, 3910 Market Street, Wilmington, NC.
"AMY' entered the UCA's unmarked police vehicle and sat in the front passenger
seat. The UCA informed "AMY' h e is agent with Homeland Security and explained
that h e is the "police." The UCA told "AMY' if sh e had problems, h e would "check" on
h er. Several time s during the meeting the UCA pulled up his shirt to show "AMY'
his badge and gun.

13. "AMY' told the UCA sh e owns two massage parlors and shares a third
massage parlor with her "sister." During a meeting in October 2020, "AMY' informed
the UCA that the name of h er other store was called "Yucca Spa" (604 Shipyard Blvd. ,
Wilmington, NC). She also told him that sh e h as a friend, "JENNY," later identified
as LEE, that h elps at the massage parlor.

14. The UCA told "AMY' not t ell anyone he is the police and "AMY' stated
sh e understood and the UCA "has to know when the police come." The UCA explained
to "AMY' if sh e gives him money she could get into trouble and if the UCA took money
from her he could get into trouble. "AMY' said sh e understood and stated, "Only you
and me ." "AMY' handed the UCA $1,000 in U.S. currency.

15. On March 15, 2021, LEE texted the UCA and informed him that sh e had
transferred h er businesses the previous month (February) to "YOKO." LEE gave the
UCA "YOKO's" t elephone number and the address of 415 S. College Road,
Wilmington, NC. LEE told the UCA that "YOKO" would be expecting him and to stop
by the business. LEE also said to call her if h e needed any h elp. "YOKO" was
sub sequently identified as XueJin BAI.

16. The UCA texted LEE back and aske d if she sold all her businesses to
h er ''YOKO." LEE responded "no" and said "YOKO" would get VIP Spa, located at
6786 Market Street, Wilmington, NC a nd Comfort Asian Massage, locate d at 415 S.
College Road, Wilmington, NC. LEE told him that she had transferred the Cary
parlor, located at 115 S.W. Maynard Road, Cary, NC, to her "partner," "HANNAH,"
later identified as Og Bun PARK. She indicate d that she intended to transfer the
Durham parlor to PARK, aka "HANNAH," a s well.

17. Initially, investigators identified "HANNAH" as Jinhua Piao.

"HANNAH" supplied a phone number to the UCA that is registered to Piao. When
U.S. Marshals deputie s went to arrest "HANNAH" at the residence sh e provided on

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her cell phone registration (in Queens, in the Eastern District of New York), men who
identified themselves as Piao's uncle and husband said she was on a walk with her
aunt. Deputies called "HANNAH's" number and Piao answered and surrendered.
After her arrest, Piao indicated to the U.S. Attorney's Office for the Eastern District
of New York that Piao shares the "HANNAH" phone with her aunt, Og Bun PARK.
PARK came to the federal courthouse in Brooklyn and does physically appear to
match the women on surveillance video making payments as "HANNAH." PARK also
has provisionally indicated that she goes to New York and recognizes the other people
named in this complaint. Thus, PARK, not Piao, is "HANNAH."

The Payments

18. Since August 2020, the UCA met periodically with LEE, SONG, BAI,
CAO, and PARK or employees working for them to collect bribe payments. In total,
the UCA has collected $15,400.00 from the Lee organization, as detailed below:

a. August 11, 2020: $1,600.00 paid by LEE and SONG at Panera in

Wilmington, NC.

b. August 11, 2020: $1,000.00 paid by CAO at 3910 Market Street,

Wilmington, NC 28403.

c. October 17, 2020: $1,600.00 paid by LEE and SONG at 115 S.W.
Maynard Road, Cary, NC 27511.

d. October 28, 2020: $800.00 paid by CAO at 3910 Market Street,

Wilmington, NC.

e. November 18, 2020: $1,600.00 paid by PARK at 115 S.W. Maynard

Road, Cary, NC 27511.

f. November 18, 2020: $800.00 paid by CAO at 3910 Market Street,

Wilmington, NC.

g. December 16, 2020: $800.00 paid by CAO at 3910 Market Street,

Wilmington, NC.

h. January 20, 2021: $800.00 paid by CAO at 3910 Market Street,

Wilmington, NC.

i. March 16, 2021: $800.00 paid by BAI at 415 S. College Road,

Wilmington, NC

j. March 16, 2021: $800.00 paid by CAO at 604 Shipyard Blvd. ,

Wilmington, NC.

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 k. March 17, 2021: $800.00 paid by PARK at 115 S.W. Maynard Road,
Cary, NC.

1. April 14, 2021: $800.00 paid by BAI at 415 S. College Road,

Wilmington, NC.

m . April 14, 2021: $800.00 paid by CAO at 3910 Market Street,

Wilmington, NC.

n . April 15, 2021: $800.00 paid by a female employee named "LUNA"

at 115 S.W. Maynard Road, Cary, NC.

o. May 26, 2021: $800.00 paid by CAO at 3910 Market Street,

Wilmington, NC .

p. May 26, 2021: $800.00 paid by BAI at 415 S. College Road,

Wilmington, NC

18. During each payment, other HSI agents performed surveillance, and
payments were captured on audio or video. Each payment and any other items
included with it were immediately logged into HSI evidence.

The Massage Parlors and their Operators

19. Members of the LEE organization have discussed how they operate their
illegal massage parlors with the UCA. For example, on October 17, 2020, the UCA
met with LEE and SONG to collect a "bribe" payment at Caribou Coffee in Cary, NC,
which is located next to the New Happy Spa, 115 S.W. Maynard Road, Cary, NC
27511. During the meeting, LEE told the UCA she and SONG live in North Myrtle
Beach, SC, together. LEE advised the UCA that the Cary store has two workers and
will have ten customers per day. LEE said the Durham store has two workers, and
the Wilmington store has one worker and sometimes will have four to five customers
per day. LEE said that she and SONG each own one store in Wilmington. LEE said
the rent at the Cary store is $2,600 to $2,700 per month. (Lee said SONG is her best
friend then said SONG was her sister.)

20. LEE admitted the workers "do hands" and gave a brief hand stroking
motion resembling a "hand job." The UCA asked LEE and SONG if he could look at
the "shop." LEE told the UCA to wait and she would go first. The UCA walked into
the business. LEE gave him a tour of the business. LEE told the UCA that the
workers were hiding from him. LEE also mentioned that she must pay someone else
to put the business under a different name, indicating her awareness that illegal
activity occurs there.

21. On March 16, 2021, during a meeting between "AMY'' and the UCA at
604 Shipyard Blvd. , Wilmington, NC, "AMY'' directed the UCA to a room near the

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front and closed the door. The UCA noticed a camera over t h e filing cabinet. "AMY'
walked over to the cabinet and stood directly under the camera and pointed up and
whispered "camera." "AMY' reached into the cabinet and retrieved an envelope and
tucked it in her blouse . "AMY' motioned for the UCA to move closer to the door and
out of view of the camera, then positioned her body away from the camera and pulled
an envelope out from under her blouse and handed it to the UCA.

22. On March 19, 2021, LEE texted the UCA stating sh e had an
"emergency." LEE then texted an a d for a massage parlor located at 3910 Market
Street, Wilmington, called King Spa, and said, "has problems now." The UCA called
LEE and recorded the phone call. LEE told the UCA that someone sh e called "NANA"
h a d texted h er and reported that police were at that massage parlor, which belonged
to "NANA." LEE told the UCA that "NANA" was one of h er "friends." LEE confirmed
that "NANA" also owns a massage parlor at 604 Shipyard Boulevard in Wilmington.
She urge d the UCA to talk to "NANA." As sh e discussed "NANA," the UCA realized
that she was t alking about "AMY," which "AMY' later confirmed by mentioning t his
conversation between her , the UCA, and LEE at a lat er meeting. A short time later,
the UCA texted LEE and "NANA" and told them that the police had pulled over a
vehicle in the parking lot and that the incident had nothing to do with "NANA's" or
"AMY' s" store.

23. On April 14, 2021 , during a meeting between LEE, SONG, and the UCA
at Starbucks in Cary, LEE told the UCA that SONG wanted to open a spa in Cary,
and SONG asked the UCA to h elp h er find a store . LEE a dmitted the lease at t h e
Durham store (2223, Highway 54, Suite J, Durham , NC 27713) was in her name. The
UCA asked LEE where the girls would come from if SONG opened a store. LEE
explained they place ads in Korean and Chinese n ewspapers in the U nited States.
LEE said that most of the girls come from New York a nd other cities. LEE stated that
owners invest $60,000 in massage parlors. Workers make 40 percent and can earn
$180 to $200 plus tips. LEE told UCA that sh e would speak to "HANNAH" about his
payment and proposed lunchtime the following day. She instructed the UCA to go to
the back door because "HANNAH" doesn't like people to see him and they h ave
cameras.

24. In April 2021, HSI agents and Cary Police Department (CPD) officers
conducted surveillance on New Happy Spa, 11 5 S.W. Maynard Road, Cary, NC 275 11.
Officers initiated traffic stops on clients seen entering and leavin g the business.
Three men testified that they received so-called "happy endings" toward the end of a
thirty- or sixty-minute massage, during which masseuses manually stimulated their
penises, generally to ejaculation. Some reported receiving the same "happy ending"
at prior visits to that massage parlor. E ach ma n a dmitted to then payin g an
a dditional tip after the happy ending. A fourth customer testified that the masseuse
touched his genitals during the massage a nd that h e jerked his body away in surprise .
A fifth customer denied any sexu al touching.

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 25. On May 2021, HSI agents and New Hanover County Sheriffs Office
(NHCSO) officers conducted surveillance on Comfort Asian Massage, located at 415
S. College Road, Wilmington, NC; King Spa, located at 3910 Market Street,
Wilmington, NC; Yucca Treatment Spa, located at 604 Shipyard Blvd., Wilmington,
NC; and VIP Spa, located at 6786 Market Street, Wilmington, NC. Officers initiated
traffic stops on clients seen entering and leaving the above businesses. Fourteen
customers were interviewed and thirteen were given grand jury subpoenas. At least
one or two customers at each business received a "happy ending." Seven customers
testified they received "happy endings" toward the end of a thirty - or sixty-minute
massage, during which masseuses manually stimulated their penises, generally to
ejaculation.

26. A customer who was pulled over after leaving Comfort Asian Massage
admitted he had received multiple "happy endings" at VIP Spa, located at 6786
Market Street, Wilmington, NC. The customer admitted he knows the owners of both
spas and assists them periodically with their businesses. In exchange, they allow
him one free massage monthly, though that covers only the "door fee;" he still must
pay the "tip" for his happy ending. The customer identified those operators as
"YOKO" (BAI), whom he positively identified; "JANEY," whom he could not identify
by picture but whose phone number, which he provided, matches LEE's; and a third
female whose name he does not know .1

27. The customer also reported that about three months ago he was at a
meeting with "JANEY," "YOKO," and a third Asian female who wanted to purchase
VIP Spa from a woman named Yung Hi KIM. At the meeting, he observed the third
Asian female walk in with a tote bag full of U .S. currency wrapped in cellophane. The
customer stated Yung Hi KIM later told him that she sold VIP Spa for $70,000.00.

28. The customer further acknowledged "JANEY'' had asked him if she
could use his name for business and corporation records for VIP Spa. "JANEY'' said
she would pay him $700.00 per month for the use of his name. "JANEY'' told the
customer that she would use her name for a debit card for the business. The customer
stated he told her "no."

29. The customer also explained that Asian massage parlors make a lot of
money and the "mamasan" will take home large sums of cash and put it in a safe at
their residence for safekeeping.

This customer has a federal conviction for conspiracy and transporting stolen goods. He also
admitted to knowingly assisting the operation of illegal massage parlors, mostly for owners who are
not the subject of this investigation. I nonetheless believe the information he h as provided to be
truthful and credible because independent investigation corroborates ma ny of the details h e has
provided in interviews with law enforcement.

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 CONCLUSION

30. Based on the foregoing investigation, I have probable cause to believe

that Ok Hwa LEE aka "JENNY'' aka "JANEY," Shanyu SONG, Og Bun PARK aka
"HANNAH," XueJin BAI aka ''YOKO," and Ming Ji CAO aka "AMY'' aka "NANA" did
commit violations of federal law, including 18 U.S.C. § 371 (conspiracy to violate the
law of the United States, that is, paying a bribe to a public official in violation of 18
U.S.C. § 201(b)(l)).

M.C. Glenn Covington

Special Agent
Homeland Security Investigations

2-02.1
On this ( / day of June~. M.C. Glenn Covington appeared before me via
reliable means, was placed under oath, and attested to the contents of this Affidavit.

J~ -

United States Magistrate Judge

Eastern District of North Carolina

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