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Sang-Hyun Park, Et. Al. Complaint

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Sang-Hyun Park, Et. Al. Complaint ATTACHMENT A Count One (Conspiracy) From in or about June 2006 through on or about the date of this Criminal Complaint, in Bergen County, in the District of New Jersey and elsewhere, defendants Known Name Alias(es) Sang-Hyun Park “Jimmy,” “Jianfang Jiang,” and “Zhen Li” Hyun-Jin LNU [last name “Hai Hua Xu” unknown] Dong-Il Kim “Cai Juan Zhang,” and “Zhankun Liu” Sung-Sil Joh “Jenny,” and “Zhanhong Fan” Joong-Hyun Jung Osung Kwon “Xiaoling Zhang” Jin LNU “Jin,” “Zhaofang Chen,” and “Jianxin Jiang” Min-Soo Son “Chris” Young-Hee Ju “Stephanie,” and “Mingji Piao,” Hyo-Il Song “Daniel,” “Yan Hua Wei,” “Haizhe Pei,” “Minghao Li,” and “Dongyun Zhou” Dong-Won Kim “Andy Kim,” “Guangying Zhang,” “Huaying Lu,” and “Wei Yun Zhong” 1 Known Name Alias(es) Seung-Ho Noh “Peter,” “Mr. Park,” “Zhong Z. Yin,” “Chae Yoon Lim,” and “Zhiquing Zhang” Matthew J. Kang “Jun-Yong Kang” Rita S. Kim “Rita Han” Hyon-Suk Chung “Clara” Young-Woo Ji “Fei Chen” Sang-Kyu Seo Hyun-Yop Sung “Shanji Li” FNU [first name unknown] LNU#1 “Mr. Choi,” and “Xijun Gu” Hyeon-U Kim “Deshang Zhang,” and “Xiurong Xu” Edward M. Ha Jong-Hoon Kim “John,” “Zhengshu An,” “Ruiping Chen,” and “Chun Shi Huang” Chi-Won Jeon “Xianzi Luo,” and “Fengling Jin” Jung-Hyuck Seo “Xiaoqin Zhang” Jong-Kwan Hong “Dongshu Li” In-Sook Lee “Susan,” and “Ping Fang” Sung-Rok Joh “Zhang Li” Jung-Bong Lee “Hong Guo Cui,” and “Wei Xiang Lu” Hye-Won Jung “Meihong He” Son-Hee Chong “Mingshun Yuan” In-Suk Joo “Danhua Wang” 2 Known Name Alias(es) Byung Jang “Pyung-Hak Jang,” and “Xue Hui Shi” Amy Yang “Sung-Cha Yang,” “Yulan Qian” and “Amy Pitts” Song-Ja Park “Run Hong Liu” Min-Jun Kwon “Kwon Yi” Jung-Sook Ko “Grace S. Lim,” and “Haishun Jin” Myung-Kyun Ko “Longnan Cui” Yoon-Hee Park “Yun-Hee Park,” “Zhangqi Zhang,” and “Xiaofang Zhu” Alex S. Lee “Yicun Zhu,” and “Yun Hu” Kyung-Ki Kim “Yuting Zhao” knowingly and intentionally conspired and agreed with each other and others to commit offenses against the United States by: (1) producing without lawful authority identification documents and false identification documents, in and affecting interstate and foreign commerce, contrary to Title 18, United States Code, Section 1028(a)(1) and (c)(3)(A); (2) knowingly transferring, possessing, and using, without lawful authority, a means of identification of another person with intent to commit and in connection with unlawful activity that constitutes a violation of federal law, including credit card fraud (18 U.S.C. § 1029), mail fraud (18 U.S.C. § 1341), wire fraud (18 U.S.C. § 1343), bank fraud (18 U.S.C. § 1344), and buying and selling social security cards and numbers (42 U.S.C. § 408), in and affecting interstate and foreign commerce, contrary to Title 18, United States Code, Section 1028(a)(7); 3 (3) buying and selling social security cards for the purpose of obtaining things of value, contrary to Title 42, United States Code, Section 408(a)(7)(C); and (4) with intent to defraud, trafficking in and using one or more unauthorized access devices during any one-year period, and by such conduct obtaining things of value aggregating $1,000 or more during that period, contrary to Title 18, United States Code, Section 1029(a)(2). In furtherance of the conspiracy and to effect its unlawful objects, the above-listed defendants and their co-conspirators committed and caused to be committed the overt acts, among others, in the District of New Jersey and elsewhere, as set forth in Paragraphs 50 through 114 below of Attachment B. In violation of Title 18, United States Code, Section 371. 4 Count Two (Aggravated Identity Theft) From in or about January 2009 through in or about October 2009, in Bergen County, in the District of New Jersey and elsewhere, defendants Sang-Hyun Park, a/k/a “Jimmy,” “Jianfang Jiang,” and “Zhen Li,” and Hyun-Jin LNU, a/k/a “Hai Hua Xu,” during and in relation to violations of federal law, namely, credit card fraud (18 U.S.C. § 1029), mail fraud (18 U.S.C. § 1341), wire fraud (18 U.S.C. § 1343), bank fraud (18 U.S.C. § 1344), and fraud relating to social security cards and numbers (42 U.S.C. § 408), knowingly transferred, possessed, and used, without lawful authority, the means of identification of another person, namely, Y.L., as described below in Attachment B, in violation of Title 18, United States Code, Section 1028A and Section 2. 5 Count Three (Aggravated Identity Theft) From in or about January 2009 through in or about July 2009, in Bergen County, in the District of New Jersey and elsewhere, defendant Young-Hee Ju, a/k/a “Stephanie” and “Mingji Piao,” during and in relation to violations of federal law, namely, credit card fraud (18 U.S.C. § 1029), mail fraud (18 U.S.C. § 1341), wire fraud (18 U.S.C. § 1343), and fraud relating to social security cards and numbers (42 U.S.C. § 408), knowingly transferred, possessed, and used, without lawful authority, the means of identification of another person, namely, Mingji Piao, as described below in Attachment B, in violation of Title 18, United States Code, Section 1028A and Section 2. 6 Count Four (Aggravated Identity Theft) In or about February 2009, in Bergen County, in the District of New Jersey and elsewhere, defendant Hyo-Il Song, a/k/a Daniel,” “Yan Hua Wei,” “Haizhe Pei,” “Minghao Li,” and “Dongyun Zhou,” during and in relation to violations of federal law, namely, credit card fraud (18 U.S.C. § 1029), mail fraud (18 U.S.C. § 1341), wire fraud (18 U.S.C. § 1343), and fraud relating to social security cards and numbers (42 U.S.C. § 408), knowingly transferred, possessed, and used, without lawful authority, the means of identification of another person, namely, Minghao Li, as described below in Attachment B, in violation of Title 18, United States Code, Section 1028A and Section 2. Count Five (Aggravated Identity Theft) From in or about August 2009 through in or about October 2009, in Bergen County, in the District of New Jersey and elsewhere, defendant Dong-Won Kim, a/k/a Andy Kim,” “Guangying Zhang,” “Huaying Lu,” and “Wei Yun Zhong” during and in relation to violations of federal law, namely, credit card fraud (18 U.S.C. § 1029), mail fraud (18 U.S.C. § 1341), wire fraud (18 U.S.C. § 1343), and fraud relating to social security cards and numbers (42 U.S.C. § 408), knowingly transferred, possessed, and used, without lawful authority, the means of identification of another person, namely, Guangying Zhang, as described below in Attachment B, in violation of Title 18, United States Code, Section 1028A and Section 2. 7 Count Six (Conspiracy to Commit Wire Fraud) From in or about October 2009 through in or about December 2009, in Bergen County, in the District of New Jersey and elsewhere, defendants Sang-Hyun Park, a/k/a “Jimmy,” “Jianfang Jiang,” and “Zhen Li,” Hyun-Jin LNU, a/k/a “Hai Hua Xu,” Min-Soo Son, a/k/a “Chris,” and Sang-Kyu Seo knowingly and willfully conspired and agreed with each other and others to devise a scheme and artifice to defraud the credit card companies referred to in Paragraph 72 below of Attachment B, and to obtain money and property by means of materially false and fraudulent pretenses, representations, and promises, and to do so by means of interstate wire communications, as described in Paragraph 72 below of Attachment B, contrary to Title 18, United States Code, Section 1343, in violation of Title 18, United States Code, Section 1349. 8 Count Seven (Conspiracy to Commit Wire Fraud) In or about January 2010, in Bergen County, in the District of New Jersey and elsewhere, defendants Sang-Hyun Park, a/k/a “Jimmy,” “Jianfang Jiang,” “Zhen Li,” Hyun-Jin LNU, a/k/a “Hai Hua Xu,” Jong-Hoon Kim, a/k/a “John,” “Zhengshu An,” “Ruiping Chen,” “Chun Shi Huang,” and Hag-Sang Jang knowingly and willfully conspired and agreed with each other and others to devise a scheme and artifice to defraud the credit card companies referred to in Paragraph 89 below of Attachment B, and to obtain money and property by means of materially false and fraudulent pretenses, representations, and promises, and to do so by means of interstate wire communications, as described in Paragraph 89 below of Attachment B, contrary to Title 18, United States Code, Section 1343, in violation of Title 18, United States Code, Section 1349. 9 Count Eight (Conspiracy to Commit Wire Fraud) From in or about April 2010 through in or about May 2010, in Bergen County, in the District of New Jersey and elsewhere, defendants Sang-Hyun Park, a/k/a “Jimmy,” “Jianfang Jiang,” and “Zhen Li,” Hyun-Jin LNU, a/k/a “Hai Hua Xu,” Osung Kwon, a/k/a “Xiaoling Zhang,” Yong Kim Lee, and Hi-Joo Yang knowingly and willfully conspired and agreed with each other and others to devise a scheme and artifice to defraud the credit card companies referred to in Paragraph 94 below of Attachment B, and to obtain money and property by means of materially false and fraudulent pretenses, representations, and promises, and to do so by means of interstate wire communications, as described in Paragraph 94 below of Attachment B, contrary to Title 18, United States Code, Section 1343, in violation of Title 18, United States Code, Section 1349. 10 Count Nine (Money Laundering) From on or about June 2009 through on or about July 2010, in Bergen County, in the District of New Jersey and elsewhere, defendant Sang-Hyun Park, a/k/a “Jimmy,” “Jianfang Jiang,” and “Zhen Li,” knowingly conducted and attempted to conduct financial transactions affecting interstate commerce and foreign, as more fully set forth in Paragraph 105 below of Attachment B, involving the proceeds of specified unlawful activity, namely, credit card fraud (18 U.S.C.
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