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neon hana, sean Tater nom ‘compe ‘orci tie ccrszoze (20705) Information to Obtain i rcensfeston "de Socuer de polce a Search Warrant 2001924 Dénonciation en vue d'obtenir un mandat de perquisition a amu Sanco coset some waar 7THis 8 THE FORMATION of Amy Lea Dorothy PAMBIANCO Peace Officer %° SRE SSS SS To oR SSeS RS of ‘The Canada Border Services Agency Edmonton do ta erpater scr tama sane oosers’————— ———bémonton, in the Province of Alberta, hereinafter called the Informant, taken betore me. province d'Alberta, cl-aorés appelé fe dénonciateur. portée devant mo ‘THE INFORMANT SAYS THAT LE DENONCIATEUR DECLARE QUE Things to be Searched for: |. The Following “Things” dated between November 11, 2015 and June 28, 2018, relating to the business operations of: c= ‘Triple Maple Leaf Canada (TML Canada Group) Corp. World Immigration Group (WIG) Corp. Helping Migrants Canadian Immigration Corp. and or in the names of: Carlito Manansala BENITO also known as Carl Benito Charles Jefferson BENITO Namely; 2. Any document, record, leer, o fax (sent or received, including all enclosures) pertaining to immigration documentation for study permit and work permit extension applications between November 1, 2015 and present, for all clients of: ‘Triple Maple Leaf Canada (TML Canada Group) Corp. World Immigration Group (WIG) Corp. Helping Migrants Canadian Immigration Corp. Carlito Manansala BENITO also known as Carl Benito Charles Jefferson BENITO More specifically: a) Client files and all retated supporting documentation between November 11, 2015 and present for all clients who applied for study permits and or work permit extensions: and ) All financial records between November 1, 2015 and present related to payments and or loans, 10 be made or received, including bank records, e-transfer records, bank drafts, financial logs and ledgers, cancelled cheques, cheque stubs, cheque registers, credit card statements, credit card records, calculation records, and hand written notes. 3. Any document. record, letter, or fax (Sent or received. including all enclosures) pertaining to employment records and employee files between September 16, 2016 and present for ‘Triple Maple Leaf Canada (TML Canada Group) Corp. World Immigration Group (WIG) Corp. Helping Migrants Canadian Immigration Corp. Carlito Manansala BENITO also known as Carl Benito Charles Jefferson BENITO ‘More speci sally: 4) Employee files and supporting documentation; +) Any sent or received fax, correspondence and all enclosures, notebooks, address books, business documents, contracts, employee files, employee lists, employee schedules, employee time sheets, ‘employee hour logs, employee work logs, employee time cards, employee contaet information, job site logs, day timers, notes, telephone and cellular records, postal and courier documents and receipts, Page 134 040 ‘erszoz 200705) v2001924C and any related supporting documentation and/or attachments; ©) All financial records related to employee payments, to be made or received, including bank records, e-transfer records, bank drafts financial logs and ledgers, cancelled cheques, cheque stubs, cheque registers, credit card statements, credit eard records, written record of wages, payroll documents, calculation records, hand written notes and payroll ledgers. 4, ems described in paragraph 1, 2. and 3 in electronic format, as well as documents/records that ‘may be uniquely electronic including but not limited to: email (received, sent, deleted or in draft form); and records and content of past instant messaging or online chat conversations or other electronic communication, that are stored on or available (0 a computer system or other data storage device, 5. Any other device or software or manuals or data security key used or capable of being used to create, store, manipulate or reproduce the items in paragraphs 2 and 3. HEREINAFTER referred to as the said “Things”. ‘These “Things” will afford evidence that, Triple Maple Leaf Canada (TML Canada Group) Corp. And oF World immigration Group (WIG) Corp. And or Helping Migrants Canadian Immigration Corp. And or Carlito Manansala BENITO also known as Carl Benito And or Charles Jefferson BENITO did, on or between November 11, 2015 and June 28, 2018, at or near the City of Edmonton in the Province of Alberta, knowingly counsel, induce, aid or abet or attempt to counsel, induce. aid or abet persons, to directly or indirectly misrepresent or withhold material facts relating o a relevant matter that induced or could induce an error in the administration of the Immigration and Refugee Protection Act, contrary to Section 126 of the Immigration and Refugee Protection Act, thereby committing an offence pursuant (o section 128 of the same Act; did, on or between September 16, 2016 and June 28, 2018, at or near the City of Edmonton in the Province of Alberta, employ a foreign national, in a capacity in which the foreign national is not authorized under the Immigration and Refugee Protection Act to be employed, and thereby did commit an offence contrary to Paragraph 124(1)(c) of the Immigration and Refugee Protection Act, thereby committing an offence pursuant (o section 125 of the same Act; and that he has reasonable grounds for believing thatthe things, or some part of them are in the @t quil a des motifs raisonnables de croire que lesdiies chases ou una partie ‘entra elles s@ rouvent dans 7360 Singer Way NW, Edmonton, Alberta ‘sess compl of placer’ de abaten cones rama a fepporinnt ema ae wos Gea oar ponies Ge pire ‘urn emplcemen! a! of Carlito BENITO and Charles BENITO. of Edmonton. fa ol ecopanl rise be aa 7 For oo Tah ae ‘nom de occupant des eur pagar ex cons in the Province of Alberta, hereinafter called "the location”, province «Alberta, c/-aprés appelé emplacement” Page 231 ON ALBERTA ‘grounds of bell Ensure here ‘Sanchar int ‘hese grounds ae ewe the OFFENCE he TTeMs soup and ‘he LOCATION be soached ‘Aputeries motte ‘aonnabies Sassueruily a Ln appor eden ‘ana cos movie Tinea rion ies ‘annus ‘ers202¢ 20075) Fie Wa dssor ae posce v2001924C ‘TABLE OF CONTENTS A) Introduction 'B) Investigative Sources C) Legislation D) Overview E) Background to the Investigation F) Grounds to Believe an Offence Against This Act Has Been Committed G) Grounds to Believe the Things to be Seized will Afford Evidence of the Offence H) Grounds to Believe the Things Sought are Presently at the Place to be Searched 6 1) Conetusions ‘A. INTRODUCTION |. J, Amy Pambianco, am an Acting Investigator with the Canada Border Services Agency (CBSA) within the Enforcement and Intelligence Operations Division (EIOD) in Edmonton, Alberta. Pursuant to subsection 138(1) of the Immigration and Refugee Protection Act (IRPA), | have the authority and powers of a Peace Officer, including those set out in section 487 to 492.2 of the Ctiminal Code —to enforce the IRPA. 2. L have been employed with CBSA since August 4, 2008, in a variety of positions. I have been assigned to the Criminal Investigations section since July 17, 2017. Since becoming a peace officer with CBSA, I have successfully completed various levels of general and specialized training Provided to all CBSA Border Services Officers. In addition, I have completed a specialized Investigator training course. 3. 1am responsible for the investigation and case management of offences pursuant to the Customs ‘Act and the Immigration and Refugee Protection Act (IRPA). I am the officer in charge of the investigation giving rise to this warrant, 1 have a thorough understanding of all the facts detailed in this Information and I believe them to be true. 4. 1am seeking a warrant to search the office of Triple Maple Leaf Canada (TML Canada Group) Corp and or World Immigration Group (WIG) Corp. and or Helping Migrants Canadian Immigration Corp, located at conference room TC3 in the Ramada Hotel Edmonton South at $359 Calgary Trail NW, Edmonton, Alberta T6H4J9, pursuant to Section 487 of the Criminal Code. 5.1 have reasonable grounds to believe that the “Things” will aford evidence that Carlito BENITO (BENITO) of Triple Maple Leaf Canada (TML Canada Group) Corp (Triple Maple Leaf Canada) and or World Immigration Group (WIG) Corp (World Immigration Group) and or Charles BENITO ‘of Helping Migrants Canadian Immigration Corp (Helping Migrants) did, knowingly counsel, induce, aid or abet or attempt to counsel, induce, aid or abet persons, 10 directly or indirectly misrepresent oF ‘withhold material facts relating to a relevant matter that induced or could induce an error in the administration of the IRPA, contrary to Section 126 of the IRPA, thereby committing an offence pursuant to section 128 of the same Act, 6. | have reasonable grounds to believe that the “Things” will afford evidence that Charles BENITO and or Helping Migrants did employ a foreign national, in a capacity in which the foreign national is ‘ot authorized under the Immigration and Refugee Protection Act to be employed, and thereby did ‘commit an offence contrary to Paragraph 124(1)(c) ofthe Immigration and Refugee Protection Act. B. INVESTIGATIVE SOURCES 7. Ihave developed personal knowledge of the facts hereinafter deposed to, except where they are stated to be based on information and belief. 8. Other peace officers and government employees: Where | am relying on information provided verbally by other officers or employees, or by review of their notes and reports Iwill identify that, In ‘my experience, | have found these sources of information to be reliable. 9. Computer systems and corporate records: Much of the information | am relying on in this {Information has been provided by records held by CBSA and Immigration Refugees and Citizenship Canada (IRCC) and the Government of Alberta for the purposes of administering their respecti ‘mandates. Based on my experience, | believe these sources of information to be reliable. Page 30t3t #0 ‘ots202« 200705) enter a Poles Fle a |} itentRenon 1" de dossier potce v2001924C C. LEGISLATION 10. The Immigration and Refugee Protection Act (IRPA) state that: a. S. 124 (1) Contravention of Act ~ Every person commits an office who ¢. Employs a foreign national in a capacity in which the foreign national is not authorized under this Act to be employed. b. S. 126 Counselling misrepresentation ~ Every person who knowingly counsels, induces, abets or attemps to counsel, induce, aid or abet any person to directly or indirectly misrepresent or Withhold material facts relating to a relevant matter that induces or could induce an error in the administration of this Act is guilty of an offence. ©. S. 127 Misrepresentation — No person shall knowingly 3. Directly or indirectly misrepresent or withhold material facts relating to a relevant matter that induces or could induce an error in the administration of this Act b. Communicate, direetly or indirectly, by any means, false or misleading information or declarations with intent to induce or deter immigration to Canada: or 4. S. 128 Penalties — A person who contravenes a provision of section 126 or 127 is guilly of an offence and liable 2. On conviction on indictment, to a fine of not more than $100,000 or to imprisonment for a term of ‘not more than five years, or to both; or b. On summary conviction, to a fine of not more than $50,000 or (o imprisonment for a term of not ‘more than two years, or to both. 11. The immigration and Refugee Protection Regulations (IRPR) state that 2. $.215 (1) A foreign national may apply fora study permit after entering Canada if they (a) hold a study permit; (©) apply within the period beginning 90 days before the expiry oftheir authorization to engage in studies in Canada under subsection 30(2) ofthe Act, or paragraph 188(1)(a) of these Regulations, and ending 90 days after that expiry; (©) hold a work permit; (4) are subject to an unenforceable removal order: (€) hold a temporary resident permit issued under subsection 24(1) of the Act that is valid for at least six months: (O are a temporary resident who {is studying at the preschool, primary or secondary level, i) isa visting or exchange student who is studying ata designated learning institution, oF {Gli) has completed a course or program of study that is a prerequisite to their enrolling at a designated learning institution; or (g) are in a situation described in section 207. ». S. 220 Financial Resources - An officer shall not issue a study permit to a foreign national, other than one described in paragraph 215(1)(d) of (e), unless they have sufficient and available financial resources, without working in Canada, 10 pay the tuition fees for the course or program of studies that they intend to pursue; {i, maintain themself and any family members who are accompanying them during their proposed period of study; and pay the costs of transporting themself and the family members referred to in paragraph (b) to and from Canada, Canada is subject to the following conditions: ©.S. 220.1 (1) The holder ofa study permit tution and remain enrolled at a designated learning, (a) they shall enroll ata designated learning institution until they complete their studies; and (b) they shall actively pursue their course or program of study. Evidence of compliance with conditions 8.220.1(4) The holder of a study permit must provide evidence to an officer of their compliance with the conditions set out in subsection (1) if (a) the officer requests the evidence because the officer has reason to believe that the permit holder is ‘not complying o has not complied with one oF more of the conditions; or (b) the officer requests the evidence as part of a random assessment of the overall level of compliance with those conditions by permit holders who are or were subject to them, Mh Wh ALBERTA ‘or52024 2007705) arte Polen Faw a Wr edanttcaan 1" dosir de potce v2001924C D. OVERVIEW 12. In January 2018, Immigration, Refugees and Citizenship Canada (IRC) identified a possible fraud trend in the issuance of study permits to foreign nationals in need of status and who failed to ‘meet Immigration and Refugee Protection Regulations (IRPR) subsection 220.1, by applying to, but ‘ot attending school. In the process of their regulatory functions IRCC found that a number of these foreign nationals were counselled by their Immigration Consultant to apply for a study permit for the sole purpose of remaining in Canada, without intentions of attending school. Some foreign nationals who were unable to meet the financial requirements for obtaining a study permit under section 220 of IRPR were, offered a short term loain for a large sum of money from BENITO of Triple Maple Leal’ ‘Canada and or World Immigration Group, In order to prove they met the financial requirement of section 220 of IRPR, a bank statement providing an account balance was submitted to [RCC demonstrating that they could pay the tition fees and support themselves for the proposed period of stay. To obtain an account statement from the TD bank, they were instructed by BENITO to open a TD account, driven to a TD Bank by BENITO’s secretary. and a large stum of money was transferred into their account at which point they acquired an account statement from the bank as proof of funds, ‘They would then proceed to another TD Bank branch and the secretary would assist in transferring the money into another foreign nationals account for their statement, oF back to the source. Due to the volume of cases identified by the IRCC, BENITO being the common consultant associated to the applications, and the transfer of money into and out of foreign nationals’ accounts, the case was referred to the CBSA Criminal Investigations Division. 13. To date five foreign nationals have been interviewed in relation to the misrepresentation on their study permit applications and a further 79 foreign nationals have been identified as obtaining study permits for the Academy of Learning or Makami College through BENITO and his companies but did not attend school. Three of the five interviewed stated that BENITO arranged for money to be transferred into their bank account for a very short period of time and have provided a copy of their ‘TD bank account deposit history showing a $17,000 transfer into and out of their accounts to comply with the study permit application requirements, 14. Through this investigation into counselling misrepresentation, | have also learned that Charles BENITO, son of BENITO, operates Helping Migrants Canadian Immigration Corporation out of the same location as BENITO, in the Ramada Edmonton South at $359 Calgary Trail, Edmonton, Alberta. This was discovered through a FINTRAC report and through the interview of an arrested person who was found to be working at that location. CBSA Inland Enforcement reported this person for working at Helping Migrants without authorization, 15. There is a definite overlap between BENITO and Charles BENITO’s companies, Triple Maple Leaf, World Immigration and Helping Migrants. All three companies have used helpingmigrant@gmail.com as a main point of contact for their clients and IRCC. All three companies operate out of the same location, conference room T3C located in the Ramada Edmonton South, 5359 Calgary Trail, Edmonton, Both BENITO and Charles BENITO use their home address, 7360 Singer Way NW Edmonton as the mailing address for IRC. Finally, the records address for ‘Triple Maple Leaf and Helping Migrants is 7360 Singer Way NW Edmonton 16. Through this investigation | have also learned that BENITO is counselling misrepresentation on applications for work permit extensions. He is counselling foreign nationals to make applications ‘which he knows will be refused, as they are incomplete. This is being used as a mechanism to buy ‘more time in Canada allowing the applicant to benefit from implied status until the application is decided upon. They are making an application which is not truthful, as they have no intention of Working at that location, nor do they have the requirements to do so. Investigator Note: Implied status gives an applicant whose work permit has expired, the ability to remain in Canada and continue to work provided a work permit extension has been submitted to IRC. The implied status begins when the work permit extension application is received and ends when a decision is made by IRC on the work permit application. This typically taking three to four months to process. 17. This investigation is ongoing and | am seeking a warrant to obtain evidence of IRPA offences ‘commitied by BENITO, Charles BENITO, Triple Maple Leaf Canada (TML) Canada Group Corp, World immigration Group (WIG) Corp and Helping Migrants Canadian Immigration Corp. Pageof31 BAD ALBERTA ‘crsz0ze oars) ere Ne, Paica Fe Wo a eaenscsbon =A ds desir de pte v2001924C §. BACKGROUND TO THE INVESTIGATION 18. 1 was assigned as the lead Investigator for this file on March 26, 2018 by the Acting Manager of Criminal Investigations and Hearings, Kristine CONROY. | was presented with Investigator James WHITTAKER's (Investigator WHITTAKER) notes, and an email from IRC Officer Leona MARTIN (Officer MARTIN). All the information he provided me was obtained from Officer MARTIN through her regulatory investigation, 1 was tasked to review the information and conduct a preliminary investigation into the allegations. 19. fier reviewing an email chain between Officer MARTIN and Investigator WHITTAKER between February 12, 2018 and February 20, 2018, | learned the following: a) IRCC’s regulatory investigation was initiate unit March 2017 by the IRCC progeam integrity fraud +) While processing study permit applications officers noticed a trend related to study permits for smatl designated learning institutions; ©) Details of the trend are as follows i. A large quantity of study permit applications were received at the Case Processing Centre (CPC) in Vegreville for atendance in the Advanced Clinical Massage Therapy Program at Makami College in Edmonto: Makami College is a private designated learning institution. The program runs for two years and results in a diploma. Tuition fees are $12,450 for the first year and $14,450 for the second year, Applicants initially came to Canada as low-skilled temporary foreign workers. Once they reached a Limit in obtaining a work permit extension (Four year limit), they would apply for a study permit at ‘a small designated learning institution; iv. No deposit is required, to hold a position in the program and there is no cost for a Letter of Acceptance; ¥, Many applicants had submitted both a study permit application and a work permit extension ion pri of their existing permit. This would enable them to remain in implied staus fora longer period of tim: Vi. Most applicants who received a study permit for these institutions have not, or are not, attending as required by subsections 220.1(1)(a) and (b) of the Immigration and Refugee Protection Regulations (IRPR); vii. Several applicants were reported by the IRC for non-compliance with subsection 220.1 of IRPR; Vili. A large number of these applicants used BENITO as their immigration consultant; ix, Several applicants have identified that BENITO counselled them to apply for study permits and ‘work permits in order to extend their status and continue working: and ‘x Several applicants have stated they were provided loans from BENITO to satisfy the study permit application requirement for proof of funds. In these cases the funds were deposited in their bank accouni and withdrawn in the same day. 20. Afier reviewing the notes made by Investigator WHITTAKER, I learned the following: a. According to the Immigration Consultants of Canada Regulatory Council (ICCRC) BENITO is a registered Consultant associated to Consultant Identification number R508779; b. Corporate Registry System (CORES) check confirms BENITO to be the sole director for the following corporations: i, Triple Maple Leaf Canada (TML Canada Group) Corp: a. Active from February 15, 2013 to present; and b, Records address of 7360 Singer Way, Edmonton Alberta, T6R3R9. World Immigration Group (WIG) Corp: . Active from July 11, 2017 fo present; and Page st31 awd orsz0ce 200705) v2001924C b. Records address of $359 Calgary Trail, Edmonton Alberta, T6H4J9 (Ramada Hotel). €. Home address is 7360 Singer Way NW, Edmonton Alberta T6R3R9. 21, Between March 26, 2018 and March 28th, 2018, | viewed BENITO's website, htip:/! hhelpingmigrants.net/ and found photos with names of foreign nationals who successfully obtained study permits, and in Some cases, their spouses who successfully obtained open work permits as a result. For each person, a photo with the foreign national and BENITO, or in one case. Charles BENITO, was taken and is now used on the website as advertising for new clients. From this website and using the Global Case Management System (GCMS an immigration database owned and operated by IRC, which CBSA also uses and has access to), | created alist of nine foreign nationals who successfully obtained study permits for either Makami College or the Academy of Learning, 22, On March 26, 2018, | queried Ms. LIBELO, a name I had obtained from BENITO’s websit GCMS and learned the following: 2, Her authorized consultant was BENITO of Triple Maple Leaf Canada, 7360 Singer Way NW Edmonton, 780-298-4308, carlbenito2012@gmail.com; '. She made an application for a study permit on June 21, 2016 to study at the Academy of Learning; ¢. Included in the application was TD Bank Account statement belonging to Ms. LIBELO showing proof of funds dated April 21, 2016 with a balance of $17,200; 4. On July 23, 2016, Ms, LIBELO was issued a study permit, Based on Ms. LIBELO’s successful study permit application, her husband was issued an open work permit. Investigator Note: When a study permit is issued to a foreign national with a spouise who is accompanying them, the spouse is entitled to apply for an open work permit. 23, Between March 29, 2018 and May 17, 2018, | used an excel spreadsheet provided by Investigator WHITTAKER to find names of foreign nationals who applied for study permits using BENITO as their consultant. This spreadsheet was exported from GCMS by Investigator WHITTAKER and was the result of query of the email address: helpingmigrants@gmail.com, which he received from Officer MARTIN. This email address was associated to BENITO. It contained names ofall foreign nationals who used that email as a contact email address for their applications. Using this information | pulled a sample of names of foreign nationals who applied for study permits and whose ‘main contact email address was helpingmigrants@gmail.com. As mentioned previously this email ‘address is associated to Triple Maple Leaf, World Immigration and Helping Migrants. This list included 18 foreign nationals. 24. On April 5, 2018, | ran a Canadian Police Information Centre (CPIC) query for BENITO. The check was non resultant for criminality in Canada and the USA, Results from the Registered Owner query produced the fotlo 4. Carlito Manansala BENITO date of birth, February 21, 1954, is associated to Driver's Licence ‘number 122909377; , Address of 7360 Singer Way NW, Edmonton AB T6R3R9: . Phone number 780-246-7193; and 4d. Registered owner of a 2008 Mercedes Benz, plate LYMI88. 25. On April 9, 2018 I received an email from Officer MARTIN which contained an excel spreadsheet with a list of 23 foreign nationals she identified in relation to IRCC’s investigation on ‘study permit applications. This list included foreign nationals who applied for study permits using BENITO and or Charles BENITO as their consultant. Of the 23 names, she identified eight, through her regulatory investigation whom obtained valid study permits but are in violation of subsection 220.1 of IRPR, as they failed to attend school, For all applications made by BENITO and or Charles BENITO the foreign nationals showed proof of funds to be between $17,000 and $20,000. Most ‘were workers whose permits expired and were applying for restoration through a study permit, and ‘most were applying (o attend a program of study that had no relation to the line of work or purpose of stay in Canada. Some of these applications were refused, as IRC did not believe these persons to be ‘genuine students and were not satistied that they would leave at the end of their authorized stay. Page 7et3 4. x) ‘orsz024 200708) inure ~ Poles Fs Wo. |W tidenttcaon 1" ar eoever de polce v2001924C Investigator Note: Restoration of temporary resident status applies when a visitor, student or worker hhas lost their status but makes an application to reinstate or restore their status within 90 days of it expiring. 26. On April 11, 2018 I called Arie! BAUTISTA, whose name was included in the list provided by Officer MARTIN, listed as one of the foreign nationals in violation of subsection 220.1 of IRPR, He agreed to come into the CBSA office on April 12, 2018 for an interview. 27. On April 12, 2018 1 queried Ariel BAUTISTA in GCMS and learned the following: a. His authorized consultant was BENITO of Triple Maple Leaf‘ Canada; b. He arrived in Canada and obtained a work permit on September 29, 2008; «. He had a work permit with a Labour Market Impact Assessment (LMIA) to work as a Journeyman from September 9, 2014 to September 8, 2016; 4, He made an application for a study permit on August 30, 2016 to study at the Academy of Learning, shortly before the expiry of his work permit; ¢. In his application to IRC he submitted proof of funds in the amount of $22,800; £. Based on this application and supporting documents, study permit number F311200408 was issued Mr. BAUTISTA on October I, 2016; g. He made an application for a work permit on September 9, 2016 (prior to receiving a response for his study permit application), however it was refused as he did not have a valid LMIA; Investigator Note: A Labour Market Impact Assessment (LMIA) is a document that an employer in Canada requires before hiring a foreign worker. A positive LMIA will show that there is a need for a foreign worker to fill the job and that no Canadian worker is available to do the job. 1h, He made an application for another study permit, on January 27, 2018, close to the expiry of his previous study permit application, however this application was refused. as the IRCC Officer did not believe it was a genuine application; and i. His consultant for this study permit application was Charles BENITO of World Immigration Group at 7360 Singer Way. NW Edmonton AB, and helpingmigrants@gmail.com. 28. On April 13, 2018, Investigator WHITTAKER and I went to Mr. BAUTISTA’ residence as he did not appear for his interview the previous day. He informed us that he spoke with BENITO's office and they told him it was not necessary for him to attend the CBSA office and that they would take care of it. Afler speaking with him, he agreed to attend the CBSA office later that day. At 1300hrs Mr. BAUTISTA and his wife came into the CBSA Office for an in person, video and audio recorded interview. From this interview I learned the following: a. He first met with BENITO in July or August of 2016. as he wanted to apply for Permanent Residency and his status was nearing ex; b. He met BENITO at his office in the Ramada Hotel in Edmonton, where BENITO had numerous staff working, including his son; ¢. BENITO gave him the following options to maintain his status in Canada: Humanitarian and Compassionate Permanent Resident application; Have his common law apply to sponsor him for permanent residency; and ‘Study permit application, 4d. On BENITO'S advice he decided to submit an application for permanent residency under ‘humanitarian and compassionate grounds, He needed to maintain status in Canada while he waited for the application to be processed. To remain in status he was advised to apply for a study perm: ¢. He had the money for proof of funds for the study permit application but it was in RRSP's. Pogo $0131 1% ALBERTA, ‘orsz02« res) aaioc io -Paiea Fe No 1 eienstcoton-W" aa Gosier de ple v2001924C BENITO told him to remove it from his RRSP and transfer it to his regular bank account to show it as being accessible; f. He was issued a study permit for the Academy of Learning, he had the funds to attend school, however did not attend school. Instead he found employment as a cleaner, as he needed to save ‘money to send back home to his kids and his mother. He also needed money to pay for his Humanitarian and Compassionate application fee and BENITO'S professional fees (still owes BENITO $7000); 8, When his study permit was nearing expiry hte went to BENITO again and another study permit application was submitted, but this time for Makami College, this application was refused by IRCC, as they did not believe he was a genuine student. 29. On April 16, 2018, CBSA Inland Enforcement Officer Mike FRASER informed me that he had a subject in custody who appeared to be working without authorization for Helping Migrants, immigration consulting company owned by Charles BENITO. The subject in custody was Maryann OCAY, a Filipino foreign national. OCAY was arrested by Edmonton Police Service for an ‘outstanding immigration Warrant. When FRASER interviewed OCAY at CBSA and searched her belongings he found the following items in her possession: 2. Paystubs for employment at Helping Migrants dated February 28, 2018 and March 13, 2018 with ‘an address of 7360 Singer Way NW. Edmonton AB T6R3R9; and », Letter confirming her employment at Helping Migrants from September 16, 2016 to present, written and signed by Charles BENITO with contact information, helpingmigrants@gmail.com and 780-340-4308, 30. Officer FRASER reported OCAY in the regulatory stream, under subsection 41(a) and 30(1) of IRPA for failing to comply with the Act, specifically working without authorization for Helping Migrants at 7360 Singer Way NW. Edmonton AB T6RIR9. Investigator Note: A foreign national may not work on Canada unless they are authorized to do so under IRPA. A foreign national found to be working without authorization may be reported under the regulatory stream for Non-Compliance with the IRPA. 31. I queried Maryann OCAY in GCMS and learned the following 1 Her authorized consultant was BENITO of Triple Maple Leaf Canada; She entered Canada on December 9, 2009 and was issued a work permit valid until December 8, 2010; . She applied for a study permit on October 17, 2016 with proof of funds listed as $36,000, however it was refused on November 11, 2016; 4. Prior to refusal of the study permit, she was refused three work permit applications and an Humanitarian and Compassionate application; and €. She had been without status in Canada since May 20, 2015. 32. Afier Officer FRASER was finished with his regulatory process, Investigator WHITTAKER and | conducted a video and audio recorded interview of OCAY. During this interview OCAY stated the following: a. She made the paystubs and letter of employment herself. as she is volunteering at the Immigration Consulting office at the Ramada Hotel, office of BENITO and Charles BENITO. but she was never paid: b, She confirmed that BENITO and Charles BENITO both work at the Ramada Hotel, she BENITO goes by Carl and his son goes by Charles; ¢. She ereated the paystubs and letter of employment so she could obtain a car loan: d. She used BENITO as her consultant to apply for a study permit in December of 2016 to restore her ‘talus, in order (0 do this she borrowed money from her cousin; Praeger Ah id) ‘orsz024 200705) ident ne, —Potea Fie no Pr ddenticaton 1" de doer de potce v2001924C ¢. For the study permit application she had to show the Canadian Government that she had $36,000; f. This study permit was refused by IRC: & Her address on her driver's licence is listed as 7354 Singer Way NW, Edmonton T6R 3R9; h, This address is owned by the BENITO"s and there are four Filipino’s staying there: i. When she volunteers she answer's phones, there are approximately five or six people plus his son working there; j. There are no other volunteers, the other workers are Permanent Residents and; k. She used BENITO as her consultant for her current Humanitarian and Compassionate application which is still pending, 33. On April 17, 2018, I spoke with Ms. LIBELO over the phone and arranged for an interview with her on April 27, 2018. I requested that she send an email with all documents relating to her study permit and proof of funds, along with any transaction slips or bank records she may have, prior to the imerview so I could review them. 34. On April 18, 2018, Investigator WHITTAKER and | attempted to do a garbage pull at BENITO's residence, 7360 Singer Way NW, Edmonton, AB and 7354 Singer Way NW, Edmonton, AB. We ‘were unable to pull the garbage as it was not out on the curb, however we observed who was later confirmed to be BENITO’s son, Charles BENITO, leave 7360 Singer Way, walk two houses down to 7354 Singer Way, open the garage, and leave in a black Volkswagen Passat, plate number BXV3373. ‘On our way back to the office we drove by the Ramada Hotel where BENITO's business is located, {In the parking lot in front of the Ramada Hotel business centre entrance we recorded the following, plate numbers: a. BXV3373 AB; b. STAR99 AB; and c. BNWI659 AB, 35. Afler returning to the office | queried the plate numbers through CPIC. They came back as being registered to the following people: a. STARS9 AB — 2017 Black Convertible Mercedes Benz ~ Estrella BENITO, born February 10, 1955. 7360 Singer Way NW, Edmonton AB: b. BNW1659 AB 2011 Black Nissan Murano ~ Claire Bangalisan MAGLAQUE, born June 24, 1979 and; ¢, BXV3373 AB — VW Jetta ~ Estrella BENITO, born February 10, 1955. 7360 Singer Way NW, Edmonton AB. 36. then queried Claire MAGLAQUE through GCMS and learned the following: a, Her mailing address is listed as 7360 Singer Way NW, Edmonton; b. She currently holds the status of a visitor, however her visitor record expires on April 30, 2018; and ¢. The consultant for that application was Carlito BENITO. 37. On April 19, 2018 I ran a CPIC query for Charles BENITO and learned the following: a, Charles Jefferson BENITO date of birth, June 9, 1994, is associated to Driver's Licence number 159073840; . Address of 7360 Singer Way NW, Edmonton AB TOR3R9; and Poge 10131 ah 10 ALBERTA, ‘ersz024 00778) ene ie ~Polea Fe No. i edenticnton 1" ds dosir de paleo v2001924C cc. Phone number 80-863-8959. 38. On April 19, 2018 | queried Jayson TAUYA, in GCMS, a name | obtained from Officer MARTIN’s referral. From this query I learned the following: 4. His authorized Consultant was BENITO of Triple Maple Leaf Canada; b, He made an application for a study permit on February 9, 2016 to study al the Academy of Learning; €. TD Bank Account statement for the account belonging to Mr. TAUYA was submitted showing proof of funds dated January 28, 2016 with a balance of $17.195; 4d. Based on this application and supporting documents, study permit number F311041210 was issued Mr. TAUYA on February 17, 2016. 39. On the same day, April 19, 2018, | spoke with Mr, TAUYA on the phone he confirmed he would attend the CBSA Office on April 23, 2018 for an interview. I requested that he email all the documents pertaining to his study permit in advance including any bank information relating to the transaction of money between him and BENITO. That same day Mr. TAUYA emailed me the following documents: a. Client Assessment form for Triple Maple Leaf Canada completed by Mr. BENITO listing all application options available to Mr. TAUYA, dated January 21, 2016: BA i consultation agreement dated January 21, 2016, signed by BENITO and Mr. TAUYA; ©. Copy of receipt for $150 for payment made to BENITO on January 21, 2016 for the Initial Consultation; d. TD Bank account statement dated January 28, 2016, in Mr. TAUYA's name showing a balance of $17,071.45, and total assets of $17,195.70; ¢. TD Deposit Account History Financial Enquiry for Mr. TAUYA pertaining to transactions between December 1, 2015 and December 22, 2017. Included in this document were two transactions made on January 28, 2016, one transfer of $17,000 into Mr. TAUYA’s bank account ‘made from branch number 8194 and one transfer of $17,000 out of Mr. TAUYA"s bank account made at branch number 02: £. An official receipt dated March 10, 2016, from BENITO at Triple Maple Leaf Canada for an consultation assessment and study permit application, totalling $1,650 and noting the dates of payment for each service. 8, Client Record of Visit for Triple Maple Leaf Canada, 7360 Singer Way NW Edmonton, AB at 780-298-4308 helpingmigrants@gmail.com, dated January 28, 2018 for the payment for study permit application assistance; |. Copy of receipt for $750 payment made to BENITO on January 28, 2016 for an assistance fee for Mr. TAUYA’s study per 40. On April 23, 2018, Investigator WHITTAKER and |, interviewed Mr. TAUYA. In this interview Mr. TAUYA stated the following: a. In January 2016 he met BENITO in the Chinook Mal was eight months away from work permit expiry; Calgary, Alberta, At this time his status ». He set up an appointment to meet BENITO at BENITO’s home office in Edmonton; ¢. BENITO's home was being used for the immigration business. When Mr. TAUYA arrived there were other clients waiting to see BENITO. Mr. TAUYA was instructed to go down slairs where a secretary behind a desk signed him in and took his information, He was then instructed to wait untit BENITO was free and when called to go upstairs to a room BENITO had his office in. in BENITO's office there was a computer, filing cabinets and lots of papers, you could also see out of the office, into another waiting room; Ameer ALBERTA cers2oa« acorns) 1v2001924C 4, BENITO gave him the following options to maintain his status in Canada: i. Marry a Canadian Citizen or Permanent Resident; Humanitarian and Compassionate Permanent Resident application; and iii, Study permit application. «. During the consultation these options were written on a Triple Maple Leaf Canada client assessment form dated January 21, 2016, BENITO walked Mr. TAUYA through all application options available, Mr. TAUYA said BENITO went through the above options on the assessment form writing in the costs and time frames of the applications. Included in this list was a study permit application, and a hand written note below with the following information regarding the study permit applicati study permit ($150+10) “LOA”. $17K ($250 CASH) $250+10 $1,500; Mr. TAUYA said the hand written notes on the document referred to the following: i, Study permit with $150 written underneath, is the cost associated to the permit; ji, “LOA” stands for Letter of Acceptance; iii. $17K with $250 cash writen below, $17K was the amount BENITO would loan him and the ‘$250 was the fee associated to the short loan; and iv. $1500 is what BENITO charges for processing the permit. &. BENITO told Mr. TAUYA the study permit application was his best option, however he would heed to show he had $17,000 in his bank account to meet the IRC requirements; hh, He told BENITO he did not have the money, BENITO told him that was no problem, they would help him; i. There was a lending fee of $250.00 to be paid in cash for the borrowing of $17,000; j. In referencing the TD Bank Deposit Account history in Mr. TAUYA’s name, showing the transfer ‘of $17,000 into his account on January 28, 2016 and then the transfer of the $17,000 out of the account on the same day, he stated the following: i. BENITO’s secretary, who he knows as, Gigi MAGTALAS drove him and an unknown Filipino also in need ofa study permit, to two TD bank branches; fi, Ms. MAGTALAS had $17,000 cash; iii, Ms, MAGTALAS deposited the $17,000 cash into the unknown Filipino’s bank account; iv, The unknown Filipino then transferred $17,000 into Mr. TAUYA’s bank account; v. Mt. TAUYA received a statement from TD Bank showing his account balance, date stamped January 28, 2016; and vi, Ms. MAGTALAS assisted Mr. TAUYA in transferring the money out of his account into another account on the same day. k. He could not afford the tuition to go to school, and support his family in the Philippines, therefore ‘was unable to attend school. He was told by BENITO that he did not have to go to school, and he ‘could work 20 hours a week 2s per the conditions on a study permit, until he obtained an LMIA for a new job; |. He applied for and received a study permit for the Academy of Learning along with a work permit, however never attended school; and m, Mr. TAUYA said BENITO was his consultant whom he trusted so he followed his instructions. 41, On April 23, 2018, I received an email from Officer MARTIN with an updated list of foreign Page 120194 @& Ae corsz02s 20105) darter Poiea Fe Wo, I aidentcaton “ds dose de potce v2001924C nationals she identified in relation to IRCC’s investigation on study permit applications, In addition to the 23 names she previously provided me, she added an additional three foreign nationals who used BENITO to apply for study permits and did not attend school 42. On April 27, 2018, Investigator WHITTAKER and |, interviewed Ms. LIBELO over the phone. Prior to the interview Ms. LIBELO emailed a package of documents to me containing 20 pages, ‘hich I will reference below. During this interview Ms. LIBELO stated the following: a. She first learned of BENITO on her facebook newsfeed, and contacted him in April 2016, as her and her husband’s status was due to expire in June 2016; b. Their first meeting with BENITO and Triple Maple Leaf Canada, was on April 21, 2016; ¢. Prior to this meeting BENITO sent her a text with the times and location, Ramada Edmonton South Hotel 5359 Calgary Trail, 780-246-7193 (phone number from his driver's licence query), and listed the following number in the text, 587-335-4308; 4. At this meeting they were given the following options by BENITO: i. Study Permit; Express entry; and. . Humanitarian and Compassionate Permanent resident application. €. BENITO (old them the easiest way to get status was through a study permit application, as the express entry you need to do a test and obtain a LMIA and the Humanitarian and Compassionate application requires being in Canada for a long period of time; F. They chose to make a study permit application because they were running out of status and this would provide Mr. LIBELO with an open work permit; &, They did not have the money to meet the financial requirements of the study permit applicat h. BENITO told them he could lend them the money for the application; i. BENITO asked them to speak to his secretary, who told them to open a TD Bank account; j. Ms. LIBELO and her husband opened a joint TD Bank account; k. After opening the account, they went back to Triple Maple Leaf Canada office at the Ramada Hotel and the secretary took them to another TD Bank; |. At this bank $17,000 was transferred into the LIBELO’s TD account, They then obtained a statement summary from the bank to demonstrate proof of funds to IRC in support of Ms. LIBELO’s study permit application; 'm. They then went to another TD Bank and transferred $17,000 back to the secretary; 1. Ms, LIBELO cannot remember the secretary's name; ©. All the transfers were done electronically and on the same day, April 21, 2016; P. The fee for the borrowing of $17,000 was $450 paid in cash, no receipt was provided. 1 was listed fon the sticky note attached to the retainer agreement, which she provided by email prior to the interview; 4, In August 2016, she obtained her study permit for the Academy of Learning: She ‘not attend school, as they did not have the funds to do so; 8. Ms, LIBELO stated BENITO was aware they did not have the money to attend school, however she acknowledged that they vequired the study permit in order to obtain an open work permit for her hhusband fo work fo support their family. At the timie the LIBELO'S were actively tying to start a familys and Page 130131 4% Mw ccrsz0ze (200708), dane Na Poca Fa Wo, Iw aidentcston -¥ 8 dose de polce v2001924C {Included in the emailed documents received from Ms. LIBELO was photocopies of phone sereenshots showing e-transfers of various amounts sent from her bank to BENITO"s email at carlbenito2012@gmail.com, 43. On May 5, 2018, I received a report from The Financial Transactions and Reports Analysis Centre of Canada (FINTRAC). From this report | learned the following: a. On March 16, 2016, Charles BENITO deposited $10,000 cash into an account held by Helping Migrants Canadian Immigration Corp. 44. On May 8, 2018, I conducted a CORES search of Helping Migrants Canadian Immigration Corp and learned the followir 4. The sole director is Charles Jefferson BENITO of 7360 Singer Way, NW Edmonton, AB T6R3R' b. Itis a named Alberta Corporation with a registration date of January 21, 2016; and. ¢. The registered office and Records address is 7360 Singer Way NW Edmonton, AB T6R3R9. 48. On May 9, 2018, | received an email from the GCMS information request I had submitted on March 29, 2018. The email contained information related to all applications submitted by BENITO and his companies. 46. On May 22, 2018, a Production Order for documents along with a sealing order was approved by Provincial Court Judge L.K. STEVENS and was submitied to TD Bank Group with a due date of June 22, 2018, The Production Order ordered the TD Bank Group to provide information for all the {transactions surrounding the transfer of $17,000 into and out of both TAUYA and LIBELO's bank accounts and information on what other accounts the $17,000 went into and the names of the account holders. 47. On May 23, 2018, | queried Maria CARSON in GCMS, a name | obtained from Officer MARTIN'S referral and the GCMS information request. From this query I learned the following: 8. Her authorized Consultant was BENITO of Triple Maple Leaf Canada of 7360 Singer Way NW. Edmonton, carlbenito2012@email.com; b. She made an application for a study permit on December 23, 2015 to study at the Academy of Learning; 6. Royal Bank Account statement for the account belonging to Ms. CARSON was submitted showing proof of funds dated November 18, 2015 with a balance of $18,096; 4. Based on this application and supporting documents, study permit number F31 1012638 was issued Ms. CARSON on January 24, 2016; ©. On November 30, 2015 her work permit expir £. On January 5, 2016, she submitted a work permit extension, which was refused by IRCC on April 15. 2016, as she did not submit a valid LMIA with her application, therefore submitted an incomplete ‘application; and &. From November 30, 2015 to April 15, 2016 (approximately 4 months) she benefited from implied status and was eligible to work, 48. On May 23, 2018, I queried Gleneth TOMAYAO in GCMS, a name I obtained from the GCMS information request. From this query | learned the following: 4. She made an application for a study permit on December 23, 2015 to study at the Academy of Learning; b. Her address associated to the application was 7360 Singer Way NW, Edmonton; . She applied to attend the Academy of Learning and provided proof of funds for $24,946; Page 140131 erszezs (200705) ere Ne Potee Fea rr ezansseshan 1dr does de poles v2001924C 4. Her application was refused, as 90 days had passed since the expiry of her temporary resident status and she was no longer eligible for restoration: and ‘¢. She was sent a letier from IRCC on April 12, 2016 advising she no longer had status and must leave Canada. 49. On May 23, 2018, CBSA Investigator Jim WHITTAKER interviewed Maria CARSON. Ms, CARSON was identified as being a client of BENITO’S through the GCMS information request and information received from Officer MARTIN. Based on the video and audio recorded interview and Investigator WHITTAKER’S notes | learned the following: 2 Ms, CARSON had a work permit at Tim Horton’s which was about to expire on January 25, 2016, She looked for another employer to complete LMIA but was unsuccessful and became concerned she ‘would have to leave Canada once her work permit expired; b. Ms. CARSON, learned of Carlito BENITO and Triple Maple Leaf Canada through friends and was instructed by them to watch Mr. BENITO’S facebook videos on the services he provides for people in her predicament; ‘¢. On November 11, 2015, Ms. CARSON called Triple Maple Leaf Canada and was instructed to attend at 7360 Singer Way S.W, Edmonton which was Carlito BENITO's house and home office of ‘Triple Maple Leaf Canada; d. Ms. CARSON paid an initial consultation fee of $150 (o BENITO'S secretary, she then met with Carlito BENITO; ¢. BENITO completed a “Client Assessment” form with Ms. CARSON and went over several options for Ms. CARSON to extend her status in Canada and possibly obiain Permanent Residence. ‘The options were written and explained by BENITO and are as follows: i. Apply for a work permit extension without an LMIA which would result in a guaranteed refusal by IRCC. However, during the decision making process which usually takes four months Ms. CARSON ‘would have implied status and could work ($155 government fee and $450 consultant fees); Once the refusal letter comes from IRCC, Ms. CARSON could apply for restoration of status and either apply for a tourist visa or another work permit ($355 government fee and $450 consultant fees): or ili. Apply for a Study Permit, $1500. £. Ms. CARSON said BENITO told her that she would need to show she had $17,000 in her bank ‘account for the study permit application to be approved. BENITO explained to her that the proof of finds was a requirement for the application so the IRC would be satisfied she could support hersell™ while she was studying. Ms. CARSON said she had approximately $5000 saved and could ask her Uncle for a loan but said it would have taken too long. Ms. CARSON said BENITO told her that for ‘$250 he could arrange a loan for the $17,000 so that she could get a bank statement showing she had the funds for the application. Ms. CARSON said BENITO instructed her (o return the next week. Ms. CARSON then went with BENITO'S secretary “Gigi” to the bank and had the $17,000 deposited into her account. Ms. CARSON said she and Gigi had to attend several banks to withdraw the funds as they would only let her take $5000 out at a time. The funds were given back to Gigi. 8, Ms. CARSON had BENITO’S office submit an application for study permit to the Academy of Learning, a designated learning institution in Edmonton. The application was supported by Ms. CARSON'S bank statement showing she had in excess of $17,000 to support her while she attended school. The study permit application was successful and Ms. CARSON received a study permit. The study permit was issued January 24, 2016 h. Ms. CARSON never attended the Academy of Learaing, she did not have the funds to attend school. but as she had implied status she did find another employer to apply for a LMIA, She applied for and received a new work permit for new employer EDO Japan on October 12, 2016. CARSON hhas worked for EDO Japan since that date, i. According to GCMS records and Investigator WHITTAKER's notes, shortly after the study permit application, IRCC received a work permit extension for the same employer that Ms, CARSON had a work permit for and was soon to expire. The work permit extension did not have the required LMIA, Page 150131 ty wd ‘orsz024 007m) Tenia na = Poe Fe |W aizensicstn 1" de Sosse de poco v2001924C ‘and was submitted to take advantage of implied status forthe four months it would take IRCC to process and refuse the application Investigators note - The “Client Assessment” form completed by BENITO provides direct evidence BENITO knowingly counselled Ms. CARSON to: ~ Submit an incomplete work permit extension application without the required documents knowing it would be refused by IRCC: and + Provide a $17,000 loan for a fee of $250 so Ms. CARSON could provide a bank statement showing she had the funds in her bank to live in Canada as a student. 50. On May 24, 2016, CBSA Investigator WHITTAKER interviewed Glenneth TOMA YOA. | identified Ms. TOMA YOA as being a client of BENITO through GCMS queries of BENITO's business email address. Based on the videotaped interview and Investigator WHITTAKER's notes | leamed the following: a. Ms, TOMAYOA found herself without a job after working as a food counter attendant for one year; b. Ms. TOMAYOA learned of BENITO through his business Facebook site and called Carlito BENITO to set up an appointment in his office; ¢. Ms. TOMAYOA attended the BENITO office which at the time was located at the Delta Hotel in south Edmonton. While there Ms. TOMAYOA met with BENITO who completed a Client ‘Assessment form and provided Ms. TOMA YOA with several options to extend her stay in Canada or obtain Permanent Residency. According to the Client Assessment form the options written by BENITO are as follows: i. Spousal sponsorship, BENITO wrote on the form for TOMAYOA to go to www.plentyoffish.com (0 find a suitable Canadian candidate to marry her. $550 application fee; ji, Obtain a supervisor LMIA and apply for Permanent Residency. $550 application fee; iil. Apply for a Study Permit takes 3-4 months for the process. $1500 application fee; 4. Ms, TOMAYOA chose to apply for a study permit and did have the funds in her bank to satisty the requirements of the application, However, according to notes in GCMS, mentioned above, Ms, ‘TOMAYOA's study permit was refused by IRCC, as her status was no longer restorable. Ms. TOMA YOA was asked if BENITO loaned her money for her study permit application. Ms. TOMAYOA stated that she had her own funding for her study permit application. Ms, TOMAYOA said she knew it was occurring and did admit that in Aprit of 2018 she picked a Filipino foreign national up at BENITO'S Ramada Hotel office. She drave him to the TD Bank and loaned hit $12,000 for the day so he could show he had the money in his account. The money was then transferred back to her. Ms, TOMA YOA received $500 eash for this loan, £. Ms. TOMAYOA stated that she knew many of the workers that BENITO used in his business at the Ramada Hotel, Ms. TOMAYOA said there were numerous Filipino nationals working in the office, many of whom she knew had no authorization to work anywhere in Canada. Ms. TOMA YOA said some of the people had no status to even be in Canada and were waiting for Humanitarian and ‘Compassionate applications to be decided upon with IRC. 51. On June 6, 2018, static surveillance of BENITO and Charles BENITO's businesses, Triple Maple Leaf Canada and World Immigration and Helping Migrants was conducted in the parking lot of 5359 Calgary Trail, Ramada Hotel Edmonton South. Investigators attended the location at 7:30 A.M prior to business hours and positioned so they could observe possible employees park and enter the business. Licence plates were communicated back to CBSA office where I completed the following CPIC queries on the license plates of individuals observed entering the business centre location prior 10 or shortly after business opening hours of 9:00 A.M. Based on the CPIC results| ran queries through GCMS and learned the following: a, DE LA CRUZ, Daisy, registered owner of plate BZN9425 |. Currently on a valid study permit for Makami College; and ii, Used BENITO as her consultant, Popo 1634 MB no ALBERTA ‘crs2024 200706) va001924¢ b. AGUILA, Severino, registered owner of plate BYM1403, i. Currently without status; Has a Humanitarian and Compassionate Permanent Resident application approved just hours (une 6, 2018). Has been without status since September 20, 2017; ea iii, Applied for three study permits, using BENITO as his consultant, The first two showing proof of funds as over $30,000 for Makami College and the last one showing proof of funds as $17,000 for the Academy of Learning: and . Address in CPIC is 7354 Singer Way NW, Edmonton which is owned by Estrella BENITO. ¢. ELMAN, Ma Jesicca Manalo, registered owner of plate BTV5385, i. Currently without status in Canada; Has an outstanding exclusion order; and She is included on the list that was provided to me by Officer MARTIN, persons who used BENITO as their consultant and obtained a study permits, however are either confirmed or suspected of not attending school. Investigator note: An exclusion order is a type of removal order issued to those in violation of the IRPA which means the person cannot legally remain in Canada and must leave the country. 4d, UBALDO, Lorna Dela Pena, registered owner of plate BNJO844 i. 1s currently a Permanent Resident of Canada through a Humanitarian and Compassionate application; and ii, Had applied for a work permit which was refused on March 9, 2016, as there was no valid LMIA submitted, €. BENITO, Estrella, registered owner of plate BXV3373 i, Canadian citizen and ii, Spouse of Carlito BENITO. {Using the facebook Helping Migrants Canada website, Investigator WHITTAKER identified Charles BENITO as the driver of the vehicle bearing plate BXV3373, Charles parked, exited vehicle ‘and was seen to be carrying a banker box with what appeared to be full of documents into the imigration consulting office loacted in the Ramada Hotel business centre. &. At the time surveillance was discontinued at 11:00 A.M those individuals were still atthe location. 52. On June 7, 2018 static surveillance continued atthe same location. Licence plates were again ‘communicated back to the CBSA office where queries were completed. ‘The following foreign nationals were observed entering the business prior to or shorily after business opening hours: a. CONTRERAS, Joseph registered owner of plate BXFO678: i. Currently on a valid work permit until June 5, 2019 on valid for employment at a specific location in Faweett, Alberta, b, UBALDO, Loma : registered owner of plate BNJO844: i, Permanent Resident of Canada, ¢. ALLADO, Anthony registered owner of plate BWC8497: i. No Status in Canada; Page 17031 Wa orsaozs 0070s) Titer Wa ~ Pen Fie Wa 1 ionstcston-1 as Cesir de police v2001924C ‘mailing and residential address is listed in GCMS as 7360 Singer Way, NW Edmonton, 4d. OCAY, Maryann, registered owner of plate BSW3679 i, No Status in Canada, she is currently in CBSA removal process and is mentioned above, as Investigator WHITTAKER and | interviewed her on April 16, 2018 when she was arrested by Inland inforcement for working without authorization for Charles BENITO; ¢. ELMAN, Ma Jesieca Manalo i, Currently without status in Canada; and ii, She was observed ai and entering the building the previous day of surveillance. 1. At the time surveillance was discontinued those individuals were still atthe location, On the same date at 2:00 P.M, Investigator WHITTAKER conducted a drive by at the Ramada Hotel location and noted that all vehicles identified in paragraph 48 were still parked in their original parking spots. 8. This surveillance operation supports the statements made to Investigators during the interview of Ms. TOMAYOA. During her interview she stated that BENITO typically employs a number foreign nationals who are without status, some of which are waiting for pending humanitarian and ‘compassionate applications. Investigator Note: A foreign national is unauthorized to work in Canada if they do not have valid ‘work permit. Ia foreign national has a work permit with an LMIA. it will specify a work location and authorized to work, They can not work in a location or in a position other than specified on their permit. 53. On June 8, 2018, drive by of BENITO and Charles BENITO’s businesses, Triple Maple Leaf, World Immigration and Helping Migrants Immigration located at 5359 Calgary Trail T6H49 Ramada Edmonton South was conducted. Vehicles belonging to the following subjects, identified in previous surveillance, were in the parking lot at 1040hrs on June 8, 2018: a, OCAY, Maryann; b. ELMAN, Ma Jesicca Manalo; ¢. UBALDO, Loma; and . DE LA CRUZ, Daisy, 54. On June 11, 2018, | spoke with Audrey BRATTBERG, the Owner and Administrator forthe Academy of Learning. | introduced myself and explained | was looking for confirmation of student attendance for foreign nationals whom received a Letter of Acceptance from her institution, Ms. BRATTBERG said she would provide that information once | sent an email withthe student names ‘nd dates of birth. { sent an email to her with the names of foreign nationals who had received acceptance leiters to the Academy of Learning. 55. On that same day I also spoke with Shannon SNIDER. the Director of the Student Advisory Services Department for Makami College. Ms. SNIDER advised me that she will provide us the information we require and may also send additional names from her audit. An email was sent to her with the names of foreign nationals who had received acceptance letters to Makami College. Ms. SNIDER said she would follow up with an email confirming attendance for those students. 56. On June 12, 2018, Investigator Whittaker received a call from Ariel BAUTISTA. Mr. BAUTISTA had been asked to call Whittaker for a follow up interview. Based on WHITTAKER’S notes | learned the following: a. Mr. BAUTISTA said that he was told by Carlito BENITO that he needed to submit a work permit extension so that he could remain working past the expiration of his current work permit; b, Mr. BAUTISTA said his employer was not willing to extend his work contract and never did apply fora new LMIA for him so he could continue working; ¢. Mr. BAUTISTA said BENITO told him that he would submit a work permit extension without the required LMIA so that he would receive implied status until the study permit that was in process was approved: and Page 18et31 0 ‘ors202s goo705) Fie Ne 1 exeaitcoton-1" ds desir potce 1001924C d. Mr. BAUTISTA said he knew the work permit extension would be refused because it was incomplete, 57. On June 12, 2018, | sent DF! ( Digital Forensic Investigator) BOYLE SUFFIELD the following Phone numbers for her to search through Whooster, an investigative tool she utilizes as a DF: 8. 780-246-7193 belonging to Carlito BENITO obtained through a driver's licence query: +, 780-850-2275 belonging to Carl Mark BENITO obtained through a driver's licence que ©. 780-863-8959 belonging to Charles Jefferson BENITO obtained through a driver's licence query; and 4, 587-335-4308 and 780-298-4308 found in GCMS associated to applications made by Triple Maple Leaf Canada and or World Immigration Group. 58. DFI BOYLE SUFFIELD’s search concluded that all the above phone numbers are cell phones numbers. 59. DFI BOYLE SUFFIELD also searched additional phone numbers which she found on BENITO's Facebook page “Carl Benito Triple Maple Leaf Canada”, She confirmed that they are all associated ‘o cell phones. She provided me a copy of the sereen she viewed where the phone numbers and ‘contact information are listed. From this I learned the following: 4. Contact information is provided for Facebook, WhatsApp, Viber, Skype, Tango, call, and text, Providing the ability to communicate and provide services to people internationally. ‘These are all services related to online computer communications and cell phone communications allowing people {0 communicate internationally for free over the internet. This page lists Team Canada, with the following phone numbers and or contact information: i. Kuya Carl BENITO: a, www.Facebook.com/Carl Benito; b. 780-863-8959; . wow.Facebook.com/KuyaCarl Benito.1; 4d, 587-335-4308; and ¢, Skype address: Carl Benito 2012; ii, Cheska SANTOS: a, www.Facebook.Com/YnaCruz.355; b. www.Facebook.com/Cheska.Santo,946954; ©. 587-336-4308; 4, 780-271-4308; and ¢. 780-271-4308. i. Charles BENITO: a. www. Facebook.com/Charles.Benito.98 b, 780-298-4308; iv, Laisa LEE (Quezon): a. www Facebook.com/profile.php?id=10001596586611 b. 780-298-4308; ¢, 587-437-4308; 4. www. Facebook.com//Queenie.Uy. 1481; and 403-702-4308 v. Mark BENITO: ‘a, www.Facebook.com/Mark.Benito.9250; and . 403-702-4308. vi. Atclt GUTIERREZ: a. www. Facebook com/AteLt. Gutierrez; , 780-271-4308; and ©. 587-336-4308, vii. Rosas ECKO (Davao): Wao ALBERTA ‘ors202« 200708) iene ie -Polen Fie na | cdenaicaton =" ds dosti de potce v2001924C ‘a. 780-271-9889, viii, Rain BUENA VISTA; a. www. Facebook.com/Rain, Buenavista; and b, 780-246-7193, ix, Kuya Zanjoe BATANGAS: ‘a, www-Facebook.com/Zanjoe Mars.3; and b. 780-236-4308. 60. On June 13, 2018, | received a response from Audrey BRATTBERG of the Academy of Learning, She confirmed that of the $4 names | provided her, none of the individuals who received a Letter of Acceptance from The Academy of Learning had attended any of their campuses in Edmonton or Calgary. These applications were submitted by BENITO and Charles BENITO acting as consultants. 61. On June 14, 2018, | received an email from Investigator Glenn BONE with results from an Alberta Land Title name search he requested on my behalf. This search shows both Carlito BENITO. and Estrelia BENITO as the owners of 7360 Singer Way Edmonton. 62. On June 15, 2018, | conducted an analysis of the GCMS information request that was completed in order to identify the number of foreign nationals BENITO submitted applications for work permit extensions without LMIA's. This data included all applications associated to BENITO between January 1, 2016 and March 29, 2018, The analysis resulted in 96 incomplete work permit applications made by BENITO on behalf of his clients, all these applications were refused, however by making these applications, these individuals benefited from implied status. 63. On June 14, 2018, CBSA Intelligence Officer Scoit KNOWLES attended Room TC-3, Ramada Edmonton South at $359 Calgary Trail, Edmonton Alberta, Based on Officer KNOWLES notes | eared the following: 4. The room was organized with collapsible plastic tables, set up in a call centre type of arrangement ‘with several tables placed together in several rows spanning the roony; b. There was a sign outside that said Triple Maple Leaf Canada with Carlito BENITO, Charles BENITO and Mark BENITO on the sign; «€. There were approximately 16 people working in the room with an older man assisting someone on ‘laptop at a table atthe head of the room. All individuals were seated and had a laptop in front of them: 4. There were no filing cabinets or noticeable storage areas for documents but did see bankers boxes stored al the back of the room; . There were no land line phones present, only cell phones; and £ Everyone appeared to be of Filipino descent in the room, 64, On June 17, 2018, in reviewing BENITO's website, huip://helpingmigrants.neV in the section “About Carl BENITO" it states that BENITO has been working as an immi Alberta since 2012 and also states that he has a background in Canadian polities and was elected and served as member to the 27th Alberta Legislature representing the electoral district of Edmonton-Mill ‘Woods from 2008-2012. It states that he fully understands that finding work and moving to Canada can prove to be a difficult process and to let him take care of the entire process. so you can fully enjoy your work and your new life in Canada. He also has a percentage rate for suecessful applications which shows his suecess rate for study permits at 95 percent, 65. On June 19, 2018, | confirmed with Tina BADA of Service Canada that between the dates of November |1, 2015 and June 18, 2018, neither BENITO or Charles BENITO or any of tf ‘companies applied for LMIA'S to have foreign nationals working in any of their companies. 66. On June 20, 2018 I received a response from Shannon SNIDER, the Director of the Student Advisory Services Department for Makami College. Ms. SNIDER confirmed that of the 31 names 1 provided her, only six of the individuals who received a Letter of Acceptance from of Makami College had attended their school. OF those six. two withdrew early, two graduated by did not pay ego 2031 Aad ccrs202e 200706) Tertier e-Polea Fas wa, or sceneteston "dv Cosi de polce v2001924C their full ition and one was in good standing. These applications were submitted by BENITO and Charles BENITO acting as consultants. 467. On June 20, 2018, based on the information | had previously received from both Academy of Learning and Makami College, I calculated that 85 foreign nationals were approved study permits by IRC. Of the 85 applicants, only six foreign nationals actually attended school, which means that a {otal of 79 (93%) of BENITO and Charles BENITO’s clients who obtained study permits never attended school, 68. On June 20, 2018, | received documents from TD Bank Group in relation to my Production Order ‘which required the TD Bank Group to provide information for all of the transactions surrounding the transfer of $17,000 into and out of both TAUYA and LIBELO’s bank accounts. Based on thi information | learned the following: a, On January 28, 2016 at 10:43 A.M. $17,000 was transferred from Evan FERNANDEZ to Jayson ‘TAUYA at TD Bank Branch 8194 in Edmonton Alberta; . On January 28, 2016 at 11:34 A.M. $17,000 was transferred from Jayson TAUYA to Allan ALBINA at TD Bank Branch 0296 in Edmonton, Alberta; . On April 21, 2016 at 6:08 P.M. $17,000 was transferred from Elizabeth LOPEZ to Edna LIBELO at TD Bank Brank 8326 in Edmonton, Alberta; and d. On April 21, 2016 at 6:29 P.M. $17,000 was transferred from Edna LIBELO to Remen TORRESS at TD Bank Branch number 0296 in Edmonton Alberta. 669. Based on the information provided by TD Bank Group a search of the names associated to the transfer of funds was completed in GCMS by CBSA Investigator Stuart PETERS. Based on the documents provided by Investigator PETERS and the information | previously obtained through GCMS queries, | learned the following about the names associated to the transfers of $17,000; Evan FERNANDEZ: isa foreign national fi, He applied for a study permit to study at the Academy of Learning: ili. This application was refused; iv. His consultant was BENITO of Triple Maple Leaf Canada; and v. He submitted a statement from TD Bank as proof of funds dated January 28, 2016 (the same date ‘as Mr. TAUYA's bank statement), showing an account balance of $17,637. b, Allan ALBINA: i. tsa foreign national; ji, He applied for a study permit to study at the Academy of Learning: iti This application was refused; and iv. His consultant was BENITO. . Elizabeth LOPEZ: Obiained Canadian Citizenship in 2013. d. Remen TORRESS: Isa foreign national; He applied for a study permit to study at Makar College; ‘This application was approved by IRC iv, His consultant was BENITO of Triple Maple Leaf Canada; and Page hat wr ‘ors2024 200705) aero Ne. Paice Fe Wo, IN aiconeston Wd dossier de poce v2001924C vv. He submitted a statement from TD Bank as proof of funds dated April 21, 2016 (the same date as Ms. LIBELO’s bank statement), showing an account balance of $17,200, 70. Based on the information above, within approximately one hour, $17,000 transited through three of BENITO's clients on January 28, 2016. On April 21, 2016 within approximately half an hour, $17,000 transited between two of BENITO's clients. All five of these clients were applying for study permits. 71. On June 22, 2018, in reviewing the information provided to me previously by Officer MARTIN, 1 searched the name of foreign national, Alojado DANTE. in GCMS whom was listed as one of Charles BENITO’ clients. From this query I leaned the following: 4. His most recent study permit application was refused, the refusal letter was addressed to the client and mrcharlesbenito@gmail.com; and b. There was a use of representative form for Charles BENITO and World Immigration Group with a ‘mailing address of 7360 Singer Way, NW, Edmonton and an email of helpingmigrants.com. 72. On June 25, 2018 I queried mrcharlesbenito@gmail.com in GCMS and obtained a lst of 18 foreign nationals who used this email address for a main email contact. From this list {learned the following in GEMS: a. Seven foreign nationals applied for work permit extensions without valid LMIA's, (much like the 96 applications made by BENITO) therefore with incomplete applications. F, GROUNDS TO BELIEVE AN OFFENCE AGAINST THIS ACT HAS BEEN COMMITTED 73. Based on the above information, there are reasonable graunds to believe the following: Carl Benito Charles Jefferson BENITO Triple Maple Leaf Canada (TML Canada Group) Corp. World Immigration Group (WIG) Corp. Helping Migrants Canadian Immigration Corp. Did knowingly counsel, induce, aid or abet or attempt to counsel, induce, aid or abet persons, to directly or indirectly misrepresent or withhold material facts relating to a relevant matter that induced oor could induce an error in the administration of the Immigration and Refugee Protection Act, contrary to Section 126 of the Immigration and Refugee Protection Act, thereby committing an offenice pursuant 1o section 128 of the same Act; in relation to their study permit applications. My grounds for belief are as follows: 74. Mr. TAUYA stated BENITO counselled him to apply for a study permit even though he had no intention of going to school and did not have the required funds. To support the requirements of the study permit application, BENITO arranged for someone to loan Mr. TAUYA $17,000. The fee for this loan was $250 cash, the result was Mr. TAUYA obtained a bank statement showing he had in excess of $17,000 in his bank, On the same day the funds were returned to the unknown lender. Mr. TAUYA applied for and was approved for a study permit based on the application submitted by BENITO's office through Triple Maple Leaf Conada Mr. TAUYA obtained a study permit, however did not attend school, and BENITO was aware that he would not be attending. 75. Ms. LIBELO stated BENITO counselled her to apply for a study permit even though she did not have the required funds. To support the requirements ofthe study permit application, BENITO arranged for someone to loan Ms. LIBELO $17,000. The fee for this loan was $450 cash. the result was Ms, LIBELO obtained a bank statement showing she had in excess of $17,000 in her bank ‘account. On the same day the funds were returned to the unknown lender. Ms. LIBELO applied for ‘and was approved for a study permit based on the application submitted by BENITO's office through Triple Maple Leaf Canada, Based on this study permit, her husband was also issued an open work permit. Ms. LIBELO obtained a study permit, however did not attend school, and BENITO was aware that she Would not be attending. 76, Ms, CARSON stated BENITO counselled her to apply for a study permit even though she did not hhave the required funds. To support the requirements of the study permit application, BENITO Page 22031 tid ‘ers2024 200705) Teenie Na. Poica Fi Wo |W eeentfestn 1" dv dosed pace v2001924C arranged for someone to loan Ms. CARSON $17,000. The fee for this loan was $250 cash, the result ‘was Ms. CARSON obtained a bank statement showing she had in excess of $17,000 in her bank account. On the same day the funds were returned to the unknown lender. Ms. CARSON applied for ‘and was approved for a study permit based on the application submitted by BENITO. Ms. CARSON obtained a study permit, however did not attend school. 77. Ms, TOMAYOA stated that she knew of BENITO loaning money to study pe they could obtain study permits. She stated that in April of 2018 she picked a Filipino foreign national up at BENITO’ office, at the Ramada Hotel, took him to the Bank and loaned him $12,000 for the day so he could show he had the money in his account. The money was then transferred back to her, and she received $500 cash for this loan, it applicants so 78, Based on the information received from TD Bank Group, on January 28, 2016, within approximately one hour, $17,000 transited through three of BENITO’s clients bank accounts and on April 21, 2016 within approximately half an hour, $17,000 transited between two of BENITO’s clients bank accounts, All five ofthese elients were applying for study permit. 79. A list of 54 names and dates of birth for foreign nationals who obtained acceptance letters was provided to the Academy of Learning on June 11, 2018. These applications were submitted by BENITO and Charles BENITO acting as consultants. On June 13, 2018, the Academy of Learning responded to my request confirming that out of the 54 names provided, none of the foreign nationals ever attended any of their Academy of Learning campuses in Edmonton to Calgary. 80. A list of 31 names and dates of birth for foreign nationals who obtained acceptance letters was provided to Makami College on June 11, 2018, These applications were submitted by BENITO and ‘Charles BENITO acting as consultants, On June 20, 2018, Makami College responded to my request confirming that out of the 31 names provided to them, only six of the foreign nationals attended school at Makami College. 81. Based on the above information, there are reasonable grounds to believe the following: Carlito Manansala BENITO Charles Jefferson BENITO Triple Maple Leaf Canada (TML Canada Group) Corp. World Immigration Group (WIG) Corp. Helping Migrants Canadian Immigration Corp. Did knowingly counsel, induce, aid or abet or attempt fo counsel, induce, aid or abet persons, 10 directly or indirectly misrepresent or withhold material facts relating to a relevant matter that induced ‘or could induce an error in the administration of the Immigration and Refugee Protection Act, contrary to Section 126 of the Immigration and Refugee Protection Act, thereby committing an offence pursuant to section 128 of the same Act; in relation to applications for work permit extensions. My grounds for belief are as follows: 82. Ms. CARSON stated BENITO of Triple Maple Leaf counselled her to apply for a work permit extension when she was not in possession of a valid LMIA in order to extend her status in Canada. BENITO wrote directly on her client assessment that she was to apply for a work permit extension with no LMIA, which would give her implied status until she received a refusal letter from IRC. BENITO counselled her to make an incomplete application knowing it would be refused, so that she ‘would benefit from implied status and could continue working. 83. Mr, BAUTISTA stated BENITO counselled him to submit a work permit extension when he was ‘notin possession of a valid LMIA, nor was his employer willing to obtain one. BENITO counselled him to make an incomplete application in order to benefit from implied status allowing him to work ‘while waiting for his study permit to be processed. 84. Both Ms. CARSON and Mr. BAUTISTA were counselled to make an incomplete application, ‘one that requires a job offer and LMIA to be submited at the time of the application, knowing that it will be refused. They had no intention to actually work atthe location they were applying to work at, and applying for a work permit for a job they had not been offered, therefore misrepresenting or ‘withholding material facts relating to a relevant matter that induces or could induce an error in IRPA. Page 236134 il) sae 2007108) ere No, Paica Fe Wo 17 aenstconon “0 ds desir de poke v2001924C this both of these foreign nationals benefited from implied status, which allowed them both {0 work for a period past the expiry of their work permits and allowed for the processing of their study permit applications. 85, Based on data from the GCMS information request we were able 1o confirm that BENITO made 96 incomplete applications for work permit extensions without LMIA’s. 86. A search of the email address associated specifically to Charles BENITO confirms that he submitted seven incomplete applications for work permit extensions without LMIA’s, 87. Based on the information provided from Ms. CARSON and Mr. BAUTISTA, along with the information gathered pertaining to applications submitted by both BENITO and Charles BENITO from GCMS, | have reasonable grounds to believe that they are counselling foreign nationals to misrepresent material facts on their applications to benefit from implied status, therefore inducing an error in the act 8. Based on the above information, there are reasonable grounds to believe the following: Carlito Manansala BENITO Charles Jefferson BENITO ‘Triple Maple Leaf Canada (TML Canada Group) Corp. World Immigration Group (WIG) Corp. Helping Migrants Canadian Immigration Corp. Did employ foreign nationals, in a capacity in which the foreign nationals are not authorized under the Immigration and Refugee Protection Act to be employed, and thereby did commit an offence Contrary to Paragraph 124(1X(c) of the Immigration and Refugee Protection Act. My grounds for belief are as follows: 89, Maryann OCAY was arrested by Inland Enforcement for an outstanding immigration warrant. ‘White in custody she was found to be in possession of paystubs in her name, for employment at Helping Migrants and a letter of employment for September 2016 to present day, signed by Charles BENITO. ‘The business address for Helping Migrants listed on the paystub is 7360 Singer Way NW, Edmonton AB T6R3R9, a residence owed by Carlito BENITO and Estrella BENITO. This is also the address associated to both Triple Maple Leaf Canada and Helping Migrants in CORES. The ‘email address associated to Helping Migrants is helpingmigrants@gmail.com, which is also the same email address associated to Triple Maple Leaf Canada and World Immigration Group. All three companies operate out ofthe business centre at the Ramada Edmonton South at 5359 Calgary Trail Ms. OCAY does not have a valid work permit, nor does she have legal status in Canada, When interviewed by the Criminal Investigations Division she stated she had created them herself and had only volunteered there. During surveillance ata later date, she was observed by investigators centering the business centre in the Rantada Edmonton South located at 5359 Calgary Trail, Edmonton Alberta, with a lunch in hand, Her vehicle was there from early in the day and was still there when Investigators drove by the location again. Investigators drove by the location the following day and OCAY’s vehicle was again, parked in the lot outside the Ramada Edmonton South 1 5359 Calgary Trail. 90. In an interview with Ms, TOMA YOA, who has been inside BENITO's office on numerous ecasion and has friends working there, she stated that BENITO hires foreign nationals without status while they are waiting for applications to be approved. She stated many of these people have applied for Humanitarian and Compassionate Permanent Resident Applications. 91, Based on the paystubs and employment letter in Ms. OCAY’s possession as well as the statement made by Ms. TOMAYOA, static surveillance of BENITO and Charles BENITO's business location al the business center in the Ramada Edmonton South located at $359 Calgary Trail, Edmonton Alberta, was conducted over a period of two days along with numerous drive bys of the location, During this time, five foreign nationals without legal status in Canada, were observed parking outside the Ramada Edmonton South and entering the business center location, and remaining there for much ‘of the day and returned again on subsequent days, 92, Surveillance conducted over several days at BENITO'S office at $359 Calgary Trail, Edmonton showed several of the same vehicles registered to foreign nationals as arriving to the office at office ‘opening time and remaining at the office well into the day. None of the foreign nationals have work Permits to be employed legally by BENITO. Charles BENITO or any of their companies. Page 240131 8 aw (ers2024 200705) Fie Wa eu sss de poke v2001924C 93. Based on the information provided by Tina BADA of Service Canada on June 19, 2018, BENITO fand or Charles Jefferson BENITO have not applied for LMIA’s for Triple Maple Leaf Canada and or ‘World Immigration Group and or Helping Migrants between the dates of November 11, 2015 and June 18, 2018. This means that any foreign workers whom are not Permanent Residents of Canada, ‘employed at those locations would be employed without proper work permits. G. GROUNDS TO BELIEVE THE THINGS TO BE SEIZED WILL AFFORD EVIDENCE OF ‘THE OFFENCE 94. Throughout the investigation to date and based on the aforementioned paragraphs, | have reasonable grounds to believe that the items described in the “Things to be searched for" of this information will afford evidence of the offences described in this information. My grounds for belief are summarized as follows: 4) | believe it is common practice for immigration consulting businesses to keep files for each individual they have a consultation with, This allows them to process applications for that person, follow up on those applications, make further applications and keep track of payment schedules for services provided to them. Of the five witnesses interviewed, documents were obtained from four of ‘hem, all of which were photocopies, but were the copies they had received from BENITO of Triple Maple Leaf Canada, These documents included initial consultation agreements, client assessment assessments, Fees for Permanent Residency Applications, Requests for Letter of Acceptance, Client Record of Visits, and Retainer Agreements. These documents as a whole demonstrate the long term scheme to maintain status in Canada and the total cost for each foreign national to do this. The Client Assessment forms will pravide the long term plan for the foreign national and include each application, what is required, how much time each application will provide them to stay and iilso ‘demonstrates the misrepresentations involved in those applications and the counselling of those mistepresentations. b) I believe that as a common practice, businesses keep files for each individual employee, These files will normally contain such things as copies of offers of employment, employment contracts, Correspondence related to employment, schedules, hour logs, pay records, time sheets. and time cards, These employee files will afford both paper and electronic evidence BENITO and or Charles BENITO and or Triple Maple Leaf Canada and World Immigration Group and or Helping Migrants employed foreign nationals in a capacity in which they are not authorized under this Act; ©) believe that financial records related to payments, to be made or received, including bank records, e-transfer records, bank drafts financial logs and ledgers, cancelled cheques, cheque stubs, cheque registers, credit card statements, credit card records, written record of wages, payroll documents, calculation records, hand written notes, payroll ledgers, and employee contact information will afford evidence that BENITO and or Charles BENITO and or Triple Maple Lear and or World Immigration and or Helping Migrants did counsel misrepresentation on multiple applications relating to study permits and work permit extensions. In running a business of this size, i would be logical to keep a ledger or list of what people owe, to ensure they make all their payments. Transaction histories provided by three witnesses show that $17,000 was transferred into ‘and out of their accounts on the same date that a bank statement was obiained. ‘This is the same date that they met with BENITO, who they all stated made arrangements for his secretary to take them to the bank to transfer they money into their account. This short term loan is accompanied by a lending, {fee of between $250 and $450. The moving of $17,000 into bank accounts in order to obtain an official document from the Bank as proof of funds to support their application is misrepresentation in contravention of IRPA. BENITOs aiding and counseling Mr. TAUYA, Ms. LIBELO and Ms, CARSON to provide a bank document showing funds that are not theirs, is counsel rmisrepresentations in contravention of IRPA. 4) I believe the search of computers, cell phones and other electronic devices will afford electroni evidence to support the alleged offences. According to Intelligence Officer KNOWLES, the business location at TC3 business centre in the Ramada Edmonton South 5359 Calgary Trail, was an open conference room with approximately 16 laptops set up with people working at desks who also had cell phones which they appeared to be answering in relation to business activities. This would correspond with the information obtained by DF! BOYLE SUFFIELD’s search of the phone numbers ted on BENITO’ Triple Maple Leaf Facebook page. Her search of these phone numbers resulted in all numbers being associated to cell phones and no land lines. On BENITO's facebook page Contact information is provided for Facebook, WhatsApp, Viber, Skype, Tango, call, and text, Page 25043¢ an) cers20z« (acon v2001924C providing the ability 10 communicate and provide services to people internationally. These are all services related t0 online computer communications and cell phone communications allowing people to communicate internationally for free over the internet. Many of the numbers found on this site are listed in their clients GCMS information as the primary contact number. BENITO'S Clients have also used one of the following two e-mail addresses: carlbenito2012@gmail.com or helpingmigrants@gmail.com, as their primary email contact for the correspondence relating to applications through IRCC. Charles BENITO'S clients have used one of the following two e-mail addresses: helpingmigrants@gmail.com or mrcharlesbenito@gmail.com. ¢) Intelligence Officer KNOWLES who entered the business center located at the Ramada Edmonton South, stated there are approximately 16 workstations with computers at that location, Currently most immigration documentation can be electronically transmitted to IRC. In my experience as an investigator 1 believe that computers, computer peripherals and electronic storage data at this office will store electronie documents affording evidence that misrepresented applications were submitted to IRC by the consultants on behalf of their clients. 1) Ms. LIBELO provided a copy of two screen shots for Interac e-Transfers to Carlito BENITO sent {o carlbenito2012@gmail.com in an amounts of $500 and $520. As stated in the above information, each foreign national has been charged large amounts of money in relation to immigration applications, most of which are non-genuine and involve misrepresentations, only meant to buy them ‘a small amount of extra time in Canada. This is one method used to exchange money between BENITO and his clients. £) In my experience as an investigator, IRCC routinely uses email addresses to correspond with individuals regarding on going immigration matters. 1 believe that search for correspondence related to the following three accounts: carlbenito2012@gmail.com, helpingmigrants@amail.com and mrcharlesbenito@gmail.com will reveal evidence of applications made to IRCC containing false or misleading information. h) The receipts provided to Mr. TAUYA and Ms. CARSON between November 2015 and present are generic stationary receipts which are fillable and starts as “Received From’ These receipts ‘commonly come ina booklet format and as you fill out the receipt there is a carbon copy or a copy underneath that transcribes the information from the top copy. In my experience as an investigator | believe the originating booklets of copied receipts found at the business will show receipts for the immigration consulting services BENITO and or Charles BENITO and or Triple Maple Leaf Canada and or World Immigration and or Helping Migrans has provided. This will assist in understanding the total amount of monies provided in exchange of services that involve misrepresentation and abuse OF IRCC resources. 1H. GROUNDS TO BELIEVE THE THINGS SOUGHT ARE PRESENTLY AT THE PLACE TO BE SEARCHED Based on the above information, there are reasonable grounds to believe that the items described in “Things 1o be Searched For” of this Information will be located at 7360 Singer Way NW. Edmonton Alberta, My grounds for belief are as follows: 995. Both Triple Maple Leaf Triple Maple Leaf Canada (TML Canada Group) Corp. and Helping, ‘Migrants Canadian Immigration Corp. list their registered office and records address in CORES as 7360 Singer Way NW Edmonton Alberta, T6R3R9. Based on this information it is reasonable to believe that the records for these companies are kept at 7360 Singer Way NW Edmonton Alberta 96. On November 11, 2015, Maria CARSON was instructed to attend at 7360 Singer Way Edmonton which was Carlito BENITO’s house and home office of Triple Maple Leaf Canada. CARSON witnessed a fully operational immigration office with a secretary posted at a desk in the basement waiting room. Many other people were in the residence for immigration matters. When ‘called CARSON went upstairs where BENITO had an office. BENITO completed multiple ynigration documents for CARSON from this location. It is reasonable to believe these documents, ‘will be stored where the business operating. 97. On April 16, 2018, when Maryann OCAY was arrested by Inland Enforcement she was in possession of paystubs for employment at Helping Migranis dated February 28, 2018 and March 13, 2018. The corporate address for Helping Migrants is 7360 Singer Way NW, Edmonton AB T6RSR9. Based on this information itis reasonable to believe that records pertaining to business operations, Page 280191 Me i) ‘erste 00705) enor No Poles Fle Na i dentScaon 1" Cosuar ce potce v2001924C such as employee files and payroll would be kept at 7360 Singer Way NW, Edmonton and would afford evidence of the alleged offence under s.124(c) of RPA. 98. In GCMS, most clients of BENITO"S, Charles BENITO, Triple Maple Leaf Canada, Helping ‘Migrants, and World Immigration, list 7360 Singer Way NW, Edmonton as the primary mailing address for all correspondence with IRC. The primary mailing address in GCMS dictates where documents are sent, Therefore if a study permit application is approved it witl be mailed to the address listed in GCMS, along with any other correspondence sent by mail. Based on this, information it is reasonable to assume that all correspondence from IRCC by mail, will be sent 10 7360 Singer Way. ‘99, Between June 6, 2018 and June 7, 2018, static surveillance of BENITO and Charles BENITO's businesses, Triple Maple Leaf Canada and World Immigration and Helping Migrants was conducted a 5359 Calgary Trail, Ramada Hotel Edmonton South. Investigators observed Charles BENITO leave his vehicle carrying a banker's box full of documents, he entered the immigration office at opening hours. It is reasonable to believe that Charles BENITO was on his way into work and was carrying documents related to his business, Helping Migrants, into the office. Previous surveillance showed Charles BENITO exited his residence at 7360 Singer Way around this time, his car was seen 1 short time after that parked in front of the Ramada Hotel immigration office entrance. 100. Officer KNOWLES visited conference room TC3 at the Ramada Edmonton South he noted that it was a large room occupied by BENITO’s staff. KNOWLES noted there were no filing cabinets or document storage areas in the room. It is reasonable to believe documents are stored at BENITO"s and Charles BENITO’s residence, 7360 Singer Way NW. Edmonton, particularly as this is the address listed on clients" applications. 101. In January 2016, Jayson TAUYA’S met with BENITO, he was instructed to altend BENITO's office which was located at his residence. He described how the business was set up in the house, with BENITO's office located on the main floor and the secretary and a waiting area located in the basement. He stated there was a computer, filing cabineis and lots of papers. Based on this information itis reasonable to assume that computers, cell phones and other electronic devices located within the residence will contain evidence to support the alleged offences. 102, The investigation to date has shown that BENITO and Charles BENITO and their companies rely on emails to correspond with IRCC and their clients. The investigation thus far also has only produced cell phone numbers used in the businesses of BENITO and Charles BENITO, no land line phone numbers have been identified during the investigation. This form of communic: conducted by way of electronic devices, itis reasonabie to believe the search of those devices will afford evidence of the counselling offence and the unauthorized employment. 103. Ms. LIBELO, one of BENITO’s clients, whom he counselled to misrepresent relevant facts on her study permit application, made some of her payments through Interac e-Transfers to Carlito BENITO at carlbenito2012@gmail.com.. As stated in the above information, each foreign national has been charged significant amounts of money in relation to immigration applications many of which misrepresent material facts causing errors in the IRPA. It is reasonable to believe the search of electronic devices used in the transfer of money will afford evidence that BENITO acted for these applicants and was paid to do so. 104. Pursuant to Subsection 487(2.1) of the Criminal Code, any person authorized by this section to search a computer system or other electronic device or media in a building or place for data may: a. Use or cause to be used any computer system at the building or place to search any data contained in or available to the computer system; +, Reproduce or cause to be reproduced any data in the form of a print-out or other intl ble output; ¢. Seize the print-out or other output for examination or copying; and 4. Use or cause to be used any copying equipment at the place to make copies of the data. 105. Pursuant to Subsection 487 (2.2) of the Criminal Code, and with authorization to search a computer system for data: a. Every person who is in possession or control of any building or place in respect of which a search is carried out under this section shall, on presentation of the warrant, permit the person carrying out Pave 27031 tA) ‘ersz02e 00705) Togas No. Poles Fa Wo Wr identfeson 1" ae eevee potce v2001924C is carried out under this section shall, on presentation of the warrant, permit the person carrying out the search; b, Use (or cause to be used) any computer system at the building or place in order to search any data contained in or available to the computer system for data that the person is authorized by this section to search for; ¢. To obtain a hard copy of the data and seize it; and 4, To use or cause o be used any copying equipment atthe place to make copies ofthe data, 106. The CBSA Digital Forensics Investigator (DFI) Kelly Boyle Suffield, Winnipeg, MB, is a trained member of the Digital Forensic Unit (DFU) in the Criminal Investigations Section (CIS) within the Canada Border Services Agency (CBSA). This person is a certified expert in the forensic search, analysis, extraction and preservation of digital data from digital devices and media, and therefore understands the following: 4) Members of the DFU can forensically examine digital devices and media (computers) to retrieve a ‘wide variety of information from them. Typically, the data sought is found on memory chips or traditional hard drive(s) contained within a digital device, There are no global standards on how and Where information is stored within digital devices, as manufacturers capitalize on all available types of storage to minimize heat and size. In order to complete the most comprehensive search, the ‘examination will include searching all data storage areas within a device for the “Things to be Searched For” 'b) Where possible and practical, at the place to be searched, the DFU member will conduct an including: computers, phones, cards, disks, tapes, chips and other devices eapable of storing digital programs or data and performing logic, control or function, ©) Where possible, before considering whether to seize any digital device, media or data, the DFU member may use forensically sound tools and techniques to conduct cursory keyword searches of the digital devices and media. Without altering the original digital data, this will help determine the use, ownership, possession and maintenance of these digital devices and media, and their relevance to the “Things to be Searched For", and the terms of the search warrant. Conducting cursory keyword searches is the least intrusive and the most direct means of only seizing the items named in the things to be searched for. 4) Password protection, encryption or security may make cursory searching impractical or impossible. Before seizing digital data; or rendering it intelligible; or reproducing, transferring, communicating, undeleting or receiving data stored within digital devices and media, the DFU ‘member considers all facts aad circumstances. including the properties, stale and security of the data; technical and access limitations; and the extent and reasonableness to which it is essential to forensically recover, analyze, preserve and disclose the data. ©) The DFU member uses specialized computer hardware and software, along with techniques such as digital fingerprinting (called hash values) and write-blockers, to ensure and verify that the original data remains intact and is not altered in any way. Where possible and practical, the DFU member makes accurate and verified copies (called images) of the entire contents of digital devices and media and then performs forensic analysis on the images. It isthe experience of the DFU member that working with digital devices and media includes unpredictable variables and that depending on their ‘ype, condition, size, complexity and security, the process of imaging can take from several minutes to several days. Any copies or images produced will be included in the report to Justice pursuant to S. 490 of the Criminal Code. The imaging of digital devices and media may be completed at the place to be searched. However, where this is not possible or practical, the original digital devices and media will be seized and be imaged off-site. Such circumstances may include: extreme volumes of data, or data that has been altered, disguised, hidden, encrypted or deleted. To access such data or render it intelligible the DFU ‘member may need to work in a specialized environment using specialized techniques and computers, ‘components or software programs. ) Where possible and practical, the CBSA will implement the following procedures for seized digital devices, media and their component i) Digital devices and media that are removed from the places to be searched will be properly secured and safely transported to the CBSA’s evidence control warehouse or similar secure location; {i) Original seized digital devices and media will be imaged, and the images (and originals where relevant) will be placed in a secure CBSA location reserved for storing evidence: ) Images of digital devices or media will be verified with DFU controlled software programs and ‘computers to ensure that the seized data can be properly accessed and processed; and iv) Where possible and practical, original digital devices and media that are no longer required for Bb a0 ‘erszvze 0075) denier No. Polce Fe Wa. Wi atcenteaton =" ds dose de potce v2001924C ‘maintaining care and control ofthe devices and media for the preservation of evidence, they will be returned to the person from whom they were seized. h) The detailed post seizure analysis of the DFU member includes an exhaustive search of the digital device and media in order to determine which digital data falls within the parameters of the search ‘warrant and the things to be searched for. All of the digital forensic processes required cannot be predicted, however some examples of this process i 1) searches conducted using keywords provided by t i) entry or deciphering of passwords for password-protected programs or data: i) search for hidden or deleted data, including documents and emails; iv) retrieval of the computer user's Internet browsing history and determination of what the user was looking for on the Internet (ie. in search engines); ¥) recovery and reconstruction of fragments of Web pages and e-mails, e.g., Hotmail or Yahoo and visualization of messages in common instant messaging programs such as AOL, MSN and Yahoo; vi) recovery of documents printed by the user on his/her printer; vii) determining the last date and time users accessed certain programs or data files within the Parameters of the warrant and relevant to the investigation. )conctusions 107.1 have reasonable grounds o believe based on the aforementioned paragraphs that Carlito Manansala BENITO and or Charles Jefferson BENITO and or Triple Maple Leaf Canada (TML) Canada Group Corporation and or World Immigration Group (WIG) Corporation and or Helping Migrants Canadian Immigration Corporation did, on or between November 11, 2015 and June 28, 2018, at or near the City of Edmonton in the Province of Alberta did, knowingly counsel, induce, aid or abet or attempt to counsel, induce, aid or abet persons, to directly or indirectly ‘misrepresent or withhold material facts relating to a relevant matter that induced or could induce an error in the administration of the Immigration and Refugee Protection Act, contrary to Section 126 of the Immigration and Refugee Protection Act, thereby committing an offence pursuant to section 128 of the same Act; and 108. | have reasonable grounds to believe based on the aforementioned paragraphs that Carlito Manansala BENITO and or Charles Jefferson BENITO and or Triple Maple Leaf Canada (TML) Canada Group Corporation and or World Immigration Group (WIG) Corporation and or Helping Migrants Canadian Immigration Corporation did, on or between September 16, 2016 and June 28, 2018, at or near the City of Edmonton in the Province of Alberta did, did employ foreign ‘nationals, in a capacity in which the foreign nationals are not authorized under the Immigration and Refugee Protection Act to be employed, and thereby did commit an offence contrary to Paragraph 124(1) of the Immigration and Refugee Protection Act. 109. My investigation thus far has produced 5 witnesses who can testify that the different immigration businesses being operated under the direction of Carlito BENITO is counselling foreign nationals to misrepresent material facts in a variety of ways on IRPA applications. These ‘misrepresentations did cause an error in the administration of IRPA. The witnesses identified up to this point in the investigation can testify to the following: 2) Carlito BENITO offers many options to foreign nationals who are about to lose or have lost their status in Canada. One of these options is to apply for a study permit at one of two schools suggested by BENITO, Makami College and the Academy of Learning. . These are designated learning institutions recognized by IRC. Both colleges require no deposit of funds and have very minimal requirements for prospective students to receive a letter of acceptance; ii, BENITO counselled his clients to apply for study permits even though they cannot afford and have ‘no intention of attending fulltime studies; Ifneeded BENITO offers and organizes a one day loan of $17,000 to his clients so they can provide the government a bank statement in their name proving they have the financial resources available to attend school; and iv, BENITO counselled his clients to apply for work permit extension applications without a valid LMIA knowing they would be refused, only to benefit from implied status thereby erroneously extending their status in Canada, 110. Based on the analysis of evidence obtained from GCMS, | believe that BENITO and Charles BENITO are operating their businesses interchangeably. On numerous cecasions Charles has acted Mh WP ‘ers2024 goons) v2001924C as a consultant for World Immigration Group, which is owned by BENITO. Both BENITO and Charles BENITO use the helpingmigrants.com email address forall of their business and they both operate all three business out ofthe same location and use their home address as their records location, 111. My investigation has produced documentary evidence obtained from witnesses, the GCMS database and TD Bank Group to support the allegations that BENITO, his son Charles BENITO and their companies are knowingly counselling people to: '. Complete and submit study permit applications with financial supporting documents that have been fraudulently created for the purpose of fulfilling the financial requirements IRC has, to approve a study permit fora foreign national in Canada; c. Complete and submit study permit applications with no intentions of taking up full time study in ‘Canada and to benefit from the ability 10 work openly for 20 hours per week as stipulated by the study permit; and 4. Complete and submit work permit extension applications that are not supported by a valid LMIA. ‘This erroneously gives the applicant implied status in Canada the application is processed and refused by IRC. 112.1 have reasonable grounds to believe the search of the residence of Carlito BENITO and Charles BENITO at 7360 Singer Way NW, Edmonton, Alberta will provide both documentary and electronic evidence BENITO, Charles BENITO and or the companies they direct did counsel their clients to istepresent material facts on IRPA applications causing an error in the Administration of the Act. 4) Surveillance has been conducted on 7360 Singer Way NW, Edmonton Alberta the residence of BENITO and Charles BENITO as well as egistered records address for Triple Maple Leaf Canada and Helping Migrants; ) Both BENITO and Charles BENITO have been observed leaving the residence in the morning; c) CPIC has identified 7360 Singer Way NW, Edmonton, Alberta as both BENITO and Charles BENITO’s residence; 4) CORES searches for both Triple Maple Leaf Canada and Helping Migrants show 7360 Singer ‘Way NW Edmonton, Alberta as the Records Address and Registered Office; ‘¢) Most clients of BENITO and Charles BENITO have 7360 Singer Way NW, Edmonton listed as their mailing address in GCMS associated to their IRCC and CBSA files; 1) Use of representative forms for Triple Maple Leaf Canada, Helping Migrants and World Immigration Group list their mailing address as 7360 Singer Way, NW Edmonton; £8) Two witnesses have attended the BENITO residence at 7360 Singer Way NW, Edmonton for consultations with BENITO and have stated there is an office set up in the house. One of those witnesses stated there were filing cabinets, documents and a computer at that location; and fh Evidence of unauthorized employment in the possession of foreign national with no status in ‘Canada identified she was employed by Charles BENITO of Helping Migrants Canada, The address ‘on the letterhead was 7360 Singer Way NW Edmonton, Alberta, i) Numerous days of surveillance have resulted in observing several foreign nationals that have no status and appear to be attending the BENITO immigration office on consecutive days during business hours and remaining for a majority of the day. 13. The date parameter requested for the “Things to be Searched For", November 11, 2015 to June 28, 2018, reflects the date that the earliest evidence exists to support the grounds to believe BENITO, ‘Charles BENITO or their companies counselled a client to misrepresent material facts on an IRPA application. This was the first time Ms, CARSON met with BENITO. The date of September 16, 2016 reflects the letter of employment found in Ms. OCAY's possession. BENITO'S business is currently running and I have reasonable grounds to believe BENITO and Charles BENITO are ‘currently illegally employing foreign nationals, Page 200131 40 ALBERTA ‘ors202¢ 2007108) 1v2001924C 114.1 request that the Warrant to Search issued in relation to this document allow for execution to (ake place on June 28, 2018, between 6:00 am and 11:59 P.M, 1 would like to swear the Warrant two days prior to the execution. | do not believe the two day delay between the issuance and execution of the Warrant to Search will affect any of the facts set out in this document, The reason forthe delay is {o allow for the allocation of adequate resources and briefing of staff, traveling from outside of Edmonton, Alberta, WHEREFORE the Informant prays theta search warrant may be granted fo search the said locaton forthe said things, EN CONSEQUENCE, le dénonciatour demande qu'un mandate de perquisiton soit accords pour perquisitonner dans let ‘emplacement en vue de trouver lesaites choses, ‘Swom/Affimed before me Déclané sous sermenvAfirms devant mor on June 26,2018 : Bo at Edmonton om i A 4 a . OO wand tor te acl Mahia © supe aa cour proncie age debit ‘nse paurlsromce dAbets Jim Bowron Pogo at o'31 Wt, dl 0752036 201408) For ure win CTS2024 [eS Fe Wa Wa are v2001924C Warrant to Search [senter a — 17 taeanaaben Mandat de perquisition ALBERTA Erm Code Coan Seconset ‘ances? To the Peace Officers in he said Province oro the ‘Aux agents dela pax dole province ou sux Tianed Pa Oa i Coe roman SaaS WHEREAS t appears on the ostatimation ATTENDU QUI apport dela dapostion sous sermontdéclration ot ‘Amy Lea Dorothy PAMBIANCO es Taek Ren ena of ‘The Canada Border Services Agency oe Tiss Eaomen Ae — ror eb Txgonin aS eestor Gs that there are reasonable grounds for believing that ‘quill existe des motifs raisonnables de crovre que ‘Things to be Searched for: 1. The Following, operations, ings” dated between November 11, 2015 and June 28, 2018, relating to the business Triple Maple Leaf Canada (TML Canada Group) Corp. World Immigration Group (WIG) Corp. Helping Migrants Canadian Immigration Corp. and or in the names of: Carlito Manansala BENITO also known as Carl Benito Charles Jefferson BENITO Namely; 2. Any document, record, letter, or fax (sent or received, including all enclosures) pertaining to immigeation documentation for study permit and work permit extension applications between November 11, 2015 and present for all clients of: Triple Maple Leaf Canada (TML Canada Group) Corp. World Immigration Group (WIG) Corp. Helping Migrants Canadian Immigration Corp. Carlito Manansala BENITO also known as Carl Benito Charles Jefferson BENITO ‘More specifically: 4) Client files and all related supporting documentation between November |, 2015 and prest ‘who applied for study permits and or work permit extensions; and for all clients +) All financial records between November 11, 2015 and present related to payments and or loans, to be made or received, including bank records, e-transfer records, bank drafls, financial logs and ledgers, cancelled cheques, cheque stubs, cheque registers, creditcard statements, credit card records, calculation records, and hand written notes. 3. Any document, record, letter, oF fax (sent or received, including all enclosures) pertaining to employment records and employee files between September 16, 2016 and present for: ‘Triple Maple Leaf Canada (TML Canada Group) Corp. World immigration Group (WIG) Corp. Helping Migrants Canadian Immigration Corp. Carlito Manansala BENITO also known as Carl Benito Charles Jefferson BENITO More specifically: 8) Employee files and supporting documentation; [Potce Pie Wo A aa aosar a pe 1v2001924C. ier No A diiteabon b) Any sent or received fax, correspondence and ull enclosures, notebooks, address books, business documents, contracts, employee files, employee lists, employee schedules, employee time sheets, employee hour logs, employee work logs, employee time cards, employce contact information, job site logs, day timers, notes. telephone and cellular records, postal and courier documents and receipts, and any related supporting documentation and/or attachments; ©) All financial records related to employee payments. to be made or received, including bank records, e-ransfer records. bank dratfs, financial logs and ledgers, cancelled cheques, cheque stubs, cheque registers, credit card statements, credit card records, written record of wages, payroll documents, calculation records, hand written ‘notes and payroll ledgers. 4. lems described in paragraph 1, 2, and 3 in electronic format, as well as documents/records that may be uniquely electronic including but not limited to: email (received, sent, deleted or in dralt form); and records and Content of past instant messaging or online chat conversations or other electronic communication, that are stored 6 or available to a computer system or other data storage device. 5. Any other device or software or manuals or data security key used or capable of being used to create, store, ‘manipulate or reproduce the items in paragraphs 2 and 3. HEREINAFTER referred to as the said “Things ‘These “Things” will afford evidence that, Triple Maple Leaf Canada (TML Canada Group) Corp. And or World Immigration Group (WIG) Corp. And or Helping Migrants Canadian Immigration Corp. And or Carlito Manansala BENITO also known as Cart Benito And oF Charles Jefferson BENITO did, on or between November 11, 2015 and June 28, 2018, at or near the City of Edmonton in the Province of Alberta, knowingly counsel, induce, aid or abet or attempt to counsel, induce, aid or abet persons, to directly oF indirectly misrepresent or withhold material facts relating to a relevant matter that induced or could induce an istration of the Immigration and Refugee Protection Act. contrary to Section 126 of the Immigration and Refugee Protection Act, thereby committing an offence pursuant to section 128 of the same Act:

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