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Case 1:11-mj-00340-TCB Document 2 Filed 04/29/11 Page 1 of 12

IN THE UNITED STATES DISTRICT COURT FOR THE


CLERK. U.S. DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA ALEXANDRIA. VIRGINIA

Alexandria Division

UNITED STATES OF AMERICA

CRIMINAL NO. 1:1 l-MJ-340

TAESAN WON,

Defendant.

AFFIDAVIT IN SUPPORT OF A CRIMINAL COMPLAINT AND ARREST WARRANT

I, Carl Stiffler, being duly sworn, depose, and state as follows:

I. INTRODUCTION

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

Immigration and Customs Enforcement ("ICE") assigned to the Washington D.C. Field Office. I

have been a Special Agent for ICE for approximately two years. I am assigned to the

Washington District Office, Homeland Security Investigations, in Dulles, Virginia. My duties as

a SpecialAgent include investigating violations of immigration and customs laws. I successfully

completed the Criminal Investigator Training Program and the Immigration and Customs Agent

Training Program at the Federal Law Enforcement Training Center in Glynn County, Georgia. In

addition, I graduated from the American University with a Bachelor of Arts degree in

International Studies.

2. This affidavit is filed in support of a criminal complaint and arrest warrant

charging defendant Taesan Won with concealing, harboring, and shielding from detection an

alien in any place, including any building and any means of transportation, knowing and in

reckless disregard of the fact that the alien has come to, entered, and remained in the United
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States in violation of law, for the purpose of commercial advantage and private financial gain, in

violation of Title 8, United States Code, Sections 1324(a)(l)(A)(iii) and (B)(i).

3. This affidavit contains information necessary to support a finding ofprobable

cause and is based on my personal observations during the course of this investigation,

information conveyed to me by other law enforcement officials, and my review of records,

documents, and other physical evidence obtained during this investigation. This affidavit does

not include each and every fact observed by me or known by the government.

II. BACKGROUND

4. This case resulted in part from information received from a cooperating source

that I have utilized in the past. The cooperating source has provided me with credible

information in the past. According to the source, defendant Taesan Won ("Won") was operating

a "doumi" business in Fairfax, Virginia known as "Honey." According to Won, he and the

cooperating source were friends and at some point had a sexual relationship. Since then,

however, their relationship has soured.

5. I have been advised that the term "doumi" (or "dowoomi") means "helper" in the

Korean language. Based on my experience, I know that, in the context of nightlife within the

Korean community, a doumi refers to a woman who provides outcall companionship service to

customers at businesses, such as karaoke clubs and bars. "Doumi girls" generally work for a

doumi company (sometimes just one man). Doumi companies frequently employ multiple

women. The "doumi girls" usually wait in apartments until their supervisors receive telephone

calls requesting the doumi women. Based on my experience, when a customer at a Korean

business—usually a bar or a nightclub—desires to have a female companion, that customer (or


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the business) may call a doumi company and request that the company send doumi girls to that

business. Once at the business, the doumi girls may sing for, dance with, flirt with, pour drinks

for, and entertain the paying customer. In my investigation I have learned that these doumi girls

sometimes engage in prostitution with their customers.

III. THE DEFENDANT

6. Won is a citizen and national of the Republic of Korea (South Korea) and is

unlawfully present in the United States. On August 18,2010, the U.S. Department of State

issued Won a nonimmigrant B1/B2 tourist visa. Won subsequently entered the United States on

September 2,2010. The Department of Homeland Security granted Won admission to the

United States until March 1, 2011. On or about March 18,2011, Won filed a Form 1-539

application with U.S. Citizenship and Immigration Services (USCIS) to extend and/or change his

nonimmigrant status from a B1/B2 visitor to a nonimmigrant F-l student. Won does not have

valid work authorization in the United States and, because he was operating a business in the

United States, he was in violation of the terms of his admission to the United States. Won is

currentlyin ICE administrative custody pending removal to South Korea, but prior to that he

resided at 3276 Gallows Road, Fairfax, Virginia.

IV. PROBABLE CAUSE

A. December 7,2010 Interview of Won

7. Around November 2010, a confidential source informed me that Won wanted to

speak with me in order to provide information regarding several "doumi" companies that were

operating in Annandale, Virginia. Won advised the source that his competitors were using illegal

alien labor, and Won hoped that his information would spur ICE to pursue Won's competitors.
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8. Around December 7,2010, at Won's request, I conducted a noncustodial

interview with Won at an apartment located in Annandale, Virginia.

9. During the interview, Won informed me that:

(a) His friend, Myungsoo Kim ("Kim"), first approached him about

establishing a doumi company in April of 2010. Further, Kim advised Won that the

pair would be able to recruit Korean women on an internet website known as

"www.daum.net."

(b) Kim was also the manager of another doumi company known as "A-

Plus." Kim had ten women working for him at A-Plus and that a majority of the

women were from Korea. One woman, "Tami," was from Canada. Tami was in the

United States pursuant to a student visa.

(c) Other women who worked for A-Plus entered the United States on

the Visa Waiver program.

(d) Local Korean bars were able to contact him through weekly

advertisements that were posted in Korean magazines. There were approximately

eight to nine doumi companies operating in Annandale, Virginia and that a few ofthe

other companies had eight to nine employees.

(e) Around 7:00 P.M. each evening, business owners would call Won and

request doumi women. Won would then typically transport the doumi women to the

requested locations. The majority of the women would meet customers at a local

karaoke bar, also known as the "Norebang."


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(f) A customer was typicallycharged $70 per hour to converse with, sing,

and dance with the doumi woman. Typically, the doumi woman would get $50 and

the doumi company would receive the remaining $20.

(g) While working for A-Plus, Won could "sense" when people were

"illegal," and he overheard a few ofthe men who worked for A-Plus stating that two

of the doumi women did not have visas. In addition, Kim once advised Won that the

women who work for A-Plus did not have "papers."

10. At the end of the interview, Won also requested a U.S. Alien Registration Card for

the information he had provided.

B. February 22,2011 Interview of Hyunjung Lee

11. Around February 2011, the cooperating source discussed above advised me that

she had a roommate that was employed by a doumi company in Annandale, Virginia and that this

roommate was willing to provide information to ICE.

12. On February 22,2011, ICE Special Agents and an officer from the Fairfax County

Police Departmentconducted a non-custodial interview with the roommate, who identified

herself as "Hyunjung Lee."

13. According to Lee, she previously resided at an apartment located at 3276 Gallows

Road, Fairfax, Virginia. As mentioned above in paragraph 6, this is the same address where

Won resided until his administrative arrest.

14. During the interview, Lee stated:

(a) She entered the United States under the Visa Waiver Program in

December 2010;
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(b) She knew that under the terms of the Visa Waiver Program she was

not permitted to work in the United States.

(c) On the Internet, she saw an advertisement for women to work for a

doumi company known as "Romance."

(d) She contacted the owner of Romance and began working as a

doumi for Romance.

(e) The owner of Romance instructed her to reside at an apartment

located at 3276 Gallows Road, Fairfax, Virginia.

(f) Also living at 3276 Gallows Road were other women who worked

for Romance, women who worked for a doumi company known as "Honey," and

Taesan Won, whom she knew to be the owner of "Honey."

(g) A number of the women who resided at 3276 Gallows Road and

who worked for Romance were admitted to the United States on student visas.

C. April 25,2011 Interview of a Cooperating Source

15. On April 25,2011,1 spoke with the cooperating source, discussed above, who

previously was a friend of Won. The cooperating source informed me that she was also

acquainted with a number of women who previously worked for Won and who were

unauthorized to work in the United States. The cooperating source identified these individuals

as:

a. "Yoon Jung LNU," who possessed a U.S. tourist visa;

b. "Jessica LNU," who possessed a U.S. student visa;

c. "Bora LNU," who possessed a U.S. student visa; and


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d. "Yoo Jin LNU," who possessed a U.S. student visa.

D. March 31,2011 Interview of Taesan Won

16. On March 31,2011,1 and other law enforcement personnel encountered Taesan

Won at his residence located at 3276 Gallows Road, Fairfax, Virginia. In both the Korean

language and the English language, Won provided verbal consent to enter the residence and

speak to him. Won invited us to speak to him in a bedroom on the second floor of the residence,

so that we could speak in private. Won was not in custodyat this time.

17. Through a Korean linguist, Won advised me that he currently has three Korean

women working for his business, known as "Honey." Won stated that he was earning

approximately $3,000 to $4,000 per month as the owner of Honey.

18. Won stated that the two South Korean women encountered that I also encountered

at Won'sapartment that day were employees of Honey. One of the Korean females, later

identified as "Jeongae Lee," arrived in the United States under the U.S. Visa Waiver Program.

The other Korean female, later identified as "Sora Lee," also entered the United States under the

Visa Waiver program. When these women claimed that theydid not work for Won, Won stated

that the women were scared and probably would not admit that they worked for him.

19. Under the terms of the U.S. Visa Waiver Program, persons granted admission to

the United States are not permitted to work in the United States.

20. Won stated that he did not pay the women directly; rather, the customers paid the

women cash.
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21. Won stated that he charged customers $70 per hour and that the women would

then pay him $20 from the $70 paid by customers. Won stated that this was the first time that

both Jeongae Lee and Sora Lee worked for him in the United States.

22. Won indicated that both Jeongae Lee and Sora Lee were paying him

approximately$100 per week in rent and that one of the women arrived in the United States

approximatelytwo days prior to the interview.

23. Won stated that he knew that both Jeongae Lee and Sora Lee were not permitted

to work in the United States.

24. Won advised ICE Special Agents that he did not have Jeongae Lee or Sora Lee fill

out a DHS Form 1-9 (the Employment Eligibility Verification Form which employers must have

their employees complete to verify their eligibility to work in the United States), and that he did

not ask Jeongae Lee or Sora Lee to present any identification documents before they began

working.

25. Won was then administratively arrested pursuant to the Immigration and

Nationality Act because he was not lawfully present in the United States. ICE agents transported

Won to the Washington, D.C. Field Office in Fairfax, Virginia for administrative processing.

E. March 31,2011 Interview of Taesan Won

26. While in ICE administrative custody, Won orally was advised of his Miranda

rights both in the English language and the Korean Language. Won waived his Miranda rights

and agreed to be interviewed.

27. During the interview, Won stated:

(a) He is the owner of "Honey."

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(b) He currently has two to three women working for him.

(c) He started "Honey" in October of 2010 and had approximatelyeight

women working for him at that time.

(d) The two Koreanwomenencountered at the apartmentwith Won—i.e.,

Jeongae Lee and Sora Lee—had worked for him for only a short time.

(e) He never asked the workers for identification documents.

(f) He did not instruct the workers to have sex with male customers.

(g) Theworkers wouldcharge customers $70 per hourand of that$70 he

would receive $20.

(h) He did not report any wages to the Virginia Employment

Commission nor did he report earningsto the Internal Revenue Service.

F. April 8,2011 Interview of Taesan Won

28. On April 8, 2011, a Deportation Officer and I conducted a second custodial

interview of Taesan Won.

29. Won was again advised of his Miranda rights in the Korean Language. Won

again waived his Miranda rights in the Korean language, and agreed to be interviewed.

30. Won stated that he filed his nonimmigrant visa application in and around July or

August of 2010 with the United States Embassy in Seoul, South Korea. Won stated that, when

meeting with the U.S. Consular Officer, he (Won)advisedthe ConsularOfficer that he would be

traveling to the United States in order to develop a franchise for his Korean advertising company

known as "Hangwoong Company." Won admitted that this statement to the Consular Officer

was false.
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31. Won also told the U.S. Consular Officer that he wanted to establish branches in

the United States and that he wanted to research the United States advertising market. Won

stated that he knew that this statement to the Consular Officer was false and that he intentionally

lied to the Consular Officer in order to obtain his nonimmigrant B1/B2 tourist visa.

32. Won stated that he traveled to the United States using his nonimmigrant B1/B2

tourist visa. Won related that, after he was in the United States more than three months, he was

having a difficulttime generatingincome. At that point, Won stated that he established a doumi

company known as "Honey."

33. Won related that when he previously visited the United States earlier in 2010, he

met a friend of his from Korea known as "Myungsoo Kim." Won and Myungsoo Kim had

entered in a partnership with a doumi company known as "A-Plus."

34. Won stated that when A-Plus started operating, he and Kim had one female

working for them. Won stated that the Korean female entered the United States under the U.S.

Visa Waiver Program. Won indicated that he and Kim found other women who were willing to

work for them and that they later established a "sook-so" or "housing dormitory" located in the

Lafayette Forest Community of Annandale, Virginia, to house these women.

35. Won stated that when he resided at the apartment located in the Lafayette Forest

Communityof Annandale, Virginia, two of the women residing with him entered the United

States pursuant to the U.S. Visa Waiver Program, and three other women living there were

present in the United States pursuant to student visas. Won stated that the aforementioned

women paid Won and Myungsoo Kim rent of approximately $100 per week.

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36. Won stated that Kim advertised the business by listing the company name along

with his contact information in Korean language publications.

37. Won stated that he resided at the apartment located at 3276 Gallows Road, in

Fairfax, Virginia since December 2010. Won stated that four to five women who previously

worked for him are now residing in different apartments located in Annandale, Virginia.

38. Won related that most of the women who worked for him in the past were United

States citizens or lawful permanent residents, but that at least one woman possessed only a U.S.

student visa, and another woman entered the United States through the U.S. Visa Waiver

Program.

39. Won admitted that he knew that a person who entered the United States under the

Visa Waiver Program or with a student visa could not lawfully work in the United States.

40. Won stated that, on several occasions, he transported Korean women from the

Dulles International Airport. Won stated that the women he transported from the airport worked

either for Honey or for A-Plus. Won stated that he transported from the Dulles International

Airport seven to eight Korean women, who were admitted to the United Sates using student or

tourists visas, or who entered under the Visa Waiver Program, and thus were not authorized to

work in the United States.

41. Won related that he would advertise for Korean workers by posting Korean-

language advertisements on various Korean message boards on the Internet, which would include

Won's telephone number. Korean woman interested in working for him would call him from

Korea and Won would make flight arrangements for them to come to the United States.

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V. CONCLUSION

42. Based on the above-described facts, I respectfully submit that there is probable

cause to believe that, from in and around October 2010 to on or about March 31, 2011, in Fairfax

County, Virginia, within the Eastern District of Virginia, and elsewhere, defendant Taesan Won,

for the purpose of commercial advantage and private financial gain, knowing and in reckless

disregard that an alien had come to, entered, and remained in the United States in violation of

law, did conceal, harbor, and shield from detection, and did attempt to conceal, harbor, and

shield from detection, such alien in any place, including any building and any means of

transportation, in violation of Title 8, United States Code, Sections 1324(a)(l)(A)(iii) and (B)(i).

Signature and Acknowledgment

Carl R. Stiffler
Special Agent
U.S. Immigration and Customs Enforcement

Sworn to and subscribed before me on this 29,h


day of April 2011, at Alexandria, Virginia.

JsL
Ivan D. Davis
United States Magistrate Judge

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