Free Complaint - District Court of California - California

Document 1 Filed 05/10/2007 Page 1 of 4
United States District Coup;-tg D
NORTHERN DISTRICT OF CAL% ;
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UNITED STATES OF AMERICA Venue: SAN FRAN CQ`gK\NG
V. R\CHA\`i§£»1R\CT °°L%%iqN\A
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GHIA ROLDAN ANGELES C RIMHWEKNE UOMPLAIN T
(Name and Address ofDefendant) 7 _ 7 0
· ~· • ·..~ .. ,
I, the undersigned complainant being duly sworn, state the following is true and correct to the best of my
knowledge and belief. On or about May 8, 2007 in San Francisco County, in the Northern District of California
defendant did, utter, use, attempt to use, possess, obtain, accept or receive a visa, permit, border crossing card,
or alien registration receipt card, or other document prescribed by statute or regulation for entry into or as
evidence of authorized stay or employment in the United States, knowing it to be forged, counterfeited, altered,
or falsely made, or to have been procured by means of any false claim or statement, or to have been otherwise
procured by fraud or unlawfully obtained, in violation of Title 18 United States Code, Section 1546 .
I further state that I am a Customs and Border Protection Officer and that this complaint is based
on the following facts:
See attached Affidavit in Support of Criminal Complaint
Maximum Penalties:
Title 18 USC Section 1546:
10 years of imprisonment; $2 0,000 fine; 3 years supervised release; and $100 special assessment fee
APPROVED AS TO FORM:
en omas, SAUSA
Continued on the attached sheet and made a part hereof: EI No ’
Warrant of Arrest Requested: EIYes E.INo M/__ _,.. fi
Bail Amount: Ng ,40 “ ·»~· M
Signature of Complainant, uardo Reveles
Sworn to before me and subscribed in my presence,
May 10, 2007 at San Francisco, California
Date City and State
Elizabeth D. Laporte A
United States Magistrate Judge il H
Name & Title of Judicial Officer Signature f Judicial Officer

_ Case 1 :07—cr—00319—NJV Document 1 Filed 05/10/2007 Page 2 of 4
UNITED STATES DISTRICT COURT )
) ss. AF FIDAVIT
NORTHERN DISTRICT OF CALIFORNIA )
AFFIDAVIT IN SUPPORT OF A CRIMINAL
COMPLAINT CHARGIN G
GHIA ROLDAN ANGELES
WITH VIOLATING 18 U.S.C. § 1546,
FRAUD AND MISUSE OF VISAS, PERMITS, AND OTHER DOCUMENTS
I, Eduardo Reveles, do swear and affirm as follows,
Purpose
. 1. This affidavit establishes probable cause to arrest Ghia Roldan ANGELES for
violating 18 U.S.C. § 1546, Fraud and Misuse of Visas, Permits, and Other Documents,
when she presented a United States visa to Customs and Border Protection officers at the
San Francisco International Airport knowing it to be a counterfeit document. This
affidavit is based in part on personal knowledge, interviews, and reviews of official
documents and records, and does not contain every fact, piece of information or evidence
concerning this alleged violation.
Afiiant Background
2. I am an Officer with the United States Department of Homeland Security,
Customs and Border Protection ("CBP"). I have been employed with CBP since March
of 2003. Previously, I was employed as an Immigration Inspector with the United States
Department of Justice, Immigration and Naturalization Service, beginning on June 15,
2002. My duties include the investigation and prosecution of violations of the
Immigration and Nationality Act and related criminal immigration statutes.
Relevant Statute
3. Title 18 U.S.C. § 1546(a), Fraud and Misuse of Visas, Permits, and Other
Documents, states, in relevant part: "Whoever knowingly utters, uses, attempts to use,
possesses, obtains, accepts, or receives any visa, permit, border crossing card, alien
registration receipt card, or other document prescribed by statute or regulation for entry
into or as evidence of authorized stay or employment in the United States, knowing it to
be forged, counterfeited, altered, or falsely made, or to have been procured by means of
any false claim or statement, or to have been otherwise procured by fraud or unlawfully
obtained"— is guilty of a felony.
1

_ Case 1 :O7—cr—OO319—NJV Document 1 Filed 05/10/2007 Page 3 of 4
Case Facts and Evidence ·
4. On May 8, 2007, the subject arrived at the San Francisco International Airport
onboard Singapore Airlines Flight Number 002 irom Singapore at approximately 7:30
p.m. The subject presented an Philippine passport that was not expired (Number
UU0825229) and an expired Philippine passport (Number GG884825). The expired
Philippine passport presented by the subject included a United States tourist/business
Visa (Number 37408578). The subject presented these documents to the primary officer
for admission into the United States. The subject also presented an Arrival/Departure
Form I-94 (Number 222176278) to CBP Officer Troy Medeiros along with a Customs
Declaration Form 6059B. All the documents presented were in the subject’s name, Ghia
Roldan ANGELES.
5. At that time, Officer Medeiros noticed inconsistencies with the Visa presented
for inspection. Specifically, Officer Medeiros noticed the placement of the subject’s
nationality on the Visa was improperly indented. Officer Medeiros referred the subject
for further examination to passport control secondary to verify the authenticity of the
Visa.
6. The Visa was then examined by the San Francisco International Airport
forensic lab. Visual inspection of the Visa in the forensic lab under VCS-4 wavelength
lighting isolated where the original writing on the visa had been and revealed that the
Visa had been chemically washed. CBP Officer Hemani Del Rosario queried the
Consular Consolidated Database ("CCD") which revealed the Visa’s foil number
(Number 37408578) was originally issued to a Herminio Jr. Lopez Balagat on a
Philippine passport (Number GG417723) on April 2, 2001. Based on this inspection it
was determined that the Visa was altered and had a photo substitution.
7. On May 8, 2007, the subject was placed under oath, swom, and
administratively interviewed by CBP Officer Benito Pangan in English (Swom statement
form I-867A & B). The subject admitted that her true name is Ghia Roldan ANGELES.
The subject stated she was born in the Philippines and is a citizen of the Philippines. The
subject stated her date of birth is October 3, 1978. The subject stated she never applied
for a visa at the United States embassy in Manila, Philippines.
8. The subject stated she provided one passport and two photographs to a
messenger, working on behalf of a Mr. Efren, in Quezon City, Philippines. The subject
stated she met Mr. Efren through her aunt, who provided Mr. Efren with the subject’s
telephone number to make arrangements in the Philippines to secure a visa and passport
for travel to the United States. The subject stated that her sister deposited three thousand
dollars ($3,000) into Mr. Eiren’s bank account in the United States. The subject also
stated that Mr. Eiren would later be paid a remaining balance of nine thousand dollars
($9,000) for a total of twelve thousand dollars ($12,000).
2

Case 1 :O7—cr—OO319—NJV Document 1 Filed 05/10/2007 Page 4 of 4
9. The subject admitted to presenting the counterfeit Visa in her application for
admission to the United States with the hopes of gaining entry to obtain unauthorized
employment.
Conclusion "
10. I respectfully submit that the above presented facts establish probable cause
to believe that Ghia Roldan ANGELES did possess and utter a visa knowing it to be
counterfeit when she presented a United States tourist/business Visa to Customs and
Border Protection officers at the San Francisco International Airport in violation of Title
18, United States Code, Section 1546, Fraud and Misuse of Visas, Permits, and Other
Documents, while in the Northern District of California.
..,, . / ‘
I declare under the penalty of perjury under the ` the States that the
foregoing is true and correct. , · _ 7
Cy
, ‘ iiii
Eduardo Re s
U.S. Customs and Border Protection
U.S. Dept. of Homeland Security
SUBSCRIBED AND SWORN BEFORE ME
ON May 10, 2007
J J) F)
lge Honérable Elizabeth D. Lapirte
US Magistrate Judge
Northern District of Califomia
3

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