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Case 1:10-cr-00448-AJT Document 51 Filed 12/01/10 Page 1 of 9

IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

UNITED STATES OF AMERICA

No. l:10-CR-448-AJT

SANG BUN SURH,


a.k.a. "Chung Kim"
a.k.a. "Chung Madame,"
a.k.a. "Sang Bun Kim,"

Defendant.

STATEMENT OF FACTS

The United States of America and the defendant, SANG BUN SURH, agree that had this

matter proceeded to trial, the United States would have proven beyond a reasonable doubt the

following facts:

1. The defendant is a citizen of the Republic of Korea (South Korea) and is a lawful

permanent resident of the United States.

2. From on or about December 15,2007 to October 14, 2010, in Fairfax County, in

the Eastern District of Virginia, and elsewhere, the defendant, SANG BUN SURH, did

unlawfully and knowingly conspire with Hyeon Chul Kim, Young Mi Kim, CWN, and others to:

a. conceal, harbor, and shield from detection an alien in any place, including

any building and any means of transportation, knowing and in reckless disregard

of the fact that such alien had come to, entered, and remained in the United States

in violation of law, for the purpose of commercial advantage and private financial
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