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Sang Bun Surh Plea
Sang Bun Surh Plea
Alexandria Division
No. l:10-CR-448-AJT
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
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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