Kingdom of Jesus Christ Indictment

1 11/10/2021
2 81'(56($/ DVE
8 UNITED STATES DISTRICT COURT
9 FOR THE CENTRAL DISTRICT OF CALIFORNIA
10 April 2021 Grand Jury
11 UNITED STATES OF AMERICA, No. CR 20-00079(A)-TJH
12 Plaintiff, F I R S T
S U P E R S E D I N G
13 v. I N D I C T M E N T
14 APOLLO CARREON QUIBOLOY, [18 U.S.C. § 1594(c): Conspiracy
aka “The Appointed Son of to Engage in Sex Trafficking by
15 God,” Force, Fraud, and Coercion and Sex
aka “Sir,” Trafficking of Children;
16 aka “Pastor,” 18 U.S.C. §§ 1591(a)(1), (a)(2),
aka “ACQ,” (b)(1): Sex Trafficking by Force,
17 TERESITA TOLIBAS DANDAN, Fraud, and Coercion; 18 U.S.C.
aka “Tessie,” § 371: Conspiracy; 8 U.S.C.
18 aka “Sis Ting,” § 1325(c): Marriage Fraud;
aka “TTD,” 18 U.S.C. § 1546: Fraud and Misuse
19 HELEN PANILAG, of Visas; 31 U.S.C. § 5332: Bulk
aka “HP,” Cash Smuggling; 18 U.S.C.
20 FELINA SALINAS, § 1956(a)(1)(A)(i): Promotional
aka “Sis Eng Eng,” Money Laundering; 18 U.S.C.
21 aka “FS,” § 1956(a)(1)(B)(i): Concealment
GUIA CABACTULAN, Money Laundering; 18 U.S.C.
22 MARISSA DUENAS, § 1956(a)(2)(A): International
aka “MD,” Promotional Money Laundering;
23 AMANDA ESTOPARE, 8 U.S.C. § 1324, 18 U.S.C.
BETTINA PADILLA ROCES, §§ 981(a)(1)(C), 982 and 1594(d),
24 aka “Kuki,” and 28 U.S.C. § 2461(c) and 31 U.S.C.
MARIA DE LEON, § 5317: Criminal Forfeiture]
25 aka “Lui,”
26 Defendants.
27
28
1 The Grand Jury charges:
2 INTRODUCTORY ALLEGATIONS
3 At times relevant to this First Superseding Indictment:
4 A. THE ORGANIZATIONS
5 1. The Kingdom of Jesus Christ, The Name Above Every Name

6 (“KOJC”) was a church that was founded on or about September 1, 1985
7 in Davao, Philippines. KOJC claimed to have approximately six
8 million members in approximately 200 countries. KOJC was led by
9 defendant APOLLO CARREON QUIBOLOY, also known as (“aka”) “The
10 Appointed Son of God,” aka “Sir,” aka “Pastor,” aka “ACQ.”
11 2. In or around 1998, KOJC founded the Children’s Joy
12 Foundation (“CJF”). The stated goal of CJF was “to provide children
13 in the Philippines with various residential services, medical,
14 psychosocial, educational support and emergency assistance to harness
15 their potential in community and nation building.”
16 3. In or around 2007, KOJC began operating CJF in the United
17 States as a registered non-profit charity under Title 26, United
18 States Code, Section 501(c)(3). CJF was registered in the state of
19 California as a foreign non-profit with its principal office located
20 at 127 South Brand Boulevard, Glendale, California 91204.
21 4. KOJC owned and operated property throughout the United
22 States. Properties owned and operated by KOJC included a church and
23 main office located at the 14400 block of Vanowen Street, Van Nuys,
24 California 91405 (“KOJC Compound”). The KOJC Compound operated as
25 the headquarters of KOJC’s United States operations. Inside the KOJC
26 Compound was an office operated by KOJC administrators, including, at
27 various times, defendants HELEN PANILAG, aka “HP,” GUIA CABACTULAN,
28 MARISSA DUENAS, aka “MD,” and AMANDA ESTOPARE.
2
1 5. KOJC further owned and operated a commercial building
2 located at 94-378 Pupupani Street, Waipahu, Hawaii 96797 (“94-378
3 Pupupani Street”), where KOJC in Hawaii operated and KOJC workers
4 resided. KOJC’s operations in Hawaii were led by KOJC administrator
5 defendant FELINA SALINAS, aka “Sis Eng Eng,” aka “FS,” who worked out
6 of an office at 94-378 Pupupani Street.
7 6. KOJC administrators at the KOJC Compound and 94-378
8 Pupupani Street reported to senior administrators in the Philippines,
9 including defendants TERESITA TOLIBAS DANDAN, aka “Tessie,” aka “Sis
10 Ting,” aka “TTD,” and PANILAG, who reported to the head of KOJC and
11 CJF, defendant QUIBOLOY.
12 B. KOJC ADMINISTRATORS’ NATIONWIDE SOLICITING OPERATIONS
13 7. Under the direction of defendant QUIBOLOY, KOJC

14 administrators brought certain KOJC workers from the Philippines to
15 the United States to spend long hours illegally soliciting money for
16 KOJC outside of businesses across the United States. KOJC
17 administrators also imposed mandatory daily cash solicitation quotas
18 on such KOJC workers. At the direction of KOJC administrators, the
19 KOJC workers represented to the public that donated money would be
20 used by CJF to help impoverished children, when in fact the money
21 directly financed KOJC operations and the lavish lifestyle of KOJC
22 leaders, including defendants QUIBOLOY, DANDAN, and SALINAS.
23 8. In order to traffic KOJC workers into the United States to
24 solicit for KOJC, KOJC administrators, including defendants QUIBOLOY
25 and DANDAN, fraudulently obtained United States nonimmigrant visas
26 for KOJC workers by falsely representing in visa applications that
27 the workers were traveling to the United States to engage in church-
28 related concerts and similar religious activities, when in reality
3
1 they were bringing the KOJC workers to the United States to engage in
2 street-level solicitation throughout the country.
3 9. KOJC administrators maintained the legal immigration status
4 of workers who proved capable of meeting daily cash solicitation
5 quotas by fraudulently obtaining student visas for such workers or by
6 forcing them to enter into sham marriages with other KOJC workers who
7 had already obtained United States citizenship. These workers, in
8 turn, stayed in the United States and solicited year-round for KOJC.
9 C. SEX TRAFFICKING OF PASTORALS
10 10. Pastorals were young women within KOJC who were selected to
11 work as personal assistants for defendant QUIBOLOY. Pastorals were
12 recruited by defendant QUIBOLOY and other KOJC administrators,
13 including defendants DANDAN and SALINAS and others known and unknown
14 to the Grand Jury. Pastorals were typically between the ages of
15 twelve and twenty-five.
16 11. Pastorals prepared defendant QUIBOLOY’s meals, cleaned his
17 residences, gave him massages using lotion, and traveled with him on
18 trips throughout the world, to include the United States.
19 12. Pastorals engaged in sex with defendant QUIBOLOY on a
20 schedule determined by defendants QUIBOLOY and DANDAN, and others
21 known and unknown to the Grand Jury, in what was referred to by the
22 pastorals as “night duty.” For some pastorals, “night duty” began
23 before the pastoral reached the age of eighteen.
24 13. Defendant QUIBOLOY and other KOJC administrators coerced
25 pastorals into having “night duty” – that is, sex – with defendant
26 QUIBOLOY under the threat of physical and verbal abuse and eternal
27 damnation by defendant QUIBOLOY and other KOJC administrators.
28 Defendant QUIBOLOY and other KOJC administrators told pastorals that
4
1 performing “night duty” was “God’s will” and a privilege, as well as
2 a necessary demonstration of the pastoral’s commitment to give her
3 body to defendant QUIBOLOY as “The Appointed Son of God.”
4 14. Pastorals who performed their duties, to include “night
5 duty,” to the satisfaction of defendant QUIBOLOY and other KOJC
6 administrators were rewarded by defendant QUIBOLOY and other KOJC
7 administrators with privileges, including trips to tourist
8 destinations like Disneyland, flights in private jets, use of cell
9 phones, and yearly monetary payments referred to as “honorariums” by
10 KOJC administrators.
11 D. THE DEFENDANTS
12 15. The below-referenced defendants were the main KOJC

13 administrators in the Philippines and United States and were in
14 charge of organizing the activities of KOJC workers in the United
15 States, including efforts to solicit money for KOJC:
16 a. Defendant QUIBOLOY was the founder of KOJC and CJF,
17 was the principal leader of both organizations, and was the religious
18 leader of KOJC. Defendant QUIBOLOY generally operated out of a
19 compound controlled by KOJC in Davao City, Philippines. Prior to in
20 or around February 2018, defendant QUIBOLOY frequently traveled to
21 the United States to observe KOJC and CJF’s operations in the United
22 States and to speak with local administrators. When in the United
23 States, defendant QUIBOLOY stayed at large residences that he
24 controlled, including residences in Calabasas, California, Las Vegas,
25 Nevada, and Kapolei, Hawaii.
26 b. Defendant DANDAN was the International Administrator
27 of KOJC and, along with other administrators, was in charge of KOJC
28 and CJF operations in the United States and elsewhere. Defendant
5
1 DANDAN generally operated out of KOJC’s compound in Davao City,
2 Philippines. Prior to in or around February 2018, defendant DANDAN
3 frequently traveled to the United States to oversee KOJC and CJF’s
4 operations. As the International Administrator of KOJC, defendant
5 DANDAN was responsible for approving KOJC worker assignments and
6 fraudulent marriages and would receive reports on the soliciting
7 activities of KOJC workers.
8 c. Defendant PANILAG previously was the lead KOJC
9 administrator in the United States before being promoted to an
10 international role in which she oversaw the reporting of KOJC
11 financial information from KOJC operations worldwide.
12 d. Defendant SALINAS was the lead KOJC administrator in
13 Hawaii. Defendant SALINAS operated KOJC facilities throughout Hawaii
14 and reported directly to KOJC leadership in the Philippines. In this
15 role, defendant SALINAS was responsible for collecting and securing
16 the passports and immigration-related documents from KOJC workers in
17 Hawaii in order to prevent the workers from freely accessing their
18 documents. Defendant SALINAS was also in charge of tracking the
19 money raised by KOJC workers in Hawaii and reporting the amounts
20 raised to KOJC administrators located in the Philippines. Defendant
21 SALINAS provided daily solicitation quotas for KOJC workers to meet
22 and would direct the flow of solicited funds from Hawaii to KOJC
23 administrators in the Philippines.
24 e. Defendant CABACTULAN was the lead KOJC administrator
25 in the United States. Defendant CABACTULAN operated the KOJC
26 Compound and maintained direct communication with KOJC leadership in
27 the Philippines. Defendant CABACTULAN was in charge of tracking
28 funds raised by KOJC workers in the United States and reporting such
6
1 amounts to KOJC administrators in the Philippines until in or around
2 2015, when defendant ESTOPARE took over this role. Defendant
3 CABACTULAN was also previously responsible for overseeing the
4 completion and submission of immigration-related documents for KOJC
5 workers from the Philippines and elsewhere, before the role was
6 transferred to defendant DUENAS.
7 f. Defendant DUENAS was the human resources leader of
8 KOJC in the United States and was responsible for collecting and
9 securing the passports and immigration-related documents from KOJC
10 workers in order to prevent KOJC workers from freely accessing their
11 passports and immigration-related documents. Defendant DUENAS also
12 handled fraudulent immigration-related documents for KOJC workers,
13 including applying for sham marriages and student visas obtained on
14 behalf of KOJC workers to allow the workers to remain in the United
15 States and solicit funds for KOJC.
16 g. Defendant ESTOPARE was in charge of tracking money
17 raised by KOJC workers in the United States and reporting the amounts
18 raised to KOJC administrators located in the Philippines. Defendant
19 ESTOPARE also provided daily solicitation quotas for KOJC workers and
20 would direct the flow of solicited funds from the United States to
21 KOJC administrators in the Philippines.
22 h. Defendant BETTINA PADILLA ROCES, aka “Kuki,” handled
23 financial matters and discipline. Defendant ROCES received
24 fundraising reports, and cash from KOJC worker solicitation activity
25 would be delivered to her.
26 16. Defendant MARIA DE LEON, aka “Lui,” was a paralegal and
27 notary who owned and operated Liberty Legal Document Services in Los
28 Angeles, California. Defendant DE LEON was paid by defendants
7
1 CABACTULAN and DUENAS, and others known and unknown to the Grand
2 Jury, to complete and process fraudulent marriages and immigration-
3 related documents for KOJC workers.
4 E. NONIMMIGRANT VISAS
5 17. A citizen of a foreign country who wished to enter the

6 United States generally was required to first obtain a visa from the
7 United States Government: either a nonimmigrant visa for temporary
8 stay, or an immigrant visa for permanent residence. Visitor visas
9 were nonimmigrant visas for persons who wanted to enter the United
10 States temporarily for business (visa category B-1), for tourism,
11 pleasure, or visiting (B-2), for both purposes (B-1/B-2), or to
12 attend school in the United States (F or M). An individual in the
13 United States on a visitor visa (B-1/B-2) was not permitted to accept
14 employment or work in the United States.
15 18. In order to apply for a nonimmigrant business and/or
16 tourist visa, an applicant was required to complete and submit a
17 Nonimmigrant Visa Application and schedule an appointment for a visa
18 interview. Generally, the visa interview would take place at a
19 United States Embassy/Consulate in a foreign country.
20 19. In order to apply for a student visa, an applicant was
21 required to have a foreign residence and intend to return to that
22 residence upon completion of his or her studies. While on a student
23 visa, the student was required to study at the academic institution
24 through which the visa was granted. In general, a student visa
25 holder was allowed to hold off-campus employment only if the
26 employment was related to his or her area of study and was approved
27 by United States Customs and Immigration Services.
28 20. In order for a foreign student to study in the United
8
1 States on an F-1 student visa, the student was required to declare
2 and promise under oath to United States authorities that the student
3 sought the F-1 student visa solely for the purpose of pursuing the
4 student’s course of study.
5 21. Receiving a nonimmigrant visa from the United States
6 Government was a privilege, not a right. In order to be granted a
7 nonimmigrant visa to visit the United States, applicants were
8 required to overcome the presumption in the United States Immigration
9 and Nationality Act that all visa applicants were immigrants who
10 intended to remain in the United States.
11 F. MARRIAGES AND IMMIGRATION
12 22. United States Citizenship and Immigration Services

13 (“USCIS”) was an agency of the Department of Homeland Security.
14 USCIS was a government agency that oversaw lawful immigration to the
15 United States. USCIS provided the procedures for a United States
16 citizen or a lawful permanent resident to acquire permanent resident
17 status for their immigrant spouse that lived in the United States or
18 abroad.
19 23. A foreign national could obtain lawful permanent resident
20 status in the United States based upon his or her valid marriage to a
21 United States citizen.
22 24. If the marriage was in the United States, the United States
23 citizen was required to file a Form I-130, Petition for Alien
24 Relative, with USCIS seeking to accord the beneficiary spouse
25 “immediate family relative” status. The petitioner was required to
26 submit his or her marriage certificate with the application, and
27 there was no waiting period to obtain an immigrant visa.
28 25. The beneficiary immigrant spouse was required to file a
9
1 Form I-485, Application to Register Permanent Residence or Adjust
2 Status. By so doing, the beneficiary applied to adjust his or her
3 status to that of a lawful permanent resident. If the marriage,
4 which was the basis of the application, was less than two years old,
5 the beneficiary was accorded conditional lawful permanent resident
6 status, which expired after two years.
7 26. Within ninety days of the expiration of conditional lawful
8 permanent resident status, the petitioner and the beneficiary were
9 required to file with USCIS a Form I-751, Petition to Remove
10 Conditions on Residence. The petition required certification that
11 the marriage was entered in accordance with the laws of the place
12 where the marriage took place and was not for the purpose of
13 procuring an immigration benefit.
14 27. A perjury clause instructing the signor that all
15 information provided must be truthful and accurate was present on
16 Form I-130, Form I-485, and Form I-751.
17 28. A “sham” marriage was a marriage that was entered into for
18 the primary purpose of circumventing the immigration laws.
19 G. CURRENCY TRANSACTION REPORTING REQUIREMENTS
20 29. Pursuant to Title 31, United States Code, Section 5313, and
21 regulations thereunder, including Title 31, Code of Federal
22 Regulations, Chapter X, Parts 1010.311 and 10101.306(a), financial
23 institutions were required to prepare and file Currency Transaction
24 Reports with the United States Department of Treasury to report cash
25 transactions in amounts greater than $10,000. Title 31, Code of
26 Federal Regulations, Chapter X, Part 1010313(b) provided that
27 multiple transactions at the same financial institution on the same
28 day were to be treated as a single transaction; deposits made on a
10
1 weekend or a holiday were treated as if received on the next business
2 day.
3 30. To complete a Currency Transaction Report, the financial
4 institution was required to verify and record the name and address of
5 the person presenting the transaction, and the identity, account
6 number, and social security or taxpayer identification number, if
7 any, of any person or entity on whose behalf the transaction was to
8 be effected.
9 31. These Introductory Allegations are incorporated into all
10 Counts of this First Superseding Indictment.
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1 COUNT ONE
2 [18 U.S.C. § 1594(c)]
3 [DEFENDANTS QUIBOLOY, DANDAN, and SALINAS]
4 A. OBJECTS OF THE CONSPIRACY
5 1. Beginning no later than in or around 2002, and continuing

6 to at least in or around 2018, in Los Angeles County, within the
7 Central District of California, and elsewhere, defendants APOLLO
8 CARREON QUIBOLOY, aka “The Appointed Son of God,” aka “Sir,” aka
9 “Pastor,” aka “ACQ,” TERESITA TOLIBAS DANDAN, aka “Tessie,” aka “Sis
10 Ting,” aka “TTD,” and FELINA SALINAS, aka “Sis Eng Eng,” aka “FS,”
11 and others known and unknown to the Grand Jury, conspired with each
12 other to knowingly, in and affecting interstate and foreign commerce,
13 recruit, entice, harbor, transport, provide, obtain, and maintain by
14 any means, and benefit, financially and by receiving anything of
15 value, from participation in a venture that recruited, enticed,
16 harbored, transported, provided, obtained, and maintained by any
17 means:
18 a. Minor victims K.A., K.P., and K.F., knowing and
19 recklessly disregarding, and with reasonable opportunity to observe,
20 that the child victims had not attained the age of 18 and would be
21 caused to engage in a commercial sex act, in violation of Title 18,
22 United States Code, Sections 1591(a)(1), (a)(2), (b)(2); and
23 b. Victims R.E., J.B., K.A., K.P., and K.F., knowing and
24 recklessly disregarding that force, threats of force, fraud, and
25 coercion, as defined in Title 18, United States Code, Section
26 1591(e)(2), and any combination of such means, would be used to cause
27 victims R.E., J.B., K.A., K.P., and K.F. to engage in commercial sex
28
12
1 acts, in violation of Title 18, United States Code, Sections
2 1591(a)(1), (a)(2), (b)(1).
3 B. MEANS BY WHICH THE OBJECTS OF THE CONSPIRACY WERE TO BE
4 ACCOMPLISHED
5 2. The objects of the conspiracy were to be accomplished, in
6 substance, as follows:
7 a. Defendants QUIBOLOY, DANDAN, and SALINAS, and others
8 known and unknown to the Grand Jury, would recruit female victims
9 ranging in age from approximately twelve to twenty-five to work as
10 personal assistants, referred to as “pastorals,” for defendant
11 QUIBOLOY. At the direction of defendants QUIBOLOY, DANDAN, and
12 SALINAS, and others known and unknown to the Grand Jury, female
13 victims prepared defendant QUIBOLOY’s meals, cleaned his residences,
14 gave him massages using lotion, and traveled with him on trips
15 throughout the world, to include the United States.
16 b. Defendants QUIBOLOY, DANDAN, and SALINAS, and others
17 known and unknown to the Grand Jury, would instruct female victims to
18 write “commitment letters” to defendant QUIBOLOY in which the victims
19 would devote their lives, including their bodies, to defendant
20 QUIBOLOY as “The Appointed Son of God.”
21 c. Defendants QUIBOLOY, DANDAN, and SALINAS, and others
22 known and unknown to the Grand Jury, would order female victims,
23 including minor victims, to have sex with defendant QUIBOLOY on a
24 schedule determined by defendants QUIBOLOY and DANDAN, and others, in
25 what was referred to as “night duty.”
26 d. Defendants QUIBOLOY, DANDAN, and SALINAS, and others
27 known and unknown to the Grand Jury, would tell female victims that
28 obedience to defendant QUIBOLOY was the will of God and that “night
13
1 duty” was pleasing to God and a privilege, and would allow the
2 victims to obtain salvation.
3 e. Defendants QUIBOLOY, DANDAN, and SALINAS, and others
4 known and unknown to the Grand Jury, would tell female victims who
5 expressed hesitation at “night duty” that they had the devil in them
6 and risked eternal damnation.
7 f. Defendants QUIBOLOY and SALINAS, and others known and
8 unknown to the Grand Jury, would tell female victims who had
9 performed “night duty” not to speak of it.
10 g. Defendant QUIBOLOY would threaten and physically abuse
11 victims who attempted to leave KOJC or were not available to perform
12 night duty. Defendant QUIBOLOY would also physically abuse female
13 victims for communicating with other men or engaging in other
14 behavior that upset him. Defendant QUIBOLOY deemed such behavior
15 adultery and a sin.
16 h. Defendants QUIBOLOY and DANDAN would provide female
17 victims who were obedient and performed their duties well, to include
18 “night duty,” with rewards such as good food, luxurious hotel rooms,
19 trips to tourist spots, and yearly cash payments that were based on
20 performance. These rewards were purchased by defendant QUIBOLOY and
21 KOJC administrators using money raised through solicitation by KOJC
22 workers, including KOJC workers in the United States and the Central
23 District of California.
24 i. Defendants QUIBOLOY and SALINAS, and others known and
25 unknown to the Grand Jury, would retaliate against victims who
26 escaped KOJC by harassing, threatening, and making allegations of
27 criminal misconduct against the victims. Defendant QUIBOLOY would
28 give sermons, broadcasted to KOJC members around the world, in which
14
1 he would allege that victims who escaped had engaged in criminal
2 conduct and sexually promiscuous activity, and therefore faced
3 eternal damnation, in order to discourage other victims from leaving,
4 retaliate against and discredit the victims, and conceal the sexual
5 activity between defendant QUIBOLOY and the victims.
6 C. OVERT ACTS
7 3. In furtherance of the conspiracy, and to accomplish its

8 objects, on or about the following dates, defendants QUIBOLOY,
9 DANDAN, and SALINAS, and others known and unknown to the Grand Jury,
10 committed various overt acts within the Central District of
11 California, and elsewhere, including, but not limited to, the
12 following:
13 Overt Act No. 1: In or around 2002, defendant QUIBOLOY had
14 sex with victim K.F. when she was approximately fifteen years old.
15 Overt Act No. 2: In or around 2005, defendant SALINAS asked
16 victim K.A., before victim K.A. was to perform “night duty,” whether
17 victim K.A. was a virgin.
19 sex with victim K.A. when she was approximately seventeen years old.
20 Overt Act No. 4: In or around 2005, defendant SALINAS
21 instructed victim K.A. not to tell anyone about having sex with
22 defendant QUIBOLOY.
24 provided lingerie for victim J.B., and gave victim J.B. lotion to put
25 on defendant QUIBOLOY as part of her “night duty.”
27 sex with victim J.B. and told her not to tell anyone.
15
1 instructed victim R.E. to write a commitment letter devoting her
2 life, to include her body, to defendant QUIBOLOY.
3 Overt Act No. 8: In or around 2009, defendant QUIBOLOY
4 instructed victim R.E. to write a commitment letter dedicating

5 herself to defendant QUIBOLOY after victim R.E. resisted having sex
6 with defendant QUIBOLOY.
7 Overt Act No. 9: In or around 2009, defendant QUIBOLOY, while
8 engaging in sex acts with victim R.E., told victim R.E. that the sex
9 acts were in the Father’s will and that the Father was happy over
10 what the Son was doing.
11 Overt Act No. 10: In or around 2009, defendant SALINAS told
12 victim R.E. that if victim R.E. was afraid to go near defendant
13 QUIBOLOY, then victim R.E. had the devil in her.
15 sex with victim K.P. when she was approximately fourteen years old.
16 Overt Act No. 12: In or around 2014, defendant DANDAN directed
17 victim R.E. to purchase erectile dysfunction medication for defendant
18 QUIBOLOY.
19 Overt Act No. 13: In or around 2013, in Calabasas, California,
20 defendant QUIBOLOY yelled at victim J.B. and called her a “whore” for
21 not performing sexually to his satisfaction.
22 Overt Act No. 14: In or around 2014, defendant QUIBOLOY hit
23 and slapped victim R.E. and required her to solicit money in Los
24 Angeles, California for speaking with another man.
25 Overt Act No. 15: On or about February 12, 2015, defendants
26 QUIBOLOY and SALINAS, and others known and unknown to the Grand Jury,
27 directed a KOJC worker, who was a minor, to make false allegations of
28 sexual assault against victim K.A. in order to retaliate against
16
1 victim K.A. for leaving KOJC.
2 Overt Act No. 16: On or about October 12, 2018, defendant
3 QUIBOLOY gave a recorded sermon in which he publicly accused victim

4 R.E. of engaging in cybersex and stealing KOJC equipment, publicly
5 accused victim B.P. of engaging in cybersex, and publicly accused
6 victim K.A. of stealing a credit card before leaving the KOJC.
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1 COUNT TWO
2 [18 U.S.C. §§ 1591(a)(1), (a)(2), (b)(1), 2(a)]
3 [DEFENDANTS QUIBOLOY and SALINAS]
4 Beginning in or around 2009, and continuing through in or around
5 2014, in Los Angeles County, within the Central District of
6 California, and elsewhere, defendants APOLLO CARREON QUIBOLOY, aka
7 “The Appointed Son of God,” aka “Sir,” aka “Pastor,” aka “ACQ,” and
8 FELINA SALINAS, aka “Sis Eng Eng,” aka “FS,” each aiding and abetting
9 the other, in and affecting interstate and foreign commerce,
10 knowingly recruited, enticed, harbored, transported, provided,
11 obtained, and maintained by any means, and benefitted, financially
12 and by receiving anything of value, from participation in a venture
13 that recruited, enticed, harbored, transported, provided, obtained,
14 and maintained by any means, victim R.E., knowing and recklessly
15 disregarding that force, threats of force, fraud, and coercion, as
16 defined in Title 18, United States Code, Section 1591(e)(2), and any
17 combination of such means, would be used to cause victim R.E. to
18 engage in a commercial sex act.
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1 COUNT THREE
2 [18 U.S.C. §§ 1591(a)(1), (a)(2), (b)(1), 2(a)]
7 “The Appointed Son of God,” aka “Sir,” aka “Pastor,” aka “ACQ,”
8 TERESITA TOLIBAS DANDAN, aka “Tessie,” aka “Sis Ting,” aka “TTD,” and
15 and maintained by any means, victim J.B., knowing and recklessly
16 disregarding that fraud and coercion, as defined in Title 18, United
17 States Code, Section 1591(e)(2), and any combination of such means,
18 would be used to cause victim J.B. to engage in a commercial sex act.
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1 COUNT FOUR
2 [18 U.S.C. §§ 1591(a)(1), (a)(2), (b)(1), 2(a)]
7 “The Appointed Son of God,” aka “Sir,” aka “Pastor,” aka “ACQ,”
8 TERESITA TOLIBAS DANDAN, aka “Tessie,” aka “Sis Ting,” aka “TTD,” and
15 and maintained by any means, victim K.A., knowing and recklessly
16 disregarding that force, threats of force, fraud, and coercion, as
17 defined in Title 18, United States Code, Section 1591(e)(2), and any
18 combination of such means, would be used to cause victim K.A. to
19 engage in a commercial sex act.
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1 COUNT FIVE
2 [18 U.S.C. §§ 1591(a)(1), (a)(2), (b)(1)]
3 [DEFENDANT QUIBOLOY]
6 California, and elsewhere, defendant APOLLO CARREON QUIBOLOY, aka
7 “The Appointed Son of God,” aka “Sir,” aka “Pastor,” aka “ACQ,” in
8 and affecting interstate and foreign commerce, knowingly recruited,
9 enticed, harbored, transported, provided, obtained, and maintained by
10 any means, and benefitted, financially and by receiving anything of
11 value, from participation in a venture that recruited, enticed,
12 harbored, transported, provided, obtained, and maintained by any
13 means, victim K.P., knowing and recklessly disregarding that force,
14 threats of force, fraud, and coercion, as defined in Title 18, United
15 States Code, Section 1591(e)(2), and any combination of such means,
16 would be used to cause victim K.P. to engage in a commercial sex act.
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24
25
26
27
28
21
1 COUNT SIX
2 [18 U.S.C. §§ 1591(a)(1), (a)(2), (b)(1), 2(a)]
3 [DEFENDANTS QUIBOLOY and DANDAN]
7 “The Appointed Son of God,” aka “Sir,” aka “Pastor,” aka “ACQ,” and
8 TERESITA TOLIBAS DANDAN, aka “Tessie,” aka “Sis Ting,” aka “TTD,”
9 each aiding and abetting the other, in and affecting interstate and
10 foreign commerce, knowingly recruited, enticed, harbored,
11 transported, provided, obtained, and maintained by any means, and
12 benefitted, financially and by receiving anything of value, from
13 participation in a venture that recruited, enticed, harbored,
14 transported, provided, obtained, and maintained by any means, victim
15 K.F., knowing and recklessly disregarding that force, threats of
16 force, fraud, and coercion, as defined in Title 18, United States
17 Code, Section 1591(e)(2), and any combination of such means, would be
18 used to cause victim K.F. to engage in a commercial sex act.
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21
22
23
24
25
26
27
28
22
1 COUNT SEVEN
2 [18 U.S.C. § 371]
3 [ALL DEFENDANTS]
4 A. OBJECTS OF THE CONSPIRACY
5 1. Beginning on a date unknown, but no later than in or around

6 January 2009, and continuing to on or about January 29, 2020, in Los
7 Angeles County, within the Central District of California, and
8 elsewhere, defendants APOLLO CARREON QUIBOLOY, aka “the Appointed Son
9 of God,” aka “Sir,” aka “Pastor,” aka “ACQ,” TERESITA TOLIBAS DANDAN,
10 aka “Tessie,” aka “Sis Ting,” aka “TTD,” HELEN PANILAG, aka “HP,”
11 FELINA SALINAS, aka “Sis Eng Eng,” aka “FS,” GUIA CABACTULAN, MARISSA
12 DUENAS, aka “MD,” AMANDA ESTOPARE, BETTINA PADILLA ROCES, aka “Kuki,”
13 and MARIA DE LEON, aka “Lui,” and others known and unknown to the
14 Grand Jury, conspired with each other to knowingly and intentionally
15 commit offenses against the United States, namely:
16 a. Benefitting from Forced Labor, in violation of Title
17 18, United States Code, Section 1589(b);
18 b. Trafficking with Respect to Forced Labor, in violation
19 of Title 18, United States Code, Section 1590(a);
20 c. Document Servitude, in violation of Title 18, United
21 States Code, Section 1592(a)(3);
22 d. Marriage Fraud, in violation of Title 8, United States
23 Code, Section 1325(c);
24 e. Fraud and Misuse of Visas, in violation of Title 18,
25 United States Code, Section 1546(a);
26 f. Promotional Money Laundering, in violation of Title
27 18, United States Code, Section 1956(a)(1)(A)(i);
28 g. Concealment Money Laundering, in violation of Title
23
1 18, United States Code, Section 1956(a)(1)(B)(i);
2 h. International Promotional Money Laundering, in
3 violation of Title 18, United States Code, Section 1956(a)(2)(A); and
4 i. Avoiding Reporting Requirements, in violation of Title
5 18, United States Code, Section 1956(a)(1)(B)(ii).
6 B. MEANS BY WHICH THE OBJECTS OF THE CONSPIRACY WERE TO BE
7 ACCOMPLISHED
8 2. The objects of the conspiracy were to be accomplished, in
9 substance, as follows:
10 a. Defendants QUIBOLOY, DANDAN, PANILAG, SALINAS,
11 CABACTULAN, DUENAS, and ESTOPARE, and others known and unknown to the
12 Grand Jury, would knowingly recruit, harbor, and obtain certain KOJC
13 workers for labor and services by concealing, removing, confiscating,
14 and possessing the passports and other immigration and identification
15 documents of such KOJC workers.
16 b. Defendants QUIBOLOY, DANDAN, PANILAG, SALINAS,
18 Grand Jury, would prevent and restrict, and attempt to prevent and
19 restrict, without lawful authority, certain KOJC workers’ liberty to
20 move and travel in order to maintain the labor and services of KOJC
21 workers, some of whom were and had been a victim of a severe form of
22 trafficking in persons through fraud and coercion for the purpose of
23 subjection to involuntary servitude and peonage, as defined in
24 Section 103 of the Trafficking Victims Protection Act of 2000.
25 c. Defendants QUIBOLOY, DANDAN, PANILAG, SALINAS,
27 Grand Jury, would coordinate to have certain KOJC workers, who were
28 previously recruited as KOJC members from the Philippines, admitted
24
1 into the United States by obtaining United States nonimmigrant visas
2 under false pretenses. Specifically, defendants QUIBOLOY, DANDAN,
3 PANILAG, SALINAS, CABACTULAN, DUENAS, and ESTOPARE, and others known
4 and unknown to the Grand Jury, would instruct KOJC workers to state
5 to immigration authorities and in immigration-related documents that
6 they were traveling to the United States to perform in church-related
7 concerts, when in fact the primary purpose of the travel to the
8 United States was for KOJC workers to beg for and solicit donations
9 across the country under the guise of being CJF “volunteers.”
10 d. Defendants DANDAN, CABACTULAN, and DUENAS, and others
11 known and unknown to the Grand Jury, would provide certain KOJC
12 workers with prepared responses and letters to provide to immigration
13 authorities upon arrival into the United States in an effort to avoid
14 detection. The prepared responses and letters stated, in substance,
15 that the KOJC workers would be performing as vocalists or
16 instrumentalists at KOJC concerts, and did not reference soliciting
17 on behalf of CJF or KOJC. At the time KOJC workers received the
18 prepared responses and letters, some of the KOJC workers were aware
19 that their purpose for entering into the United States was to solicit
20 for KOJC, while other KOJC workers were unaware of the actual purpose
21 until they were forced by defendants QUIBOLOY, DANDAN, PANILAG,
22 SALINAS, CABACTULAN, DUENAS, and ESTOPARE, and others known and
23 unknown to the Grand Jury, to solicit on the streets nearly every
24 day, year-round, working very long hours, and often sleeping in cars
25 overnight, without normal access to over-the-counter medicine, and,
26 at times, sufficient clothing.
27 e. Once KOJC workers arrived in the United States,
28 defendants PANILAG, SALINAS, CABACTULAN, and DUENAS, and others known
25
1 and unknown to the Grand Jury, would confiscate the passports and
2 other immigration-related documentation from them and store the
3 documents at the KOJC Compound, among other locations. KOJC workers
4 were allowed to access their immigration-related documents only if
5 traveling on behalf of KOJC or if KOJC workers provided a
6 justification for needing their immigration-related documents that
7 defendants PANILAG, SALINAS, CABACTULAN, and DUENAS, and others known
8 and unknown to the Grand Jury, found acceptable. Defendants PANILAG,
9 SALINAS, CABACTULAN, DUENAS, and ESTOPARE, and others known and
10 unknown to the Grand Jury, would confiscate all forms of
11 identification from each KOJC worker and provide the KOJC worker with
12 a badge that identified the worker as a “volunteer” with CJF.
13 f. Defendants QUIBOLOY, DANDAN, PANILAG, SALINAS,
15 Grand Jury, would transport certain KOJC workers across the country
16 to solicit donations as CJF “volunteers.” These “volunteers” were
17 referred to as Full Time Miracle Workers, or “FTMWs.” KOJC workers
18 fundraised for KOJC nearly every day, year-round, working very long
19 hours, and often sleeping in cars overnight, despite many of the KOJC
20 workers being prohibited from doing so by the terms and conditions of
21 their visas.
22 g. Defendants QUIBOLOY, DANDAN, PANILAG, SALINAS,
24 Grand Jury, would arrange for KOJC workers to be housed in communal
25 living conditions at the KOJC Compound and in other locations across
26 the United States, with multiple KOJC workers housed in shared rooms
27 and under poor conditions.
28 h. Defendants DANDAN, PANILAG, SALINAS, CABACTULAN,
26
1 DUENAS, and ESTOPARE, and others known and unknown to the Grand Jury,
2 would instruct KOJC workers to solicit on behalf of CJF, but not to
3 mention KOJC. Defendants PANILAG, SALINAS, CABACTULAN, DUENAS, and
4 ESTOPARE, and others known and unknown to the Grand Jury, provided
5 KOJC workers with CJF pamphlets, and instructed KOJC workers to
6 falsely inform the public that the money was used to aid impoverished
7 Filipino children.
8 i. Defendants DANDAN, PANILAG, SALIANS, CABACTULAN, and
9 ESTOPARE, and others known and unknown to the Grand Jury, would set
10 daily cash solicitation quotas for KOJC workers. These daily quotas
11 were increased during the months of September/October through
12 January/February of the following year for a period referred to as,
13 among other terms, the Month of Blessings or MOB, or Knights of
14 Harvest or KOH. KOJC workers who failed to meet their daily
15 solicitation quotas were often punished by KOJC administrators,
16 including defendants SALINAS and ESTOPARE, by being yelled at,
17 shamed, berated, physically abused, or forced to fast, i.e., abstain
18 from food, while being locked in a room at the KOJC Compound. KOJC
19 workers in the United States would be organized into fundraising
20 groups across the United States. While soliciting, any expenses,
21 such as food, lodging, and medical expenses, came out of the group’s
22 fundraising quota for that day. For that reason, KOJC workers often
23 skipped meals and slept in cars while fundraising for KOJC.
24 j. Prior to the start of the Month of Blessings,
25 defendants QUIBOLOY, DANDAN, PANILAG, SALINAS, CABACTULAN, DUENAS,
26 and ESTOPARE, and others known and unknown to the Grand Jury, would
27 arrange for KOJC workers to meet for a multi-day orientation in
28 California. During the orientation, defendants QUIBOLOY, DANDAN,
27
1 PANILAG, SALINAS, CABACTULAN, DUENAS, and ESTOPARE, and others known
2 and unknown to the Grand Jury, held meetings in which KOJC workers
3 were instructed on how to fundraise for KOJC and on how to complete
4 immigration paperwork. During the orientation, defendants QUIBOLOY
5 and DANDAN encouraged workers to fundraise money for KOJC.
6 k. Defendants SALINAS and ESTOPARE, and others known and
7 unknown to the Grand Jury, would direct the sending and receiving of
8 updates from fundraising groups on the performance of individual KOJC
9 workers and steps that were being taken for KOJC workers to meet
10 their solicitation quotas.
11 l. Defendants SALINAS and ESTOPARE, and others known and
12 unknown to the Grand Jury, would provide instructions via text
13 message, Facebook, and other means of communication regarding what to
14 do with the solicited money collected each day. Defendant ESTOPARE
15 would often instruct KOJC workers to deposit the cash into accounts
16 and then wire transfer the money to other KOJC workers located in the
17 Philippines who were designated to receive the money by KOJC
18 administrators.
19 m. Defendant PANILAG, and others known and unknown to the
20 Grand Jury, would drive across the United States collecting money
21 that was solicited by fundraising groups. Defendant PANILAG would
22 arrange for the money to be driven back to a residence in Calabasas,
23 California for later transport to the Philippines. While meeting
24 with fundraising groups across the country to collect money,
25 defendant PANILAG would provide motivational speeches to the
26 fundraising groups to encourage the workers to solicit more money.
27 n. Defendants QUIBOLOY, DANDAN, PANILAG, SALINAS,
28
1 Grand Jury, would seek to maintain United States immigration status
2 for KOJC workers who proved capable of meeting the cash solicitation
3 quotas by obtaining student visas for such KOJC workers, or by
4 arranging for such KOJC workers to enter into sham marriages with
5 other KOJC workers who had already obtained United States
6 citizenship, for the purpose of evading the immigration laws.
7 o. Defendants QUIBOLOY, DANDAN, PANILAG, SALINAS,
8 CABACTULAN, DUENAS, and DE LEON, and others known and unknown to the
9 Grand Jury, would arrange for KOJC workers who entered into such
10 fraudulent marriages to then apply for United States lawful permanent
11 resident status and citizenship based on the fraudulent marriages.
12 Defendants PANILAG, CABACTULAN, DUENAS, and DE LEON completed and
13 filed fraudulent marriage paperwork on behalf of KOJC workers and
14 arranged for the KOJC workers to be transported to a set location for
15 a sham marriage ceremony. Defendants PANILAG, CABACTULAN, DUENAS,
16 and ESTOPARE paid legal and document-processing fees for the
17 fraudulent immigration filings to defendant DE LEON, using funds
18 drawn from KOJC accounts.
19 p. Defendants DUENAS and DE LEON, and others known and
20 unknown to the Grand Jury, would prepare KOJC workers for interviews
21 with immigration authorities by providing lists of potential
22 marriage-based questions and having KOJC workers rehearse their
23 answers in order for the sham marriages to appear legitimate.
24 q. After KOJC workers who entered into fraudulent
25 marriages obtained United States citizenship, defendants QUIBOLOY,
26 DANDAN, PANILAG, CABACTULAN, and DUENAS would arrange for KOJC
27 workers to divorce their respective spouses to ensure that KOJC
28 workers subject to the divorces with United States citizenship could
29
1 then enter into fraudulent marriages with other KOJC workers who had
2 not yet obtained United States permanent residency or citizenship.
3 Defendants DUENAS and DE LEON would prepare and file divorce
4 paperwork on behalf of the KOJC workers, sometimes without the
5 knowledge or consent of the KOJC worker.
6 r. In order to manufacture the appearance of legitimacy
7 for the fraudulent marriages, defendant DUENAS would possess ATM
8 cards to show immigration authorities that KOJC workers in the
9 fraudulent marriages had joint banking accounts, and defendants
10 CABACTULAN and DUENAS would possess male and female wedding rings for
11 KOJC workers to use during fraudulent marriage ceremonies.
12 s. Defendants DANDAN, PANILAG, CABACTULAN, and DUENAS
13 would enroll certain KOJC workers at colleges in the United States.
14 Defendants CABACTULAN, DUENAS, and DE LEON would then fraudulently
15 apply for the KOJC workers to obtain United States student visas,
16 when in fact the purpose of the visas was to enable the KOJC workers
17 to remain in the United States to solicit for KOJC.
18 t. Defendants DANDAN, PANILAG, DUENAS, and DE LEON would
19 file affidavits of support on behalf of KOJC workers obtaining
20 student visas that falsely certified that the workers would be
21 supported by and staying with them while in the United States on
22 student visas, when in fact the workers were sent around the country
23 to solicit for KOJC.
24 u. Defendants CABACTULAN and DUENAS, and others known and
25 unknown to the Grand Jury, would complete and file college enrollment
26 paperwork for KOJC workers on student visas. Defendants CABACTULAN,
27 DUENAS, and ESTOPARE would pay the tuition for the KOJC workers on
28 student visas, using funds drawn from KOJC bank accounts. KOJC
30
1 workers attended college approximately one day a week, but would
2 otherwise spend their time soliciting money for KOJC.
3 v. Defendants DANDAN, PANILAG, CABACTULAN, DUENAS,
4 ESTOPARE, and ROCES would have KOJC workers deposit cash received
5 from soliciting and begging into bank accounts that they controlled.
6 w. Defendants DANDAN, PANILAG, CABACTULAN, DUENAS,
7 ESTOPARE, and ROCES would make efforts to ensure that KOJC workers
8 did not deposit more than $10,000 in cash into a bank account in
9 order to avoid bank reporting requirements and detection, including
10 by instructing workers to deposit cash in increments below $10,000
11 and at different bank branches.
12 x. After KOJC workers deposited cash received from
13 soliciting and begging into bank accounts under their control,
14 defendants DANDAN, PANILAG, CABACTULAN, DUENAS, ESTOPARE, and ROCES
15 would transfer those funds to certain KOJC accounts in the
16 Philippines in order to fund, among other things, construction of a
17 stadium and defendant QUIBOLOY’s lavish lifestyle.
18 y. Defendants DANDAN, CABACTULAN, PANILAG, and ESTOPARE,
19 and others known and unknown to the Grand Jury, would coordinate the
20 transfer of money raised by KOJC workers to the KOJC Compound by
21 physically picking up the money at locations across the country,
22 directing others to pick up the money, and by arranging for the money
23 to be wire transferred to a KOJC member in the Philippines.
24 Defendant ESTOPARE, and others known and unknown to the Grand Jury,
25 instructed KOJC workers to make cash deposits of less than $10,000
26 into bank accounts used for the wire transfers in order to avoid
27 reporting requirements and detection from banks.
28 z. For the money that was physically transferred to the
31
1 KOJC Compound, defendant ESTOPARE, and others known and unknown to
2 the Grand Jury, would provide KOJC workers approximately $9,000 in
3 cash to carry when they returned to the Philippines. The money would
4 be rolled into socks and placed in the luggage and on the person of
5 KOJC members flying on commercial airplanes to the Philippines from
6 the United States, or in bulk amounts stored in private jets operated
7 by KOJC under the direction of QUIBOLOY.
8 aa. Defendant QUIBOLOY would arrange for money raised by
9 KOJC workers to be packed in his luggage for transport back to the
10 Philippines by private jet.
11 bb. Money solicited in the United States, although
12 advertised by KOJC and CJF as designated to aid impoverished Filipino
13 children, would be used to directly finance certain KOJC-related
14 operations in the Philippines and United States, and the lavish
15 lifestyle of KOJC leaders, as directed by defendants QUIBOLOY and
16 DANDAN, and others known and unknown to the Grand Jury.
17 cc. Defendants QUIBOLOY and SALINAS, and others known and
18 unknown to the Grand Jury, would retaliate against members who
19 escaped KOJC by harassing, threatening, and making allegations of
20 criminal misconduct against the former members. Defendant QUIBOLOY
21 would give sermons, broadcasted to KOJC members around the world, in
22 which he would allege that former members who escaped had engaged in
23 criminal conduct and sexually promiscuous activity, and therefore
24 faced eternal damnation, in order to discourage other members from
25 leaving, retaliate against and discredit the former members, and
26 conceal the criminal conduct set forth herein. Defendant QUIBOLOY
27 would also order KOJC workers to harass former members over social
28 media and via other avenues.
32
1 C. OVERT ACTS
2 3. In furtherance of the conspiracy, and to accomplish its

3 objects, on or about the following dates, defendants QUIBOLOY,
4 DANDAN, PANILAG, SALINAS, CABACTULAN, DUENAS, ESTOPARE, ROCES, and DE
5 LEON, and others known and unknown to the Grand Jury, committed
6 various overt acts within the Central District of California, and
7 elsewhere, including, but not limited to, the following:
8 Overt Act No. 1: On or about January 19, 2009, defendant
9 DANDAN, and others known and unknown to the Grand Jury, arranged for
10 victim K.L., who was a United States citizen, to marry another KOJC
11 worker with whom victim K.L. had no romantic relationship, for the
12 purpose of enabling the KOJC worker to obtain legal permanent
13 resident status. In order to effectuate the marriage, defendant
14 DANDAN, and others known and unknown to the Grand Jury, facilitated
15 the completion of marriage paperwork on behalf of victim K.L. and
16 arranged for victim K.L. to attend a marriage ceremony in Las Vegas,
17 Nevada.
18 Overt Act No. 2: In or around May 2010, victim A.L. and her
19 two children’s passports were confiscated at the direction of
20 CABACTULAN and stored at the KOJC Compound upon victim A.L. joining
21 KOJC.
22 Overt Act No. 3: On or about November 23, 2010, defendant
23 QUIBOLOY instructed KOJC workers not to discuss the financial affairs
24 of KOJC, including quotas, the Month of Blessings, and how much money
25 KOJC was raising.
26 Overt Act No. 4: In or around 2013, defendant CABACTULAN
27 confiscated the passport of victim J.B. and stored the document at
28 the KOJC Compound upon victim J.B.’s arrival in the United States to
33
1 solicit donations as a KOJC worker.
2 Overt Act No. 5: On or about September 23, 2013, defendant
3 DANDAN, and others known and unknown to the Grand Jury, arranged for
4 victim K.L., who was a United States citizen, to marry another KOJC
5 worker with whom victim K.L. had no romantic relationship, for the
8 DANDAN, and others known and unknown to the Grand Jury, facilitated
9 the completion of marriage paperwork on behalf of victim K.L. and
10 arranged for victim K.L. to attend a marriage ceremony in Ohio.
12 PANILAG sent defendant DANDAN an email titled “2014-USA FTMWS Set-
13 Up/Financial Goal for Approval” that listed KOJC workers and their
14 respective soliciting goals.
15 Overt Act No. 7: On or about March 24, 2014, defendant DANDAN
16 signed an I-134, Affidavit of Support, that was submitted in support
17 of KOJC worker A.M.’s application for a United States F-1 student
18 visa.
19 Overt Act No. 8: On or about April 1, 2014, defendant DUENAS
20 applied for a United States F-1 student visa, using a USCIS Form I-
21 539, on behalf of KOJC worker A.M. and enrolled her in college at the
22 California University of Business and Technology in order for A.M. to
23 remain in the United States and solicit for KOJC.
25 DUENAS sent an email to defendants DANDAN and PANILAG in which
26 defendant DUENAS stated, “[A]ttached herewith is the list of FTW’s
27 [full time workers] bound to USA via LAX and SF and List of FTW’s
28 bound [to] USA via JFK New York. I already sent to the tickets for
34
1 FTW’s via LAX and SF to [names omitted] . . . We will also send [yo]u
2 later a series of probable questions and answers; just in case they
3 will be ask by the immigration officer upon entry. Their answers
4 must coincide with the office, just in case we receive an inquiry or
5 call. We are finishing it now because [defendant CABACTULAN] will be
6 answering the phone.”
8 PANILAG sent defendant DANDAN an email titled “2014-USA MOB WORKERS

9 MEETING” that contained the agenda for KOJC’s Month of Blessings
10 meeting at the Silver Saddle Ranch, in California City, California.
12 QUIBOLOY gave a speech to KOJC workers in which he encouraged the
13 workers to raise money for KOJC by soliciting.
15 ESTOPARE sent an email titled “format” containing a Microsoft Excel
16 spreadsheet for KOJC workers to report the amount of money raised.
17 Overt Act No. 13: On or about November 10, 2014, defendants
18 DUENAS and DE LEON, and others known and unknown to the Grand Jury,
19 facilitated the completion of a Form I-130, Petition for Alien
20 Relative, on behalf of victim K.L. in support of a KOJC worker’s
21 petition to obtain lawful permanent resident status based on the KOJC
22 worker’s sham marriage to victim K.L.
24 PANILAG sent defendant DANDAN an email titled “Tentative Sked of
25 Players” that listed the flight schedules of KOJC workers arriving to
26 the United States.
27 Overt Act No. 15: In or around November 2014, defendant DUENAS
28 applied for admission to the California University of Business and
35
1 Technology on behalf of KOJC worker J.M. in order for J.M. to apply
2 for a United States F-1 student visa.
4 QUIBOLOY and SALINAS, and others known and unknown to the Grand Jury,
5 directed a KOJC worker, who was a minor, to make false allegations of
6 sexual assault against victim K.A. in order to retaliate against
7 victim K.A. for leaving KOJC.
8 Overt Act No. 17: On or about February 23, 2015, defendant
9 PANILAG signed an I-134 Affidavit of Support that was submitted in
10 support of KOJC worker J.M.’s application for a United States F-1
11 student visa.
12 Overt Act No. 18: On or about June 29, 2015, defendant DUENAS
13 submitted a letter in support of an I-751, Petition to Remove
14 Conditions on Residence, attesting to the validity of a sham marriage
15 between victim A.L. and another KOJC worker.
16 Overt Act No. 19: On or about August 7, 2015, defendant DUENAS
17 sent an email containing an attached document titled “MULTIPLE VISA
18 FTMWS and THEIR AVE.docx” that included columns titled “Name in USA,”
19 “Status,” “Ave.Income,” and “Area.” The columns contained a list of
20 KOJC workers, each KOJC worker’s status in the United States, and the
21 average money raised by each KOJC worker per day.
23 PANILAG possessed a ledger titled “2014 MOB Summary Oct. 17 – Jan.
24 16, 2014” that documented the amount of money raised by KOJC workers,
25 the immigration status of the KOJC worker, and whether the KOJC
26 worker was an “income” or “non-income” worker.
28 PANILAG sent an email to defendant DANDAN and others titled
36
1 “Pointers: MOB meeting” that contained guidance for KOJC workers who
2 were involved in soliciting funds for KOJC, including the drivers,
3 coordinators, and solicitors.
5 ESTOPARE sent an email to other KOJC members, including defendant

6 DANDAN, titled “2015 mob plan” that contained guidance for KOJC
7 workers who were involved in soliciting funds for KOJC, including the
8 drivers, coordinators, and solicitors.
9 Overt Act No. 23: On or about October 24, 2015, defendants
10 PANILAG and ESTOPARE received an email from a KOJC group leader, with
11 the subject line “OCTOBER2302115FR,” providing a daily tally of money
12 raised by KOJC workers of $2,777.
13 Overt Act No. 24: On or about December 1, 2015, defendant
14 DUENAS sent defendants DANDAN and PANILAG, and others, an email
15 titled “re: UPDATED LIST OF VISA EXPIRY” that listed multiple KOJC
16 workers’ visa status and the expiration date for each worker’s visa.
18 SALINAS sent a text message to KOJC workers, in Tagalog, stating that
19 “the pastor’s wish is now a minimum of 300 and up.”
21 SALINAS sent a text message to a KOJC worker, in Tagalog, telling the
22 worker to collect at least “700” and the pastor’s wish was for the
23 worker to collect “1,000.”
25 ESTOPARE sent an email titled “names send thru moneygram” that
26 provided the names of KOJC workers located in the Philippines whom
27 other KOJC workers were to wire transfer money to.
28
37
2 DUENAS sent a template letter on KOJC letterhead to other KOJC

3 members via email addressed to the “Honorable Consul, United States
4 of America.” The “RE” line read, “RE: Invitation for [blank] as
5 GUEST for the LIVE Concert Crusade in UNITED STATES OF AMERICA.” The
6 body of the letter stated that the person named in the “RE” line was
7 “one of our special guest for this Kingdom’s Concert Crusade, [and]
8 his presence in the concert schedule is deemed important. Thus, the
9 Kingdom’s USA Chapter is sponsoring his stay in the country from
10 [blank] to [blank] covering food and travel accommodation for the
11 whole duration of the event.”
12 Overt Act No. 29: On or about March 15, 2016, defendant DUENAS
13 applied for a United States F-1 student visa, using a USCIS Form I-
14 539, on behalf of victim J.F. and enrolled her in college at the
15 California University of Business and Technology in order for victim
16 J.F. to remain in the United States and solicit for KOJC.
17 Overt Act No. 30: On or about March 23, 2016, defendant DUENAS
18 applied for a United States F-1 student visa on behalf of KOJC worker
19 J.L. using a USCIS Form I-539, and enrolled J.L. in college at the
20 California University of Business and Technology in order for J.L. to
21 remain in the United States and solicit for KOJC.
22 Overt Act No. 31: On or about March 23, 2016, defendant
23 SALINAS signed an I-134 Affidavit of Support that was submitted in
24 support of KOJC worker J.L.’s application for a United States F-1
25 student visa.
26 Overt Act No. 32: On or about May 30, 2016, defendant DUENAS
27 sent defendants DANDAN and PANILAG an email titled “TENTATIVE 2017
28 SET UP OF FTWMS KD GOAL, ADMIN, AND KLC PAYABLES FOR REVIEW” that
38
1 listed, among other things, the KOJC workers’ assignments and
2 soliciting goals.
3 Overt Act No. 33: On or about July 5, 2016, defendant DUENAS
4 sent defendants DANDAN and PANILAG an email titled “RE: WORKERS

5 PAPERS UPDATE REPORT” that listed the status of immigration
6 applications filed for KOJC workers and whether additional documents
7 were needed for the filings.
9 DUENAS sent defendants DANDAN, PANILAG, and ESTOPARE an email titled
10 “RE: USA MANPOWER 2016” that listed, among other things, KOJC
11 workers’ immigration status and whether each KOJC worker was “INCOME”
12 or “NON-INCOME.”
14 DUENAS’s Bank of America account received a cash deposit of $5,337,
15 while defendant DUENAS’s Wells Fargo account received a cash deposit
16 of $8,310.
18 PANILAG’s Wells Fargo account received separate cash deposits of
19 $2,000 and $6,000.
21 PANILAG’s Wells Fargo account received a cash deposit of $6,300.
23 ESTOPARE’s Bank of America account received a cash deposit of $9,000,
24 while defendant ESTOPARE’s Wells Fargo account received separate cash
25 deposits of $1,500 and $3,500.
27 DUENAS, and others known and unknown to the Grand Jury, arranged for
28 victim K.P. to marry another KOJC worker, who was a United States
39
1 citizen and with whom victim K.P. had no romantic relationship, for
2 the purpose of enabling victim K.P. to obtain lawful permanent
3 resident status based on the marriage. In order to effectuate the
4 marriage, defendant DUENAS, and others known and unknown to the Grand
5 Jury, facilitated the completion of marriage paperwork on behalf of
6 victim K.P. and arranged for victim K.P. to attend a marriage
7 ceremony in Los Angeles, California.
9 DUENAS applied for a United States F-1 student visa on behalf of KOJC
10 worker A.A., using a USCIS Form I-539, and enrolled A.A. at
11 California University of Business and Technology in order for A.A. to
12 remain in the United States.
14 PANILAG sent defendant DANDAN an email titled “TENTATIVE 2017 SET UP
15 OF FTWMS KD GOAL, ADMIN, AND KLC PAYABLES FOR REVIEW” that listed,
16 among other things, the KOJC workers’ assignments and soliciting
17 goals.
18 Overt Act No. 42: On or about April 11, 2017, defendant
19 DUENAS, and others known and unknown to the Grand Jury, facilitated
20 the completion of a Form I-130, Petition for Alien Relative, on
21 behalf of victim K.P., based on victim K.P.’s sham marriage to a KOJC
22 worker, in order for victim K.P. to obtain legal permanent resident
23 status.
24 Overt Act No. 43: On or about June 19, 2017, defendant DE LEON
26 of KOJC worker R.V.’s application for a United States F-1 student
27 visa.
28 Overt Act No. 44: On or about June 30, 2017, defendant DUENAS
40
1 applied for a United States F-1 student visa on behalf of KOJC worker
2 G.S., using a USCIS Form I-539, and enrolled G.S. at Ezra University
3 in order for G.S. to remain in the United States.
4 Overt Act No. 45: On or about July 2, 2017, defendant
5 CABACTULAN sent a text message to a KOJC worker stating, “[s]ince May

6 29, labor day you guys started doing FR and every Sunday for Tribute.
7 Can you give me your individual income for that? Your total
8 contribution for Tribute is [only] $300+ unbelievable!”
9 Overt Act No. 46: On or about July 3, 2017, defendant
10 CABACTULAN sent a text message to a KOJC worker discussing the topics
11 of an upcoming meeting which included, among other things,
12 fundraising goals and the Month of Blessings goals and plans.
13 Overt Act No. 47: On or about June 9, 2017, defendant DE LEON
15 of KOJC worker G.S.’s application for a United States F-1 student
16 visa.
17 Overt Act No. 48: On or about August 17, 2017, defendant
19 victim L.A.M., who was a United States citizen, to marry another KOJC
20 worker with whom victim L.A.M. had no romantic relationship, for the
24 the completion of marriage paperwork on behalf of victim L.A.M. and
25 arranged for victim L.A.M. to attend a marriage ceremony in Los
26 Angeles, California.
28 ROCES’s Wells Fargo account received separate cash deposits of $5,000
41
1 each.
3 DUENAS issued a check to Liberty Legal for $1,850, with certain KOJC
4 workers listed on the memo line.
6 SALINAS sent a message to a KOJC worker via Facebook messenger, in
7 Cebuano, that read, “give me all the deposit slips and all the
8 expenses. Report daily to me and give me all the request. It is up
9 to me who I am going to approve. Your job is to let me know
10 everything.”
11 Overt Act No. 52: On or about February 22, 2018, defendant DE
12 LEON signed an I-134, Affidavit of Support, that was submitted in
13 support of KOJC worker M.C.’s application for a United States F-1
14 student visa.
16 CABACTULAN and DUENAS, and others known and unknown to the Grand
17 Jury, arranged for victim P.Y., who was a United States citizen, to
18 marry another KOJC worker with whom victim P.Y. had no romantic
19 relationship, for the purpose of enabling the KOJC worker to obtain
20 legal permanent resident status. In order to effectuate the
21 marriage, defendant DUENAS, and others known and unknown to the Grand
22 Jury, facilitated the completion of marriage paperwork on behalf of
23 victim P.Y. and arranged for victim P.Y. to attend a marriage
24 ceremony in Los Angeles, California.
27 victim R.R., who was a United States citizen, to marry another KOJC
28 worker with whom victim R.R. had no romantic relationship, for the
42
4 the completion of marriage paperwork on behalf of victim R.R. and
5 arranged for victim R.R. to attend a marriage ceremony in Los
6 Angeles, California.
8 QUIBOLOY caused approximately $335,000 in United States currency and

9 $9,000 in Australian currency to be loaded into his luggage for
10 transportation from Calabasas, California to Davao City, Philippines.
12 SALINAS possessed a ledger containing a financial summary for 2017-
13 2018 for KOJC workers in Hawaii.
15 DUENAS applied for a United States F-1 student visa on behalf of KOJC
16 worker M.C., using a USCIS Form I-539, and enrolled M.C. at Francis
17 University in order for M.C. to remain in the United States.
18 Overt Act No. 58: On or about March 1, 2018, defendant DE LEON
20 of KOJC worker M.H.’s application for a United States F-1 student
21 visa.
22 Overt Act No. 59: On or about March 27, 2018, defendants
23 CABACTULAN and DUENAS refused to provide victim A.L. with her
24 Permanent Resident Card until victim A.L. wrote and signed a letter
25 stating, among other things, that all of her work at KOJC was
26 voluntary.
27 Overt Act No. 60: On or about June 19, 2018, defendant
28 ESTOPARE, using a bank account in the name of “The Executive Pastor
43
1 of the Kingdom of Jesus Christ TNAEN,” paid $1,200 to Francis
2 University for the tuition of KOJC worker M.C.
3 Overt Act No. 61: On or about June 26, 2018, defendant
4 CABACTULAN, using a bank account in the name of “The Executive Pastor

5 of the Kingdom of Jesus Christ TNAEN,” paid $2,450 to California
6 University of Business and Technology for “Praya tuition fee.”
7 Overt Act No. 62: On or about August 17, 2018, defendant
8 CABACTULAN, using a bank account in the name of “The Executive Pastor
9 of the Kingdom of Jesus Christ TNAEN,” paid $1,375 to Liberty Legal
10 Document Services for “[H.O.] – citizenship.”
13 of the Kingdom of Jesus Christ TNAEN-TN,” paid $2,435 to Liberty
14 Legal Document Services for the processing of immigration-related
15 documents.
17 CABACTULAN signed a fraudulent lease agreement, purporting to rent a
18 room to victim K.P. and another KOJC worker at a residence in
19 Calabasas. The lease agreement was submitted in support of a Form I-
20 751, Petition to Remove Conditions on Residence, filed on behalf of
21 victim K.P., based on victim K.P.’s sham marriage, in order for
22 victim K.P. to obtain legal permanent resident status.
23 Overt Act No. 65: On or about April 12, 2019, defendant
24 DUENAS, using a bank account in the name of “Marissa A Duenas,” paid
25 $1,500 to Liberty Legal Document Services for “lawyers representation
26 fee” for M.C. and T.O.
27 Overt Act No. 66: On or about May 2, 2019, defendant DUENAS,
28 and others known and unknown to the Grand Jury, arranged for victim
44
1 M.F., who was a United States citizen, to marry another KOJC worker
2 with whom victim M.F. had no romantic relationship, for the purpose
3 of enabling the KOJC worker to obtain legal permanent resident status
4 based on the marriage. In order to effectuate the marriage,
5 defendant DUENAS, and others known and unknown to the Grand Jury,
6 facilitated the completion of marriage paperwork on behalf of victim
7 M.F. and arranged for victim M.F. to attend a marriage ceremony in
8 Los Angeles, California.

11 of the Kingdom of Jesus Christ TNAEN,” paid $5,600 to Francis
12 University for “Tuition Fee.”
13 Overt Act No. 68: On or about November 7, 2019, defendants
14 DUENAS and DE LEON, and others known and unknown to the Grand Jury,
15 facilitated the completion of a Form I-130, Petition for Alien
16 Relative, on behalf of a KOJC worker, based on the KOJC worker’s
17 fraudulent marriage to victim M.F., in order for the KOJC worker to
18 obtain legal permanent resident status.
20 DUENAS, using a bank account in the name of “KLC of Kern County,”
21 paid $400 to Francis University for the tuition of M.C.
22 Overt Act No. 70: On or about December 5, 2019, defendant DE
23 LEON notarized a divorce petition on behalf of victim R.S. and
24 certified that the petition was “signed and sworn to (or affirmed)
25 before me,” when in fact the divorce petition was not signed by
26 victim R.S.
27 Overt Act No. 71: On or about December 5, 2019, defendant DE
28 LEON notarized a divorce petition on behalf of victim L.A.M. and
45
1 certified that the petition was “signed and sworn to (or affirmed)
2 before me,” when in fact the divorce petition was not signed by
3 victim L.A.M.
5 DUENAS, and others known and unknown to the Grand Jury, filed a Joint
6 Petition for Divorce in the State of Nevada for victim L.A.M. and a
7 KOJC worker, without the knowledge or consent of victim L.A.M.
9 DUENAS, and others known and unknown to the Grand Jury, filed a Joint
10 Petition for Divorce in the State of Nevada for victim R.S. and a
11 KOJC worker, without the knowledge or consent of victim R.S.
12 Overt Act No. 74: On or about January 29, 2020, defendants
13 CABACTULAN and DUENAS possessed approximately 72 Filipino passports,
14 seven United States passports, and one Ukrainian passport in names
15 other than the defendants, in an office at the KOJC Compound.
17 DUENAS possessed approximately four male wedding rings and
18 approximately three female wedding rings in an office at the KOJC
19 Compound.
21 DUENAS possessed a memorandum, dated March 6, 2018, titled “Financial
22 Goal for 2018,” that listed the total fundraising goal for KOJC in
23 the United States as 23,050,000 Philippine Pesos.
25 DUENAS possessed a file titled “Traitor” that contained information
26 on KOJC members who had fled KOJC.
28 SALINAS possessed a binder with multiple spreadsheets titled “MOB
46
1 2018 Hawaii” that documented the amount of money raised by each KOJC
2 worker in Hawaii on a given day.
3 Overt Act No. 79: In or around May 2020, defendant QUIBOLOY
4 gave a recorded sermon in which he declared that he would create

5 trouble for individuals that left the KOJC, specifically including
6 victim A.L., and that he will show them no mercy.
7
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
47
1 COUNT EIGHT
2 [8 U.S.C. § 1325(c); 18 U.S.C. § 2]
3 [DEFENDANTS CABACTULAN and DUENAS]
4 On or about December 4, 2016, in Los Angeles County, within the
5 Central District of California, and elsewhere, defendants GUIA
6 CABACTULAN and MARISSA DUENAS, aka “MD,” and others known and unknown
7 to the Grand Jury, each aiding and abetting the other, knowingly and
8 willfully caused victim K.P., an alien and citizen and national of
9 the Philippines, to knowingly and unlawfully enter into a marriage
10 with K.C., a United States citizen, not intending to establish a life
11 together, and for the purpose of evading a provision of the
12 immigration laws of the United States.
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
48
1 COUNT NINE
2 [8 U.S.C. § 1325(c); 18 U.S.C. § 2]
3 [DEFENDANT DUENAS]
4 On or about August 17, 2017, in Los Angeles County, within the
5 Central District of California, and elsewhere, defendant MARISSA
6 DUENAS, aka “MD,” and others known and unknown to the Grand Jury,
7 each aiding and abetting the other, knowingly and willfully caused
8 victim L.A.M., a United States citizen, to unlawfully enter into a
9 marriage with S.P., an alien and citizen and national of the
10 Philippines, not intending to establish a life together, and for the
11 purpose of evading a provision of the immigration laws of the United
12 States.
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
49
1 COUNT TEN
2 [8 U.S.C. § 1325(c); 18 U.S.C. § 2]
3 [DEFENDANTS CABACTULAN and DUENAS]
4 On or about February 9, 2018, in Los Angeles County, within the
5 Central District of California, and elsewhere, defendants GUIA
6 CABACTULAN and MARISSA DUENAS, aka “MD,” and others known and unknown
7 to the Grand Jury, each aiding and abetting the other, knowingly and
8 willfully caused victim P.Y., a United States citizen, to unlawfully
9 enter into a marriage with A.A., an alien and citizen and national of
10 the Philippines, not intending to establish a life together, and for
11 the purpose of evading a provision of the immigration laws of the
12 United States.
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
50
1 COUNT ELEVEN
2 [8 U.S.C. § 1325(c); 18 U.S.C. § 2]
7 each aiding and abetting the other, knowingly and willfully caused
8 victim R.R., a United States citizen, to unlawfully enter into a
9 marriage with C.C., an alien and citizen and national of the
10 Philippines, not intending to establish a life together, and for the
11 purpose of evading a provision of the immigration laws of the United
12 States.
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
51
1 COUNT TWELVE
2 [8 U.S.C. § 1325(c); 18 U.S.C. § 2]
3 [DEFENDANTS DUENAS and ROCES]
4 On or about May 2, 2019, in Los Angeles County, within the
5 Central District of California, and elsewhere, defendants MARISSA
6 DUENAS, aka “MD,” and BETTINA PADILLA ROCES, aka “Kuki,” and others
7 known and unknown to the Grand Jury, each aiding and abetting the
8 other, knowingly and willfully caused M.F., a United States citizen,
9 to unlawfully enter into a marriage with defendant ROCES, an alien
10 and citizen and national of the Philippines, not intending to
11 establish a life together, and for the purpose of evading a provision
12 of the immigration laws of the United States.
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
52
1 COUNT THIRTEEN
2 [18 U.S.C. §§ 1546(a), 2]
4 On or about December 21, 2016, in Los Angeles County, within the
7 each aiding and abetting the other, induced, procured, and willfully
8 caused the making under oath and knowing subscription as true a false
9 statement with respect to a material fact in an application,
10 affidavit, and other document required by the immigration laws and
11 regulations prescribed thereunder, and knowingly presented and
12 willfully caused to be presented such application, affidavit, and
13 other document that contained such false statement and that failed to
14 contain any reasonable basis in law or fact, in that defendant DUENAS
15 subscribed and presented and willfully caused to be subscribed and
16 presented to the United States Citizenship and Immigration Services
17 an Immigration and Naturalization Form I-20, Certificate of
18 Eligibility for Nonimmigrant Student Status, on behalf of an alien,
19 A.A., which contained a false material statement, to wit, that A.A.
20 sought to enter or remain in the United States solely for the purpose
21 of pursuing a full course of study at the California University of
22 Business and Technology, when in fact, as defendant DUENAS then knew,
23 A.A. would be engaged in activities other than her course of study at
24 the California University of Business and Technology, including, but
25 not limited to, working as a full-time worker for KOJC and soliciting
26 donations for CJF.
27
28
53
1 COUNT FOURTEEN
2 [18 U.S.C. §§ 1546(a), 2]
4 On or about June 30, 2017, in Los Angeles County, within the
19 G.S., which contained a false material statement, to wit, that G.S.
21 of pursuing a full course of study at Ezra University, when in fact,
22 as defendant DUENAS then knew, G.S. would be engaged in activities
23 other than her course of study at Ezra University, including, but not
24 limited to, working as a full-time worker for KOJC and soliciting
25 donations for CJF.
26
27
28
54
1 COUNT FIFTEEN
2 [18 U.S.C. §§ 1546(a), 2]
19 M.C., which contained a false material statement, to wit, that M.C.
21 of pursuing a full course of study at Francis University, when in
22 fact, as defendant DUENAS then knew, M.C. would be engaged in
23 activities other than her course of study at Francis University,
24 including, but not limited to, working as a full-time worker for KOJC
25 and soliciting donations for CJF.
26
27
28
55
1 COUNT SIXTEEN
2 [31 U.S.C. § 5332(a)]
3 [DEFENDANT QUIBOLOY]
4 Beginning on or about February 7, 2018, and continuing to on or
5 about February 13, 2018, in Los Angeles County, within the Central
6 District of California, and elsewhere, defendant APOLLO CARREON
7 QUIBOLOY, aka “The Appointed Son of God,” aka “Sir,” aka “Pastor,”
8 aka “ACQ,” with the intent to evade a currency reporting requirement
9 under Title 31, United States Code, Section 5316, knowingly concealed
10 more than $10,000 in currency, namely, approximately $335,000 in
11 United States currency, and approximately $9,000 in Australian
12 currency, in an article of luggage and attempted to transport such
13 currency from a place within the United States to a place outside of
14 the United States.
15
16
17
18
19
20
21
22
23
24
25
26
27
28
56
1 COUNTS SEVENTEEN THROUGH TWENTY-TWO
2 [18 U.S.C. §§ 1956(a)(1)(A)(i), 2]
3 [DEFENDANT DANDAN]
4 On or about the dates below, in Los Angeles County, within the
5 Central District of California, and elsewhere, defendant TERESITA
6 TOLIBAS DANDAN, aka “Tessie,” aka “Sis Ting,” aka “TTD,” together
7 with others known and unknown to the Grand Jury, each aiding and
8 abetting the others, conducted and willfully caused the following
9 financial transactions, knowing that the property involved in the
10 financial transactions represented the proceeds of some form of
11 unlawful activity, which transactions in fact involved the proceeds
12 of specified unlawful activity, namely, trafficking with respect to
13 forced labor, in violation of Title 18, United States Code, Section
14 1590(a), and with the intent to promote the carrying on of such
15 specified unlawful activity:
16 COUNT DATE TRANSACTION

17 SEVENTEEN 12/27/2016 Check issued by defendant DANDAN
payable to Nationstar Mortgage for
18 mortgage payment on Calabasas mansion
in the amount of $13,880.86
19 EIGHTEEN 01/30/2017 Check issued by defendant DANDAN
21 NINETEEN 03/02/2017 Check issued by defendant DANDAN
23 TWENTY 03/31/2017 Check issued by defendant DANDAN
25 TWENTY-ONE 05/01/2017 Check issued by defendant DANDAN
27
28
57
2 TWENTY-TWO 05/31/2017 Check issued by defendant DANDAN
4
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
58
1 COUNT TWENTY-THREE
2 [18 U.S.C. §§ 1956(a)(1)(A)(i), 2]
3 [DEFENDANT ESTOPARE]
4 On or about January 29, 2018, in Los Angeles County, within the
5 Central District of California, and elsewhere, defendant AMANDA
6 ESTOPARE, together with others known and unknown to the Grand Jury,
7 each aiding and abetting the others, conducted and willfully caused a
8 financial transaction, namely, the issuance of a check payable to
9 “Mr. Cooper” constituting a mortgage payment on the Calabasas mansion
10 in the amount of $14,063.17, knowing that the property involved in
11 the financial transaction represented the proceeds of some form of
12 unlawful activity, which transaction in fact involved the proceeds of
13 specified unlawful activity, namely, trafficking with respect to
15 1590(a), and with the intent to promote the carrying on of such
16 specified unlawful activity.
17
18
19
20
21
22
23
24
25
26
27
28
59
1 COUNTS TWENTY-FOUR THROUGH TWENTY-SIX
2 [18 U.S.C. §§ 1956(a)(1)(B)(i), 2]
3 [DEFENDANT CABACTULAN]
5 Central District of California, and elsewhere, defendant GUIA
6 CABACTULAN, together with others known and unknown to the Grand Jury,
7 each aiding and abetting the others, conducted and willfully caused
8 the following financial transactions, knowing that the property
9 involved in the financial transactions represented the proceeds of
10 some form of unlawful activity, which transactions in fact involved
11 the proceeds of specified unlawful activity, namely, trafficking with
12 respect to forced labor, in violation of Title 18, United States
13 Code, Section 1590(a), and knowing that the transactions were
14 designed in whole and in part to conceal and disguise the nature,
15 location, source, ownership, and control of the proceeds.

17 TWENTY-FOUR 11/27/2017 Cash deposit of $4,000 into defendant
CABACTULAN’s Wells Fargo account
18 TWENTY-FIVE 12/01/2017 Cash deposit of $3,000 into defendant
19 TWENTY-SIX 12/04/2017 Cash deposit of $4,401 into defendant
20
21
22
23
24
25
26
27
28
60
1 COUNTS TWENTY-SEVEN THROUGH THIRTY-SEVEN
2 [18 U.S.C. §§ 1956(a)(1)(B)(i), 2]
3 [DEFENDANT ROCES]
5 Central District of California, and elsewhere, defendant BETTINA
6 PADILLA ROCES, aka “Kuki,” together with others known and unknown to
7 the Grand Jury, each aiding and abetting the others, conducted and
8 willfully caused the following financial transactions, knowing that
9 the property involved in the financial transactions represented the
10 proceeds of some form of unlawful activity, which transactions in
11 fact involved the proceeds of specified unlawful activity, namely,
12 trafficking with respect to forced labor, in violation of Title 18,
13 United States Code, Section 1590(a), and knowing that the
14 transactions were designed in whole and in part to conceal and
15 disguise the nature, location, source, ownership, and control of the
16 proceeds.

18 TWENTY-SEVEN 12/02/2016 Cash deposit of $2,345 into defendant
ROCES’s Wells Fargo account
19 TWENTY-EIGHT 12/12/2016 Cash deposit of $2,545 into defendant
20 TWENTY-NINE 12/19/2016 Cash deposit of $2,350 into defendant
21 THIRTY 12/19/2016 Cash deposit of $1,370 into defendant
22 THIRTY-ONE 12/22/2016 Cash deposit of $2,995 into defendant
23 THIRTY-TWO 12/27/2016 Cash deposit of $5,860 into defendant
24 THIRTY-THREE 01/03/2017 Cash deposit of $2,855 into defendant
25 THIRTY-FOUR 01/03/2017 Cash deposit of $4,267 into defendant
26 THIRTY-FIVE 02/27/2017 Cash deposit of $3,699 into defendant
27
28 ///
61
2 THIRTY-SIX 02/27/2017 Cash deposit of $2,522 into defendant
3 THIRTY-SEVEN 03/01/2017 Cash deposit of $3,905 into defendant
4
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
62
1 COUNTS THIRTY-EIGHT THROUGH FORTY
2 [18 U.S.C. §§ 1956(a)(2)(A), 2]
3 [DEFENDANT CABACTULAN]
5 Central District of California, and elsewhere, defendant GUIA
6 CABACTULAN, together with others known and unknown to the Grand Jury,
7 each aiding and abetting the others, knowingly transported,
8 transmitted, and transferred, and willfully caused the
9 transportation, transmission, and transfer of, and knowingly aided,
10 abetted, counseled, commanded, induced, and procured another person
11 to transport, transmit, and transfer, the funds listed below to a
12 place outside the United States from and through a place inside the
13 United States, with the intent to promote the carrying on of
16 1590(a):

18 THIRTY-EIGHT 07/25/2019 Wire transfer of $30,000 from
California Credit Union to The
19 Executive Pastor of the Kingdom of
Jesus Christ’s Banco de Oro account in
20 the Philippines
THIRTY-NINE 11/22/2019 Wire transfer of $30,000 from
21 California Credit Union to The
Executive Pastor of the Kingdom of
22 Jesus Christ’s Banco de Oro account in
the Philippines
23 FORTY 01/10/2020 Wire transfer of $35,000 from
Jesus Christ’s Banco de Oro account in
25 the Philippines
26
27
28
63
1 COUNTS FORTY-ONE AND FORTY-TWO
2 [18 U.S.C. §§ 1956(a)(2)(A), 2]
3 [DEFENDANT ESTOPARE]
5 Central District of California, and elsewhere, defendant AMANDA
6 ESTOPARE, together with others known and unknown to the Grand Jury,
7 each aiding and abetting the others, knowingly transported,
8 transmitted, and transferred, and willfully caused the
9 transportation, transmission, and transfer of, and knowingly aided,
10 abetted, counseled, commanded, induced, and procured another person
11 to transport, transmit, and transfer, the funds listed below to a
12 place outside the United States from and through a place inside the
13 United States, with the intent to promote the carrying on of
16 1590(a):

18 FORTY-ONE 02/20/2018 Wire transfer of $6,000 from
Jesus Christ Tnaen, Inc.’s Banco de
20 Oro account in the Philippines
FORTY-TWO 04/12/2019 Wire transfer of $38,935 from
21 California Credit Union to The
Executive Pastor of the Kingdom of
22 Jesus Christ Tnaen, Inc.’s Banco de
Oro account in the Philippines
23
24
25
26
27
28
64
1 FORFEITURE ALLEGATION ONE
2 [18 U.S.C. § 1594(d) and 28 U.S.C. § 2461]
3 1. Pursuant to Rule 32.2 of the Federal Rules of Criminal
4 Procedure, notice is hereby given that the United States of America
5 will seek forfeiture as part of any sentence, pursuant to Title 18,
6 United States Code, Section 1594(d), and Title 28, United States
7 Code, Section 2461(c), in the event of any defendant’s conviction of
8 any of the offenses set forth in Counts One through Six of this First
9 Superseding Indictment.
10 2. Any defendant so convicted shall forfeit to the United
11 States of America the following:
12 (a) Any property, real or personal, that was involved in,
13 used, or intended to be used to commit or to facilitate the
14 commission of such violation, and any property traceable to such
15 property;
16 (b) Any property, real or personal, constituting or
17 derived from, any proceeds that such person obtained, directly or
18 indirectly, as a result of such violation, or any property traceable
19 to such property; and
20 (c) In the event such property is not available for
21 forfeiture, a sum of money equal to the total value of the property
22 described in subparagraphs (a) and (b).
23 3. Pursuant to Title 21, United States Code, Section 853(p),
24 as incorporated by Title 28, United States Code, Section 2461(c), any
25 defendant so convicted shall forfeit substitute property, up to the
26 total value of the property described in the preceding paragraph if,
27 as the result of any act or omission of said defendant, the property
28 described in the preceding paragraph, or any portion thereof
65
1 (a) cannot be located upon the exercise of due diligence; (b) has
2 been transferred, sold to, or deposited with a third party; (c) has
3 been placed beyond the jurisdiction of the court; (d) has been
4 substantially diminished in value; or (e) has been commingled with
5 other property that cannot be divided without difficulty.
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
66
1 FORFEITURE ALLEGATION TWO
2 [18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c)]
6 United States Code, Section 981(a)(1)(C) and Title 28, United States
7 Code, Section 2461(c), in the event of any defendant’s conviction of
8 the offense set forth in Count Seven of this First Superseding
9 Indictment.
12 (a) All right, title, and interest in any and all
13 property, real or personal, constituting, or derived from, any
14 proceeds traceable to the offense; and
15 (b) To the extent such property is not available for
17 described in subparagraph (a).
21 value of the property described in the preceding paragraph if, as the
22 result of any act or omission of said defendant, the property
23 described in the preceding paragraph or any portion thereof
67
1 FORFEITURE ALLEGATION THREE
2 [8 U.S.C. § 1324 and 28 U.S.C. § 2461]
6 United States Code, Section 1324, and Title 28, United States Code,
7 Section 2461(c), in the event of any defendant’s conviction of the
8 offenses set forth in any of Counts Eight through Twelve of this
9 First Superseding Indictment.
11 States the following:
12 (a) Any conveyance, including any vessel, vehicle, or
13 aircraft, that has been or is being used in the commission of any
14 such offense;
15 (b) The gross proceeds of the commission of any such
16 offense;
17 (c) Any property traceable to such conveyance or proceeds;
18 and
19 (d) To the extent such property is not available for
21 described in subparagraphs (a), (b), and (c).
68
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
69
1 FORFEITURE ALLEGATION FOUR
2 [18 U.S.C. § 982]
6 United States Code, Section 982(a)(6)(A)(i) and (ii)(I) and (II), in
7 the event of any defendant’s conviction of the offenses set forth in
8 any of Counts Thirteen through Fifteen of this First Superseding
9 Indictment.
12 (a) Any conveyance, including any vessel, vehicle, or
13 aircraft used in the commission of any such offense;
14 (b) Any property, real or personal, that is used to
15 facilitate, or is intended to be used to facilitate, the commission
16 of any such offense;
17 (c) Any property, real or personal, that constitutes or is
18 derived from or is traceable to the proceeds obtained directly or
19 indirectly from the commission of any such offense; and
20 (d) In the event such property is not available for
22 described in subparagraphs (a), (b), and (c).
24 as incorporated by Title 18, United States Code, Section 982(b), any
70
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
71
1 FORFEITURE ALLEGATION FIVE
2 [31 U.S.C. § 5317]
3 1. Pursuant to Rule 32.2(a) of the Federal Rules of Criminal
6 United States Code, Section 5317, in the event of any defendant’s
7 conviction of the offense set forth in Count Sixteen of this First
8 Superseding Indictment.
11 (a) All property, real or personal, involved in the
12 offense and any property traceable thereto; and
13 (b) To the extent that such property is not available for
16 3. Pursuant to Title 21, United States Code, Section 853(p), as
17 incorporated by Title 31, United States Code, Section 5317(c)(1)(B),
18 any defendant so convicted shall forfeit substitute property, if, by
19 any act or omission of said defendant, the property described in the
20 preceding, or any portion thereof (a) cannot be located upon the
21 exercise of due diligence; (b) has been transferred, sold to, or
22 deposited with a third party; (c) has been placed beyond the
23 jurisdiction of the court; (d) has been substantially diminished in
24 value; or (e) has been commingled with other property that cannot be
25 divided without difficulty.
26
27
28
72
1 FORFEITURE ALLEGATION SIX
2 [18 U.S.C. § 982]
3 1. Pursuant to Rule 32.2(a) of the Federal Rules of Criminal
4 Procedure, notice is hereby given that the United States will seek
5 forfeiture as part of any sentence, pursuant to Title 18, United
6 States Code, Section 982(a)(1), in the event of any defendant’s
7 conviction of the offenses set forth in any of Counts Seventeen
8 through Forty-Two of this First Superseding Indictment.
11 (a) Any property, real or personal, involved in any such
12 offense, and any property traceable to such property; and
13 (b) To the extent such property is not available for
17 as incorporated by Title 18, United States Code, Section 982(b)(1),
18 and Title 18, United States Code, Section 982(b)(2), any defendant so
19 convicted shall forfeit substitute property, if, by any act or
20 omission of said defendant, the property described in the preceding
21 paragraph, or any portion thereof (a) cannot be located upon the
22 exercise of due diligence; (b) has been transferred, sold to, or
23 deposited with a third party; (c) has been placed beyond the
24 jurisdiction of the court; (d) has been substantially diminished in
25 value; or (e) has been commingled with other property that cannot be
26 divided without difficulty. Substitution of assets shall not be
27 ordered, however, where the convicted defendant acted merely as an
28 intermediary who handled but did not retain the property in the
73

Kingdom of Jesus Christ Indictment

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Kingdom of Jesus Christ Indictment

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1 11/10/2021

8 UNITED STATES DISTRICT COURT

9 FOR THE CENTRAL DISTRICT OF CALIFORNIA

10 April 2021 Grand Jury

11 UNITED STATES OF AMERICA, No. CR 20-00079(A)-TJH

3 At times relevant to this First Superseding Indictment:

5 1. The Kingdom of Jesus Christ, The Name Above Every Name

2 located at 94-378 Pupupani Street, Waipahu, Hawaii 96797 (“94-378

3 Pupupani Street”), where KOJC in Hawaii operated and KOJC workers

4 resided. KOJC’s operations in Hawaii were led by KOJC administrator

6 of an office at 94-378 Pupupani Street.

7 6. KOJC administrators at the KOJC Compound and 94-378

8 Pupupani Street reported to senior administrators in the Philippines,

9 including defendants TERESITA TOLIBAS DANDAN, aka “Tessie,” aka “Sis

11 CJF, defendant QUIBOLOY.

12 B. KOJC ADMINISTRATORS’ NATIONWIDE SOLICITING OPERATIONS

13 7. Under the direction of defendant QUIBOLOY, KOJC

2 street-level solicitation throughout the country.

3 9. KOJC administrators maintained the legal immigration status

4 of workers who proved capable of meeting daily cash solicitation

5 quotas by fraudulently obtaining student visas for such workers or by

7 had already obtained United States citizenship. These workers, in

9 C. SEX TRAFFICKING OF PASTORALS

2 a necessary demonstration of the pastoral’s commitment to give her

3 body to defendant QUIBOLOY as “The Appointed Son of God.”

4 14. Pastorals who performed their duties, to include “night

5 duty,” to the satisfaction of defendant QUIBOLOY and other KOJC

6 administrators were rewarded by defendant QUIBOLOY and other KOJC

7 administrators with privileges, including trips to tourist

8 destinations like Disneyland, flights in private jets, use of cell

9 phones, and yearly monetary payments referred to as “honorariums” by

12 15. The below-referenced defendants were the main KOJC

2 Philippines. Prior to in or around February 2018, defendant DANDAN

3 frequently traveled to the United States to oversee KOJC and CJF’s

4 operations. As the International Administrator of KOJC, defendant

5 DANDAN was responsible for approving KOJC worker assignments and

6 fraudulent marriages and would receive reports on the soliciting

7 activities of KOJC workers.

8 c. Defendant PANILAG previously was the lead KOJC

9 administrator in the United States before being promoted to an

10 international role in which she oversaw the reporting of KOJC

11 financial information from KOJC operations worldwide.

12 d. Defendant SALINAS was the lead KOJC administrator in

13 Hawaii. Defendant SALINAS operated KOJC facilities throughout Hawaii

14 and reported directly to KOJC leadership in the Philippines. In this

15 role, defendant SALINAS was responsible for collecting and securing

16 the passports and immigration-related documents from KOJC workers in

17 Hawaii in order to prevent the workers from freely accessing their

18 documents. Defendant SALINAS was also in charge of tracking the

19 money raised by KOJC workers in Hawaii and reporting the amounts

20 raised to KOJC administrators located in the Philippines. Defendant

21 SALINAS provided daily solicitation quotas for KOJC workers to meet

23 administrators in the Philippines.

24 e. Defendant CABACTULAN was the lead KOJC administrator

25 in the United States. Defendant CABACTULAN operated the KOJC

26 Compound and maintained direct communication with KOJC leadership in

27 the Philippines. Defendant CABACTULAN was in charge of tracking

2 2015, when defendant ESTOPARE took over this role. Defendant

3 CABACTULAN was also previously responsible for overseeing the

4 completion and submission of immigration-related documents for KOJC

6 transferred to defendant DUENAS.

7 f. Defendant DUENAS was the human resources leader of

9 securing the passports and immigration-related documents from KOJC

10 workers in order to prevent KOJC workers from freely accessing their