United States v. Modugumudi

I
Case: 1:18-cr-00262 Document #: 1 Filed: 04/30/18 Page 1 of 42 PageID #:1 lt

AO 91 (Rev. 11/11) Criminal Complaint AUSA Christopher V. Parente (312) 886-2447
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
FITED
UNITED STATES OF AMERICA
CASE NUMBER: APR 3 A?nlA/
v. UNDER SEAL
KISHAN MODUGUMUDI,
ct
tuui,ffi,tyffiilnr
also known as "Sreeraj Chennuppati," "Raju"
and
CHANDRA KALA PURNIMA MODUGUMUDI,
18C R 262
also known as "Vebha", "Vebha Jayam", "Vibha I,IAGISTRATE JUDGE COX
Jayam"
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge
and belief.
From on or about May 11, 2017, to on or about January 22,2018, at Chicago, in the Northern
District of Illinois, Eastern Division, and elsewhere, the defendants violated:
Code Section Offeruse Description,
Title 8, United States Code, Section aided and abetted by one another and others, did
1328 directly and indirectly import into the United
States Victims A, B, C, D, and E, all female Indian
aliens, for the purpose of prostitution and other
immoral purposes, and did keep, maintain, control,
support, employ and harbor Victims A, B, C, D, and
E, in a house and in other places for the purpose of
prostitution and other immoral purposes, in
pursuance of such illegal importation.
This criminal complaint is based upon these facts:
X Continued on the attached sheet.
BRIAN GINN
Special Agent, Homeland Security Investigations
(HSI)
By telephone on April 28,2018, at approximately 1:15 p.m., I placed HSI Special Agent Brian Ginn under
Affidavit was true and correct.

Date: Anril 28.2OI8
Judge's signature
City and state: Chicaso. Illinois SUSAN E. COX. U.S. Maeistrate Judge
Printed name and Title
Case: 1:18-cr-00262 Document #: 1 Filed: 04/30/18 Page 2 of 42 PageID #:2
AFFIDAVIT
I, BRIAN GINN, being duly sworn, state as follows:
1. I am a Special Agent with Homeland Security Investigations (HSI). I
have been so employed since 2004. Prior to this, I was employed as a United States
Border Patrol Agent from 2001 to 2004.
2. As part of my duties as a Homeland Security Investigations Special
Agent, I investigate criminal violations relating to federal criminal offenses
involving alien harboring, alien smuggling, human trafficking, importation of aliens
for immoral purposes, and visa fraud.
3. This affidavit is submitted in support of a criminal complaint alleging
that KISHAN MODUGUMUDI, also known as "Sreeraj Chennuppati," and "Raju,"
and CHANDRA KALA PURNIMA MODUGUMUDI, also known as "Vebha," "Vebha
Jayam", and "Vibha Jayam" have violated Title 8, United States Code, Section 1328.
Because this affidavit is being submitted for the limited purpose of establishing
probable cause in support of a criminal complaint charging KISHAN
MODUGUMUDI and CHANDRA KAI,A PURNIMA MODUGUMUDI with
importation of aliens for purposes of prostitution, I have not included each and
every fact known to me concerning this investigation. I have set forth only the facts
that I believe are necessary to establish probable cause to believe that the
defendants committed the offense alleged in the complaint.
AFFIDAVIT
I, BRIAN GINN, being duly sworn, state as follows:
1. I am a Special Agent with Homeland Security Investigations (HSI). I
have been so employed since 20A4. Prior to this, I was employed as a United States
Border Patrol Agent from 2001 to 2004.
2. As part of my duties as a Homeland Security Investigations Special
Agent, I investigate criminal violations relating to federal criminal offenses involving
alien harboring, alien smuggling, human trafficking, importation of aliens for
immoral purposes, and visa fraud.
3. This affidavit is submitted in support of a criminal complaint alleging
that KISHAN MODUGUMUDI, also known as "Sreeraj Chennuppati," and "Raju,"
and CIIANDRA I{ALA PURNIMA MODUGUMUDI, also known as 'Vebha," 'Vebha
Jayam", and'Vibha Jayam" have violated Title 8, United States Code, Section 1328.
Because this affidavit is being submitted for the limited purpose of establishing
probable cause in support of a criminal complaint charging KISIIAN
MODUGUMUDI and CHANDRA KALA PURNIMA MODUGUMUDI with
importation of aliens for purposes of prostitution, I have not included each and every
fact known to me concerning this investigation. I have set forth only the facts that I
believe are necessary to establish probable cause to believe that the defendants
committed the offense alleged in the complaint.

4. The statements in this affidavit are based on my personal knowledge,
and on information I have received from other law enforcement personnel and from
persons with knowledge regarding relevant facts.
A. SI,]MIUARY OF II{\MSTIGATION
5. As summaized in detail below, law enforcement believes that KISHAN
MODUGUMUDI and CIIANDRA KALA PURNIMA MODUGUMUDI imported
Victims A, B, C, D, and E, all female Indian actresses who reside in India, into the
United States for purposes of prostitution. The MODUGUMUDIs purchased airline
tickets and hotel rooms for the victims, harbored the victims either at the
MODUGUMUDI residence in Chicago, Illinois, or at hotel rooms across the country,
and would take the victims to Telugu and other Indian conferences held across the
United States for purposes of identi$ring potential customers who would pay the
MODUGUMUDIs in order for the customers to engage in commercial sex acts with
the victims.
6. As detailed in this affidavit, the evidence in this investigation includes,
but is not limited to: (1) travel records and/or victim statements that directly or
indirectly identifr the MODUGUMUDIs as the individuals who provided them with
their travel to the United States; (2) hotel and travel records demonstrating the
MODUGUMUDIs paid for victims' travel and hotel rooms throughout the United
States; (3) the statement of a customer acknowledgrng the purchase of a commercial
sex act at a Chicago area hotel with an Indian actress offered by Chandra Kala
MODUGUMUDI; (4) statements from a victim that Chandra Kala MODUGUMUDI
brought men to her hotel room for purposes of commercial sex acts; (4) text messages
from the MODUGUMUDIs' cell phones demonstrating multiple conversations
between the MODUGUMUDIs and customers believed to be advertising and./or
arranging for commercial sex acts with Victims A, B, C, D, and E; and (5) ledgers
recovered from a search of the MODUGUMUDI residence which are indicative of
prostitution dates and payments set up for Victims A, B, C, D, and E by the
MODUGUMUDIs, in some cases corresponding with the text messages that are
believed to be arranging for commercial sex acts with the victims and the travel and
hotel room locations paid for by the MODUGUMUDIs.
7. Both Kishan MODUGUMUDI and Chandra Kala MODUGUMUDI have
overstayed their visas in the United States and, unrelated to this investigation, were
arrested by the United States Border Patrol on January 23,2018. They were released
on bond from immigration custody on February 23,2018.
B. Individual A
8. On November 20, }OLT,Individual A arrived at O'Hare International
Airport on a flight from Delhi, India. Individual A presented a B1lB2 visitor visa to
immigration officials.l Individual A's visa was obtained at the United States
Embassy in New Delhi on November 6, zlilT.Individual A submitted a document to
the Embassy officials claiming she was coming to the United States to be honored by
the Telegu Association of Southern California (TASC) at an event on November 18,
1A B1/B2 visa allows a visitor to visit the United States for periods of time from six months
to one year.
3
2017.2 Notes associated with Individual A's visa application stated, "...Film actress
to Telegu Association Star Night; in CA. Will stay for 10 days..."
9. Because Individual A did not arrive in the United States until November
20,2017 , two days afber the purported event listed as justification for the issuance of
hervisa, and traveled to Chicago instead of California, agents became suspicious and
inquired further.
L0. Individual A stated that she was now coming to the United States for a
different conference hosted by the North America Telugu Society (NATS). Individual
A presented immigration officials with a letter stating Individual A would be a guest
at the NATS conference to be held at the Renaissance Convention Center in

Schaumburg, Illinois, on November 25,20L7.
11. Law enforcement contacted the President of TASC who stated they did
have a conference in California on November 18, 20L7, but it was now over. The
President stated that he did not know Victim A and she was not a guest or honoree
at the conference. Law enforcement contacted a NATS official who stated they too
were unfamiliar with Individual A and that they had no conference scheduled for
November 25,2017, at the Renaissance Center. Agents further confrrmed with the
Renaissance Center that there was no conference scheduled for November 25,2017.3
2 Telugus are a Dravidian ethnic group based in India. There are several Telugu associations
in the United States that assist in the preservation and celebration of the Telugu culture and
host conventions and events in furtherance and celebration ofthe culture.
3 Pursuant to the ongoing investigation, HSI Special Agents have subsequently interviewed
both the President of the TASC and the Chairman of the NATS who allegedly signed the
letters Individual A presented. Both have confirmed that the letters are fraudulent and were
not issued by their organizations for Individual A.
4
\2. Individqal A was interviewed further about the purpose of her travel.
Individual A stated that both letters she provided to law enforcement from the TASC
and NATS were sent to her by an individual named "Raju." Individual A was
introduced to "Raju" by an acquaintance in India. Individual A stated that "Raju"

paid for her airline ticket and hotel room in the United States and sent her
confirrnation documents by email. Individual A stated that "Raju" was supposed to
pick her up at the airport and she provided officers with her contact number for "Raju"
that ended in 6887. Individual A also provided agents with the email address "Raju"
used to communicate with her and send her the TASC and NATS letters. The email
address provided was sreerajchennuppati@email.com. Individual A stated she did
not know much about "Raju" other than he allegedly worked for an organization in
the United States.
13. Officers conducted an open source internet search for the name "sreeraj
chennuppati", which is the name from the Gmail address used to communicate with
Individual A, and discovered an article from a media source called "Indiaglitz."4 Th.e
article headline stated, "Imposter tryrng to draw actresses into prostitution exposed."
The article stated, "lflor the past few months one Kishan MODUGUMUDI has
allegedly been posing himself as Sreeraj Chennupati . . . It is known that this guy is
operating a sex racket and has been taking people to the USA on fake visas. He is
carrying out all of this along with his friend Vibha Jayam in Chicago says a source."
a Indiaglitz appears to be an entertainment website focused on the Indian entertainment

industry.
5
L4. Individual A was denied entry into the United States and her visa was
revoked.
15. A record check for the 6887 telephone number provided by Individual A
for "Raju" showed it as being associated with a Kishan MODUGUMUDI. Records
received pursuant to a subpoena subsequently issued to AT&T for the 6887 telephone
number showed it as being subscribed to by Kishan MODUGUMUDIs. Officers also
discovered a second telephone number ending in 3114 that was associated with the
travel reservation for Individual A. According to records obtained from Comcast, the
3114 telephone number is subscribed in Kishan MODUGUMUDI's name.
16. Based on records returned in response to a subpoena to Google, the

email address sreeraj.chennuppati@gmail.com was created on 11/18/2016. The
recovery email address for sreerajchennuppati@gmail.com is

mkishanS4S@gmail.com. The Google subscriber for mkishanS4S@gmail.com
is listed as "kishan modugumudi" and the 6887 phone number is also associated with
this account. MkishanS4S@gmail.com was created on October 17,2009. TWo
refused U.S. Visa Applications from June 2Ol4listed mkishan3456@gmail.com as
Kishan MODUGUMUDI's email address.
17. Based on Internet Protocol (IP) address access information for both
sreeraj.chennuppati@gmail.com and mikishan3456@gmail.com, both accounts have
been accessed on several occasions from IP addresses that were detennined, based on
5 The AT&T return stated that the subscriber was "KISHAN MODUGUM" at 5701 W
BELDEN ST, CHICAGO, IL, the known location of Modugumudi's residence (the
"Modugumudi residence") in API 1E and APT lW.
6
records from Comcast, to be assigned to a High Speed Internet Account of Kishan
MODUGUMUDI at the Modugumudi Residence. The phone number associated with
Kishan MODUGUMUDI's Comcast account is the 6887 number.
C. Victim A
18. On December 26, 20L7, law enforcement interviewed Victim A at
Newark International Airport.6 Victim A arrived at Newark airport on a flight from
Mumbai, India. Victim A presented a 81/82 U.S. visa and stated she would be in the
United States for three months to perform at various cultural events. Victim A had
obtained her visa on September 22,2017 . Notes associated with her visa application
stated, "...madam is actress for 4.5 years...states she is guest of honor at Telugu
event..." Victim A's travel history showed she previously travelled from India to
Chicago, Illinois on October 6, 2017, and stayed in the United States through
November 13,2017.
19. During Victim A's interview with immigration officials at the airport,
Victim A stated that an individual named "Raju Geru" assisted her with her visa
application. Victim A stated her final destination was going to be Irving, Texas,
where she would perform a Hollywood dance at a New Year's Eve celebration.
20. Victim A stated that during her previous trip to the United States on
October 6, 2OL7, she came for a cultural event in Pennsylvania organized by "Raju
Geru." Victim A stated while performing at this event she was forced to engage in
prostitution. Victim A claimed that she did not actually perform any prostitution acts
6 Victim Ais 27 year old female Indian National.
7
but met with customers in a room for thirty minutes at a time and just engaged in
conversation. Victim A stated that when customers were sent to her room for thirty
minutes at a time she would ask them to help her out and show her the way.
According to Victim A, the people told her to tell 'I/ebha" that she did it and after
that they would give her a return ticket to India. During a search of Victim A's cell
phone, agents observed text messages between Victim A and an individual named
'I/ebha" talking about clients being good tippers, that she "did it" one time, and
Victim A's need to bathe between client interactions.
2L. Victim A stated that she travelled to four different cities during her
October 6 through November L3,20L7 stay in the United States. In three of the cities
(with Chicago being the exception) people were sent to her room for the alleged
purpose of prostitution and that 'Vebha" was traveling with her to these cities.
Victim A stated that between visits to the other cities she was kept at a residence in
Chicago. According to location information obtained from Victim A's cell phone, the
location of the Modugumudi Residence7 was listed as a "location" on Victim A's phone.
22. Based on Victim A's admissions, she was denied entry into the United
States and her visa was revoked.
23. On January 11, 2OL7, Victim A was interviewed by U.S. Department of
State, Diplomatic Security Service agents in India as part of this investigation.8
7 The residence is located at 5701W. Belden, Chicago, Illinois in apartments lE and IW.
8 Victim A was accompanied by an attorney to the interview. At the beginning of the
interview, Victim A's attorney requested a guarantee of protection and confidentiality before
she would ever testifr against Kishan MODUGUMUDI. Victim A's attorney also requested
that his client receive some sort of leniency on the 5-year ban preventing her from visiting
8
Victim A was shown photo arrays and identified Kishan MODUGUMUDI as the
individual she knew as "Raju" and Chandra MODUGUMUDI as the individual she
knew as'Vebha."
24. Victim A stated that after her visa was revoked on December 26,2017,
she received a call in India from Kishan MODUGUMUDI (who she referred to as
"Raju"), warning her not to tell anyone what happened while she was in the United
States. Victim A stated that Kishan MODUGUMUDI threatened her and her
family's lives if she told anyone what happened. Kishan MODUGUMUDI told Victim
A that it would be nothing for him to harm her if she talked to the police about him
because she is small and unknown, not a big actress. Kishan MODUGUMUDI
further stated he had a copy of her passport with her family's name and address in
it.
25. Victim A stated that during her visit to the United States on October 6,
2Ol7,she was picked up at the airport by Kishan MODUGUMUDI. Victim A stated
that Kishan MODUGUMUDI brought her to the Modugumudi Residence.e Victim A
described the Modugumudi residence as being two separate apartments. Victim A
stated she stayed in one apartment with another unknown woman on the top floor
and the MODUGUMUDIs stayed in another apartment on the ground floor. Victim
A stated she was not allowed to leave the Modugumudi residence on her own and that
the United States based on her recent visa revocation. Agents informed Victim A they had
no authority to make her any promises but would let authorities in the U.S. know of her
request. No other threats or promises were made to Victim A.
eVictim A identified the Modugumudi residence by a photo shown to her by agents of the
outside of the apartment building in which the Modugumudi Residence is located.
anytime she wanted to go out she would be escorted by a member of the
MODUGUMUDIS' staff.
26. Victim A stated that while staying at the Modugumudi Residence she
would travel to other U.S. cities and was forced into prostitution, although she again
maintained she never actually engaged in any sexual activity. These prostitution
dates were set up by Chandra MODUGUMUDI who Victim A referred to as'Vebha".
Victim A stated that'Vebha" would bring men to Victim A's hotel room and stay for
about 10 minutes and then'Vebha" would leave the room. Victim A stated that she
never actually slept with any of the customers and asked them for help.
27. During the interview, Victim A provided copies of two letters she had
presented as part of her U.S. Visa Application and application for admission into the
United States. The letters were from the Te1ugu Association of North America
(TANA) and the Telegana Peoples Association of Dallas (TPAD). The letters were
invitations for Victim A to be a guest at events for the associations in the United
States. Law enforcement has since spoken with the presidents of both TANA and
TPAD who have confirmed that the letters are fraudulent.
28. Law enforcement obtained Victim A's personal email address from her
U.S. Visa Application. Law enforcement obtained IP records for Victim A's email
address during the time period of October 6,2017, through November 13,2017, which
was her previous visit to the United States. On October 10 and 11, 2017, there were
four log-ins to Victim A's email account using an IP address that according to Comcast
records belonged to Kishan MODUGUMUDI's internet account at the Modugumudi
10
Residence during that timeframe. Records obtained from American Airlines revealed
that Victim A's ticket reservation for her travel to the United States on October 6,
2017 listed the same 6887 telephone number that Individual A had provided as
"Raju's" contact number in the United States. The email address of
mkishan3456@gmail.com was also associated with the reservation. ,
29. Additionally, based on subpoenaed travel agency records, it appears that
the same credit card that purchased Victim ,{s airline ticket was also used to
purchase Individual A's ticket, as well as Victim B's ticket (see below). This same
credit card is known through the investigation to have paid for the 6887 telephone
number account.
30. Agents further obtained records from Priceline.com indicating Victim
A's ticket was purchased on Priceline under an account in the name of Kishan
MODUGUMUDI. The card holder name for the purchase was Chandrakala
MODUGUMUDI. The billing address listed on the account is the address of the
Modugumudi Residence. The phone number associated with the Priceline account
is the same 6887 number provided by Individual A as the number belonging to "Raju."
The email associated with the account is mkishanS45@gmail.com. Priceline records
revealed a total of 76 airline ticket purchases associated with the email address on
the account from November 8, 2016 through November 29, 2017. All of the names
appear to be names of Indian descent, including Victim A. Based on the investigation

to date, some of the nambs were recognized as other suspected victims. The phone
number associated with all of the reservations was the 6887 number. The cardholder
11
name for the purchase of the majority of the tickets was either Kishan
MODUGUMUDI or Chandrakala MODUGUMUDI (with her name presented in
various ways). The billing address for the ticket purchases was the Modugumudi
Residence.
31. Priceline records also revealed a total of 42 hotel reservations from
November 9,2016 to January 3, 2018, associated with the email address associated
with the Priceline account. These reservations were at various hotels throughout the
United States and made in many different names all appearing to be names of Indian
descent, some of which are recognized as those of victims in this investigation. The
phone number associated with all of the reservations was the 6887 number.
32. As detailed later in this affidavit, law enforcement has found evidence
which it believes shows that Victim A was advertised and'used for commercial sex
acts while in the United States.
D. Victim B
33. Following the encounter with Individual A by law enforcement in
November 2O17, Victim B was identified as another victim whose travel appeared to
be associated with Kishan MODUGUMUDI. Victim B obtained her U.S. B1lB2 Visa
on February 16,20t7. Notes associated with her visa application stated, "Model to
ATA event in atlanta for l week - App is model and actor...misheard, going to Illinois,
not atlanta..." According to travel records, Victim B most recently traveled to the
United States on December 24,2017, arriving at O'Hare International Airport from
t2
India via Abu Dhabi.10 Prior to Victim B arriving in Chicago, U.S. Customs and
Border Protection (CBP) in Abu Dhabi conducted a pre-clearance inspection of Victim
B. During this preclearance inspection, CBP learned that Victim B was an actress
traveling to Chicago for a Telugu Association Event and that Kishan
MODUGUMUDI was her event manager. Victim B had the email address
sreerajchennuppati@gmail.com and the 6887 phone number for this individual.
34. Based on records obtained from the travel agency through which Victim
B's reservation was made, the address associated with Victim B's reservation for this
trip was the Modugumudi Residence. The phone number associated with Victim B's
reservation was the same 6887 number that was provided by Individual A as
belonging to "Raju." As stated previously, what appears to be the same credit card
that paid for the travel of Individual A and Victim A also paid for the reservation of
Victim B. Victim B's departure flight from Chicago was scheduled for the afternoon
ofJanuary 9,2018.
35. In the morning hours of January 9,20L8, agents conducted surveillance
at the Modugumudi Residence. Agents observed an unknown Indian male,

Individual B, exit the building in which the Modugumudi Residence is located
carrying a suitcase. A short time later, Kishan MODUGUMUDI exited the
'0 Travel records show that Victim B previously travelled to the United States on multiple
occasions, to include February to March 20L7, May to June 2017, and June to November
2017. Each time Victim B flew into Chicago O'Hare International Airport. Several domestic
flights for Victim B to and from Chicago were purchased by the identifred Priceline account
of the MODUGUMUDIs during Victim B's previous trips to the United States.
13
Modugumudi Residence along with Victim B and Individual 8.11 The three
individuals entered a black Toyota Avalon.12 Agents observed Kishan
MODUGUMUDI drive Victim B to O'Hare International Airport. MODUGUMUDI
later met Victim B and Individual B inside the airport and was observed talking with
Victim B outside the check-in area and then watching Victim B enter the security
checkpoint. MODUGUMUDI and Individual B returned to their vehicle.
which it believes shows Victim B was advertised and used for commercial sex acts
while in the United States.
E. VICTIM C
37. Victim C was identified as another victim whose travel was associated
with Kishan MODUGUMUDI. Victim C obtained her U.S. Visitor Visa on August
17,20t7. Notes associated with her visa application stated, "...going to function in
Detroit, 40th anniversaqr of Detroit Telugu Association...". According to travel
records, Victim C traveled to Chicago on August 23,2017 and then departed the
United States via Chicago on September 9, 2017. During that timeframe, a ticket
was purchased by the MODUGUMUDIs'Priceline account for a trip from Chicago to
Newark.
38. After leaving the United States, Victim C returned, arriving at Dallas
Fort Worth Airport on September 29,20L7. Based on records from Qatar Airways,
ll Agents recognized MODUGUMUDI from his Illinois driver's license photo.

According to Illinois Secretary of State Records, this vehicle is registered to Kishan
12
MODUGUMUDI at the Modugumudi Residence.
t4
the email address rqkishan3456@gamil.com and the 6887 number were associated
with the reservation. According to Priceline records, Victim C travelled from Dallas
to Chicago on Octob er 3,2017. According to Priceline records, Victim C's airline ticket
for this trip was purchased by the MODUGUMIIDIs'Priceline account. Priceline
records further demonstrate that a return ticket from Chicago to Dallas on October
6,20L7,was also purchased by the MODUGUMUDIs'Priceline account,
which it believes shows that Victim C was advertised and used for commercial sex
F. VICTIM D
40. Victim D was identified as another victim whose travel is associated
with Kishan MODUGUMUDI. Victim D is an Indian national female who obtained
her B1/B2 Visa in December 2OL4. Notes associated with her visa application stated,
"App invited by TLCA to appear at cultural events. App is a VJ13..." Priceline records
have shown that the MODUGUMUDIs'Priceline account purchased domestic U.S.
airline tickets for Victim D in Novembe r 2016, December 2016, January 20t7,
October 20L7 and a hotel room in New Jersey for Victim D in November 2017 . Victim
D's most recent travel to the United States was on January 5,20L8 when she anrived
at Washington Dulles Airporfra. Information obtained from subpoenaed Expedia

records show that Victim D's ticket to the United States was purchased with a visa
13 Abbreviation for'Video Jockey".

1aVictim D also flew into Dallas with Victim C on September 29,2017. The email address
mikishanS4S@gnnail.com and the phone number 6887 were associated with her reservation.
t5
card in the name of Chandrakala Purnima MODUGUMUDI, with the 6887 phone
number listed as the traveler's phone number, and mkishan3456@gmail.com listed
as the email address associated with the reservation. Victim D listed the "Radisson
Hotel Harrisburg, Camp Hill Bypass PA" as her U.S. destination on her I-94 arrival
record. Priceline records have shown that the MODUGUMUDI's Priceline account
made a reseryation on January 3, 2018 for a stay at the Radisson Hotel Harrisburg,
Camp Hill, PA from January 5, 20L8 to January 7,2018. The reservation was made
in the name of Kishan MODUGUMUDI.
41. On January L2,2018, Victim D was observed by agents leaving the
location of the Modugumudi Residence in an IJber billed to the account of Kishan

MODUGUMUDI. Based on promotional materials, Victim D was known on that date
to be appearing at an Indian association event in the Chicago area along with other
victims in this case. Victim D was followed to a hotel in Schaumburg, Illinois where
Kishan MODUGUMUDI was later observed arriving. It was also learned through
the investigation that Victim D was scheduled to appear at an Indian Telugu
association event in Gaithersburg, Maryland on January 20,2018.
which it believes shows that Victim D was advertised and used for commercial sex
G. VICTIM E
43. Victim E was identified as another victim whose travel is associated
with Kishan MODUGUMUDI. Victim E is an Indian national female who obtained
16
her B1/82 Visa on May 5, 20L7. Notes associated with her visa application stated,
"telegu and kanada major actress; invited by american telegu association and
conference as guest; 3 weeks; CA, MO". Victim E arrived in the United States at
Chicago O'Hare International Airport on May LL, 20L7. At that ii*", she listed the
"Comfort Suites, Chicago, IL" as her U.S. destination.ls
44. Priceline records reflected that the MODUGUMUDIs'Priceline account
purchased a flight from Washington to Chicago for Victim E in May 20t7, a flight
from Chicago to Dallas on November 30, 2017.
which it believes shows that Victim E was advertised and used for commercial sex
H. KISIIAN MODUGUMI,]DI & CIIANDRA KAI,A MODUGI.JMT]DI
46. A review of visa application records for Kishan MODUGUMUDI

revealed that he previously attempted to obtain a U.S. visa two times in 2014. One
of those times, Kishan MODUGUMUDI was refused a visa in part because he
15During the interview and inspection of Individual A, it was learned from Individual A that
"Raju" had purchased her airline tickets and provided her with a hotel reservation at Comfort
Suites at 4200 N River Rd, Schiller Park, IL. Individual A did not have a copy of the reservation
but "Raju" sent her a picture of the business card for the hotel. Law enforcement contacted the
hotel and learned that there was no reservation there in the name of Individual A. This Comfort
Suites, listed in a variety of ways, appears as the U.S. destination for many of the believed victims
in this case on their I-94 arrival records. Law enforcement also believes that this location may
have been used for the prostitution of some of the victims as documented later in this affidavit.
Records for the MODUGUMUDIs' Priceline records reflected that there had been reservations
made at this hotel in the name of Kishan MODUGUMUDL RecoTds obtained directly from this
hotel show several stays in the name of KISHAN MODUGUMUDI or CHANDRAKALA
PURNIMA MODUGUMUDI between March 2011 andMarch 2018.
t7
presented fraudulent documents in support of his application. Kishan
MODUGUMUDI stated in his 20L4visa applications that he was involved in the film
industry and wanted to travel to the United States in order to make contacts and
receive an award from the Telugu association.
47. MODUGUMUDI eventually received a U.S. visa in 20t5 and traveled to
Chicago on April 6,20L5. MODUGUMUDI was admitted to the United States at that
time for a period of stay not to exceed October 5,20L5. Based on database checks,
MODUGUMUDI never left the United States.
48. A review of visa application records for Chandra Kala MODUGUMUDI
show that she was issued a U.S. Visa in July 2014. MODUGUMUDI entered the
United States at Chicago on August 11, 2015 and was admitted at that time for a
period of stay not to exceed February 10, 2016. MODUGUMUDI subsequently filed
an application to extend her authoized period of stay in the United States. The
application was granted and she was authorized to stay in the United States until
August 8,2016. In August 20L6, MODUGUMUDI again applied to extend her stay
in the United States. This application was denied. Based on database checks,
MODUGUMUDI never left the United States.
L ARREST OF THE MODUGI.]MUDIS & INFOMRA'TION

REI,ATED TO VICTIM D
49. On January 23, 2OL8, Kishan MODUGUMUDI and Chandra Kala
MODUGUMUDI were encountered by the United States Border Patrol (USBP) at an
interstate rest area in Tiffin, Ohio. The MODUGUMUDIs were arrested by USBP as
visa overstays and placed into removal proceedings. On February 23,2018, the
18
MODUGUMUDIs were released from immigration custody on bond. A hearing in the
MODUGUMUDIs'immigration case is currently scheduled for November 2018.
50. Several identification documents for the MODUGUMUDIs,
miscellaneous documents, and credit/debit cards were recovered by USBP pursuant
to the arrests. One of the miscellaneous documents was a handwritten note on
Marriott hotel stationary. Written on the top of the note and underlined was the first
name of an individual I recognized as Victim D. The handwritten note on Marriott
Hotel Stationary had "Washington D.C." written next to Victim D's name. Written
below this was "January 19th Morning" with an arrow pointing to "Room NO: 207"
with an arrow pointing to "2 times". Written below this was "January 19th venkat"
with an arrow pointing to "Room NO: 404" with an arrow pointing to "l time"".
Written below this was what appeared to be "January 20th Dayegano" with an arrow
pointing to "Rom NO 404" with an arrow pointing to "1 time". Below this was written
"Jan 20th One Event DC" with an arrow pointing to "1000 $ Money". Based on my
training and experience and the investigation to date, I believe this may be a record
of acts of prostitution performed by Victim D while she was in the United States in
January 2018.
J. SEARCH OF THE MODUGI]MI]DI RESIDENCE
51. On February 16, 20L8, a federal search warrant was executed at the
Modugumudi Residence in Chicago. During the search of the residence, law
enforcement recovered multiple items of evidentiary value including: (1)
approximately 70 condoms, the majority of which were divided up into multiple
19
ziplock bags; (2) a fraudulent U.S. lawful permanent resident card and social security
card in the name of Kishan MODUGUMUDI; (3) copies of a letter purportedly from
the American Telugu Association to the Consulate General of the United States in
Hyderabad, India, requesting a visa for an Indian citizen, as well as a copy of that
individual's appointment letter for BllB2 visa interview at U.S. Consulate in India;
and (4) and numerous pink and yellow business cards which contained only the name
'Vebha Jayam" and two phone numbers for her, one of which ended in7176 and the
other which ended in 6L67, and (5) diaries/ledgers which based on my training,
experience, and the investigation to date are believed to be ledgeqs of prostitution
activity performed by several believed victims in this case.
52. One of the diaries/ledgers was a diary labeled "DIARY 2018". One of the
first pages inside "DIARY 20L8" stated that it was the Personal Record of 'I/ebha
Jayam". A page in the "DIARY 20L8" had Victim B's first name written on top of it.
The page had six lines which listed dates from December 2g,2OL7 to January 7 ,2018.
After each date was an arrow pointing to either "l-time" or "2times", and then an
arrow pointing to a location which appeared to be Chicago or North Carolina. The
same signature appears afber each line. Based on my training, experience, and the
investigation to date, I believe that this is a ledger of prostitution acts performed by
Victim B during her stay in the United States from December 2017 to January 2018,
as documented by Chandra Kala MODUGUMUDI. Further, the diary contained a
page on which was written Victim D's first name and "Garu" followed by "Jan 5th Fri
2018 IUSAI Landed. PA." Following this was a page apparently showing that Victim
20
D had been paid "1000$" for an event in Harrisburg on January 6, 20L8 and "1000$"
for an event in Chicago on January 12,2018. Following this was a page on which was
written three lines. The first line stated,"L-5-2018-Harrisburg-1time-helieved name
of clientl-cash paid 1000$" and was followed by what is believed to be the signature
of Victim D. The second line stated, "1-6-2018-Harrisburg-1time-helieved name of
clientl-cash paid l-000$" and was followed by what is believed to be the signature of
Victim D. The third line stated, "L-L6-2018-Philadelphia-2 times-[believed name of
clientl". Based on my training, experience, and the investigation to date, I believe
that this is a ledger of prostitution acts performed by Victim D while she was in the
United States in January 20L8, as documented by Chandra Kala MODUGUMUDI.
53. What appeared to be similar ledgers of prostitution involving Victim A,
Victim B, Victim C, Victim D, and Victim E and others in the United States during
2Ot7 were found in a diary labeled "2OLGDL\RY'16 which was discovered during the
search warrant at the Modugumudi Residence. One of the first pages of this diary
stated that it was the personal record of "ChandraKala Purnima MODUGUMUDI".
K. SEARCH OF THE MODUGI.]MI.]DIS' CELL PHONES
54. After the MODUGUMUDIS arrest by USBP in Ohio, the
MODUGUMUDIS provided written consent to search their cell phones. The
MODUGUMUDIS had four cell phones in their possession at the time of their arrest.
taThe "DIARY 20L6" appears to have been preprinted on the cover of the hard backed diary
by the manufacturer of the book. Many of the handwritten dates inside the diary are recorded
as 2017 dates and other information within the diary appears to show that the dates are in
20L7.
27
While the search of these cell phones is still ongoing, law enforcement has recovered
multiple pertinent text/chat conversations which further demonstrate the

MODUGUMUDIS' involvement in the importation of aliens for purposes of
prostitution, to include Victim A, Victim B, Victim C, Victim D, and Victim E as
documented below in a selection of the recovered texUchat exchanges:
a. In one recovered chat string beginning on November 2,2017, and
continuing to November 14,2017,r2 Individual C and the user of the 7L76 phone18,
which law enforcement believes belonged to Chandra Kala MODUGUMUDI, engaged
in a chat conversation regarding Victim A, during which Victim B also appeared to
be offered for prostitution based on the investigation to date. The following are
excerpts from the chat string, with the user of the7l76 phone listed as Chandra based
on the belief that she was the individual using the phone:
November 21 2Ol7 Excerpt 1:
Individual C: Is Victim A available?le
Individual C: In Chicago
17The times in which the chat was displayed in data extracted from the cell-phone were UTC
+ 0. The times/dates reflected in this affidavit were adjusted to Central Standard Time and
Central Daylight fime.
18 Law enforcement believes this phone belonged to Chandra Kala MODUGUMUDI based on
the following: (1) the cell phone was recovered from the MODUGUMUDIs at the time of their
arrest; (2) the Apple ID on the phone was chandrakalamod@ennail.com, (3) the number was
listed on the business cards bearing the nameIIEBHA JAYAM"'which were found at the
Modugumudi Residence; (4) the phone number was found to be saved as the phone number
for 'Vebha Jayam" in the phone of Victim B during outbound inspection at O'Hare
International Airport on January 9,20L8; and (5) records obtained from AT&T show that
KISHAN MODUGUMUDI is the subscriber for the phone number.
re lndividual C uses the first name of Victim A.
22
Chandra: Can I call
Individual C: Can't talk I'm outside
November 21 2Ol7 Excerpt 2:
Individual C: Want to see Victim A the model
Chandra: Sorry wrong number
Individual C: Vibha madam it's not wrong number
Individual C: I can't talk otherwise I'd explain to you over phone I don't
want to text all and all so
November 7r 2Ol7 Excerpt 1
Individual C: Victim A is available
Individual C: ...one of my ftiend gave your number
Individual C: I want Victim A for 3, 4 hours for 1000$ It's possible
let me know.
Chandra: Sends an image that appears to be ofVictim B
Chandra: Sends a second image that appears to be of Victim B
Chandra: Sends a third image that appears to be of Victim B
Individual C: No not this one baby
Chandra: I know she's ready for 1200$
Chandra: l time only

Individual C: No I like the other one
Chandra: Sends an image that appears to be of Victim A
23
Chandra: Sends a second image that appears to be of Victim A
Chandra: Sends a third image that appears to be of Victim A
Chandra: Sends a fourth image that appears to be of Victim A
Individual C: Yes this one baby
Chandra: Yes
November 7r20l7 Excerpt 3 q
Individual C: I really would be happy If I could that price
Individual C: But I can't
November 7 r 2Ol7 Excerpt 4
Chandra: It's all in your hand O
Chandra: If you can she can make some and you and I would
be happy
Chandra: Sir pls
November 7 r 2Ol7 Excerpt 5
Individual C: That's my max budget 1200
Individual C: Let me know in case she decided
Individual C: Okay I'll give in your hand

Individual C: and drop her in morning right
Individual C: Also you have hotel?
Chandra: I don't have a hotel sir
Chandra: She's staying today my house
24
Individual C: I can give cash to you or someone you know first and
then I can go pick her up....
Individual C: I'm on my way
b. Based on the chat string, Chandra appears to direct Individual C
to a Dunkin Donuts near the Modugumudi Residence after which she provides
Individual C the address of the Modugumudi Residence as follows:
November 7, 2Ol7 Excerpt 9
Chandra: lGives the address of the Modugumudi Residence]
Individual C: I'm here2o
Chandra: K sir I'm coming
Individual C: If gonna be long sweetie
Individual C: 5 min or long
Individual C: can I request lingiera [ingerie]2l
c. In the "2016 DIARY' that was recovered during the search

warrant at the Modugumudi Residence, a page was found on which was written
Victim A's first name followed by, "1Qtn Od 2Ol7 Chicago landed". A page following
20This message was sent approximately four minutes after Chandra provided Individual C
the address of the Modugumudi Residence.
21 This is the last text in the chat and occurs shortly after midnight on November 8,20L7
CDT.
25
this appeared to document dates, the number of "times" something was done (i.e
"2times", "4times"), what are believed to be the names of customers and./or the
location where acts occurred, monetary amounts, and a notation that the monetary
amount was paid followed on each line by a signature. The final entry on the page
stated: "Nov 7th-2 times Chicago North Indian-450$-paid" and was followed by a
signature which was dated as "7th Nov 2017". Individual C's contact name appears
in the above chat with what is believed to be his first name followed by, "Chicago
North Indian". Thus, it is believed that this entry corresponds to prostitution
performed by Victim A with Individual C at the Modugumudi Residence as arranged
by Chandra Kala MODUGUMUDI in the chat.
d. On November I-3, 20L7, Individual C appears to inquire with
Chandra to see if Victim A is again available.
November I-3r 2Ol7
Individual C: Is Victim A available22
Chandra: Yes sir
Individual C: Can you do for thousand
Chandra: Call plszs
e. In another recovered chat string occurring on December 1, 2OL7,
what is believed to be Chandra Kala MODUGUMUDI using the 7tl6 phone and
22 Individual C uses an abbreviated version of the first name of Victim A

23 Individual C was identifred from his phone number. I have attempted to interview
Individual C and in doing so have confrrmed that it is his phone number which appears in
the chat. Individual C has until now declined to be interviewed and has retained counsel.
26
Individual D engaged in a chat which appeared to discuss Victim B and Victim E. The
following are excerpts of that chat:
December lr 2Ol7 Excerpt I

Individual D: Hi
Chandra: Who's this
Individual D: [Provides his name and gives the name of his friend
apparently as a reference]
December lr 2O17 Excerpt 2
Chandra: Hi sir can I call sir
Individual D: No
Individual D: I can't talk
December lr 2Ol7 Excerpt 3
Chandra: Victim E2a available
Individual D: But he said you have someone new
Individual D: I am not Telugu
Chandra: Canlsendapics
Chandra: Yes sir Victim E
Individual D: ok
Individual D: Send
Chandra: Sends seven images that appear to be of Victim E
2aChandra provides what is known to be the screen name of Victim E. Victim E stated that
this was her film name during outbound inspection at Chicago O'Hare International Airport
on December 3,20L7.
27
Chandra: She's Victim E
Individual D: K
Chandra: Available today and tomorrow only2s
Individual D: Ok
Individual D: I am not rich. I can't effort [sic] thousands of dollars.
Individual D: Some thing reasonable price.
Chandra: What s ur budget sir
Individual D: Same last time rate. I did 2 times with tall girl south
Indian You came to drop her at comfort inn
Chandra: 3 hrs 2 times 2500$
Chandra: This s the budget
Individual D: Thanks. I can't effort [sic]
Chandra: Finall [slc] price 2000$ 2 times
Individual D: Last time I paid only 800 two times with that girl I paid to
you only.
Chandra: Who
Individual D: South Indian Girl
Chandra: I don't know sir

Chandra: Any updates let me know sir
Chandra: Finall price 2000$ 2 times
25Victim E departed the United States from Chicago O'Hare International Airport on
December 3,2017, consistent with this statement as this chat occurred on December L,2017.
28
Individual D: [Sends an image that appears to be of Victim B apparently
in reference to the "South Indian Girl" with whom he
previously had an encounter with arranged by Chandra
based on the context of this chat.l
Chandra: 1400$ payrng sir ur
Individual D: No
Individual D: I don't know

Individual D: I paid only 800
Chandra: Sends another image that appeared to be of Victim E
Chandra: She is not coming
Chandra: lOUVo fixed price
Chandra: 2000$ only today and tomorrow
Chandra: Tell me yes or no sir
Individual D: I will let you know tomorrow26
f. In another recovered chat string from December 6,20L7 through
January 22,2018, the Chandra MODUGUMUDI phone appeared to engage in chats
with Individual E which appear to advertise Victim D for prostitution2T:
26Individual D was identified by his phone number. Individual D's first name appeared as
his contact name in the chat. Individual D has since been interviewed by myself and other
agents regarding this chat. I have confirmed that it is Individual D's phone number which
appeared in the chat. Individual D claimed he could not tell me who had used his phone to
have these chats and denied engaging in prostitution. Individual D claimed that he had been
at a restaurant with friends and one of them had used his phone. Individual D provided
Individual C as one of the friends who was with him at the restaurant.
27Victim D was in the United States from September 29,20L7 to December 10, 2017 when
she departed via Chicago O'Hare International Airport. As documented previously, Victim
29
December 61 20ll Chat

Individual E: Any foiends ! Send pics
Individual E: One of my friend looking
Chandra: Where's he
Individual E: Chicago
Chandra: Only Victim D28 garu Available
Chandra: Sends image that appears to be of Victim D
Chandra: Sends second image that appears to be of Victim D
Chandra: Anchor2e Victim D garu
Chandra: 2500$ 1 time only
Individual E: Good pics
Individual E: Some other photos
Chandra: Google
Chandra: Victim D Anchor
January 22, 201.8 Excerpt

Chandra: Victim D Anchor Available Nj
Chandra: Sends image that appears to be of Victim D
Chandra: Sends second image that appears to be of Victim D
D returned to the United States on January 5,20L8 and subsequently departed in February
2018.
28 Chandra gives Victim D's first name
2eOn promotional materials for Indian association events, Victim D is referred to as an
"Anchor" apparently in reference to her being a Video Jockey or "VJ".
30
Chandra: Sends third image that appears to be of Victim D
Chandra: Sends fourth image that appears to be of Victim D
Individual E: For me ?
Chandra: [Smiley face emoticon]
Individual E: [Thumbs Up emoticon]
g. In another recovered chat string from January 22,20L8, what is
believed to be Victim D3o and the Chandra MODUGUMUDI phone engaged in the
following conversation which appears to show Victim D reporting to Chandra that
she had completed a sex act, specifically referencing the number of "times", consistent
with the aforementioned entries in the recovered diariesfledgers from the
Modugumudi Residence:
Chandra: l time only
Victim D: Done
Victim D: Blow job lo ne [sad emoticon and happy emoticon]
Victim D: But he is very happy
Chandra: Ok mam ["thumbs up" emoticon]
h. In a recovered chat string occurring shortly after midnight CST
on October 8, 20L7, between Individual F and the user of the 6887 phone31, law
so The phone number for Victim D is the one she listed on her U.S. Visa Application and her
first name, along with "ancor", appears as her contact name in the chats.
31 Law enforcement believes the 6887 phone belonged to Kishan MODUGUMUDI based on
reasons to include the following: (1) the cell phone was recovered from the MODUGUMUDIs
at the time of their arrest; (2) the phone was provided by Individual A as the phone number
for "Raju" who has been identified pursuant to this investigation as Kishan MODUGUMUDI;
(3) AT&T records show KISHAN MODUGUMUDI to be the subscriber for the phone; (4) it is
31
enforcement believes that Kishan MODUGUMUDI offered Victim C and Victim D for
a prostitution date with Individual F in Frisco, Texas32. The following are excerpts
from the chat string, with the user of the 6887 phone listed as Kishan based on the
belief that he was the individual using the phone:
October 8,2Ol7 Excerpt L
Kishan: Victim D R Victim C33
October 8r 2Ol7 Excerpt 2
Individual F: Victim C
Kishan: Ok sir
Individual F: How much
Kishan: Sends image that appears to be of Victim C
Kishan: 2200$ sir ine time
October 8r 2Ot7 Excerpt 3
Individual F: Ok
Individual F: 2000 ok
October 8r2Ol7 Excerpt 4
the phone number associated with the email account of Kishan MODUGUMUDI,
mkishan3456@snail.com, (5) lease and security deposit documents for the Modugumudi
Residence list this as the phone number for Kishan MODUGUMUDI, texts were observed on
the phone with the landlord for the MODUGUMUDI residence in which the landlord refers
to him as "Mr. Kishan".
32As documented previously in this affrdavit, Victim C arrived in the United States at Dallas
Forth Worth Airport on September 29,20L7. Tbavel records show that Victim D arrived on
the same flight as Victim C.
33 Provides the first names of Victim D and Victim C
32
Kishan: Hyatt House 2875 Parkwood Boulevard Frisco, Texas,
75034
Individual F: How much time??
Kishan: 2hours
Individual F: Ok, will be there if 2000
Kishan: no sir [so sir for you it's $2000.00 plus $fOO tip]sa
Individual F: Ok
Individual F: On my way
Kishan: ok sir
Kishan: room no l-08 sir
Individual F: Ok, almost there
Kishan: k sir
i. As documented earlier in this affidavit, according to Priceline
records, Victim C travelled from Dallas to Chicago on October 3, 20L7. According to
Priceline records, Victim C's airline ticket for this trip was purchased by the
MODUGUMUDIs'Priceline account. Priceline records further demonstrate that a
return ticket from Chicago to Dallas on October 6,2017, was also purchased by the
MODUGUMUDIs' Priceline account. Priceline records reflected that the
3a This was translated from Telugu by an HSI Agent who is fluent in Telugu
33
MODUGUMUDIs' Priceline account made reservations for Chandra Kala

MODUGUMUDI and Victim C at the Hyatt House in Frisco, TX from October 7 ,2017
to October 8, 2017. Records obtained from the Hyatt House in Frisco, Texas show
that the guest for Room 108 from October 7, 2017 to October 8, 2017 was
"Chadrakalapur Modugumudi". A review of the previously discussed "2016 DIARY'
that was recovered at the Modugumudi Residence, showed that it contained a page
on which was written Victim C's first name followed by, "sep 29th-2OL7 landed Dallas
TX". Ensuing pages after this appeared to document dates, the number of "times"
something was done (i.e "ltime","2times"), what are believed to be the names of
customers and./or the location where acts occurred, monetary amounts, and a notation
that the monetary amount was paid. A signature appears on each line of these
apparent ledgers. The name in the signature appears to start with the first letter of
Victim C's name. On top of one of the pages was written, "Dallas TX 2"d Time Travel".
Under this were several lines con'esponding to different dates in October to include:
"Oct 7th - ltime-helieved initials of clientl-900$", "Oct 7th - ltime - helieved name
of clientl- 900$", and "Oct 7th -ltime-believed name of clientl-900$"as.
L. IIVTERVIEW OF INDTYIDUAL G
55. During the review of texts on the 6887 phone and another phone ending
in 458736, several text strings were observed, which based on the investigation to
35 The aforementioned chat with Individual F happened shortly after midnight on October 8,
20L7.
36 This phone was also found with the MODUGUMUDIs at the time of their arrest. The
Apple ID for this phone was sreerajchennuppati@gmail.com. The extracted data showed that
the 6887 number may have previously been the phone number on this device. A database
34
date, were believed to be for the advertisement or arrangement of prostitution with a
client using a Chicago area telephone number. I conducted a database check which
showed that the number was associated with Individual G in the Chicago area.
56. On March 13, 2018, I and other agents interviewed Individual G.
Individual G provided his cell-phone number as the number which appeared in the
texts on the 6887 and 4587 phones.
57. Individual G confirmed that he knew someone named 'Vebha"37.

Individual G knew'T'ebha" to conduct cultural events and to have contacts with film
personalities and Telugu actresses. Individual G had seen'Vebha" at these cultural
events. Individual G explained that to his knowledge, these film personalities and
actresses come to the United States for events on temporary visas.
58. Individual G recognized Chandra Kala MODUGUMUDI from a photo
as'T'ebha".
59. After being advised of the nature of the investigation and of the
discovered text messages involving his phone number that appeared to be related to
prostitution involving Telugu actresses, Individual G confirmed that he did have
conversations with Vebha" regarding the price to have sex with actresses. Initially,
Individual G stated that he never actually engaged in a commercial sex act with the
check showed the number as being associated with "KISHAN MODUGUM". A response from
AT&T for a request for subscriber information for this number is currently pending.
37 Individual G was not sure if the spelling of the name was'Vebha" or'Vibha".
35
victims. Individual G could not remember which actress or actresses he had

discussed with'Vebha".
60. While discussing how Individual G knew to contact'Vebha" regarding
the price to have sex with the actresses, Individual G explained that 'Vebha" is known
in the local Telugu community as one of the women to go to or contact regarding
having sex with actresses.
61. Individual G stated that he had once talked to a man named "Nagaraju"
regarding sex with the actresses. Individual G recalled that "Nagaraju" had an area
code which was the same as the area code as the 6887 phoness. Per Individual G,
"Nagaraju" and'Vebha" know each otheCe. Individual G explained that "Nagaraju"
and'I/ebha" send pictures of the actressesao and that they had both sent him pictures
ofthe actresses.
62. Later in the interview, Individual G admitted to meeting one of the
actresses for sex. Individual G confirmed that'Vebha" arranged for him to meet the
actress. Individual G stated that he could not remember who the actress was and
that he met her at a Chicago area hotel in what he believed was over a year ago.
Individual G confirmed that 'Vebha" arranged for this meeting with the actress and
38Individual G was asked during the interview if he recognized the 6887 number. Individual
G did not recognize the specific number. In my presence, Individual G searched his cell-
phone for the number in his contacts but it was not found.
3e Individual G was shown a photo of Kishan MODUGUMUDI but did not recognize him.
a0lndividual G advised that the pictures of the actresses were also sent as marketing for the events.
Individual G confirmed that the pictures were also sent to advertise prostitution some of the time.
36
'Vebha" told him what hotel room to go to. Individual G stated that it could be that
'I/ebha" told him what the price was41. Individual G believed that the girl had the
condom. Individual G stated that he was there for more than an hour and explained
that he was there for the actress'company in addition to the sexual act.
63. During an interwiew with Individual G on April 19, 20L8, he admitted
to meeting'Vebha" in the hotel lobby area and payrng her with what he believed was
approximately $1100.00 in cash afber which'T'ebha" told him the room number to go
to. He went to the room and met the woman with whom he engaged in sexual
intercourse. Individual G identified the Comfort Suites O'Hare from a photograph as
the hotel where this occurred. Individual G again identifred CIIANDRA KAIA
MODUGUMUDI from a photograph as'\trebha"42.
64. Pursuant to a review of the text messages, on June 24,20t7,Individual
G texts the 4587 number and asks in Telugu, "How's it going". The 4587 number
replies in Teluguas, "Will you make it by 1.30pm. I will call at 1 pm and remind you"
and then, "Come straight away sir". The 4587 number then texts Individual G the
name of Victim Eaa and an apparent U.S. phone number for her.
65. I reviewed the aforementioned "2016 DIARY' discovered at the
Modugumudi Residence. I observed that written on a page below "Cash work" and
alAt the time of this interview, Individual G stated that he had gifted online shopping to the
woman he slept with as payment. During a subsequent interview, Individual G later
admitted to paying'Vebha" in cash to have sex with the woman.
a2 In his written identification, Individual G wrote the name as'Vibha".
as As translated by an HSI Agent fluent in Telugu.
aa Screen name of Victim E
37
the name of Victim Eas was an entry which listed Individual G's name in almost the
same way as it appeared in the contacts on the 4587 phonea6, followed by, "2times
600$ - o6-24-L7".
M. SEARCH OF KISIIAN MODUGUMUDI'S GIT{AIL ACCOI.]NTS.
66. On February 23, 2018, law enforcement obtained federal search

warrants for Kishan MODUGUMUDI's two known Gmail accounts which are
discussed in this affidavit.aT On April 9, 20L8, Google. Inc. provided law

enforcement with records from Google for these two accounts. Included in the records
were e-mails between the sreerajchennuppati@gmail.com account and known or
believed email addresses of Victims A, B, C, D, and E which included Kishan
MODUGUMUDI sending victims A, B, C, and E various Telugu Association letters
for the victims to use in order to obtain visas to visit the United Statesa8, as well as
airline tickets and./or travel itineraries for all of the victims to travel from India to
the United States.
a5 Screen name of Victim E

a6The contact on the phone and in the ledger both include Individual G's first name followed
by'Yedavaa" on the phone and "yedava" in the ledger. "Chicago" appears before the name
in the contact on the phone and after the name on the ledger.
a7 The accounts searchedwere sreerajchennuppati@gmail.com and mkishan3456@gmail.com.
Both accounts contained numerous emails that showed Kishan MODUGUMUDI to be the
user ofthe accounts.
a8 It is believed that the victims used the letters to obtain U.S. visas because they were all
sent close in time to their U.S. visa interviews in India and the contents of the letters
correspond with notes for the victims U.S. visa applications as to their stated purpose for
traveling to the United States Further, as documented previously in this affidavit,
Individual A and Victim A provided information that they used the letters provided to them
to obtain their U.S. visas.
38
67. On December 22,20L1, Victim A sent an email to the
sreerajchennuppati@gmail.cqm account which stated, "I am sorrJ, if I caused you
any inconvenience. I am not aware of any inconvenience that I caused but still you
constantly keep calling me and threatening me. From this of I would like to stop all
interaction'via voice messages,text messages br call etc. please do not call me and
don't try to contact me. It was very unpleasant doing business with you and I don't
war-rt to do any business with you now or in future. If you try contacting me again
I'll have to make formal complaint.' Victim A signed the email with her nam.e.
CONCLUSION
68. Based.upon the above information, there is probable cause to believe
that KIS}IAN MODUGUMUDI ANd CIIANDRA KAI,A PURNIMA MODUGUMIIDI
have imported. Victims A, B, C, D, and E into the United States for purposes of
prostitution antl in violation of Title 8, United States Code, Section L328
,.'r.< FURTHERAFFIAI\IT SAYETH NOT.
ffi;5g,-.r-lAp-".+
-H,o. ;Y zn<wl:
,
o^J
I ,.J'si.* 3'^'li
SWORN to me by telephone on April 28 ,2018.
SUSAN E. COX
United States Magistrate Judge

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Case: 1:18-cr-00262 Document #: 1 Filed: 04/30/18 Page 1 of 42 PageID #:1 lt

Affidavit was true and correct.

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

I, BRIAN GINN, being duly sworn, state as follows:

1. I am a Special Agent with Homeland Security Investigations (HSI). I

Border Patrol Agent from 2001 to 2004.

2. As part of my duties as a Homeland Security Investigations Special

Agent, I investigate criminal violations relating to federal criminal offenses

involving alien harboring, alien smuggling, human trafficking, importation of aliens

for immoral purposes, and visa fraud.

3. This affidavit is submitted in support of a criminal complaint alleging

that KISHAN MODUGUMUDI, also known as "Sreeraj Chennuppati," and "Raju,"

and CHANDRA KALA PURNIMA MODUGUMUDI, also known as "Vebha," "Vebha

MODUGUMUDI and CHANDRA KAI,A PURNIMA MODUGUMUDI with

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

I, BRIAN GINN, being duly sworn, state as follows:

1. I am a Special Agent with Homeland Security Investigations (HSI). I

Border Patrol Agent from 2001 to 2004.

2. As part of my duties as a Homeland Security Investigations Special

Agent, I investigate criminal violations relating to federal criminal offenses involving

alien harboring, alien smuggling, human trafficking, importation of aliens for

immoral purposes, and visa fraud.

3. This affidavit is submitted in support of a criminal complaint alleging

that KISHAN MODUGUMUDI, also known as "Sreeraj Chennuppati," and "Raju,"

and CIIANDRA I{ALA PURNIMA MODUGUMUDI, also known as 'Vebha," 'Vebha

MODUGUMUDI and CHANDRA KALA PURNIMA MODUGUMUDI with

committed the offense alleged in the complaint.

4. The statements in this affidavit are based on my personal knowledge,

5. As summaized in detail below, law enforcement believes that KISHAN

MODUGUMUDI and CIIANDRA KALA PURNIMA MODUGUMUDI imported

United States for purposes of prostitution. The MODUGUMUDIs purchased airline

MODUGUMUDI residence in Chicago, Illinois, or at hotel rooms across the country,

6. As detailed in this affidavit, the evidence in this investigation includes,

States; (3) the statement of a customer acknowledgrng the purchase of a commercial

from the MODUGUMUDIs' cell phones demonstrating multiple conversations

between the MODUGUMUDIs and customers believed to be advertising and./or

recovered from a search of the MODUGUMUDI residence which are indicative of

prostitution dates and payments set up for Victims A, B, C, D, and E by the

hotel room locations paid for by the MODUGUMUDIs.

7. Both Kishan MODUGUMUDI and Chandra Kala MODUGUMUDI have

on bond from immigration custody on February 23,2018.

Embassy in New Delhi on November 6, zlilT.Individual A submitted a document to

the Telegu Association of Southern California (TASC) at an event on November 18,

to Telegu Association Star Night; in CA. Will stay for 10 days..."

A presented immigration officials with a letter stating Individual A would be a guest

at the NATS conference to be held at the Renaissance Convention Center in

introduced to "Raju" by an acquaintance in India. Individual A stated that "Raju"

confirrnation documents by email. Individual A stated that "Raju" was supposed to

address provided was sreerajchennuppati@email.com. Individual A stated she did

the United States.

a Indiaglitz appears to be an entertainment website focused on the Indian entertainment

for "Raju" showed it as being associated with a Kishan MODUGUMUDI. Records

number showed it as being subscribed to by Kishan MODUGUMUDIs. Officers also

3114 telephone number is subscribed in Kishan MODUGUMUDI's name.

16. Based on records returned in response to a subpoena to Google, the