Criminal Complaint — U.S. v. Edwards (M.D. Fla.) (M.D. Fla.)

Record facts

U.S. District Court, Middle District of Florida, Orlando Division · No. 6:20-mj-01673-LHP · Doc. 1 · 2020-09-18 · Docket on CourtListener

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Case 6:20-mj-01673-LHP Document1 Filed 09/18/20 Page1of5PagelD1

AO 91 (Rev. LI/1 1) Criminal Complaint

UNITED STATES DISTRICT COURT

for the
Middle District of Florida

United States of America )
V. )
JOSHUA EVAN EDWARDS ) Case'Ne
a/k/a lan Heringa . , \
JOY ESTHER EDWARDS ) 6:20- ny, - IU 73
EVAN WILLIAM EDWARDS ) J
MARY JANE EDWARDS )
a/k/a Mary Jo Heringa )
7 Defendant(s) -
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of June 29, 2019 in the county of Orange _ inthe
Middle _ District of Florida , the defendant(s) violated:
Code Section Offense Description
18 U.S.C. § 1546 Fraud and misuse of visas, permits, and other documents

This criminal complaint is based on these facts:

See the attached affidavit.

rif Continued on the attached sheet.

Complailant's signature

Javier A. Mondejar, Enforcement Officer, USCBP

Printed name and title

Sworn to before me and signed in my presence.

ow 9 ARID me

Judge's signature

_ Orlando, Florida LESLIE R. HOFFMAN, U.S. Magistrate Judge

Printed name and title

City and state:
Case 6:20-mj-01673-LHP Document1 Filed 09/18/20 Page 2 of 5 PagelD 2

STATE OF FLORIDA CASE No. (gy: Z6- my -l(074

COUNTY OF ORANGE
AFFIDAVIT

I, JAVIER A. MONDEJAR, Enforcement Officer at Orlando International
Airport working for United States Customs and Border Protection (““USCBP”) in
Orlando, Florida, being duly sworn, state the following:

L I am a Criminal Enforcement Officer at Orlando International
Airport and have been so employed since 2008. Prior to assuming that position, I
was a Customs and Border Protection Officer, and have been employed with the
agency since 2006. I am responsible for conducting criminal investigations of the
criminal statutes contained in the Immigration and Nationality Act, and related
offenses contained in Titles 8 and 18 of the United States Code.

ve The statements contained in this affidavit are based upon my own
personal knowledge, as well as information provided to me by other law
enforcement officials and employees of USCBP. I have not included in this
affidavit each and every fact and circumstance known to me, but only the facts and
circumstances that I believe are sufficient to establish probable cause.

3. On August 1, 2018, JOSHUA EVAN EDWARDS (“JOSHUA”)
and JOY ESTHER EDWARDS (“JOY”) each presented a Form I-129, L1A Visa
Application, U.S. Citizenship Immigration Services (USCIS) and supporting
documentation, to the USCBP Officer at Edmonton International Airport, Alberta,

Canada and boarded a United Airlines Flight #2084 to George Bush International
Case 6:20-mj-01673-LHP Document1 Filed 09/18/20 Page 3 of 5 PagelD 3

Houston Airport in Texas. The USCIS Form I-129 was forged, and included false
representations concerning their employment. Upon presentment of the Form I-
129 to USCBP, USCBP issued LIA visas to both JOSHUA and JOY and they
were admitted into the United States with LIA, nonimmigrant visas.

4. On August 5, 2018, EVAN WILLIAM EDWARDS (“EVAN”), MARY
JANE EDWARDS (“MARY”), presented a Form J-129, along with supporting
documentation, as support of an L1A Visa application for EVAN, and an L2 Visa
application for MARY to the USCBP Officer at Edmonton International Airport,
Alberta, Canada and boarded a United Airlines Flight #2084 to George Bush
International Houston Airport in Texas. The USCIS Form I-129 was forged, and
included false representations concerning their employment. Upon presentment of
the Form I-129 to USCBP, USCBP issued an LIA visa to EVAN and an L2 visa
to MARY, and they were admitted into the United States on their respective
nonimmigrant visas.

5. On or about June 29, 2019, EVAN, MARY, JOSHUA and JOY flew
from Edmonton International Airport to Orlando International Airport on board
Swoop Airlines Flight #792 from Alberta, Canada. Upon arrival at Edmonton
International Airport, EVAN, MARY, JOSHUA and JOY proceeded to the
primary inspection station and requested admission into the United States. EVAN
presented a Canadian Passport (#HP241064), MARY presented a Canadian

Passport (#HL519476), JOSHUA presented a Canadian Passport (#HL518485)

2
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and JOY presented a Canadian Passport (#HL519476) bearing their names and
photographs as well as their respective stamps indicating their nonimmigrant visa
status. The USCBP Officer reviewed the documents and admitted EVAN,
JOSHUA, JOY as LIAs and MARY as an LZ, in to the United States until August
03, 2021.

6. CBP Criminal Enforcement Unit (CBP/CEU) discovered the
violations on the Visa Applications during an investigation by the U.S. Secret
Service Office in Orlando as CBP/CEU is part of the Task Force for the Orlando
Office. The Form I-129s submitted by EVAN, MARY, JOSHUA, and JOY were
all purportedly signed by an individual, W.G. These forms represented that EVAN,
JOSHUA and JOY would be working in the United States on behalf of W.G., in
the name of ASLAN International Ministry, Inc.

The L2 visa obtained by MARY was predicated on the LIA visa application of her
husband, EVAN.

7. On September 11th and September 18th, 2020, Edmonton Police
Department conducted interviews of W.G., and W.G.’s son. W.G.’s son indicated
that his father has had dementia since 2017 and has not been able to sign any
documents. W.G.’s son denied any knowledge that W.G.’s signature was on any
documents related to visa applications or job offers for the Edwards family. W.G.’s
son stated that W.G. resigned from the board of ASLAN International Ministry in

2007 and W.G.’s son has not signed anything related to ASLAN International

3
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Ministry on his father’s behalf.

8. Based upon the foregoing, your affiant submits that there is probable
cause to believe that, on or about June 29, 2019, in the Middle District of Florida,
EVAN WILLIAM EDWARDS, MARY JANE EDWARDS, JOSHUA EVAN
EDWARDS and JOY ESTHER EDWARDS knowingly possessed and used a
nonimmigrant visa, which they knew to be procured by means of a false claim and
statement, otherwise procured by fraud, and unlawfully obtained, in violation of
18 U.S.C. § 1546 (a).

FURTHER AFFIANT SAYETH NAUGHT.

—TJavier A Mondejar

Criminal Enforcement Officer
U.S. Customs and Border Protection

Sworn and subscribed to before me on this
18th day of September, 2020, in Orlando, Florida.

Lalit lobar

LESLIE R. HOFFMAN \
United States Magistrate Ju

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