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Case 9:19-cr-80056-RKA Document 14 Entered on FLSD Docket 04/12/2019 FILED
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Apr 12, 2019

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

ANGELA E. NOBLE
CLERK U.S. DIST. CT.
S. D. OF FLA. - MIAMI

19-80056-CR-ALTMAN/BRANNON

CaseNo.

18 U.S.C. § 1752(a)(l)
18 U.S.C. § 1001 (a)(2)
UNITED STATES OF A.t'1ERICA,
vs.

YUJING ZHANG,
Defendant.

INDICTMENT
The Grand Jury charges that:
COUNT ONE
Unlawful Entry of Restricted Buildings and Grounds
(18 U.S.C. § 1752(a)(1))
On or about March 30, 2019, in Palm Beach County, in the Southern District of Florida,
the defendant,
YUJING ZHANG,
did knowingly enter and remain, and attempt to enter and remain, in a restricted building and
grounds, that is, the Mar-a-Lago Club and its grounds, without lawful authority to do so, in
violation of Title 18, United States Code, Sections 1752(a)(l) and 2.
COUNT TWO
False Statements
(18 U.S.C. § 1001(a)(2))
On or about March 30, 201 9, in Palm Beach County, in the Southern District of Florida,

in a matter within the jurisdiction of the Department of Homeland Security, United States Secret

1

 Case 9:19-cr-80056-RKA Document 14 Entered on FLSD Docket 04/12/2019 Page 2 of 5

Service, an agency of the executive branch of the Government of the United States, the
defendant,

YUJING ZHANG,
did knowingly and willfully make a materially false, fictitious and fraudulent statement and
representation to a Department of Homeland Security, United States Secret Service Agent, that
is, when asked whether she was authorized to be at the Mar-a-Lago Club and its grounds, the
defendant stated she was there to attend a "United Nations Friendship Event," when in truth and
in fact, and as the defendant then and there well knew, no such event was scheduled at Mar-aLago and its grounds, in violation of Title 18, United States Code, Section l001 (a)(2).
A TRUE BILL.

ASSISTANT UNITED STATES ATTORNEY

C1 '1.c TuL

MICHAELil°:. S-H-E-'R'-"W-=IN=-.- --

- ASSIST ANT UNITED STATES ATTORNEY

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Case 9:19-cr-80056-RKA Document
14 Entered
on FLSD
Docket 04/12/2019 Page 3 of 5
UNITED STATES
DISTRICT
COURT
SOUTHERN DISTRICT OF FLORIDA
UNITED STATES OF AMERICA

CASE NO.

vs.

CERTIFICATE OF TRIAL ATTORNEY*

YUJING ZHANG,
Defendant.
--------------'

Superseding Case Information:

Court Division: (Select One)
Miami
FTL

Key West
WPB
--FTP

New Defendant(s)
Number of New Defendants
Total number of counts

Yes

No

I do hereby certify that:

1.

I have carefully considered the allegations of the indictment, the number of defendants, the number
of probable witnesses and the legal complexities of the Indictment/Information attached hereto.

2.

I am aware that the information supplied on this statement will be relied upon by the Judges of this
Court in setting their calendars and scheduling criminal trials under the mandate of the Speedy Trial
Act, Title 28 U.S.C. Section 3161.

3.

Interpreter:
(Yes or No)
List language and/or dialect

4.

This case will take

5.

Please check appropriate category and type of offense listed below:

5

Yes

ll7lafi'a'a ri n
days for the parties to try.

(Check only one)

I
II
Ill
IV

v

0
6
11
21
61

to 5 days
to 10 days
to 20 days
to 60 days
days and over

(Check only one)

_x_

Petty
Minor
Misdem.
Felony

x

6.
Has this case been previously fifed in this District Court? (Yes or No)
No
If yes:
Judge:
Case No.
(Attach copy of dispositive order)
--------------Has a complaint been filed in this matter?
(Yes or No)
Yes
If yes:
Magistrate Case No.
_19_-_m_._j-_0_8_10_0_-_W_M
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
Related Miscellaneous numbers:
Defendant(s) in federal custody as of
03-30-2019
Defendant(s) in state custody as of
----------------------Rule 20 from the
D1stnct of
Is this a potential death penalty case? (Yes or No)

No

7.

Does this case originate from a matter pending in the Northern Region of the U.S. Attorney's Office
prior to October 14, 2003? _ _ Yes
_x_ No

8.

Does this case originate from a matter pending in the Central Region of the U.S. Attorney's Office
prior to September 1, 2007? _ _ Yes _x_ No

MICHAEL SHERWIN
ASSISTANT UNITED STATES ATTORNEY
Court No. A5501230

'PenaltySheet(s) attached

 Case 9:19-cr-80056-RKA Document 14 Entered on FLSD Docket 04/12/2019 Page 4 of 5

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
PENALTY SHEET

Defendant's Name: YUJING ZHANG

~-"-"-~~~~"""'-'"-~~~~~~~~~~~-

Count#: I
Unlawful Entry of Restricted Buildings and Grounds
Title 18, United States Code, Section l 752(a)(l)

*Max. Penalty: 1 Year Imprisonment; $1,000 Fine; and 1 Year Supervised Release
Count#:2
False Statements
Title 18, United States Code, Section 1001 (a)(2)

*Max. Penalty: 5 Years' Imprisonment; $250,000 Fine; 3 years' Supervised Release
Count#:

*Max. Penalty:
Count#:

*Max. Penalty:

*Refers only to possible term of incarceration, does not include possible fines, restitution,
special assessments, parole terms, or forfeitures that may be applicable.

 Case 9:19-cr-80056-RKA Document 14 Entered on FLSD Docket 04/12/2019 Page 5 of 5

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NUMBER: - - - - - - - - - BOND RECOMMENDATION

DEFENDANT: YUJING ZHANG
Pre-Trial Detention

(Personal Surety) (Corporate Surety) (Cash) (Pre-Trial Detention)

By:

Last Known A d d r e s s : - - - - - - - - - - -

What Facility:

Agent(s):

USSS S/A Samuel lvanovich
(FBI) (SECRET SERVICE) (DEA)

(IRS) (ICE) (OTHER)