ENDORSED XAVIER BECERRA Attorney General of California We PATRICIA M. Fusco Supervising Deputy Attorney General SEP 2019 AMANDA G. PLISNER (SBN 258157) VIKRAM MANDLA (SBN 237101) Superigleurk of ttl?tggurt Deputy Attorneys General By 300 S. Spring Street, Suite 1702 Los Angeles, CA 90013 Telephone: (213) 269?6174 Email: Amanda.Plisner@doj.ca.gov Attorneys for People of the State of California SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA PEOPLE OF THE STATE OF Case No. C1912332 CALIFORNIA, SECOND AMENDED FELONY Plaintiff, COMPLAINT v. Action Filed: June 26, 2019 JING CHIAN HUANG aka ?Lili? SHU MEI LIN aka ?Shelly? 1/62), SHAO LEE aka ?Cindy? (6/16/69), PEIHSIN LEE aka ?Boss Lili? (12/18/57), PENGCHENG CAI aka (12/3/87), DAFENG WEN (10/2/87), Defendants. THE ATTORNEY GENERAL OF THE STATE OF CALIFORNIA accuses the above? named defendants of the following? crimes, which are connected to one another in their commission: COUNT ONE On or between September 26, 2016, and October 13, 2019, in the County of Santa Clara, defendants JING CHIANG HUANG, SHU MEI LIN, and SHAO LEE committed the crime of CONSPIRACY, in Violation of PENAL CODE SECTION 182(a)(l), in that they did unlawfully Second Amended Felony Complaint conspire together, and with other persons whose identity is unknown, to commit the crime of HUMAN TRAFFICKING, in violation of PENAL CODE SECTION 236.1(b) a felony, and that pursuant to and for the purpose of carrying out the objectives and purposes of the aforesaid conspiracy, the said defendants committed the following overt act(s) at and in the County of Santa Clara: OVERT ACT 1 On March 16, 2016, defendant JING CHIANG HUANG transferred $4,500 from her Bank of America account ending 4717 to defendant SHU-MEI Bank of America account ending 0333. OVERT ACT 2 On April 21, 2016, defendant SHAO LEE paid $500 to Backpageeom for advertisements associated with the email cindylee@gmail.com. OVERT ACT 3 On September 26, 2016, defendant SHU MEI LIN traveled from her home in San Jose to meet YL at the Premier Inn. OVERT ACT 4 Defendant JING CHIANG HUANG arranged for the October 7, 2016 activation of a phone that was later provided to YL. OVERT ACT 5 Between October 6, 2016, and October 13, 2016, defendant JING CHIANG HUANG called defendant SHAO LEE at least five times. OVERT ACT 6 Between October 6, 2016, and October 11, 2016, defendant SHAO LEE called defendant JING CHIANG HUANG at least four times. Second Amended Felony Complaint OVERT ACT 7 In October 2016, SHAO LEE used her cindvlee@gmail.com email address to post advertisements featuring photos of young Asian women available to provide ?Incall? in exchange for cash. OVERT ACT 8 On October 8, 2016, defendant SHU MEI LIN called YL and told her she was not free to leave the Premier Inn and would be performing sex act in exchange for money there. OVERT ACT 9 Between October 8, 2016, and October 13, 2016, while YL was at the Premier Inn, defendant JING CHIANG HUANG called YL 6 times. OVERT ACT 10 On October 9, 2016, defendant SHAO LEE called YL and informed her that a customer had arrived to the Premier Inn for her. OVERT ACT 11 On October 13, 2016, defendant SHAO LEE directed a Ventura County Sheriff 3 Detective to Room 118 of the Premier Inn to meet ?Sammy,? later identi?ed as YL. OVERT ACT ?12 On December 30, 2016, defendant JING CHIANG HUANG accompanied defendant SHU MEI LIN to an ATM where defendant SHU MEI LIN deposited $7,160 in cash into her Bank of America account ending in 0333. I OVERT ACT 13 On March 1, 2017, defendant JING CHIANG HUANG provided housing for a commercial sex worker was on ?rest for period.? OVERT ACT 14 On September 29, 2017, JING CHIANG HUANG used her home for a condom unwrapping operation. Second Amended Felony Complaint OVERT ACT 15 In October 2016, defendant SHAO LEE telephonically directed commercial sex buyers to multiple brothel locations. COUNT W0 For a further and separate cause of action, being a different offense from but connected in its commission as the charges set forth in Count One: On or between June 1, 2019, and July 7, 2019, in the County of Santa Clara, defendants JING CHIANG HUANG, PEIHSIN LEE, PENGCHENG CAI, and DAFENG WEN committed the crime of CONSPIRACY, in Violation of PENAL CODE SECTION 182(a)(1), in that they did?unlawfull'y conspire together, and?with other persons whose identity is unknown, to commit the crime of HUMAN TRAFFICKING, in violation of PENAL CODE SECTION 236.1(b) a felony, and that pursuant to and for the purpose of carrying out the objectives and purposes of the aforesaid conspiracy, the said defendants committed the following overt act(s) at and in the County of Santa Clara: OVERT ACT 1 On or between June I, 2019, and June 26, 2019, PENGCHENG CAI directed ZW to work at various brothel locations. OVERT ACT 2 On or between June 1, 2019, and June 26, 2019, PENGCHENG CAI collected money from ZW. OVERT ACT 3 On or between June 1, 2019, and June 26, 2019, PENGCHENG CAI threatened ZW regarding future job opportunities if she stopped working for him. OVERT ACT 4 On or between June 1, 2019, and June 26, 2019, DAFENG WEN directed commercial sex buyers to brothel locations. Second Amended Felony Complaint x1001 OVERT ACT 5 On or between June 1, 2019, and June 26, 2019, DAFENG WEN directed the collection of money earned from commercial sex acts. OVERT ACT 6 On or between June 1, 2019, and June 26, 2019, DAFENG WEN directed the commission of particular sex acts as requested by commercial sex buyers. OVERT ACT 7 On or between June 1, 2019, and June 26, 2019, DAF ENG WEN arranged the distribution of condoms to brothel locations. OVERT ACT 8 On June 26, 2019, JING CHIANG HUANG stored passport at JING CHIANG residence on Clifton. OVERT ACT 9 On July 2, 2019, JING CHIANG HUANG asked PEIHSIN LEE and PENGCHENG CAI to collect debts owed to her. OVERT ACT 10 On July 2, 2019, PENGCHENG CAI told JING CHIAN HUANG he would give her money he collected from four locations. OVERT ACT 11 On July 3, 2019, PEIHSIN LEE told ZW to pay whatever she makes committing commercial sex acts to JING CHIANG HUANG. OVERT ACT 12 On July 7, 2019, JING CHIAN HUANG called PEIHSIN LEE and directed her to have a 3rd party delete pictures of prostitutes on his phone. COUNT THREE For a further and separate cause of action, being a different offense from but connected in its commission as the charges set forth in Count-s? One through-TWO: On or between September Second Amended Felony Complaint 26, 2016, and October 13, 2019, in the County of Santa Clara, defendants JING CHIANG HUANG, SHAO LEE, and SHU MEI LIN committed the crime of HUMAN TRAFFICKING FOR A SEX ACT, a violation of PENAL CODE SECTION a Felony, in that they did willfully and unlawfully deprive and/or Violate the personal liberty of YL with the intent to maintain a violation of PENAL CODE SECTION 266h. COUNT FOUR For a further and separate cause of action, being a different offense from but connected in its commission as the charges set forth in Counts One through Three: On or between June 1, 2019, and July 7, 2019, in the County of Santa Clara, defendant JIN CHIANG HUANG committed the crime of HUMAN TRAFFICKING FOR A SEX ACT, a violation of PENAL CODE SECTION a Felony, in that she did willfully and unlawfully deprive and/or violate the personal liberty of ZW with the intent to maintain a violation of PENAL CODE SECTION 266h. COUNT FIVE For a further and separate cause of action, being a different offense from but connected in its commission as the charges set forth in Counts One through Four: On or between June 1, 2019, and September 10, 2019, in the County of Santa Clara, defendants PEIHSIN LEE and PENGCHENG CAI committed the crime of HUMAN TRAFFICKING FOR A SEX ACT, a violation of PENAL CODE SECTION 236. 1 a Felony, in that they did willfully and unlawfully deprive and/or violate the personal liberty of ZW with the intent to maintain a violation of PENAL CODE SECTION 266h. COUNT SIX For a further and separate cause of action, being a different offense from but connected in its commission as the charges set forth in Counts One through Four: On or between April 15, 2018, and September 10, 2019, in the County of Santa Clara, defendants PENGCHENG CAI and DAFENG WEN committed the crime of HUMAN TRAFFICKING, a violation of PENAL Second Amended Felony Complaint CODE SECTION a Felony, in that they did willfully and unlawfully deprive and/or violate the personal liberty of CW with the intent to obtain forced labor or services. 9' For a further and separate cause of action, being a different offense from but connected in its commission as the charges set forth in Counts One through Five: On or about April 12, 2015, in the county of Santa Clara, defendant JING CHIANG HUANG committed the crime of FILING FALSE TAX RETURN in violation of REVENUE AND TAXATION CODE SECTION 19706, a felony, in that she did willfully and with like intent, make, render, or verify a false or fraudulent return or statement, to wit: 2014 California Resident Income Tax Return. COUNT EIGHT For a farther and separate cause of action, being a different offense from but connected in its commission as the charges set forth in Counts One through Six: On or about April 18, 2016, in the. county of Santa Clara, defendant JING CHIANG HUANG committed the crime of FAILURE TO FILE TAX RETURN in violation of REVENUE AND TAXATION CODE SECTION 19706, a felony, in that she being a person required by law to~f11e a tax return or to supply information, did willfully fail to file a tax return or supply information for the period January 1, 2015, through December 31, 2015, with the intent to evade tax, to wit: 2015 California Resident Income Tax Return. COUNT NINE For a further and separate cause of action, being a different offense from but connected in its commission as the charges set forth in Counts One through Seven: On or about April 18, 2017, in the countyof Santa Clara, defendant JING CHIANG HUANG committed the crime of FAILURE TO FILE TAX RETURN in violation of REVENUE AND TAXATION CODE SECTION 19706, a felony, in that she being a person required by law to file a tax return or to supply information, did willfully fail to ?le a tax return or supply information for the period January 1, 2016, through December 31, 2016, with the intent to evade tax, to wit: 2016 California Resident Income Tax Return. Second Amended Felony Complaint COUNT TEN For a further and separate cause of action, being a different offense from but connected in its commission as the charges set forth in Counts One through Eight: On or between November 25, 2016, and December 1, 2016, in the county of Santa Clara, defendant JING CHIANG HUANG committed the crime of MONEY LAUNDERING in violation of PENAL CODE SECTION a felony, in that she willfully and unlawfully conducted transactions involving monetary instruments of a total value exceeding $5,000, to wit: $8,807.72 deposited into an account at Citibank, NA, knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly from the proceeds of criminal activity. COUNT ELEVEN For a further and separate cause of action, being a different offense from but connected in its commission as the charges set forth in Counts One through Nine: On September 21, 2016, in the county of Santa Clara, defendant SHAO LEE committed the crime of MONEY LAUNDERING in violation of PENAL CODE SECTION a felony, in that she willfully and unlawfully conducted transactions involving monetary instruments of a total value exceeding $25,000, to wit: $55,000 deposited into an account at Wells Fargo Bank, NA, knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly from the proceeds of criminal activity. COUNT TWELVE For a further and separate cause of action, being a different offense from but connected in its commission as the charges set forth in Counts One through Ten: On or between October 3, 2016, and October 6, 2016, in the county of Santa Clara, defendant SHAO LEE committed the crime of MONEY LAUNDERING in violation of PENAL CODE SECTION a felony, in that she willfully and unlawfully conducted transactions involving monetary instruments of a total value exceeding $5,000, to wit: $13,841 deposited into an account at Wells Fargo Bank, N.A., knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly from the proceeds of criminal'activityQ Second Amended Felony Complaint COUNT THIRTEEN For a further and separate cause of action, being a different offense from but connected in its commission as the charges set forth in Counts One through Eleven: On December 30, 2016, in the county of Santa Clara, defendant SHU MEI LIN committed the crime of MONEY LAUNDERING in violation of PENAL CODE SECTION a felony, in that she willfully and unlawfully conducted transactions involving monetary instruments of a total value exceeding $5,000, to wit: $7,160 deposited into an account at Bank of America, NA, knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly from the proceeds of criminal activity. SPECIAL ALLEGATION ONE STATUS EXEMPT FROM LOCAL CUSTODY It is further alleged that prison custody time for the felony offenses charged in counts Three through Five are to be served in state prison pursuant to PENAL CODE SECTION 1170. NOTICE: Conviction of the offenses charged in counts Three through Six will require the charged defendants to register pursuant to Penal Code section 290 et seq. Willful failure to register is a crime. NOTICE: Conviction of these offenses will require the defendant to provide DNA samples and print impressions pursuant to Penal Code section 296 and 296.1. Willful refusal to provide the samples and impressions is a crime. NOTICE: The People of the State of California intend to present evidence and seek jury ?ndings regarding all applicable circumstances in aggravation, pursuant to Penal Code section 1170(b) and Cunningham v. California (2007) 549 US. 270 [127 856, 166 L.Ed.2d 856]. Second Amended Felony Complaint NOTICE: Any allegation making a defendant ineligible to serve a state prison sentence in the county jail shall not be subject to dismissal pursuant to Penal Code section 1385. I declare under the penalty of perjury that the foregoing is true and correct. Executed this lmay of September, 2019, at Santa Clara, California. Respectfully Submitted, XAVIER BECERRA Attorney General of California PATRICIA M. FUSCO Supervising Deputy Attorney General AMANDA G. PLISNER Deputy Attorney General Attorneys for People of the State of California 10 Second Amended Felony Complaint