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Sample Indictment—Conspiracy—Aid and Abet—Involuntary Servitude—Kidnapping—Transporting and Harboring Aliens

UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA February 1995 Grand Jury UNITED STATES OF AMERICA, CR 95-714(A)-ABC Plaintiff, v. F I R S T S U P E R S E D I N G SUNI MANASURANGKUN, I N D I C T M E N T aka "Khun Na," aka "Auntie," [18 U.S.C. § 371: Conspiracy; aka "Na," 18 U.S.C. § 1584: Involuntary WIRACHAI MANASURANGKUN, Servitude; 18 U.S.C. § 1201: aka Hong Wongdee, Kidnapping; aka "Daeng," 8 U.S.C. § 1324(a)(1)(A)(ii): SURACHAI MANASURANGKUN, Transporting Certain Aliens; aka Tavee Uvawas, 8 U.S.C. § 1324(a)(1)(A)(iii): aka "Boi," Harboring Certain Aliens; PHANASAK MANASURANGKUN, 18 U.S.C. § 2: Aiding and aka Thanes Panthong, Abetting] aka "Gi," aka "Noi," SANCHAI MANASURANGKUN, aka Sanchai Pongprapin, aka "San," aka "Sukit," CHAVALIT MANASURANGKUN, aka "Lek," SUNTHON RAWANGCHAISONG, aka "Ton," SERI KANCHAKPHAIRI, RAMPHA SATTHAPRASIT, aka "Pa," and SUPHON WIRAYUTWILAI, aka "Pon," Defendants. _____________________________ The Grand Jury charges: INTRODUCTION Defendants SUNI MANASURANGKUN, aka "Auntie," aka "Khun Na," aka "Na," WIRACHAI MANASURANGKUN, aka Hong Wongdee, aka "Daeng," SURACHAI MANASURANGKUN, aka Tavee Uvawas, aka "Boi," PHANASAK MANASURANGKUN, aka Thanes Panthong, aka "Gi," aka "Noi," SANCHAI MANASURANGKUN, aka Sanchai Pongprapin, aka "San," aka "Sukit," CHAVALIT MANASURANGKUN, aka "Lek," SUNTHON RAWANGCHAISONG, aka "Ton," SERI KANCHAKPHAIRI, RAMPHA SATTHAPRASIT, aka "Pa," and SUPHON WIRAYUTWILAI, aka "Pon," ("defendants") were responsible for operating garment making enterprises known at various times from the late 1980's to the present as SK Fashion, S & P Fashion, Pat Fashion, Alex, D & R Fashion, and other names ("SK Fashion"). A basic operating principle of SK Fashion was to profit from the manufacture of garments, using sweatshop labor performed by a captive work force. From in or about April, 1989 until in or about August, 1993 the defendants used the rental units located at 2614 Santa Anita Avenue, El Monte, California as a labor compound ("El Monte labor compound") and held their workers at that location. There are seven units at this location and the property is surrounded by a perimeter wall. The only exit, in the front of the labor compound, is blocked by a mechanical gate. From in or about August, 1993 until in or about December, 1993, the defendants relocated their operation from the El Monte labor compound to a warehouse at an unknown location ("warehouse compound") and held their workers at this warehouse compound. From in or about December, 1993 until on or about August 2, 1995, the defendants returned to the El Monte labor compound and held their workers at that location. The defendants operated additional sites, where they used additional labor, and which were used as shipping points for their goods, and as fronts for the El Monte labor compound. From in or about July, 1992 until on or about August 2, 1995, two such fronts were located at or near 1319 W. 12th Place and 1314 West 12th Street, Los Angeles, California ("12th Street locations" or "downtown factory"). At all times relevant to this indictment, the defendants would recruit numerous laborers from Thailand ("Thai laborers" or "Thai aliens" or "Thai workers") to fulfill their work force requirements. At times the defendants obtained approximately seventy Thai laborers to use for their enterprise. These Thai laborers were predominantly women who came from impoverished backgrounds and had little education. The defendants fraudulently tricked these Thai laborers into becoming part of defendants' captive work force, brought them to the United States illegally, then held these Thai workers as slaves at the El Monte labor compound and elsewhere. COUNT ONE [18 U.S.C § 371] OBJECTS OF THE CONSPIRACY Beginning on a date unknown to the Grand Jury but no later than in or about April, 1989, and continuing until on or about August 2, 1995, in Los Angeles County, within the Central District of California and elsewhere, defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, SUNTHON RAWANGCHAISONG, SERI KANCHAKPHAIRI, RAMPHA SATTHAPRASIT, SUPHON WIRAYUTWILAI, and others known and unknown to the Grand Jury, conspired and agreed with each other to commit offenses against the United States, namely: to willfully hold numerous Thai laborers in a condition of involuntary servitude, in violation of Title 18, United States Code, Section 1584; to unlawfully kidnap, inveigle, decoy, seize, and confine numerous Thai laborers, and hold them for the purpose of using them as a work force, the defendants willfully transporting such laborers in interstate and foreign commerce, in violation of Title 18, United States Code, Section 1201(a)(1); to knowingly induce numerous illegal aliens to enter the United States to work for them, in violation of Title 8, United States Code, Section 1324(a)(1)(A)(iv); to knowingly transport numerous illegal aliens to the El Monte labor compound and other labor sites within the United States to work for them, in violation of Title 8, United States Code, Section 1324(a)(1)(A)(ii); and to harbor numerous illegal aliens in the El Monte labor compound and other labor sites, in violation of Title 8, United States Code, Section 1324(a)(1)(A)(iii). PLAN AND PURPOSE OF THE CONSPIRACY It was the plan and purpose of the defendants' conspiracy to knowingly and willfully trick the Thai laborers into accepting employment by misrepresenting to them the basic terms of their work and living conditions. It was further the plan and purpose of the defendants' conspiracy to illegally transport the Thai aliens from Thailand to the defendants' labor sites within the United States. At the El Monte labor compound and elsewhere, it was further the plan and purpose of the defendants' conspiracy to hold the Thai laborers to a condition of involuntary servitude. The defendants compelled such involuntary servitude by subjecting the Thai laborers to an unlawful debt which the defendants created through fraud, by threatening harm to the Thai laborers and their families if they tried to escape, and by physically confining and isolating the Thai laborers inside the El Monte labor compound and elsewhere in conditions designed to eliminate all resistance to such servitude. MEANS OF THE CONSPIRACY The objects and plan of the conspiracy were to be accomplished, in substance, as follows: Defendants WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, SANCHAI MANASURANGKUN, SUPHON WIRAYUTWILAI and others known and unknown to the Grand Jury would recruit laborers in Thailand. They would trick these Thai laborers into accepting employment from them by misrepresenting to the workers the basic terms of their employment and conditions of their lives in the United States, including deceiving the workers about their wages, their hours of work, the severe restrictions on their freedom which the defendants intended to place on them, the defendants' intention to confiscate their travel documents, and the defendants' intention to restrict free communications with their families. Defendants WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, SANCHAI MANASURANGKUN, SUPHON WIRAYUTWILAI and others known and unknown to the Grand Jury would, by fraud and deceit, induce the Thai laborers to take on an unlawful debt, intending that later such debt be used as leverage to hold them against their will. Defendant SANCHAI MANASURANGKUN and others known and unknown to the Grand Jury would provide certain of the Thai workers with fraudulent passports, tourist visas, plane tickets, jewelry, and "show money" to aid them in smuggling the Thai aliens to the United States in violation of law. Defendant SANCHAI MANASURANGKUN and others known and unknown to the Grand Jury would arrange for a tour group to accompany the Thai laborers until they were delivered to the United States. Defendants SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, SUPHON WIRAYUTWILAI and others known and unknown to the Grand Jury would apprehend the Thai aliens at Los Angeles International Airport ("LAX"). Defendants SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, SUPHON WIRAYUTWILAI and others known and unknown to the Grand Jury would transport the Thai aliens from LAX to the El Monte labor compound or the warehouse compound. Upon the delivery of the Thai workers to the El Monte labor compound or the warehouse compound, defendants SUNI MANASURANGKUN and PHANASAK MANASURANGKUN would confiscate the passports the workers were holding and take back the show money from them. Upon the delivery of the Thai workers to the El Monte labor compound, defendant SUNI MANASURANGKUN would assign the Thai laborers to their work and sleeping units within the compound. Defendants SUNI MANASURANGKUN and SANCHAI MANASURANGKUN would then dictate to them the rules of work and confinement, including directing the Thai laborers that they were not free to leave the El Monte labor compound. The rules also included restrictions on the workers' movement and communications even within the El Monte labor compound. Defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, SUNTHON RAWANGCHAISONG, SERI KANCHAKPHAIRI, RAMPHA SATTHAPRASIT, SUPHON WIRAYUTWILAI and others known and unknown to the Grand Jury, aiding and abetting each other, would act as overseers, forcing the Thai laborers to work at the El Monte labor compound, the downtown factory, and the warehouse compound for up to twenty hours a day with few breaks. The defendants would pay only meager wages for this labor, much of which would be subtracted to pay the unlawful debt demanded by the defendants. Defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, SUNTHON RAWANGCHAISONG, SERI KANCHAKPHAIRI, RAMPHA SATTHAPRASIT, and SUPHON WIRAYUTWILAI, aiding and abetting each other, would subject the Thai laborers to poor and crowded living conditions and to unsafe work conditions. Defendant RAMPHA SATTHAPRASIT operated a commissary within the El Monte labor compound at which she would charge the Thai laborers inflated prices for food and other products. Before full-time guards were hired, defendants WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, and CHAVALIT MANASURANGKUN, aiding and abetting each other, would watch the Thai workers to intimidate and deter the Thai workers from attempting to escape from the oppressive conditions at the El Monte labor compound. Defendants SUNTHON RAWANGCHAISONG and SERI KANCHAKPHAIRI would act as full-time guards, watching the Thai workers, and intimidating and deterring the Thai workers from attempting to escape from the oppressive conditions at El Monte labor compound. Defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, SUNTHON RAWANGCHAISONG, SERI KANCHAKPHAIRI, and RAMPHA SATTHAPRASIT, while aiding and abetting each other, would direct physical threats at both the Thai laborers and their families in Thailand to further scare the Thai workers from attempting to escape from the El Monte labor compound. The defendants and others known to the Grand Jury would erect and direct others to erect physical barriers to prevent the workers from escaping from the El Monte labor compound, including boarding the windows in the Thai workers' units, barricading some of the doors to the workers' quarters, raising the perimeter wall by adding a spiked iron fence, stringing barbed wire around the compound, and installing coils of razor wire around much of the compound perimeter. Defendants SUNI MANASURANGKUN, PHANASAK MANASURANGKUN, RAMPHA SATTHAPRASIT and others known and unknown to the Grand Jury would censor and monitor mail and telephone communications to and from the Thai laborers to further isolate them from the outside world and to prevent them from getting help, as well as to aid the defendants in tricking future Thai laborers into coming to the El Monte labor compound. OVERT ACTS In furtherance of the conspiracy, and to accomplish the objects of the conspiracy, defendants and others known and unknown to the Grand Jury committed various overt acts, in Los Angeles County, within the Central District of California and elsewhere, including but not limited to the following: In or about the summer of 1992, defendant SANCHAI MANASURANGKUN recruited Sompith Sinsurient as a laborer in Thailand, deceiving her about the basic conditions of her life and work in the United States. In or about the summer of 1992, Defendant SANCHAI MANASURANGKUN fraudulently imposed an unlawful debt on Sompith Sinsurient, intending that such debt later be used as leverage to hold her against her will. In or about August, 1992, in Thailand, defendant SANCHAI MANASURANGKUN summoned Sompith Sinsurient to an apartment. She was then accompanied to the airport by three men and put on a plane to the United States. In or about August, 1992, defendants PHANASAK MANASURANGKUN and SUPHON WIRAYUTWILAI transported Sompith Sinsurient and other Thai laborers from LAX directly to the El Monte labor compound. In or about August, 1992, defendant SUNI MANASURANGKUN confiscated the passport and show money from Sompith Sinsurient. In or about August, 1992, defendant SUNI MANASURANGKUN forbade Sompith Sinsurient from freely leaving the El Monte labor compound and freely leaving her quarters within the compound. From in or about August, 1992 until on or about August 2, 1995, defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, SUNTHON RAWANGCHAISONG, SERI KANCHAKPHAIRI, RAMPHA SATTHAPRASIT, SUPHON WIRAYUTWILAI, and others known and unknown to the Grand Jury, while aiding and abetting each other, acted as overseers, imposing oppressive hours, meager pay, and poor working conditions on Sompith Sinsurient and other workers at the El Monte labor compound, the warehouse compound, and the downtown factory. From in or about August, 1992 until in or about 1993, defendants WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SUPHON WIRAYUTWILAI, and RAMPHA SATTHAPRASIT loaded Sompith Sinsurient and other Thai workers into the back of a truck, took them to the market, and guarded and watched them while they were there. From in or about August, 1993 until in or about December, 1993, defendant SUNI MANASURANGKUN ordered that Sompith Sinsurient and the other Thai workers be forcibly and instantly relocated from the El Monte labor compound to the warehouse compound. From in or about August, 1993 until in or about December, 1993, defendants SUNI MANASURANGKUN, SUNTHON RAWANGCHAISONG, RAMPHA SATTHAPRASIT, and others known and unknown to the Grand Jury watched over Sompith Sinsurient to prohibit Sompith Sinsurient from freely leaving the warehouse compound. Between in or about August, 1992 and on or about August 2, 1995, defendants SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, and CHAVALIT MANASURANGKUN, while aiding and abetting each other, threatened harm to Sompith Sinsurient and her family if she tried to escape. From in or about 1993 until on or about August 2, 1995, defendant SUNTHON RAWANGCHAISONG served as a full-time guard to prevent Sompith Sinsurient and other Thai workers from attempting to escape from the El Monte labor compound and the warehouse compound. From in or about April, 1994 until on or about August 2, 1995, defendant SERI KANCHAKPHAIRI served as a full-time guard to enforce a curfew and prevent Sompith Sinsurient and other Thai workers from attempting to escape from the El Monte labor compound. From in or about 1994 until on or about August 2, 1995, defendant RAMPHA SATTHAPRASIT operated a commissary at which she charged Sompith Sinsurient and other Thai workers inflated prices for food and other products. From in or about August, 1992 until on or about August 2, 1995, defendants SUNI MANASURANGKUN, RAMPHA SATTHAPRASIT, and others unknown to the Grand Jury censored the mail and monitored the telephone conversations of Sompith Sinsurient. Between in or about 1994 and on or about August 2, 1995, the exact date being unknown to the Grand Jury, defendant SUNTHON RAWANGCHAISONG and others known and unknown to the Grand Jury put up coils of razor wire around the perimeter of the El Monte labor compound to prevent the Thai workers from escaping. Between in or about 1993 and on or about August 2, 1995, the exact date being unknown to the Grand Jury, defendants WIRACHAI MANASURANGKUN and SURACHAI MANASURANGKUN threatened Sunguam Watanapong and Sompong Somupued at the 12th Street factory by showing them a photograph of a former Thai laborer who had been beaten, and telling them that they and other Thai laborers would also be beaten if they tried to escape. Between in or about December, 1993 and on or about August 2, 1995, the exact date being unknown to the Grand Jury, defendant SUNTHON RAWANGCHAISONG threatened Sunguam Watanapong by stating that if she tried to escape or disobeyed the curfew that Mexicans or other Americans would rape her. Between in or about January, 1993 and in or about June, 1994, the exact date being unknown to the Grand Jury, defendant CHAVALIT MANASURANGKUN threatened to burn down the home of Wannippha Srichaichanu in Thailand if she tried to escape from the defendants. In or about the spring of 1991, defendant SUPHON WIRAYUTWILAI recruited Wittiphonsak Wuttibunphonsak as a laborer in Thailand, deceiving him about the basic conditions of his life and work in the United States. In or about the spring of 1991, Defendant SUPHON WIRAYUTWILAI fraudulently imposed an unlawful debt on Wittiphonsak Wuttibunphonsak, intending that such debt later be used as leverage to hold him against his will. In or about May, 1991, defendant SUPHON WIRAYUTWILAI accompanied Wittiphonsak Wuttibunphonsak and other Thai laborers she had recruited on a plane to the United States. In or about May, 1991, defendants PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, and SUPHON WIRAYUTWILAI transported Wittiphonsak Wuttibunphonsak and other Thai laborers from LAX directly to the El Monte labor compound. In or about May, 1991, defendant PHANASAK MANASURANGKUN confiscated the passport and Thai identification card of Wittiphonsak Wuttibunphonsak and brought him to defendant SUNI MANASURANGKUN. In or about May, 1991, defendants SUNI MANASURANGKUN and SANCHAI MANASURANGKUN, while aiding and abetting each other, forbade Wittiphonsak Wuttibunphonsak from leaving the El Monte labor compound freely and unescorted. From in or about May, 1991 until on or about August 2, 1995 defendants SUNI MANASURANGKUN, SURACHAI MANASURANGKUN, RAMPHA SATTHAPRASIT, WIRACHAI MANASURANGKUN, SERI KANCHAKPHAIRI, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN and others known and unknown to the Grand Jury, while aiding and abetting each other, acted as overseers, imposing oppressive hours, meager pay, and poor working conditions on Wittiphonsak Wuttibunphonsak at the El Monte labor compound. From in or about 1994 until on or about August 2, 1995, defendant RAMPHA SATTHAPRASIT managed a commissary in the El Monte labor compound and charged Wittiphonsak Wuttibunphonsak and the other Thai workers inflated prices for food and other items. From in or about May, 1991 until on or about August 2, 1995 defendant SUNI MANASURANGKUN denied Wittiphonsak Wuttibunphonsak access to proper dental care, compelling him to pull his own teeth. From in or about May, 1991 until in or about 1993, before full-time guards were hired, defendants WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, and CHAVALIT MANASURANGKUN, while aiding and abetting each other, guarded Wittiphonsak Wuttibunphonsak at the El Monte labor camp to prevent him from trying to escape. From in or about May, 1991 until in or about 1993, defendants WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, and RAMPHA SATTHAPRASIT, while aiding and abetting each other, threatened to physical harm Wittiphonsak Wuttibunphonsak and his relatives in Thailand if he attempted to escape from the El Monte labor compound. From in or about 1993 until on or about August 2, 1995, defendant SUNTHON RAWANGCHAISONG served as a full-time guard to prevent Wittiphonsak Wuttibunphonsak and other Thai workers from attempting to escape from the El Monte labor compound. From in or about April, 1994 until on or about August 2, 1995, defendant SERI KANCHAKPHAIRI served as a full-time guard to enforce a curfew and prevent Wittiphonsak Wuttibunphonsak and other Thai workers from attempting to escape from the El Monte labor compound. COUNT TWO [18 U.S.C. § 1584; 18 U.S.C. § 2] Beginning in or about August, 1992 until on or about August 2, 1995 in Los Angeles County, within the Central District of California, defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, SUNTHON RAWANGCHAISONG, SERI KANCHAKPHAIRI, RAMPHA SATTHAPRASIT, and SUPHON WIRAYUTWILAI, while aiding and abetting each other, did knowingly and willfully hold Sompith Sinsurient to a condition of involuntary servitude for a term. COUNT THREE [18 U.S.C. § 1584; 18 U.S.C. § 2] Beginning in or about August, 1992 until on or about August 2, 1995 in Los Angeles County, within the Central District of California, defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, SUNTHON RAWANGCHAISONG, SERI KANCHAKPHAIRI, RAMPHA SATTHAPRASIT, and SUPHON WIRAYUTWILAI, while aiding and abetting each other, did knowingly and willfully hold Sawieng Singsathith to a condition of involuntary servitude for a term. COUNT FOUR [18 U.S.C. § 1584; 18 U.S.C. § 2] Beginning in or about May, 1991 until on or about August 2, 1995 in Los Angeles County, within the Central District of California, defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, SUNTHON RAWANGCHAISONG, SERI KANCHAKPHAIRI, RAMPHA SATTHAPRASIT, and SUPHON WIRAYUTWILAI, while aiding and abetting each other, did knowingly and willfully hold Wutthiphonsak Wutthibunphonsak to a condition of involuntary servitude for a term. COUNT FIVE [18 U.S.C. § 1584; 18 U.S.C. § 2] Beginning in or about April, 1993 until on or about August 2, 1995 in Los Angeles County, within the Central District of California, defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, SUNTHON RAWANGCHAISONG, SERI KANCHAKPHAIRI, RAMPHA SATTHAPRASIT, and SUPHON WIRAYUTWILAI, while aiding and abetting each other, did knowingly and willfully hold Chunpen Nunree to a condition of involuntary servitude for a term. COUNT SIX [18 U.S.C. § 1584; 18 U.S.C.§ 2] Beginning in or about February, 1991 until in or about February, 1994 in Los Angeles County, within the Central District of California, defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, SUNTHON RAWANGCHAISONG, RAMPHA SATTHAPRASIT, and SUPHON WIRAYUTWILAI, while aiding and abetting each other, did knowingly and willfully hold Rung Thiwa to a condition of involuntary servitude for a term. COUNT SEVEN [18 U.S.C. § 1584; 18 U.S.C. § 2] Beginning in or about April, 1992 until in or about February, 1994 in Los Angeles County, within the Central District of California, defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, SUNTHON RAWANGCHAISONG, RAMPHA SATTHAPRASIT, and SUPHON WIRAYUTWILAI, while aiding and abetting each other, did knowingly and willfully hold Nittaya Soikhoksoong to a condition of involuntary servitude for a term. COUNT EIGHT [18 U.S.C. § 1584; 18 U.S.C. § 2] Beginning in or about September, 1991 until in or about April, 1993 in Los Angeles County, within the Central District of California, defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, RAMPHA SATTHAPRASIT, and SUPHON WIRAYUTWILAI, while aiding and abetting each other, did knowingly and willfully hold Phatcharee Tomsari to a condition of involuntary servitude for a term. COUNT NINE [18 U.S.C. § 1201(a)(1); 18 U.S.C. § 2] From in or about August, 1992 until on or about August 2, 1995, in Los Angeles County, within the Central District of California, and elsewhere, defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, SUNTHON RAWANGCHAISONG, SERI KANCHAKPHAIRI, RAMPHA SATTHAPRASIT, and SUPHON WIRAYUTWILAI, while aiding and abetting each other, did unlawfully inveigle, decoy, seize, confine, kidnap, abduct, and carry away Sompith Sinsurient and held her in order to use her as a laborer, and the defendants willfully transported Sompith Sinsurient in interstate and foreign commerce from Thailand to the United States. COUNT TEN [18 U.S.C. § 1201(a)(1); 18 U.S.C. § 2] From in or about August, 1992 until on or about August 2, 1995, in Los Angeles County, within the Central District of California, and elsewhere, defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, SUNTHON RAWANGCHAISONG, SERI KANCHAKPHAIRI, RAMPHA SATTHAPRASIT, and SUPHON WIRAYUTWILAI, while aiding and abetting each other, did unlawfully inveigle, decoy, seize, confine, kidnap, abduct, and carry away Sawieng Singsathith and held her in order to use her as a laborer, and the defendants willfully transported Sawieng Singsathith in interstate and foreign commerce from Thailand to the United States. COUNT ELEVEN [18 U.S.C. § 1201(a)(1); 18 U.S.C. § 2] From in or about May, 1991 until on or about August 2, 1995, in Los Angeles County, within the Central District of California, and elsewhere, defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, SUNTHON RAWANGCHAISONG, SERI KANCHAKPHAIRI, RAMPHA SATTHAPRASIT, and SUPHON WIRAYUTWILAI, while aiding and abetting each other, did unlawfully inveigle, decoy, seize, confine, kidnap, abduct, and carry away Wutthiphonsak Wutthibunphonsak and held him in order to use him as a laborer, and the defendants willfully transported Wutthiphonsak Wutthibunphonsak in interstate and foreign commerce from Thailand to the United States. COUNT TWELVE [18 U.S.C. § 1201(a)(1); 18 U.S.C. § 2] From in or about April, 1993 until on or about August 2, 1995, in Los Angeles County, within the Central District of California, and elsewhere, defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, SUNTHON RAWANGCHAISONG, SERI KANCHAKPHAIRI, RAMPHA SATTHAPRASIT, and SUPHON WIRAYUTWILAI, while aiding and abetting each other, did unlawfully inveigle, decoy, seize, confine, kidnap, abduct, and carry away Chunpen Nunree and held her in order to use her as a laborer, and the defendants willfully transported Chunpen Nunree in interstate and foreign commerce from Thailand to the United States. COUNT THIRTEEN [18 U.S.C. § 1201(a)(1); 18 U.S.C. § 2] From in or about February, 1991 until in or about February, 1994, in Los Angeles County, within the Central District of California, and elsewhere, defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, SUNTHON RAWANGCHAISONG, RAMPHA SATTHAPRASIT, and SUPHON WIRAYUTWILAI, while aiding and abetting each other, did unlawfully inveigle, decoy, seize, confine, kidnap, abduct, and carry away Rung Thiwa and held her in order to use her as a laborer, and the defendants willfully transported Rung Thiwa in interstate and foreign commerce from Thailand to the United States. COUNT FOURTEEN [18 U.S.C. § 1201(a)(1); 18 U.S.C. § 2] From in or about April, 1992 until in or about February, 1994, in Los Angeles County, within the Central District of California, and elsewhere, defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, SUNTHON RAWANGCHAISONG, RAMPHA SATTHAPRASIT, and SUPHON WIRAYUTWILAI, while aiding and abetting each other, did unlawfully inveigle, decoy, seize, confine, kidnap, abduct, and carry away Nittaya Soikhoksoong and held her in order to use her as a laborer, and the defendants willfully transported Nittaya Soikhoksoong in interstate and foreign commerce from Thailand to the United States. COUNT FIFTEEN [18 U.S.C. § 1201(a)(1); 18 U.S.C. § 2] From in or about September, 1991 until in or about April, 1993, in Los Angeles County, within the Central District of California, and elsewhere, defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, RAMPHA SATTHAPRASIT, and SUPHON WIRAYUTWILAI, while aiding and abetting each other, did unlawfully inveigle, decoy, seize, confine, kidnap, abduct, and carry away Phatcharee Tomsari and held her in order to use her as a laborer, and the defendants willfully transported Phatcharee Tomsari in interstate and foreign commerce from Thailand to the United States. COUNTS SIXTEEN TO TWENTY-TWO [8 U.S.C. § 1324(a)(1)(A)(ii); 18 U.S.C. § 2] Between on or about November 10, 1990, and on or about August 2, 1995, the applicable dates being listed below, in Los Angeles County, within the Central District of California, the applicable defendants, as listed below, while aiding and abetting each other, knowingly and in reckless disregard of the fact that the Thai laborers listed below had come to, entered, and remained in the United States in violation of law, knowingly transported and moved those aliens within the United States, in furtherance of such violation of law, namely by transporting the Thai laborers from LAX to the El Monte labor compound: COUNT DEFENDANT(S) VICTIM DATE (IN OR ABOUT) 16. PHANASAK MANASURANGKUN, SUPHON WIRAYUTWILAI Sompith Sinsurient August, 1992 17. PHANASAK MANASURANGKUN, SUPHON WIRAYUTWILAI Sawieng Singsathith August, 1992 18. PHANASAK MANASURANGKUN, SUPHON WIRAYUTWILAI, CHAVALIT MANASURANGKUN, SANCHAI MANASURANGKUN Wutthiphonsak Wutthibunphonsak May, 1991 19. PHANASAK MANASURANGKUN, SUPHON WIRAYUTWILAI Chunpen Nunree April, 1993 20. PHANASAK MANASURANGKUN, SUPHON WIRAYUTWILAI Rung Thiwa February, 1991 21. PHANASAK MANASURANGKUN, SUPHON WIRAYUTWILAI Nittaya Soikhoksoong April, 1992 22. PHANASAK MANASURANGKUN, SUPHON WIRAYUTWILAI Phatcharee Tomsari September 1991 COUNT TWENTY-THREE [8 U.S.C. § 1324(a)(1)(A)(iii), 18 U.S.C. § 2] On or about August 1, 1995, in Los Angeles County, within the Central District of California, defendants SUNI MANASURANGKUN, WIRACHAI MANASURANGKUN, SURACHAI MANASURANGKUN, PHANASAK MANASURANGKUN, SANCHAI MANASURANGKUN, CHAVALIT MANASURANGKUN, SUNTHON RAWANGCHAISONG, SERI KANCHAKPHAIRI, RAMPHA SATTHAPRASIT, and SUPHON WIRAYUTWILAI, while aiding and abetting each other, knowingly and in reckless disregard of the fact that Thai laborers Sompith Sinsurient, Sawieng Singsathith, Wutthiphonsak Wutthibunphonsak, Chunpen Nunree, Sunguam Watanapong, Sompong Somupued, and approximately sixty-five (65) others, had come to, entered, and remained in the United States in violation of law, knowingly concealed, harbored and shielded these people from detection. A TRUE BILL _____________________________ Foreperson NORA M. MANELLA United States Attorney RICHARD E. DROOYAN Assistant United States Attorney Chief, Criminal Division DEVAL L. PATRICK Assistant Attorney General Civil Rights Division RICHARD W. ROBERTS Chief, Criminal Section Civil Rights Division [cited in Civil Rights Resource Manual 60]