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SUPREME COURT OF THE STATE OF NEW YORK ‘COUNTY OF NEW YORK IN THE MATTER OF AN APPLICATION FOR A WARRANT TO SEARCH A PARTIALLY LOCKED DESK TOWARDS THE REAR OF THE FIRST FLOOR OF 1179 EASTERN PARKWAY BROOKLYN, NEW YORK AFFIDAVIT IN SUPPORT OF SEARCH WARRANT Special Agent Peter Giannakos, shield #1984 being duly sworn, deposes and says: 1. Tama federal agent assigned to the Documents and Benefit Fraud Task Force of the ‘United States Department of Homeland Security’s Homeland Security Investigations (HSI), I have been deputized with the Manhattan District Attomey's Office and as such I'am a public setvant of the kind specified in §CPL 690.05(1). Ihave been an agent for approximately five years, and was a police officer with the New York City Police Department for approximately 19 months. I have participated in the exeeution of more than ten search warrants in the course of my career. 2. This affidavit is submitted in support of an application for a warrant to search a pautially locked desk towards the rear of the first floor of 1179 Hastern Parkway, Brooklyn New York where there is reasonable cause to believe that property, proceeds, end evidence of the commission of the below crimes, among others, and an attempt and conspiracy to commit the below crimes, may be found: © Grand Larceny (PLL. §155.30 et. seq.) © Scheme to Deftaud (P.L. §190.65 et. seq:) © Falsifying Business Records (P-L. §175.10) 3. ‘The information contained in this affidavit is based upon interviews with witnesses, reviews of witnesses” statements or reports by others who conducted interviews, my conversations with other law enforcement officials, my review of documents related to this investigation, personal observations ot reports of observations of other law enforcement officials, and inferences | have drawn from this information. It does not, however, include all of the information known to me with respect to this investigation, but only the information that is necessary 10 establish the requisite probable cause. 4, The property, proceeds, and evidence of the commission of, participation in, or involvement in the above crimes thai may be found in a partially locked desk towards the rear of ‘the first floor of 1179 Eastern Parkway, Brooklyn New York, includes, but is not limited to: a, Forms, materials, notes, records photographs and documents whether contained on paper in handwritten, typed, photocopied, or printed form, or within computer storage media, including, but not limited to, laptop ot desktop computers, tablets, hard drives, USB devices, flash cards and drives, magnetic tape, CD ROMS, disks, diskettes, photo-optical devices, ot handheld computer devices, or any other medium, of or related to immigration applications and other immigration documents; b. Correspondence, inventories, calendars, journals, messages, memoranda, appoiittment books and other documents regarding clients’ immigration. ca All laptop computers, and computer tablets; all computer storage media, including, but not limited to, hard drives, USB devices, flash cards and drives, magnetic tape, CD. ROMs, disks, diskettes, photo-optical devices, or handheld computer devices; and all accessori¢s, hardware, software, and other equipment or devices used in conjunction with the above-described computers and computer storage media; 4 United States currency, money orders, bank checks, personal checks, financial records of all types, stored in both tangible and electronic form, including but not limited to account statements, deposit slips, checks and correspondence; e Evidence of ownership and use of THE TARGET PREMISES, including, but not limited to, mail, keys, telephone bills, bank statements, leases, deeds, rent receipts identification bearing the name or photograph of any person, telephone books, address books, date books, calendars, and personal papers, whether these items are in THE TARGET PREMISES or in the above-described computers, camputer storage media, or electronic communication equipment, 5, With respect to the stored electronic communications, data, information and irnages contained in computers, computer storage media, electronic communication equipment, and other data storage devices and media described above, it is also requested that this Court grant permission to search and retrieve the above-described communications, data, information, and images, and to print them or otherwise reproduce them by converting them or copying them into storage in another device. 6 It is specifically requested that the search warrant authorize the seizure and removal of any and all computers, computer storage media, electronic communication equipment, other data storage devices and media described above, and any related accessories, hardware, and. software for off-site searching. Based upon my training and experience, the examination of such devices can be a time-consuming process due to the constantly changing universe of technologies, models, operation systems, and types of content stored. Because of the volume of evidence and technical requirements of forensic examination, I am aware that searching and seizing information from such devices often requires police officers to seize most orall such devices along with related peripherals and software to be searched later by a qualified person in a laboratory or other controlled environment. 7, Ik is aiso requested that the warrant be deemed executed once any computers, computer storage media, electronic communication equipment, and other data storage devices and media have been seized, and that further analysis of these items be permitted at any time thereafter. 8. Asset forth below, there is reasonable cause to believe the above-described property hs been used, was possessed for the purpose of being used, and is still being used to commit or conceal the commission of an offense, and the above-described property constitutes evidence or tends to demonstrate that an offense was committed or that a particular person participated in the commission of an offense. 9. Tam the case agent investigating the actions of Owolabi Salis, an immigration attomey who operates from offices from 1179 Eastem Parkway in Kings County and 65 Broadway Suite $33 in New York County. On July 24, 2014, Owolabi Salis was arrested pursuant to an arrest warrant issued by the Supreme Court of the State of New York. On July 24, 2014, two search warrants were executed pursuant to this arrest. One warrant was executed at 1179 Eastetn Parkway. 1" and 2™ Floors in Kings County and another warrant was executed at 65 Broadway Suite 833 in New York County. The Search Warrants were issued by The Honorable ‘Thomas Farber on July 16, 2014 and ace hereby incorporated by reference as Exhibit AL 10, Tam informed by Spevial Agent Matthew Maguire of the United States Department of State, who is assisting with the execution of the search warrant at 1179 Eastern Parkway along with Investigators from the District Attorney's Office as well as other federal that there is a partially locked desk towards the rear of the first floor. ‘The desk consists of 1 unlocked drawer which when removed shows the contents of the locked drawer below, as. ‘well as three locked drawers, two on the right and gne on the left. Special Agent Maquire and others in the team are currently at the location awaiting authorization to search and seize the contents of this partially locked desk. WHEREFORE, deponent respectfully requests that the Court issue a warrant and order of seizure in ‘the form annexed (i) authorizing a search of the locked desk on the first floor of 1179 Eastem Parkway in Kings County, for the above-described property, and (ii) directing that if such evidence is found, it be brought before the Court, Itis also requested thet the Court authorize Iaw enforcement to, conduct the search in the ‘manners specifically requested in this affidavit. No previous application has been made in this matter to any other Judge, Justice, or Magistrate. “The People request that the application in this matter and any record made or testimony given be seiled, except for one copy upon the request of the New York County District Attorney's Office. ‘Special Agent Peter Giannakos Rosemary Yu APPROVED: Assistant District Attomey ‘Swom to before me this Judge of the Supreme Court SUPREME COURT OF THE STATE OF NEW YORK, COUNTY OF NEW YORK. IN THE NAME OF THE PEOPLE OF THE STATE OF NEW YORK TO ANY POLICE OFFICER IN THE CITY OF NEW YORK Proof by affidavit having been made this day before me by Special Agent Peter Giennakos, Shield 1984 of the Documents and Benefit Fraud Task Force of the United States Department of Homeland Security’s Homeland Security Investigations (HSI) that there is reasonable cause to believe that certain property, to wit: 2, — Fortns, materials, notes, records photographs and documents whether contained on paper in handwritten, typed, photocopied, or printed form, or within ‘computer storage media, including, but not limited to, laptop or desktop computers, tablets, hard drives, USB devices, flash cards and drives, magnetic tape, CD ROMs, disks, diskettes, photo-optical devices, or handheld computer devices, or any other medium, of or related to immigration applications and other immigration documents; b. Correspondence, inventories, calendars, journals, messages, memoranda, appointment books and other documents regarding clients’ immigration proceedings; All laptop computers and computer tablets; all computer storage media, fncluding, but act limited te, bard drives, USB devices, ach cards and dives, magnetic tape, CD ROMs, disks, diskettes, photo-optical devices, or handheld ‘computer devices; and all accessories, hardware, software, and other equipment or devices used in conjunction with the above-described computers and computer storage media; d, United States currency, money orders, bank checks, personal checks, financial records of all types, stored in both tangible and electronic form, including ut not limited to account statements, deposit slips, checks and correspondence; ©. Evidence of ownership and use of THE TARGET PREMISES, including, but not limited to, mail, keys, telephone bills, bank statements, leases, deeds, rent receipts identification bearing the name o photograph of any person, telephone books, address books, date books, calendars, and personal papers, whether these items are in THE TARGET PREMISES or in the above-described computers, computet storage media, or electronic cammunication equipment may be found in a partially locked desk towards the rear of the first floor of 1179 EASTERN PARKWAY BROOKLYN, NEW YORK, and that there is reasonable cause to believe that the above-described property constitutes evidence and tends fo demonstrate that an offense was committed, that a particular person participated in the commission of an offense, and that the above- described property has been used, or was possessed for the purpose of being used, to commit or conceal the commission of an offense. ‘YOU ARE THEREFORE COMMANDED, between 6:00 am, and 9:00 p.m, to enter and to search a partially locked desk towards the rear of the first floor of 1179 EASTERN PARKWAY, BROOKLYN, NEW YORK for the above-described property, and if you find such property ot any paxt thereof; to bring it before the Court without unnecessary delay. Additionally, with respect to the stored electronic communications, data, information, and images contained in computers, computer storage media, electronic communication equipment, and other data storage devices and media described above, this Court authorizes that such stored electronic communications, data, information, and images may be reproduced by printing ot converting or copying them into storage in another device. It is specifically authorized that the search of any computers, computer storage medi, electronic communication equipment, and other data storage devices and media described above vill be deemed executed at the time those devices have been seized, and that further analysis of these items may be undertaken at any time thereafter. It is specifically authorized that any computers, comiputer storage media, electronic communication equipment, and any related accessories, hardware, and software may be seized and removed for off-site examination. ‘This warrant must be executed within 10 days of the date of issuance, Judge of the Supreme Court Dated: New York, New York ‘MOA MIN ‘NATHOOUM AVANVd NUAISVA 6L1I AO HOOT LSM AHL AO ‘UV FHL STAVMOL ASAT CHOOT ATIVILYWE V HOUVAS OL INVARIVM V Od NOLLVOMIddV NV dO WS.LLVW SL NI HOA MAN HO ALNNOD OA MAN JO ALIO TAL IO LUND AWAAAS EXHIBIT #1 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK INTHE MATTER OF AN APPLICATION FOR A ‘WARRANT TO SEARCH THE PREMISES LOCATED AT 1179 EASTERN PARKWAY I and 2” Floors, BROOKLYN, NEW YORK (“TARGET LOCATION 1”) and 65 BROADWAY SUITE 833, NEW YORK, NEW YORK (“TARGET LOCATION 2”), ‘together referred to as "THE TARGET PREMISES” AFFIDAVIT IN SUPPORT OF SEARCH WARRANT Special Agent-Peter Giannakos, shield #1984 being duly swom, deposes and says: 1. Lama federal agent assigned to the Documents and Benefit Fraud Task Foree of the United States Department of Homeland Security's Homeland Security Investigetions (HS), I have ‘been deputized with the Manhattan District Attomey’s Office and.as such I am a public servant of the kind specified in §CPL 690.05(1). Ihave been an agent for approximately five years, and was a ‘police officer with the New York City Police Department for approximately 19 months. I have participated in the execution of more than ten search warrants in the course of my career. 2. This affidavit is submitted in support of an application for a warrant to search 1179 ‘astern Parkway, Brooklyn New York (“TARGET LOCATION 1”) and 65 Broadway Suite 833, New York, New York (“TARGET LOCATION 2°), and the person of OWOLABI SALIS if ‘present therein, where there is reasonable cause to balieve that property, proceeds, and evidence __ of the commission of the below crimes, among others, and an aftempt and conspiracy to commit the below crimes, may be found: * Grand Larceny (P-L. §155.30 et. seq.) © Scheme to Defraud (P-L. §190.65 et. seq.) © Falsifying Business Records (P-L. §175.10) 3. The information contained in this affidavit’ is based upon interviews with witnesses, reviews of witnesses” statements or reports by others who conducted interviews, my conversations with other law enforcement officials, my review of documents related to this investigation, persanal observations or reports of observations of other law enforcement officials, and inferences I have drawn from this information. It docs not, however, include all of the information Inown to me with respect to this investigation, but only the information that is necessary to establish the requisite probable cause. 4. The property, proceeds, and evidence of the commission of, participation in, or involvement in the above crimes that may be found in THE TARGET PREMISES, includes, but is not limited to: a. Forms, materials, notes, records photographs and documents whether contained on paper in. handwritten, typed, photocopied, or printed form, or within computer storage media, including, but not limited to, laptop or desktop computers, ‘tablets, herd drives, USB devices, flash cards and drives, magnetic tape, CD ROMs, disks, diskettes, photo-optical devices, or handheld computer devices, or any other medium, of or related to immigration applications and other immigration documents; b. Comespondence, inventories, calendars, journals, messages, memoranda, a pinto oka an documents garding cess" immigration proceedings; c. All laptop computers, desktop computers, and computer tablets; all computer storage media, including, but not limited to, hard drives, USB devices, flash cards and: drives, magnetic tape, CD ROMS, disks, diskettes, photo-optical devices, or handheld computer devices; and all accessories, hardware, software, and other equipment or devices used in conjunction with the above-described computers and computer stotage media; 4 United States currency, money orders, bank checks, personal checks, financial records of all types, stored in both tangible and electronic form, including but not limited to account statements, deposit slips, checks and correspondence; ©. Evidence of ownership’ and use of THE TARGET PREMISES, including, but not limited to, mail, keys, telephone bills, bank statements, leases, deeds, rent receipts identification bearing the name or photograph of any person, telephone books, address books, date books, calendars, and personal papers, whether these items are in THE TARGET PREMISES or in the: above-described computers, computer storage media, or electronic communication equipment 5. Its also requested for evidentiary purposes that this Court grant authorization for law enforcement personnel to videotape and photograph the interior of THE TARGET PREMISES. 6. With respect to the stored electronic communications, data, information and inmages contained in computers, computer storage media, electronic communication equiptment, and other data storage devices and media described above, it is.also requested that this Court grant permission to search and retrieve the above-described communications, data, information, and images, and to print tkem or otherwise reproduce thent by converting them or copying them into storage in another device: 7. Iti specifically requested that the search warrant authorize the seizure and removal of any and all computers, computer storage media, electronic commirunication ‘equipment, other data storage devices and media described above, and any related accessories, hardware, and software for off-site searching. Based upon my training and expetience, the ‘examination of such devices can be a time-consuming process due to the constantly chadging amiverse of technologies, models, operation systems, and types of content stored. Because of the volune of evidence and technical requirements of forensic examination, I am aware thet searching and seizing information from such devices often requires police officers to seize most or all such devices along with related peripherals and software to be searched later by a qualified person in a laboratory or other controlled environment. 8 It is also requested that the warrant be deemed executed once any computers, computer storage media, electronic communication equipment, and other data storage devices and media have been seized, and that firther analysis of these items be permitted at any time thereafter. 9. Asset forth below, there is reasonable cause to believe the above-described property has been used, was possessed for the purpose of being used, and is still being used to commit ot conceal the commission of an offense, anid the above-described property constitutes evidence o tends to demonstrate that an offense was committed or that a particular person participated in the commission of an offense. 10. Tam the case agent investigating the actions of Owolabi Salis, an immi attorney who operates from offices from TARGET LOCATION | and TARGET LOCATION 2, hereinafter, THE TARGET PREMISES, and previously at 42 Broadway Suite 1133 in Manhattan. I am working with, and have spoken to, immigration officers from the United States Citizenship and Immigration Services, an affiliated agency within the United States Department ‘of Homeland Security regarding the filings of Owolabi Salis. I am also informed by at least ten immigrast witnesses, whose identities and addresses are known to the U.S. Department of Homeland Secutity and the New York County District Attorney's Office that Salis operates a Jaw firm called Salis Law P.C., also known as Salis and Associates. Based on my conversations ‘with these witnesses and fiom my review of various immigration documents, I believe Salis made material misrepresentations to his immigrant clients and told them that they qualified for legal permanent residence (green cards) and other immigration benefits when they did not. He obtained work permits for these immigrants and misrepresented to them the facts surtounding the manner in which the cards were acquired and the'length for which they would be valid. Based on Salis’ actions; numerous immigrants were led to falsely believe that they qualified for benefits when they did not. After the work permits were sent to Salis’ office rather than the immigrants” homes, he then demanded $4500 on top of the immigration filing fees, file opening fees, biometrics letter fees and consultation fees they already paid. Many of these immigrants paid in cash, as instructed by Salis. Others paid with money orders, bank checks or personal checks. (@) On March 27, 2014, I met with immigrant “J.W.” who informed me that he first went to Salis in October of 2011 at 42 Broadway Suite 1133 in New York County to receive copsultation and legal advice. Salis informed immigrant IW. that he qualified for immigration benefits because of his schooling and education. In addition to legal fees and filing fees, J.W. paid Salis $4500 in New York County for a work permit in April 2012 and the fee for a renewal. Over the summer of 2013, J.W. went to TARGET, LOCATION 1 to inquire about the status of his renewal. JW. also asked for a copy of his paperwork when he was at TARGET LOCATION 1 and although it was not originally released, eventually, Salis gave J.W. a partial copy of his paperwork later on. that summer. J.W.'s underlying petition was denied on June 25, 2013. (&) On March 28, 2014, I met with immigrant “.C.V." who informed me that he first met with Salis at 42 Broadway in New York County in approximately July 2012 when Salis told F.C.V. he qualified fot a work permit and something more permanent later on, neither of which was true. After receiving the temporary work permit, he paid a total of $9000 for him and his wife, in addition to legal fees and filing fees. In September 2013, he went to TARGET LOCATION 1 to renew his work permit and was never told that his ‘underlying petition was denied in April 2013 or that his work permit was n0 longer valid. (©) On April 3, 2014, I met with immigrant “C.M,” who informed me that he also went to Salis in October of 2011 at 42 Broadway in New York County. Salis informed immigrant CM. that he qualified for immigration benefits because of his schooling and education. In addition to legal fees and filing fees, CM. paid Salis in installments in New York County when the temporary work petmit arrived. For C.M's renewal paperwork and all inguiries thereafter, CM. went to TARGET LOCATION 1 to speak with either Salis or his secretaries. Despite having gone repeatedly to TARGET LOCATION 1 while he was applying or awaiting his renewal, C.M. was never told until February 2014 that his underlying petition was filed and ‘had been denied or that his ‘work permit was no longer valid. 11, To facilitate his scheme, and unbeknownst to his victims, Salis submitted the 1360 Form which is typically used for special immigrants including juveniles, Iraqi and Afghani translators for the U.S. military and victims of domestic violence including spousal, child and clder abuse. I have reviewed numerous immigration files and forms, including the forms filed for immigrants J.W., C.M. and F.C.V., which are records of the ‘United States Department of Homeland Security, and on the 1360 Salis would fill-in non-recognized non-cligible categories such as “Deferred Action Request - Dream Act" or “Self-Petitioning Parent of a US Citizen Child.” For those with U.S. born children, be would fill-in in the U.S. born child’s name under the section where the U.S. citizen abuser's name and information was required, even though ‘there were no allegations of elder abuse. Oftentimes, these children were toddlers. Along with the 1360, Salis would also file an 1485 form for an adjustment of status and an 1765 form for the employment authorization. 12, Asis the practice of the United States Department of Homeland Security's Citizenship and Immigration Services with any pending adjustment of status application (1485), while the 1360s and 1485s were being adjudicated, temporary employment authorization cards were issued solely on the basis of an existing pending adjustment of status application. Salis would then tell immigrants that they were “approved” and to come to his office to pick up their work permits which would only be released upon their payment of $4500. What the immigrants + Under the Elder Abuse eligibility, an immigrant may be entitled to adjust their status if, among other things, 1) the alien isthe parent of a U.S. citizen son or daughter who is wt least 21 years old atthe tnt the petition i filed, ‘and 2) the immigrant can demonstrate that he or she has been battered or subject to extreme eruelty by the U.S. citizen son or daughter. were not told was that these work permits were temporary and were based on a fraudulent underlying adjustment of status petition, Subsequent to the employment authorizations being issued, the baseless 1360s and 1485s were denied. The denials were then sent to 42 Broadway, Suite 1133 in New York County when Salis’ practice was there, and later when he moved, the denial letters were sent to TARGET LOCATION 1. 13. TARGET LOCATION 1 is a townhouse consisting of three floors inoluding a first floor, second floor and third floor. There is a large sign on the gate outside of 1179 Eastem Parkway with the words “Salis Law P.C.” There are also two awnings over the doors leading to the first and second floors; one awning on the first floor entrance states in substance "Satis Law P.C.” and a smaller second awning, matching in color to the first floor awning, over the second floor entrance states “Law Office.” A review of the records of the New York City Department of Finance's Office of the City Registrar indicates that 1179 Eastem Parkway in Brooklyn was purchased by “Salis Retirement and Pension Plan LLC at 42 Broadway Suite 1133, New York, New “York” on May 25, 2012 for $750,000. .An analysis of the bank records for Salis Law PC and Salis Law Business Expansion located at 42 Broadway 1133 in New York County shows that a $723,0008 was withdrawn in the form of a cashiers’ check on May 24, 2012 and $26,599 was debited on May 25, 2012. [am informed by numerous immigrant victims who retained Salis as their attomey, that although they first met at 42 Broadway in Manhattan, they later went to TARGET LOCATION | to meet with him or to pick up paperwork. ‘Two of the immigrants T spoke with said that they have gone to the second floor and observed cubicles, a conference room and at least ome secretary. On May 21, 2014, while I was conducting surveillance of TARGET LOCATION 1, I observed Owolabi Salis enter through the second floor entrance. On July 14, 2014, while I was conducting surveillance T observed Salis’ vehicle parked directly in front of TARGET LOCATION 1 14. TARGET LOCATION 2 is a room within an office building located in downtown Manhattan. On July 16, 2014, I personally went to TARGET LOCATION 2 and cbserved a name plate of “Salis Law P.C.” an the door for Suite 833. I am also informed by Jeffrey Sharp of the ‘Vermont Service Center (VSC) of the United States Citizenship and Immigration Services of the United States Department of Homeland Security, that the VSC received correspondence from Salis ‘Law P.C. with law firm stationary indicating both THE TARGET PREMISES as his offices. ‘WHEREFORE, deponent respectfully requests that the Coart issue'a warrant and order of seizure in the form annexed (i) authorizing a search of THE TARGET PREMISES and of the person of Owolabi Salis if present therein, for the above-described property, and (ji) directing that if such evidence is found, it be brought before the Court, Tis also requested that the Court authorize law enforcement to conduct the search in the: manners specifically requested in this affidavit.

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