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AO 91 (Rev 0109 Crimmal Complaint

UNITED STATES DISTRICT COURT for the

District of Delaware

United States of America ) v )

Srinivas Doppalapudi and Rakesh Mandava ) Case No 11shy qt)M ) )

Defendant

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 of 2D07- 201 in the county of New Castle in the District of---------==--- ----- shy

__D=-=el=acw=accre---_ the defendant violated --1L U S C sect 1546 amp 371 an offense described as follows

Making false material statements in a document required by the immigration laws and conspiracy to commit that offense

FILED

This criminal complaint is based on these facts JUN 2 1 2011 See attached affidavit

if Continued on the attached sheet

Sworn to before me and signed in my presence

____ Special Agent Jaso-n~R~u_n-d---e~II____~ Printed name and title

Date 06212011

City and state Wilmington Delaware The Honorable Mary Pat Thynge --- Printed name and titie

Case 112-cr-00029-SLR Document 3 Filed 062111 Page 1 of 21 PageID 1

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF DELA WARE

UNITED STATES OF AMERICA ) )

Plaintiff ) )

v ) Criminal Action No 11 ~ ~1 )

SRINIVAS DOPP ALAPUDI and ) RAKESH MANDA VA )

) Defendants )

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

I Jason C Rundell Special Agent United States Department of Labor Office ofInspector General (DOL-OIG) being duly sworn state as follows

I INTRODUCTION AND APPLICABLE STATUTES

1 I am employed as a Special Agent (SA) with DOL-OIG and have been since June 27 2004 I received a Bachelor of Arts degree in Public Justice from the State University of New York Oswego in 1992 Prior to becoming an SIA I was a United States Probation Officer for the United States District Court in the Western District of Washington I am currently assigned to the Philadelphia Regional Office Philadelphia Pennsylvania My duties as an SIA are to investigate labor racketeering and criminal violations within the programs of the United States Department of Labor

2 I graduated from the Federal Law Enforcement Training Center (FLETC) on December 232004 At FLETC I received instruction on investigative techniques regarding federal criminal cases In addition in my work as a federal agent I have participated in investigations of suspected violations of Title 18 United States Code Sections 1546 (Visa Fraud) and 371 (Conspiracy)

3 This affidavit is submitted in support of a criminal complaint against Srinivas Doppalapudi and Rakesh Mandava for violations of Title 18 United States Code Sections 1546 and 371 From my training and experience I know that it is a violation of Title 18 United States Code Section 1546 for a person to knowingly make a false material statement in a document required by the immigration laws I also know that it is a violation ofTitle 18 United States Code Section 371 for any person to conspire to commit an offense against the United States including a violation of Section 1546


4 I have been significantly involved in the investigation of Doppalapudi and Mandava and of various companies associated with Doppalapdi and Mandava including Technosoft Inc (Technosoft) American IT Group Inc (American IT Group or American IT) Streamline Technologies Inc (Streamline) GK Soft Inc (GK Soft) and PS Tech Inc (PS Tech) Based on the information outlined in this affidavit and based on my training and experience it is your affiants beliefthat Doppalapudi Mandava and others conspired to and did (a) secure employment-based visas and immigration status in the United States for aliens by submitting false and fraudulent documents to federal government agencies under the penalty of perjury and (b) obtained a financial gain from this criminal conduct

5 Unless otherwise stated the information in this affidavit is either personally known to your affiant or has been provided to your affiant by other law enforcement officers government agencies andor through a review of various documentation and records as more particularly described herein I have not set forth every fact of which I am aware concerning this investigation -- only those facts that I believe are necessary to establish probable cause to believe that the defendants have committed the crimes at issue

II FOREIGN LABOR CERTIFICATION PROGRAMS

7 The United States Department of Labor (USDOL) foreign labor certification (FLC) programs provide employers with access to foreign labor

8 The USDOLs Employment and Training Administration (ETA) is responsible for approving and certifying applications for aliens to work in the United States Hiring foreign workers for employment in the US requires approval from several government agencies First employers must seek labor certification through USDOL Once this certification is obtained the must then petition the United States Citizenship and Immigration Services (USCIS) for a visa for the alien Visa applicants must among other things establish that they are admissible to the US under the provisions of the Immigration and Nationality Act (INA) The fact that the USDOL has granted an alien labor certification does not guarantee that the alien will obtain a visa from USCIS However if the USCIS visa application is successful then the United States Department of State (DOS) will issue an immigrant visa number to the foreign worker for CS entry

9 The foreign labor certification process is the responsibility ofthe employer not the employee As a result it is the employer not the employee who applies for labor certification and a visa on behalf of the employee as part of the process set forth above If employers abuse the FLC programs such abuse can result in economic harm to American workers and businesses the exploitation of foreign workers and increased security risks associated with aliens admitted to the US by fraudulent means

10 Among the FLC programs (also known as employment visa application programs) are two that relate to this affidavit the H-IB visa program and the permanent labor certification program

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bull

A H-IB Visa Program

11 The H -1 B visa program allows an employer to temporarily employ a foreign worker in the US on a non-immigrant basis in a specialty occupation or as a fashion model of distinguished merit and ability A specialty occupation requires the theoretical and practical application of a body of specialized knowledge and that the applicant hold a bachelors degree or the equivalent in the specific specialty (ie science medicine health care education or technology) Current laws limit the number of foreign workers who may be issued an H -1 B visa or otherwise be provided H-1 B status

12 The H-1B certification is valid for a period of employment of up to three years The employer can thereafter seek an extension to this status for up to a maximum continuous period of six years unless the USCIS grants a further extension After the H-1 B visa expires the foreign worker must remain outside the US for one year before another HshyI B petition can be approved

13 In order to hire a foreign worker on an H-IB visa an employer must first have job available that meets certain criteria For example the job must be a professional position that requires at a minimum a bachelors degree in the field of specialization Fashion models of distinguished merit or ability may also apply for the H -1 B visa program

14 The employer must thereafter take certain steps as part of the H-IB visa application process

a The employer must first submit to USDOLs ETA a completed Labor Condition Application or LCA by filling out Form ETA 9035E or Form ETA 9035 Both Forms ETA 9035E and 9035 require that the employer must make several attestations regarding the nature of the employment position at issue the number of employees needed the period of employment the work location and the wage rate The forms also contain a statement warning the petitioning employer that if they make fraudulent statements on the form this may be a violation of federal law The employer is required to sign these forms before they are submitted to the USDOL

b Next the employer shall make the LCA and necessary supporting documentation available for public examination at the employers principal place of business in the US andor at the place of employment within one working day after the date on which the LCA is filed with ETA

c If the LCA is approved by USDOL the employer then must submit a copy of the approved LCA to USCIS along with with a completed petition (USCIS Form 1shy129 Petition for a Non-Immigrant Worker) requesting H -1 B classification On the Form 1-129 the employer must submit information about its company information about the alien-beneficiary and information about the proposed employment position The information about the employment position must

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18 IfUSCIS grants an employers Form 1-140 the alien is then permitted to apply to become a lawful permanent resident (also knovrn as obtaining a green card) of the United States or to submit an immigrant visa application at a US Embassy or Consulate abroad

C Your Affiants Experience With Fraudulent Employment Visa Applications

19 Based on my general knowledge of fraud schemes and in particular on my knowledge of fraud regarding foreign labor certification programs 1 am aware that some fraudulent petitioners engage in a practice knovrn as speculative employment Speculative employment is a term used to describe a circumstance where an employer does not have an available employment position but still files an employment visa application on behalf of an alien In doing so the petitioner speculates that at some point in the future they may be able to secure the alien applicant a job In filing such paperwork the petitioner includes false and fraudulent statements on the employment visa application paperwork -- statements that falsely indicate that a job opportunity with their company is presently available when in fact it is not

20 From my experience and from my review of USCIS files I know that at times after an employer has submitted a Form 1-129 or Form 1-140 to the USCIS at times the USCIS thereafter makes a Request F or Evidence (RFE) to the employer In making an RFE the USCIS asks the employer for additional information about the specific employment position that the employer intends the alien-beneficiary to occupy Employers then typically provide additional documentation to the US Government in response to this RFE - documentation indicating that its business is active that it has available employment opportunities that the applicant can fill andor that it has a physical business location Often this supporting documentation includes service contracts between the petitioning employer and other companies or clients These service contracts usually demonstrate that the petitioning business is engaging in a long-term project that requires the services of additional employees or a specific employee - services that could be provided by the visa applicant

21 Based on my knowledge of fraud schemes relating to employment visas 1 know that in order to give the appearance that a bona fide employment position exists visa petitioners sometimes create fake or altered service contracts and submit those documents to US Government agencies in support of visa applications These fraudulent service contracts make it appear as if there is a viable current employment opportunity for the visa applicant to fill when in fact no such job exists

22 It is also your affiants experience that while some fraudulent petitioners may invent petitioning companies or employers other fraudulent petitioners may list an actual employers name and location in the visa petition but have no intention of ever placing the alien-beneficiary with the listed employer Fraudulent petitioners may also misrepresent the nature of the job available the location of the job and the qualifications of the beneficiary alien in order to influence approval of an employment-based visa by United States labor and immigration officials

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include a listing of the job title work location wage rate and the dates of intended employment The fonn contains a statement indicating that by signing the form the employer cenifies under the penalty of perjury that the petition and the evidence submitted with it are all true and correct The employer is then required to sign the form before it is submitted to USCIS

d The employer shall not allow the non-immigrant worker to begin employment until USCIS grants the worker authorization to work in the US for the petitioning employer In the case of a non-immigrant who is already in H-IB status and is changing employment to another employer the alien is not allowed to work until the new employer files a petition with USCIS

e The employer is also required to maintain documentation that would enable it to meet its burden of proof to substantiate the validity of the statements made in the LCA in the event that such statement or infonnation is challenged The employer shall make such documentation available to USDOL for inspection and copying upon request

B Permanent Labor Certification (Green Card) Process

15 The second type of FLC program implicated by this affidavit is a pennanent labor certification or green card which is issued by the USDOL In contrast to the H-1B visa which provides temporary access to the United States for an alien the permanent labor certification allows an employer to hire a foreign worker to work permanently in this country

16 In order to obtain a permanent labor certification for an alien a prospective employer must first file with USDOL a Form ETA 750 (Application For Alien Employment Certification) or (after March 2005) a Form ETA 9089 (Application for Permanent Employment Certification) requesting certification on behalf of the alien employee specified in the application The F onn ETA 750 and its new version the Form ETA 9089 both require the employer to provide information on his or her business the alienshybeneficiary the work to be completed in the prospective employment position the rate of pay and the location of work In signing the form the employer certifies under penalty of perjury that the information contained in the form is true and accurate

17 If the USDOL provides the employer with a certified Form ETA 750 or 9089 the prospective employer is next required to take the certified form and submit it along with a USCIS Form 1-140 (Immigrant Petition for Alien Worker) to USCIS In doing so the employer requests that USCIS classify the alien as eligible for an employment-based immigrant visa The Form 1-140 requires the petitioning employer to provide information on his or her business the alien beneficiary the employment position that is available for the employee to fill and the amount of pay the employer has to offer for the position The employer must also sign the form declaring under penalty of perjury that he or she read and reviewed the application and that the information contained therein is true and correct to the best of his or her knowledge

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IIIINVESTIGATIVE FINDINGS

A Review of Foreign Labor Certification Filings in the State of Delaware

23 In September 2010 DOL-OIG conducted a proactive review ofH-IB VisaLCA applications and Permanent Labor Certifications filed with USDOL by employers in the State of Delaware From that review DOL-OIG discovered that between 2004 and 2009 Srinivas Doppalapudi an Indian citizen who is a lawfully admitted permanent resident of the United States had incorporated five computer consulting companies in Delaware Technosoft American IT Group Streamline GK Soft and PS Tech The review also made clear that Doppalapudi in concert with others including his employee Rakesh Mandava had filed hundreds of LCA and Permanent Labor Certifications seeking to employ foreign nationals in the United States In some of these visa petitions investigators noticed that Doppalapudi listed his home address of as the address for his businesses

24 In October 2010 now working with agents with the Internal Revenue Service - Criminal Investigations (IRS-CI) office in Delaware your affiant contacted USCIS Office of Fraud Detection and National Security (FDNS) and requested information on visa petitions filed by Doppalapudi and his businesses

25 A FDNS representative informed your affiant that US CIS records reveal the following information about employment-based visa applications (including H-1B visa applications and permanent labor certification applications) filed by Doppalapudis businesses

a From on or about April 26 2005 to May 132011 Technosoft filed 335 employment-based visa petitions with the US Government

b From on or about April 1 2008 to December 292010 American IT filed seventy-three (73) employment-based visa petitions with the US Government

c From on or about February 3 2009 to April 13 2011 Streamline Technologies filed thirty-six (36) employment-based visa petitions with the US Government

d From on or about April 2 2009 to June 152009 PS Tech filed seven (7) employment-based visa petitions with the US Government

e From on or about April 2 2009 to April 6 2009 GK Soft filed six (6) employment-based visa petitions with the US Government

B Relevant Corporations

26 Your affiant also obtained information about the fIVe corporate entities controlled by Doppapaludi that relate to this affidavit The evidence obtained regarding these entities as is set forth below indicates that Doppalapudi at times uses the names of these

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corporate entities interchangeably on employment visa application paperwork In addition Doppa1apudi often uses multiple addresses for these corporations For these reasons and because Doppalapudi appears to control each of the corporations your affiant believes that it is likely that corporate records relating to any of these entities could be found at any of the office locations associated with each of the entities

i Technosoft Inc

27 Information obtained from the internet website of the Delaware Department of State Division of Corporations shows that Technosoft Inc was incorporated on February 20 2004 The registering agent is listed as Srinivasa Rao Doppalapudi at

New Castle Delaware 19711

28 On June 2 2011 your affiant accessed Technosofts website at wwwglobaltechnosoftcom The website lists among other things the Corporate Address of Technosoft as Newark Delaware 19711 and its USA Business Address as 3202 Polly Drummond Office Park Suite 3202-A Newark Delaware 19711 The website also listed business addresses for Technosoft in Canada Singapore and India

ii American IT Group Inc

29 Information obtained from the internet website of the Delaware Department of State Division of Corporations shows that American IT Group Inc was incorporated on March 15 2007 The registering agent was listed as Srini vasa Doppa1apudi at 1211 Drummond Plaza Office Park Newark Delaware 19711

30 On June 3 2011 your affiant accessed the American IT Groups website at httpamericanitfoupcom The website lists the address for American IT Group as 1211 Polly Drummond Office Park Newark DE 19711

iii Streamline Technologies Inc

31 Information obtained from the internet website of the Delaware Department of State Division of Corporations shows that Streamline Technologies Inc was incorporated on June 25 2007 The registering agent was listed as Srinivasa Doppalapudi at 5205 W Wood Mill Drive Suite 33 Wilmington Delaware 19808

32 On June 3 2011 your affiant accessed Streamlines website at httpstreamlinetechnologiesinccom The website lists Streamlines USA Business Office address as 5205 W Wood Mill Drive Suite 33 Wilmington Delaware 19808 The website also lists an address in India

iv GK Soft Inc

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33 Records obtained from Wachovia Bank reveal that on February 25 2009 Doppalapudi opened bank account number 2000038417922 under the corporate name of GK Softmiddot and that he listed himself as the President of GK Soft on bank records Among the bank records relating to this account was a Certificate of Incorporation from the State of Delaware which shows that GK Soft Inc was incorporated in the State of Delaware on February 6 2009 Your affiant has also accessed the Delaware Department of States website and confirmed that GK Soft was in fact incorporated on this date

34 On June 3 2011 your affiant accessed GK Softs website at httoll2ksoftsolutionscom The website lists GK Softs address as 1211 Polly Drummond OffIce Park Newark Delaware 19711

v PS Tech Inc

35 Records obtained from Wachovia Bank reveal that on February 25 2009 Doppalapudi opened bank account number 2000038417919 under the corporate name PS Tech and that he listed himself as the President of PS Tech on bank account records Among these bank records was a Certificate of Incorporation from the State of Delaware that shows that PS Tech Inc was incorporated in the State of Delaware on February 6 2009 Your affiant has also accessed the Delaware Department of States website and confirmed that PS Tech was in fact incorporated on this date

36 On June 32011 your affiant accessed PS Techs website at wwwpstechsoftcomThis website lists PS Techs address as 5205 W Woodmill Drive Suite 33 Wilmington Delaware 19808

C File Reviews and Evidence Regarding Fraudulent Contracts

37 Your affiant also reviewed the contents of the USCIS files associated with employment visa applications that were filed on behalf of Technosoft American IT Streamline PS Tech and GK Soft Based on my investigative experience and the experience of other DOL-OIG agents I understand that the uscrs file generally contains all documents related to the filing of a particular employment visa application

38 Of the 335 visa petitions filed by Technosoft your affiant reviewed 104 (or 31 ) of the associated USCIS files Of the seventy-three (73) visa petitions filed by American IT your affiant reviewed twenty-seven (27) (or 37) of the associated uscrs files Of the thirty-six (36) visa petitions filed by Streamline your affiant reviewed thiny-five (35) (or 97) of the associated uscrs files Of the seven (7) visa petitions filed by PS Tech your affiant reviewed six (6) (or 86) of the associated uscrs files Of the six (6) visa petitions filed by GK Soft your affiant reviewed 100 of the associated users files

39 In reviewing these USCIS files your affiant discovered that in a number of cases fake work contracts were submitted to the US Government in support of these visa applications

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i Pain Management and Rehabilitation Contracts

40 For example your affiant discovered that with respect to six visa petitions filed by American IT and three petitions filed by Streamline Doppalapudi submitted a work contract to USCIS stating that alien-beneficiaries from American IT or Streamline were going to work at Pain Management and Rehabilitation Inc a company located in Dover Delaware These service contracts list the specific alien-beneficiarys name rate of pay and duration of employment Each contract contains the signature Srinivas Doppalapudi as well as Ganesh Balu the Director of Pain Management and Rehabilitation Inc

41 On February 4 2011 your affiant and a Special Agent from IRS-CI interviewed Dr Ganesh Balu at his business Pain Management and Rehabilitation PA (Pain Management) in Dover Dr Balu stated that the respective contracts between Pain Management and American IT and between Pain Management and Streamline which were submitted to uscrs as part of the above-referenced visa applications are fake contain false information and were not authorized by him or his business Dr Balu explained that he is a social acquaintance of Doppalapudi because their children attended the same school Dr Balu stated that Doppalapudi told him that ifhis business ever needed information technology (IT) services Doppalapudi s business could assist however Dr Balu never hired Doppalapudi

42 Dr Balu stated that in early 2010 he was contacted via telephone by USCIS officials who were questioning one contract between Pain Management and one of Doppalapudi s businesses - either American IT or Streamline Dr Balu told uscrs officials that the contract was fake and was not authorized by him Following this call from uscrs Dr Balu contacted Doppalapudi for an explanation Doppalapudi told Dr Balu that he applied for the visa because Doppalapudi thought that Dr Balu would need the work based on their conversation Doppalapudi also apologized to Dr Balu and stated that someone at Doppalapudis office must have signed Dr Balus signature on the work contract

43 The chart below illustrates the visa petitions filed by American IT and Streamline that contain fake Pain Management contracts

File No irst Name Received bv Petitioner I StatusI Las USCIS

EAC0914053251 RAYAPUOI Harish 422009 I American I Approved I I lIT

IEAC0914953474 I SAH Dinesh 422009 I American i Approved

I IT I II EAC0914152181 American I Approved I

IT EAC0915150731 I SHRESTHA

Santosh Kumar i 462009I DOODI

Suraj i 41712009 American Approved IT I

EAC0914853372 MISHRA 41152009 American i ApprovedIManoj IT I

EAC0920752308 I VIRANI Alpeshkumar 7222009 I American I Approved lIT I

I I EAC0908850776 I SANTHANAM Ravi Shankar 232009 I Streamline I Denied

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I File No i Last Name I I First Name Received bv Petitioner I Status

USCIS I EAC0914152208 I JOSHI I

I

Janak Sudhir 432009 Streamlme I Withdrawn I EAC0923051415 I KUSHWAHA I Vivek Singh 8242009 Streamline Approved

44 A review of the USCIS files listed above reveal that with the exception of two Streamline petitions all of the related Fonns 1-129 were signed by Srinivas Doppalapudi Streamline petitions EAC-09-230-S141S and EAC-09-088-S0776 are signed by Rakesh Mandava who is listed as the Human Resources Manager for Streamline

ii SIV Enterprises Contracts

4S For two petitions filed by American IT two petitions filed by Streamline and one petition filed by OK Soft Doppalapudi submitted a work contract to USCIS stating that the alienshybeneficiaries at issue were going to work at SIV Enterprises Inc CSIV Enterprises) in Delmar Delaware These work contracts list the specific alien-beneficiarys name pay rate and duration of employment Each contract contains the signature of Srinivas Doppalapudi and Vishal Patel the Director of SIV Enterprises In an additional petition filed with USCIS by Technosoft the associated Fonn 1-129 states that the alienshybeneficiary was going to work at SIV Enterprises in Delmar Delaware and would earn $77000 per year as an Applications Engineer

46 On February 222011 and again on March IS 2011 your affiant interviewed Vishal Patel at his place of business Tax Free Liquors located in Delmar Delaware Patel told your affiant that he owns Tax Free Liquors a retail alcohol sales business and that the business legal name is SIV Enterprises Inc

47 Patel stated that SIV Enterprises is party to one work contract with OK Soft that covers the employment of Patels friend Mayank Patel (no relation) Vishal Patel stated that he wanted to hire Mayank to help out at the liquor store and Mayank Patel told Vishal Patel that he needed to be hired on an H-IB visa In 2010 Vishal Patel signed a work contract with OK Soft to employ Mayank Patel at Tax Free Liquors aIkIa SIV Enterprises and pay OK Soft $4000 per month for these services Vhile employed at SIV Enterprises Mayank Patel worked full time perfonning accountingmanagement work and working on the liquor stores website

48 Vishal Patel stated that neither he nor his business SIV Enterprises is parry to work contracts with American IT Streamline or Technosoft Patel stated that has never heard of these businesses He said that the work contracts between these companies and SIV Enterprises that were submitted to the USCIS are fake contain false infonnation and were not authorized by him He said that he did not sign these contracts

49 The chart below illustrates the visa petitions filed with USClS by American IT and Streamline that contain fake contracts with SIV Enterprises

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i

File No I Last Name I First Name Received bv Petitioner Status USCIS I

EAC0913950222 JONNALAGADDA I John Benhur 4112009 American IT Denied THIMOTHY

bull EAC0923050977 I GYARA i Vinaya Kumar 8242009 American IT Approved

EAC0915150663 NAGAPPA I Bhavana 41712009 i Streamline Approved

EAC0922951154 TARIGOPULA bull Dileep 8212009 Streamline Approved

50 A review of the USCIS files associated with the petitions containing fake SlV contracts reveals that all but one of the related F onns 1-129 contain the signature of Doppalapudi The other Streamline petition EAC-09-229-51154 contains a Form 1-129 that is signed by Rakesh Mandava who is listed as the HR Manager of Streamline

51 In addition as referenced above on December 212009 Technosoft submitted a petition to USCIS (EAC-1O-055-51201) requesting to employ Vinay Kolandra on an H-IB visa The related Fonn 1-129 for this petition states that Kolandra will work at SlV Enterprises

52 Vishal Patel stated that in the beginning of March 2011 he received a telephone call from Srinivas at GK Soft the caller did not give his last name Srinivas called Vishal Patel to inquire why SIV Enterprises had not sent Februarys monthly check to GK Soft as compensation for Mayank Patels work During this telephone call Srinivas provided Vishal Patel with the following two telephone contact numbers and

53 On AprilS 2011 your affiant received records from Verizon which reveal that the subscriber for telephone number is Technosoft Inc with a service address of 3202 Drummond Plaza Newark Delaware 19711 These records also reveal that the billing address for this number is Technosoft Inc at Newark Delaware 19711

54 On May 5 2011 your affiant received records from Verizon Wireless which revealed that the current subscriber for telephone number is Srinivas Doppalapudi whose customer address is Newark Delaware 19711

D Evidence Regarding Benched Employees and the Bench List

55 Based on you affiants experience in similar investigations and in my discussions with other Special Agents 1 am aware of certain tenninology used by foreign labor cenification petitioners and alien-beneficiaries Among those are the terms benched or benching These terms refer to H -1 B visa holders for whom companies obtain visas from the US government claiming that they have ajob available for the employee when in fact they do not After coming to the United States these employees are then unpaid and are on the bench -- awaiting a paid job or searching for their own client site and employer These tenns also refer to H-IB visa holders who drop out of full-time pay and work status and are benched until full-time work is found for them

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56 On January 5 2011 Doppalapudi entered the United States at the Philadelphia International Airport on an international flight originating from India Upon re-entering the US officers from the United States Customs and Border Protection (CBP) conducted a secondary inspection of Doppalapudi and his luggage In his possession Doppalapudi had three suitcases One of those suitcases was found to contain a handshywritten document entitled Bench List This document listed dozens of individuals names most with phone numbers next to them The names were categorized in sections that appear to correspond with specific computer applications or programming languages

57 Your affiant compared the names from this bench list with USCIS files related to Technosoft American IT Streamline PS Tech and OK Soft I also compared the names to corporate wage reports filed by these companies

58 The chart below lists individuals whose names appeared on Doppalapudis bench list who are associated with visa petitions filed by one of Doppalapudi s various businesses

I Last I First USCIS Number Petitioner I DAMIDI I Ani Kumar I WAC0912751877 i American IT I I

DOOm I Santosh K I EAC091415218 i American IT HASSAN I Azeem I WAC0914752128 I American IT

KUMAR Tanya Ajit Alka I EAC0915150142 I American IT

I RAYAPUDI I Harish EAC091405325 I American IT

bull AVULA I Sridhar EAC0915253583 I Streamline NAGAPPA I Bhavana I EAC0915150663 i Streamline

bull VERMA I Saurabh I WAC1014451431 Streamline

I DEVRANI i Vikas Jagdish EAC0919352166 Streamline CHILUKURI Chaitanya WAC0919551246 Technosoft

i DASARA I Sridhar EAC0715153313 amp EACI 023350830 TechnosoftI

EAC0800853049 TechnosoftKOSHY I Thomas SRC0980008643 A87370454

JOSE Sebastian K EAC0814351035 (TECHNOSOFT- I Technosoft and Streamline denied)

i EAC0914152386(STREAMLINE)

i Santoosh Doodi

59 A review of the USCIS file for alien Santoosh Doodi whose name appears on Doppalapudis bench list reveals that on April 6 2009 American IT through an immigration attorney filed a Form I -129 regarding Doodi The Form I -129 lists Doodi s prospective employer as American IT with an address of 1211 Drummond Plaza Office Park Newark Delaware 19711 and is signed by Doppalapudi The Form 1-129 states that American IT will employ Doodi as a Database Analyst and will pay him $51000 per year This H-IB petition was approved on June 30 2009 and is valid until September 11 2012

60 Doodis DSCIS file contains a letter dated June 192009 on American IT letterhead which is addressed to USCIS and is signed by Srinivas Rao Doppalapudi President The letter states that Doodi will be employed full-time by American IT and that he will

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work at Pain Management and Rehabilitation Inc in Delaware Attached to the letter is a fake Pain Management and Rehabilitation contract which states that Doodi will work at Pain Management starting October 1 2009 will earn $51 per hour and that his position is expected to last for two years

61 Your affiant ran a wage inquiry report on Doodi s Social Security number (ending in 0628) which revealed that in 2009 his only reported wages were from American IT for $2750 wages earned in the fourth quarter of that year For the first quarter of2010 American IT reported $4750 in wages for Doodi This lack of wages earned coupled with the submission of a fake contract to USICS on Doodis behalf is an indication that in 2009 and in early 2010 Doodi was not working full time was not paid his proper rate and was benched

ii Bhavana N agappa

62 A review of the USCIS file for alien Bhavana Nagappa whose name appears on Doppalapudis bench list reveals that on April 7 2009 Streamline Technologies through an immigration attorney filed a Form 1-129 for Nagappa The Form 1-129 lists the employer as Streamline with an address of 5205 W Woodmill Drive Suite 33 Wilmington DE 19808 It is signed by Doppalapudi who is listed as Director Human Resources The Form 1-129 states that Streamline will employ Nagappa as a Programmer AnalystSAP and will pay her $48500 per year This H-1 B petition was approved on October L 2009 and is valid until August 30 2012

63 On June 172009 USCIS issued an RFE to Streamlines immigration attorney requesting specific information on Nagappas work site locations and work assignments On or about July 20 2009 in response to the RFE Streamlines immigration attorney provided USCIS with additional information on Nagappas work arrangement Submitted with this letter and mentioned in the body of the letter is a fake contract between Streamline and srv Enterprises

64 Your affiant ran a wage inquiry report on Nagappas Social Security number (ending in 1913) which revealed that she had no wages reported under her number until the second quarter of20IO when Streamline reported her earnings of$9050 In total Nagappas wages from Streamline in 2010 are $14100 -- considerably less than the $48500 annual pay listed in her visa petition These low wages coupled with the submission of the fake srv Enterprises contract is an indication that since securing an H-1 B visa with Streamline Nagappa has not been working full-time is not being paid the appropriate rate and has been on the bench

iii Sebastian Jose

65 A review of USCIS files revealed that both Technosoft and Streamline filed H-IB visa applications for Sebastian Jose whose name appears on Doppalapudi s bench list

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66 A review of Joses USCIS file reveals that on April 12008 Technosoft through an immigration attorney filed a Form I-129 for Jose The Form I-12911sts the employer as Technosoft Inc with an address of Newark Delaware 19711 and is signed by Srinivas Doppalapudi President The Form 1-129 states that Technosoft will employ Jose as a Software Engineer and will pay him $60000 per year The Form 1shy129 stated that Jose lived at and would work at

67 On April 21 2009 USCIS denied Technosofts petition (USCIS file EAC0814351 035) to sponsor Jose on an H-1 B visa In their decision uscrs stated that Technosoft did not provide adequate evidence to show that the job was a specialty occupation Additionally USClS stated that this petition and supporting evidence failed to establish the specific duties that Jose would perform

68 A review ofUSCrS file EAC-09-141-52386 reveals that on April 32009 Streamline through an immigration attorney next filed a Fonn 1-129 for Jose The Fonn 1-129 lists the employer as Streamline with an address of 5205 W Woodmill Drive Suite 33 Wilmington Delaware 19808 and is signed by Srinivas Doppalapudi who is listed as Director Human Resources The Form 1-129 states that Streamline will employ Jose as a Business AnalystSAP and will pay him $50000 per year This H-l B petition was approved on May 1 2009 and is valid until September 292012

69 Located in the uscrs file for H-l B petition filed by Streamline is a consulting agreement between Streamline and Technosoft This agreement which is dated October 13 2008 is signed by Vijay Bhaskar Divi of Technosoft and Srinivas Doppalapudi from Streamline The accompanying engagement letter states that Jose will work for Technosofts client in New York will begin work on November 6 2008 and will be paid $550 per day The paperwork submitted along with this petition gives no indication that Technosoft and Streamline are in fact both owned by Doppalapudi

70 Your affiant ran a wage inquiry report on Joses Social Security number (ending in 4069) which revealed that the only wages posted to this number are $5025 in the first quarter of 2010 and $2000 in the second quarter of 20 1 O This total amount of $7025 is significantly less than the $50000year salary listed in the visa petition filed by Streamline Coupled with fact that Doppalapudi submitted a contract in support ofthe petition that suggests that Jose will work for Technosoft -- with no indication that Technosoft is in fact a related company owned by Doppalapudi - this suggests that Jose was not working full-time and was benched at times in 2009 and 2010

iv Sridhar Dasara

71 On April 3 2007 Technosoft through an immigration attorney filed a Fonn 1-129 with uscrs to offer employmentto Indian national Sridhar Dasara The Fonn 1-129 listed the employer as Technosoft with an address of 1 Newark Delaware 19711 and listed the company President as Srini vas Doppalapudi This Form 1-129 which is signed by Doppalapudi stated that Dasara will work as an SAP Consultant and would be paid $60000 per year This H-IB petition was approved on

14


June 2 2007 and was valid until September 23 2010 Based on this petition Dasara entered the United States on or about February 122008 as an H-1B visa holder

72 On September 32010 Technosoft through an immigration attorney filed a second Form 1-129 (file number EAC-IO-233-50830) to extend Dasaras H-1B visa with Technosoft This Form 1-129 now listed Technosofts address as 3202 Drummond Plaza Office Park Newark Delaware 19711 and listed Srinivas Doppalapudi as the company Director This Form 1-129 signed by Doppalapudi stated that Dasara would work as an SAS Programmer and be paid $60000 per year This H-1B petition was approved on September 242010 and is valid until September 232013

73 Sridhar Dasaras name is on the bench list which was in Srinivasa Doppalapudis possession on January 5 2011

74 On January 20 2011 your affiant interviewed Dasara Dasara stated that in 2007 or 2008 while living in India he responded to an online job advenisement posted by Technosoft In response to his application Dasara was contacted by Doppalapudi Doppalapudi asked Dasara to report to the Technosoft office located in Hyderabad India and work on a database system there so that Doppalapudi could assess Dasaras skills While at Technosofts Hyderabad office Doppalapudi offered Dasara ajob and offered to process Dasaras H-IB visa to work in the United States

75 Dasara left his IT job in India and accepted a position at Technosoft and traveled to the US to work in the IT field expecting to earn approximately $60000 per year as is listed in his H-1B visa application In February 2008 when he arrived in the US to work for Technosoft Dasara moved in to an apartment provided by Technosoft which was located in a complex on Fairway Road in Newark Delaware However Dasara said that he was not consistently paid while with Technosoft and was instead benched Dasara lived in housing paid for by Technosoft and worked on in-house projects at a Technosoft office located nearby his apartment but he was not paid for this work Occasionally Dasara requested and received small amounts of money from Technosoft Human Resources Manager Rakesh Mandava who recorded these transactions on his laptop computer

76 While working for no pay at Technosoft Dasara asked Doppalapudi about getting paid properly He said he was told by Doppalapudi that well see about that After continuing to pressure Doppalapudi for work and proper pay Dasara was placed on an IT client site for several months in early 2009 During this short stint Dasara was paid his proper pay rate from Technosoft but when this contract ended he returned to bench and to unpaid status In May 2010 after pressuring Doppalapudi for full time work and pay Dasara was placed at a full-time IT client site and he began to receive his expected rate of pay from Technosoft

77 In September 2010 Dasara completed paperwork to extend his H-lB visa with Technosoft Some of the questions on the documents pertained to his pay while at Technosoft and because he was unpaid at the time he asked Doppalapudi what he should report on the forms Doppalapudi told Dasara that he would take care of the

15


forms Dasara thereafter partially completed the documents needed for his H-l B extension and provided the incomplete fOTIns to Doppalapudi

78 Your affiant ran a wage inquiry report on Dasaras Social Security number which revealed that he had no reported wages from Technosoft in the second half of 2009 and had minimal wages reported in the first half of 201 O In the third quarter of 201 0 his wages are the highest and are commensurate with someone earning $60000 per year

E Additional Interviews

i Hemanthkumar Sojitra

79 On April 2 2009 PS Tech through an immigration attorney filed a Form 1-129 (file number EAC-09-140-53856) with users to offer employment to Indian national Hemanthkumar Girishkumar Sojitra The Form 1-129 lists the sponsoring employer as PS Tech with an address of 5205 Woodmill Drive Suite 33 Wilmington Delaware 19808 and listed the President ofPS Tech as Srinivas Doppalapudi This Form 1-129 which is signed by Doppalapudi stated that Sojitra will work as a Programmer Analyst and be paid $62358 per year This H-1B petition was approved on May 8 2009 and is valid until September 25 2012

80 Your affiant ran a wage inquiry report on Sojitras Social Security number (ending in 7639) which revealed that he has a total of $3000 in wages reported from PS Tech from fourth quarter of 2009 through the first quarter of2011 This is approximately $59000 less than what is reported on his employment visa petition filed by PS Tech

81 On April 26 2011 your affiant interviewed Sojitra Sojitra stated that in November 2007 he entered the US on a student visa to attend a graduate program at Salem International University in Salem West Virginia After completing his masters degree in February 2009 Sojitra searched the Internet for employment and found an opportunity with PS Tech located in Delaware During the application process Sojitra contacted Srinivas Doppalapudi sent him his resume and discussed an employment opportunity in an information technology (IT) position at PS Tech Doppalapudi told Sojitra that the IT position would involve testing website applications and that he would be paid $55000 to $60000 per year

82 In March 2009 Sojitra moved to Delaware and into an apartment provided by PS Tech At the time Sojitra applied for and was granted an Optional Practical Training (OPT) status on his F-1 student visa which allowed him to work temporarily at PS Tech In April 2009 Doppalapudi filed the H-1B visa petition to employ Sojitra at PS Tech and in October 2009 this visa petition was approved Doppalapudi told Sojitra that Sojitra would begin to receive pay when his H-1B visa was filed

83 In October 2009 when his H-IB visa was approved Sojitra asked Doppalapudi for money and Doppalapudi directed him to Rakesh Mandava whom Sojitra understood to

16


be an accountant at PS Tech From this request Sojitra received a check for approximately $3500

84 Sojitra told your affiant that in 2010 he received a total of$13000 from PS Tech of which $2000 was in cash Sojitra also stated that he did not receive any pay prior to October 2010 Sojitra also told your affiant that he has never been to the PS Tech office located on Woodmill Drive but instead works at Technosoft Doppalapudi s parent company at a location nearby to the apartment where he lives

ii David Kondru

85 uscrs records revealed that both Technosoft and American IT filed H-1B applications for David Kondru A uscrs representative told your affiant that the Technosoft petition was withdrawn on April 12009 The American IT petition (file number EAC-09-140shy53186) was approved and is valid from October 12009 to September 112012 It indicates that Kondru will work at American IT and be paid $50000 per year

86 On May 19 2011 your affiant interviewed Kondru Kondru stated that in August 2006 he entered the US on an F-l student visa to pursue a masters degree at Wright State University in Dayton Ohio After completing his degree a friend told him about opportunities at Technosoft and after researching it on the internet Kondru called Technosoft and spoke with Srinivas Doppalapudi about an OPT position at Technosoft Doppalapudi interviewed Kondru on the telephone assessed his technical skills then told Kondru that if he came to Techosoft he would receive two months of training Doppalapudi told Kondru that during that time Kondru would be provided with housing and food but that Kondru would not be paid

87 In January 2008 Kondru began an OPT position at Technosoft He moved in to an apartment provided by Technosoft that was located on Fairway Road in Newark Delaware Kondru shared this apartment with four or five other Technosoft and American IT employees He said his roommates changed when new batches of employees arrived

88 After completing his two month training program at Technosoft Kondru volunteered to work on in-house projects which consisted of developing programs used for web sites of Technosofts clients Doppalapudi told Kondru that Kondru would not receive his full pay until Kondru was placed at a client site

89 Kondru stated that his H-1B application from Technosoft was denied in 2008 and that Doppalapudi told him that it was denied because there was not a contract for Kondru to work at a client site rn 2009 Kondrus H-1B visa filed by American IT was approved Doppalapudi told Kondru to find his own client location for this H-1B visa

90 From October 2009 to April or May 2010 Kondru continued to work on in-house projects at Technosoft on a less-than-full time basis because Doppalapudi had not found him a client site In May 2010 five months after his American IT H -1 B visa was

17


--- ---

approved Kondru was placed in a full-time position at a client site and began receiving his expected pay of $4800 per month

9l In 2008 and 2009 while living in the Technosoft apartment Kondru received checks from Technosofts accountant Rakesh Mandava as reimbursement for food he purchased for himself and for other employee-occupants in his apartment

92 Kondru told your affiant that he never understood why his H-IB visa was switched from Technosoft to American IT because they are the same thing Kondru stated that Technosoft and American IT maintain offices in separate buildings at the Polly Drummond Office complex in Delaware and that workers go back and forth between the two offices

93 Kondru stated Doppalapudi maintains a home office in the basement of Doppalapudis residence at 1 in Newark Delaware Kondru visited Doppapaludi at this home office on two or three occasions and as a result of his observations on those visits Kondru believes that confidential Technosoft documents are routed and stored at Doppalapudis home office

F Financial Transactions

94 Your affiant has also reviewed records relating to the following Wachovia Bank accounts over which Doppalapudi maintained signature authority

Account Name I Account Number I Date Opened I Date Closed Technosoft 2000012122372 i 030112004 bull 12082008 Technosoft 2000043320680 I 101062008 I NA

bull Streamline Technologies 2000038417469 bull 021122009 I NA i Streamline Technologies 2000030222775 081162007 I 021122009 I American IT Group I 2000029770665 I 04022007 I NA

PS Tech 2000038417919 I 021252009 NA i GK Soft 2000038417922 02252009 I NA

95 The review revealed the deposit of checks issued from third-parties into these accounts These checks each reference in the check memo field the name of a Doppalapudi employee whose visa application file contains a fake and fraudulent contract These checks thus appear to represent proceeds derived from the employment of individuals whose visas were fraudulently obtained by Doppalapudi This information is summarized in the chart below

I

I Employee Name Technosoft Streamline American IT I

I Dileep Tarigopula $34560 ---I Janak Joshi $3600 I

Bank Account Name and Sum of Checks Deposited

Harish Raya udi $45845 i --shy I $99352 I Suraj Shrestha $76231 I --shy

I

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---I I Sebastian Jose $47284 I $31080

96 Your affiant also reviewed records regarding Doppalapudis personal checks accounts at Wachovia Bank (account number 7933) and WSFS Bank (account number

__ 7867) The review of deposits made to these personal checking accounts also identified checks that appear to represent reimbursements of H-1 B visa filing fees These particular checks are drawn on accounts held in the name of individuals who are associated with a visa petition filed by one of Doppalapudis various businesses

97 For example in April 2009 American IT applied for an H-IB visa for alien-beneficiary Manoj Mishra The petition included a fake service contract from Pain Management and Rehabilitation falsely indicating that Mishra was to work at that company A review of Doppalapudis personal checking account at WSFS reveals that in mid-2009 Doppalapudi deposited four checks from Mishra totaling $3A30 Similarly in August 2009 Streamline applied for an H-IB visa for alien beneficiary Dileep Tarigopula This petition contained a fake service contract from SIV Enterprises falsely indicating that Tarigopula was to work at that company A review of Doppalapudis WSFS account records reveals that on or about July 30 2009 Tarigopula wrote a $2500 check that Doppalapudi deposited into Doppalapudis bank account Moreover in July 1 2009 Streamline filed an H-IB petition for alien-beneficiary Vikas Devrani In June 2009 Doppalapudi deposited a $2000 check written by Devrani into Doppalapudis WSFS bank account the words HI-B transfer fee are listed in the memo section of this check Devranis name also appears on Doppalapudis bench list

98 Your affiant knows from his experience in similar investigations that when alienshybeneficiaries pay their petitioning employer money to cover fees for their employmentshybased visa application it is an indication that the employer may not have a current employment vacancy This is an especially true when these payments are made to the personal account of the petitioner instead of a business account Such payments tend to indicate that there is no bona fide employment position available but instead that the petitioner-employer and the alien-beneficiary have agreed to secure an H -1 B visa simply to get the alien status in the US not to fill ajob opening

G Conclusion

99 Based on the above information and my training and experience I believe that there is probable cause to believe that Doppalapudi and Mandava violated Title 18 United States Code Sections 1546 (visa fraud) and 371 (conspiracy) Your affiant respectfully requests that the Coun issue a Criminal Complaint charging these offenses

100 Since this investigation is continuing disclosure of the complaint and affidavit will jeopardize the progress of the investigation Accordingly I request that the Court issue an Order that the complaint affidavit and related file be sealed until further order of this Court

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Sworn to and subscribed before me ----- of June 2011

norable Mary States Magistrate

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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF DELA WARE

UNITED STATES OF AMERICA ) )

Plaintiff ) )

v ) Criminal Action No 11 ~ ~1 )

SRINIVAS DOPP ALAPUDI and ) RAKESH MANDA VA )

) Defendants )

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT

I Jason C Rundell Special Agent United States Department of Labor Office ofInspector General (DOL-OIG) being duly sworn state as follows

I INTRODUCTION AND APPLICABLE STATUTES

1 I am employed as a Special Agent (SA) with DOL-OIG and have been since June 27 2004 I received a Bachelor of Arts degree in Public Justice from the State University of New York Oswego in 1992 Prior to becoming an SIA I was a United States Probation Officer for the United States District Court in the Western District of Washington I am currently assigned to the Philadelphia Regional Office Philadelphia Pennsylvania My duties as an SIA are to investigate labor racketeering and criminal violations within the programs of the United States Department of Labor

2 I graduated from the Federal Law Enforcement Training Center (FLETC) on December 232004 At FLETC I received instruction on investigative techniques regarding federal criminal cases In addition in my work as a federal agent I have participated in investigations of suspected violations of Title 18 United States Code Sections 1546 (Visa Fraud) and 371 (Conspiracy)

3 This affidavit is submitted in support of a criminal complaint against Srinivas Doppalapudi and Rakesh Mandava for violations of Title 18 United States Code Sections 1546 and 371 From my training and experience I know that it is a violation of Title 18 United States Code Section 1546 for a person to knowingly make a false material statement in a document required by the immigration laws I also know that it is a violation ofTitle 18 United States Code Section 371 for any person to conspire to commit an offense against the United States including a violation of Section 1546









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