Case 1:23-mj-04605-DHH Document 13 Filed 11/08/23 Page 1 of 1

THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MASSACHUSETTS

UNITED STATES OF AMERICA )

)
v. ) Criminal No. 23-MJ-4605-DHH
)
(2) JAMES LEE, )
)
Defendant )

GOVERNMENT’S MOTION IN SUPPORT OF DETENTION

The United States Attorney hereby respectfully moves the Court to detain the defendant

pending trial because the defendant poses a risk of flight pursuant to 18 U.S.C. § 3142(f)(2)(A).

In support of the government’s motion for detention, the government relies upon the reasons

detailed in the attached Affidavit of Special Agent Zachary Mitlitsky of the Department of

Homeland Security Investigations and additional arguments to be made and evidence to be

presented at any further detention hearings, held either in the District of Massachusetts or the

Central District of California where the defendant was arrested.

Respectfully submitted,

JOSHUA S. LEVY
Acting United States Attorney

By: /s/ Lindsey Weinstein

Lindsey Weinstein

Assistant U.S. Attorney

Date: November 8, 2023

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AFFIDAVIT OF SPECIAL AGENT ZACHARY MITLITSKY

IN SUPPORT OF DETENTION

I, Zachary A. Mitlitsky, having been sworn, state:

INTRODUCTION AND AGENT BACKGROUND

1. I am a Special Agent with United States Department of Homeland Security

(“DHS”), Homeland Security Investigations (“HSI”). I make this affidavit in support of the

government’s motion to detain pending trial JAMES LEE.

2. I have been employed as a Special Agent since August 2020 and am currently

assigned to the Office of the Special Agent in Charge (SAC), Boston, Massachusetts. I am

authorized to investigate crimes involving violations of Title 8, Title 18, and Title 19 of the United

States Code (“USC”). I am a graduate of the Federal Law Enforcement Training Center

(“FLETC”) in Glynco, Georgia, where I received training to become a Special Agent; specifically,

I have received certifications from the Criminal Investigator Training Program in February 2021

and from the HSI Special Agent Training Program in May 2021. I received training relating to the

trafficking in persons, including sex trafficking, and other offenses.

3. I am currently assigned to the Human Smuggling and Trafficking Unit, where I

investigate interstate and international human trafficking matters. I have participated in

investigations of human trafficking, human smuggling, drug trafficking, financial crimes, and

related offenses, which have included the executions of arrests and search warrants. Many of these

investigations have had national or international connections, and many required me to work

closely and share information and intelligence with members of other federal, state, and local law

enforcement agencies. I debrief defendants, informants, and witnesses who have personal

knowledge about human trafficking, including sex trafficking, and other crimes occurring in

Massachusetts, nationally, and abroad.

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4. The facts in this affidavit come from my personal observations and review of

records, my training and experience and that of other investigators assisting on this case,

information obtained from the review of reports, information obtained from interviews of

witnesses, and other sources of information gathered through my investigation. This affidavit is

intended in support of the government’s motion for detention and does not set forth all of my and

the other investigators’ knowledge about this matter.

5. This affidavit is designed to supplement information previously shared with the

Court within my Complaint Affidavit. I believe that JAMES poses a risk of flight under 18 U.S.C.

sec. 3142(f)(2)(A) and should be detained pending trial and in order to appear in Massachusetts. I

believe this based upon, among other things, his lack of ties to Massachusetts, the strength and

nature of the case, the weight of the evidence against him, the potential penalties he faces, his

financial resources (both known and unknown), and his pervasive use of fraudulent identities.

BACKGROUND OF THE INVESTIGATION AND JAMES LEE’s ROLE IN THE

PROSTITUTION NETWORK

6. Beginning on a date unknown but no later than July 2020, HAN Lee (“HAN”),

JAMES Lee (“JAMES”), and JUNMYUNG Lee (“JUNMYUNG”), and others known and

unknown, operated an interstate prostitution network with multiple brothels in Greater Boston and

Eastern Virginia. The targets advertise the prostitution network on websites under the guise of

nude model photo shoots. The targets also rent high-end apartments that commercial sex workers

then use to engage in sexual services for cash with customers from these websites. As detailed

below, JAMES rented several apartments in Boston and Eastern Virginia using his real identity,

as well as at least two fraudulent identities. In fact, JAMES is and was the sole legal tenant of at

least five brothels used by this prostitution network, all of which are located in Virginia and

Massachusetts. Bank and credit card records of HAN show that she paid for air travel for JAMES

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to Boston and Eastern Virginia to lease these apartments. Information provided by a confidential

source indicate that JAMES is regularly compensated by brothel owners, not just HAN, for both

leasing apartments to be used as brothels, and for his travel to and from the brothel locations.

Finally, financial records indicate that JAMES has several businesses and corresponding business

bank accounts in his name and in the names of his fraudulent identities, which I believe he uses to

launder the proceeds of the prostitution business.

7. The co-conspirators collectively set up the infrastructure for the brothels in multiple

states to persuade, induce, and entice the women to travel to engage in prostitution. More

specifically, they established and maintained websites advertising the women, the local brothel

phone numbers used to communicate with customers to arrange for commercial sex for a fee, the

high-end apartments where the women engaged in the commercial sex with customers and stayed

overnight during their “tour” in a specific city, and the transportation to and from airports and

brothel locations.

8. JAMES leased multiple brothel locations, that is, at least five, in Cambridge and

Watertown in Massachusetts and Fairfax and Tysons in Virginia, which were used to facilitate the

prostitution business. Four of them were in his JAMES name and two were in two different

fraudulent identities. For each of these leases, JAMES provided identification documents, in either

his identity or that of one of his fraudulent ones. He has utilized the aliases of L.H.K. and J.G.W.

to rent apartment locations that were utilized for prostitution. He falsified bank statements,

drivers’ licenses, and paystubs in support of these efforts. He is likely to have also used the alias

of E.C.C., as this name appeared on a fraudulent bank statement JAMES submitted with an

apartment rental application, but investigators have not yet identified if or how JAMES utilized

this alias in furtherance of his criminal activities.

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9. For many of these leases, JAMES flew to Massachusetts or Virginia, using his true

identity, at the start of the leases. Each of these brothels were in high-end apartment buildings,

with monthly rent as high as $5,600. Today, four of those active brothels were subject to search

warrants executed by federal law enforcement officers. From the brothels, agents recovered among

other things, condoms, cash, and women believed to be engaging in prostitution at the direction of

the prostitution ring.

10. In exchange for opening the leases in his identity, or his fraudulent ones, JAMES

received $1,000 per month for each brothel location that remained open. A review of bank records

for his co-conspirator, HAN, revealed that he in fact received at least $64,000 from her, which is

believed to be compensation for placing the brothel leases in his name, or in his fake identity.

11. I believe that JAMES in fact provides cover to the prostitution business in instances

where property managers check in on and conduct inspections of the brothel locations. For

example, according to an interview with the property manager, on August 31, 2023, at around

10:15 a.m., the property manager for 2985 District Ave, Unit 245 contacted JAMES at the listed

lessee phone number of xxx-xxx-3133 related to a possible water leak in his unit and the need for

the property manager to conduct an inspection. About twenty minutes later, the property manager

knocked on the door of Unit 245 and an unidentified Asian female, who stated her name was

“Jisoo,” opened the door. The Asian female led the property manager to an area in the utility

closet, where in fact a leak had occurred. After conducting an inspection and taking a video of the

leak, the property manager left the unit and placed another call to JAMES. During that call, the

property manager asked JAMES about who was residing in the unit, to which JAMES replied

that it was his daughter. When the property manager asked JAMES his daughter’s name, JAMES

was unable to provide an answer. During that same time period in August 2023, investigators

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viewed www.browneyesgirlsva.blog, that is, the Virginia brothel website, which advertised that

“Jisoo” would be available on September 2. Therefore, I believe that the Asian female who

answered the door for the property manager was the woman advertised as “Jisoo” on the Virginia

Brothel website. I further believe that JAMES knew the female in the apartment was staying at

that location for purposes of prostitution.

12. Additionally, based upon information provided to law enforcement by a

cooperating source (“CS”) and set forth in more detail in my Complaint Affidavit, I have reason

to believe that the prostitution network tied to HAN in Virginia and Massachusetts is not the only

prostitution network with whom JAMES has this relationship and for whom JAMES procures

leases. I am aware that JAMES offered assistance to this CS to procure a lease for a brothel that

the CS planned to open in Connecticut. See Complaint Affidavit, para 74.

JAMES’s FINANCES

13. In addition to renting apartments under these aliases, JAMES has also opened bank

accounts under these names, incorporated businesses in California utilizing these names, and

opened bank accounts under these fake businesses. Prior to JAMES’ arrest, investigators were

able to identify a number of bank accounts held by JAMES linked to these aliases, including

accounts at Bank of America and PCB Bank, however, during the execution of a search warrant at

JAMES’ residence, agents uncovered evidence of additional bank accounts (not yet known to the

government) held in the alias L.H.K. at Hanin Federal Credit Union, Merrick Bank, and Hanmi

Bank. Agents also located financial records held in the name Y.S.L. with an address of 3023

Oakwood Lane, Torrance, CA, as well as business entities previously unknown to investigators.

14. Throughout the investigation, investigators have identified a number of businesses

under the control of JAMES or one of his aliases and collected bank records on some, although

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not all, of these business entities. The names of these business entities for which bank records

have been reviewed including the following: Hidden Seller Inc, Orga Enterprise LLC, E.P.A.

Green Services Inc, A Plus C & F Inc, and Alternative Assets LLC, each listing a signatory

authority of JAMES; Action Holdings LLC, listing the signatory authority of J.G.W.; and Extra

Sauce & Profit LLC, Comiso Central LLC, and Palagonia Commerce LLC, listing the signatory

authority of L.H.K. (hereafter “the JAMES Business Accounts”). By reviewing the sources and

uses of funds passing through the JAMES Business Accounts mentioned above, investigators have

identified a much larger network of business entities transacting with JAMES’ business entities

that are suspected, at least some number of them, to also be under JAMES’ control, given the very

unusual and suspicious pattern of money moving between and among the accounts, as described

below.

15. Traditional business entities often have recurring outgoing payments to certain

vendors and recurring incoming payments from their customers, who are different from their

vendors, however, the activity in the JAMES Business Accounts often reflect money originating

from and getting paid out to many of the same business entities, as shown in the chart below:

16.

17. In total, the number of businesses that encompass the dollar amounts reflected

above include eighty-three (83) separate businesses (hereafter, the “JAMES Business Network”).

For purposes of greater transparency, a distinction has been made by investigators regarding these

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83 businesses, classifying them as “List 1” or “List 2,” dependent upon the intelligence gathered

on each. More specifically, there are fifteen (15) business entities that are categorized as “List 1”

businesses, as these businesses include the JAMES Business Accounts for which bank records

were analyzed, as well as six additional businesses for which financial research has indicated with

a high degree of certainty to be under the control of JAMES. The second listing of “List 2”

businesses contain sixty-eight (68) different businesses that have been the primary source, and/or

the recipient, of funds passing through the JAMES Business Accounts. During the execution of

a search warrant on JAMES’ residence, at least three additional business entities were identified

by agents that are not a part of the known JAMES Business Network.

18. Based on my training and experience, I believe that the volume of activity in the

accounts is intentional, in part to conceal and disguise the origin, source, ownership, and control

of money moving through the multiple accounts. In addition to funds derived from the JAMES

Business Network, the JAMES Business Accounts have also received cash deposits, money orders,

and covid relief payments, described below, that are likely to have been derived from JAMES’

criminal activity, but which are masked by the extensive flow of funds in and out of the accounts

from the JAMES Business Network. Similarly, the personal accounts held by JAMES and his

wife, as well as a personal account held in the alias L.H.K., reflect similar deposit activity, with

the addition of peer-to-peer (“P2P”) transactions from JAMES’ co-conspirator in the prostitution

business. When reviewing activity in both the personal bank accounts and the JAMES Business

Accounts, deposits since January 2020 have primarily been derived from the following sources:

JAMES Business Network $3,394,904

Covid relief funds 550,633
Cash 539,947

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P2P from Han Lee/Y.K 1 58,953

Money orders 41,753
$4,586,190
19.

20. As noted in the summary chart above, investigators have also identified a number

of deposits from various Covid-19 related relief funds flowing into JAMES’s personal and

business accounts. Records obtained from the Small Business Administration (“SBA”) regarding

these relief payments provided details regarding the name, address, phone number, and IP address

associated with loan submissions. Given this underlying data, for each loan submission, the SBA

identified additional loan applications that were a potential match as being submitted by the same

individual. For example, a loan application was submitted by JAMES for the business E.P.A

Green Services Inc (a “List 1” business), for which a relief loan was granted and $125,000

disbursed. In connection with that application, the SBA listed additional loan applications by other

business names that had been identified as potential matches, such as KAJ Intl LLC (a “List 2”

business), which submitted an application from the same device and IP address associated with

JAMES’s application for E.P.A. Green Services Inc. KAJ Intl LLC is a business incorporated in

California under yet a different individual’s name, but which based on this information from the

SBA, could likely represent another assumed identity by JAMES. Several of the business entities

that were identified by the SBA are the same business entities that are included in the “List 2”

businesses referenced above.

21. Overall, the financial activity in JAMES’ various business accounts does not

appear commensurate for the listed purposes of JAMES’s businesses. I therefore believe that

JAMES utilized these accounts to conceal and disguise illicit proceeds of the prostitution business,

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Y.K. is a known individual tied to Han Lee, the charged co-conspirator.

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in addition to possible fraudulently obtained Covid-19 related relief funds. Given the additional

business names and aliases utilized by JAMES that were only uncovered as a result of the search

warrant executed at his residence, I believe that there are many more additional aliases, businesses,

and financial accounts that law enforcement has not yet uncovered and therefore JAMES’ true

financial situation is currently unknown.

THE SEARCH WARRANT EXECUTION & JAMES’s TRAVEL HISTORY

22. During the course of the execution of a search warrant at JAMES’s home in

Torrance, California, based on preliminary information received from agents there, I am aware

that the following items were recovered:

23. From the living, from dresser drawers, agents discovered two envelopes, each

containing thousands of dollars in cash. One envelope contained approximately $5,000 and the

other contained approximately $10,000. Also in the dresser were ledgers, banking documents, and

various other identification documents both in JAMES’s name and in other names, including a

social security card in a known alias for JAMES. This known alias, however, was not one of the

names used to open the brothel leases. Therefore, this is at least a third alias for JAMES. One

ledger appears to document payments for bills in his name, his wife’s name and in the name of one

of his fraudulent identities. Also, from the dresser drawer were receipts for purchased money

orders. Agents also recovered a bank book in the name of L.K with JAMES’s address (that is, the

address of the search warrant execution) along with check books in L.K.’s name.

24. Agents also recovered two cell phones believed to be used by JAMES.

25. From the garage, investigators found inside an additional dresser. From a dresser

drawer there were financial documents, leasing agreements and various other identification

documents under the known alias of L.K. used by JAMES to procure one of the brothel leases. In

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the same drawer, seized multiple years of tax returns that were prepared in the name of L.K.,

banking documents in the name of L.K., various banking documents corresponding to businesses

located at the same address in Fullerton, California associated with yet another known alias for

JAMES.

26. In their bedroom, they also recovered tax returns in JAMES’s and his wife’s name,

prepared by the same tax preparer who did those in his fraudulent of L.K. From his bedroom they

also seized another cell phone on the floor next to his bed.

JAMES’s RECENT INTERNATIONAL TRAVEL

27. As described above, a number of items were recovered from JAMES’s home

related to his identity and his fraudulent ones, not limited to banking documents, identification

cards, social security cards, etc. Of note, however, agents did not locate JAMES’s passport.

28. In the last seven years, since 2017, JAMES is believed to have traveled to eight

different countries on 10 separate occasions.

29. In 2023, JAMES traveled round trip from San Pedro California to Ensenada

Mexico and back on a Cruise ship from September 25th to September 29th. In 2022, JAMES

traveled from Los Angeles to Singapore on March 9th and returned to Los Angeles from Japan on

March 18th. In 2020, JAMES traveled from Los Angeles to Seoul South Korea on January 3rd and

returned to Los Angeles on March 5th from Seoul. In 2019, JAMES traveled from Los Vegas to

Vancouver Canada on March 2nd. On March 21, 2019, JAMES crossed from Canada back into

the United States. On October 1st, 2019, JAMES traveled from Los Angeles to Bogota, Colombia

and on October 12th JAMES returned to Los Angeles from Bogota, Colombia.

30. In 2018, JAMES traveled from Los Angeles to Vancouver Canada on September

10th and returned from Vancouver Canada to Los Angeles on September 27th. On October 8th

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JAMES traveled again from Los Angeles to Vancouver and returned from Vancouver back to Los

Angeles on October 23rd. On December 28th JAMES traveled from Los Angeles to Seoul South

Korea. On January 18th, 2019, JAMES returned from Seoul South Korea to Los Angeles. In 2017,

JAMES traveled from Los Angeles to Panama City, Panama on October 3rd. On October 18th,

JAMES traveled from Sao Paulo Brazil to Miami, Florida.

CONCLUSION

31. For the foregoing reasons and those to be offered at the detention hearing, I believe

there is a preponderance of the evidence to believe that JAMES is a risk of flight. I further believe

that JAMES will not appear in the District of Massachusetts for his case. I also believe that

JAMES should be detained pending trial.

Respectfully submitted,

__________________________
Zachary Mitlitsky
Special Agent
Homeland Security Investigations

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