Case 9:19-mj-08100-WM Document 1 Entered on FLSD Docket 04/01/2019 Page 1 of 10

AO 91(Rev.08/* ) CriminalComplaint

U NITED STATES D ISTRICT C OU ILED BY .C.

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CRIM INAL CO M PLAINT

1,thecomplainantin thiscMe,state thatthefollow ing istrueto the bestofmy knowledgeand belief.

Onoraboutthedatets)of - - ... ..- -- p)./30/20-1i-..--. ...-. inthecounty of - . Pp.
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CodeSection Op nseDescri
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18 U.S.C.j 1001 False Statementsto a FederalOfficeq
18 U.S.C.5 1752(a)(1) Entering orRemaining in a Restrided Building orGrounds

Thiscrim inalcomplaintisbased on these facts:

PLEASE SEE AU ACHED AFFIDAVIT

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Sworn to before meandsigned in my presence.

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Date: . .- - 03/31/79-19---.
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Case 9:19-mj-08100-WM Document 1 Entered on FLSD Docket 04/01/2019 Page 2 of 10

AFFIDA VIT

Your aftiant,Sam uel Ivanovich,firstbeing duly swom ,docs hereby depose and state as

follows:

lnm a SpecialAgentoftheUnited StatesSecretService(tLUSSS''),and lhave

been so em ployed since M arch,2017. Iam presently assigned to the W estPalm Beach Resident

Om ce and have received extensive kaining in the investigation ofcotmterfeitcurrency, identity

theh, check fraud, bank gaud, and access device fraud, threating statem ents toward USSS

protected persons,secure grotmdsorbuildingsnmong otherthings. Iam an investigativeor1aw

entbrcement oo cer of the United States, in that I mn em powered by 1aw to conduct

investigations and to m ake arrests for felony offenses,under the authority of Title 18, United

StatesCode Section 3056.

2. The inform ation in this affidavit is bmsed on m y personal knowledge and

information obtained from other law enforcementpersonnel,and other individuals who have

personal know ledge of the facts. The inform ation set forth herein is provided solely for the

purposeofestablishing probable cause in supportofthe criminalcomplaintcharging Yujing

Zhang,(hereino er'CZHANGD,withmaking falsestatementstowardFederalLaw Enforcement
Agents of the U nited States, in violation of Title 1B,U nited States Code, Section 1001 and

Ilnlawfully entering a restricted building orgrounds,in violation ofTitle 18,U nited States Code,

Section 1752.Because thisam davitis subm itted forthe lim ited ptupose ofestablishing probable

cause,itdoesnotincludea1lofthedetailsoftheinvestigation ofwhich youraffiantisaware.

3. Beginning on M arch 28,2019,a Protective Zone arotm d the property know n as

the M ar-a-laago Club, located at 1100 S. Ocean Blvd., Palm Beach, Palm Beach Cotmty,
Case 9:19-mj-08100-WM Document 1 Entered on FLSD Docket 04/01/2019 Page 3 of 10

Southern Distlict of Florida, 33480, w as established to secure the building and grounds in

preparation for the visit of President of the United States D onald J. Tzum p to M ar-a-laago.

Throughout this property and the area surrotm ding M ar-a-laago,various road blocks,restricted

access signage,uniform ed Palm Beach County SheriY s Deputies,U .S.Secret Service Special

Agems,and Uniformed Division Om cers conlolaccess onto the groundsof M ar-a-Lago. ln

order to even approach duty U .S. Secret Service personnel for purposes of screening, an

individualattemptingto gainentry to M ar-a-Lago mustpassa largeprom inently displayed white

sign several feet in height, w ith red and black letting, which contain the following express

restricted entry w arning:

IJN ITED STA TES SECR ET SER VIC E R ESTRIC TED A REA
ThisareaisunderthejurisdictionoftheU.S.SecretService.You areentering
A çtRestrided BuildingorGrounds''asdefined in Title 18,United StatesCode,
Section 1752.Personsenteringwithoutlawfulauthorityaresubjeettoarrestand
prosa ution.

Youraffiantshallreferto sir sdisplaying thiswarning as ttrestricted access warning signs''

herein.

4. ()n M arch 30,2019,at approxim ately 12:15 p.m .,SpecialAgent Krystle Kerr

(whowaswearingattirecontaining U.S.SecretServicemarkedpoliceidentifiers),wason duty

screening persons attempting to gain access into M ar-a-Lago at the designated primary

checkpointlocated in a parking 1otacross the streetfrom M ar-a-Lago,when she wmsapproached

by an Asian fem ale,later identified as ZH A NG ,attem pting to gain access into the M ar-a-l-ago

club. ZH AN G irlfonned SpecialA gentK err thatshe was there to go to the pooland presented

SpecialAgentKerrwith two RepublicofChina passportsmsidentification,both in the name of

ZIIANG and displaying herphotograph.Once SpecialA gent Kerr confrm ed the identitication,
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ZH AN G 'Sinform ation and passports were then provided to M ar-a-Lago security forverification

thatZhang was listed on the M ar-a-laago access list. lnitially,M ar-a-lyago security wmsunable

to locate and verify ZH ANG was on the M ar-a-Lago access list. W ith ZIIAN G stating she w as

going to the pool,M ar-a-l-ago security then called the m anagerofthe Beach C lub to attem ptto

verify. The M ar-a-Lago M anager on duty at that tim e inform ed M ar-a-laago security that

ZH ANG is the lastnmne ofa m em ber at the M ar-a-Lago club.ZH A NG w ms asked ifthe true

member,whoshallbereferredto ast$HZ''herein,washerfather,butshedid notgiveadefmitive

answer. ZH ANG additionally did notgive a definitive answer when msked if she was there to

m eetw 1t.
h anyone. Due to a potentiallanguage banier issue,M ar-a-laago believed herto be the

relative ofm em berZhang and allow ed heraccess onto the property. Atthistim e,ZHAN G w ms

obliged to pass two m ore prom inently displayed United States Secret Service restricted access

w am ing signscontaining the snm e restricted access wam ing referenced above.

ZH AN G wasthen picked up by M ar-a-Lago valetdrivervia golf cartshuttle. At

thistim e the valetdriverasked ZHAN G where she was intending to go on M ar-a-laago property,

but ZR ANG responded that she didn'tknow where she w anted to go. The valet driver then

proceeded to drive her to the m ain reception area. During this ride,ZHANG passed three

additional United States Secret Service A gents w eming m arked U .S. Secret Service police

clothing in addition to one m ore United States SecretService Restricted A ccess sign.

Upon arrivalatthe USSS posted m ain m agnetomd ercheckpoint,ZH A NG exited

the golf cartand stopped in front of yet another United States Secret Service restricted access

sir . SpecialAgentPaulPatenaude observed ZHAN G reading the restricted access signage for

approxim ately 20 secondsbefore proceeding through the m agnetom eters. A ftercom plying with
Case 9:19-mj-08100-WM Document 1 Entered on FLSD Docket 04/01/2019 Page 5 of 10

the screening proceduresatthis checkpoint,ZHAN G proceeded to the m ain reception area ofthe

Mar-a-laago Club. Priorto heranivalatthe reception,ZHANG passed a totaloftwo (2)

additionalU nited StatesSecretService restricted accesswarning signsin this location.

Upon entering the reception area.a specific identified receptionist (hereinaRer

tttheReceptionist'')greeted ZHANG and asked why she wasatM ar-a-Lago. Aûerbeing asked
several tim es, ZH A N G finally responded that she was there for a United N ations Chinese

Am erican Association eventlater in the evening. 'IYe Receptionistknew thiseventdid notexist

on property asshe has a com plete listofevents. The Receptionistthen proceed to check a11the

access lists for M ar-a-laago to confirm that ZHANG was approved to be on property. The

Receptionistconfirm ed thatZH ANG was noton any M ar-a-laago access list. Atthis tim e,the

Receptionistm ade yotzram antaware ofthe situation and stated thatZH AN G wmsnotauthorized

to be on property.

Youraffiantthen m ade contactwith ZHA NG ,and ZH AN G again stated thatshe

wœs there to attend a t%united N ations Friendship Event''between China and the U nited States.

ZH ANG advised your affiant that she cam e to M ar-a-laago early for the event so she could

familiarize herselfw ith the prom rty and take pictures.ZH A NG stated she had doctlm entation

purportedly showing herinvitation to the event,butagents were tmable to read itasitwas in

Chinese. Yolzrafliantnotes again thatno such eventwas scheduled to take place atM ar-a-laago

duling this tim e period, and thus ZHAN G could not have any legitim ate docum entation

authorizing her entry to M ar-a-laago for such a purpose. Yotlr affiant further notes that these

statements were directly contradictory to the ZHANG 'S earlier statem entto SpecialA gentKerr
Case 9:19-mj-08100-WM Document 1 Entered on FLSD Docket 04/01/2019 Page 6 of 10

lhatZH ANG was supposedly atM ar-a-l-ago to go the pool. ZH AN G w ms then transported off

ofM ar-a-Lago property forfurtherinterview ing.

9. Youraffiantcontinued to interview ZH A NG ,who freely and w ithoutdifliculty

conversed with youraffiantin the English language,and informed herthatshe wmsnotallowed

on M ar-a-Lago property and that she unlaw fully gained access onto the protected grotm ds.

During this interview , ZH AN G then becam e verbally aggressive with agents and she wms

detained and trrmqported back to the United States SecretService - W est Palm Beach Resident

Office.

10. ZHAN G w ms then advised of her M iranda W am ings in English which she

indicated sht understood, and siglwd the warning waiving her M iranda Righls. During the

second interview ofZHANG,she claimed herChinese friend ttcharles''told herto travelfrom

Shanghai,China to Palm Beach,Floridw to attend this eventand attem ptto speak with a m em ber

ofthe President's fam ily aboutChinese and Am erican foreign econom ic relations. A gents were

unable to obtain any inform ation m ore specilically identifying ZHA NG 'S ptuported contact,

tscharles,''as ZHANG claim ed she has only spoken to him via $kW eChat,''which youram ant

knows from investigative research to be the dominant instantmessaging platform in China.

Additionally, ZH A NG stated that she did nottellagents at the m ain checkpointthat she w as

goingtothepool. Andwhenthesectuity guardtoldherthenameofttzhang''shejustthoughtit

wastheperson running the eventand she wasgoingto meetthem .However,youraffiantnotes

thatZHANG exhibited a detailed knowledge otland ability to converse in and tmderstand even
subtle nllnnces of,the English language. For exam ple, as agents w ere attem pting to obtain

written consentforexnm ination ofelectronic devices found in herpossession,ZH AN G read the

5
Case 9:19-mj-08100-WM Document 1 Entered on FLSD Docket 04/01/2019 Page 7 of 10

entire form in English out loud to agents. A dditionally,ZH A NG w ould question agents about

the context of certain words throughout the form . ln doing so, ZHA NG show ed her

understanding and com prehension ofthe English language through reading and speaking.

lnterview s were conducted of Special Agent Krystle Kem U niform ed Division

Officer Bryton Peternel and a specific identified M ar-a-laago security ofscer. Each of these

interviews affirm ed thatZH AN G told SpecialA gent Kerr she was going to the poolatM ar-a-

Lago. Additionally,O fticer Peternelstated thatshe did not give any responsts w hen œsked if

%çzhang''w asherfatherorthe person she wmsgoing to see.

12. ln the colzrse of ZHANG'S investigative detention a totaloffotzr(4) cellular

telephones,one(1)1aptopcomputer,one(1)extemalharddrivetypedevice,andone(1)thumb
drive were found in her possession. Agents requested ZH AN G 'S consentto search the devices,

to w hich ZHAN G consented. A prelim inary forensic exam ination ofthe thum b drive determ ined

itcontained m aliciousm alw are.

13. Your affiant further notcs and submits that thc defendant's false statementto

SpecialAgent Kerr was m aterialin thatby so stating,ZHANG falsely placed herselfin the

category of M ar-a-Lago club members,who are permitted pastthe initialsecurity screening

checkpointand permitted to inside the protectiveperimeterrestricted area to meetwith M ar-a-

Lago club m anagem ent. Had ZH AN G notfalsely portrayed herselfasa club m em berseeking to

visit the pool,and instead advised she w ms there to attend the non-existent ttunited N ations

Friendship Event''between China and the United States,heraccess would have declined by U.S.

SecretService atthe prelim inary inspection point. Youraffiantfurthernotes thatno sw im m ing

apparelwas fotmd in ZH A NG 'S possession oron herperson.

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Case 9:19-mj-08100-WM Document 1 Entered on FLSD Docket 04/01/2019 Page 8 of 10

14. Bmsed upon the foregoing,youraftiantrespectfully subm itsthatthere is probable

causetochargedefendantYujing ZHANG with:(a)havingknowingly makeoruseanyfalse,

tictitious,or fraudulent statem entor representation,to a federalofticer in a m atler w ithin the

jurisdiction ofthe United States Secret Service,U.S.Departmentof Homeland Security,an

agency ofthe executive branch ofthe United States,in violation ofTitle 18,United States Code,

Sedion 1001;and,(b) withhavingknowinglyenteredandremainedinarestricted buildingand

grolmds,thatis,the grounds of M ar-a-laago,ms defined under Title 18,United States Code,

Section 1752(c)(1)(B),in violation ofTitle 18,United States Code,Sections 1752(a)(1)and

1752(b)(2).
FURTHER YOU R A FFIANT SA YETH NAU GHT

M UEL OVICII
SPECIAL AGENT
U.S.SECRET SERV ICE

SW ORN TO AN D SU BSCRIBED BEFORE

M E THIS 31StDAY OF M A RC H ,2019,
I'
N PA LM BEACH COU NTY,SOU THERN D ISTRICT
OFFLORIDA.3/ -resegkon # .

H O N.W ILLIA M M A H EW M AN
UNITED STA TES M A STR ATE JUDG E

7
Case 9:19-mj-08100-WM Document 1 Entered on FLSD Docket 04/01/2019 Page 9 of 10

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT O F FLORIDA
PENALTY SHEET

Defendant's Name: Yuiino ZHANG

CaseN0: lq -6 loe - X M
.

Count# 1
Making False Statements to a FederalOfficer
Title 18,United States Code,Section 1001
Max.Penalty:0-5 years'im prisonm ent'
,$250,000fine;0-3 yearsupervised release:
and,a $100.00 specialassessment.
Count# 2
Entering orRem aining in a Restficted Building orGrounds
Title 18,Uni
ted States Code,Sections 1752(a)(1)and 1752(b)(2)
Max.Penalty:0-1years'imprisonmentor0-5years'probationl' ,$100,000 finez;0-1
yearsupewised release3:and,a $25.00 specialassessm ent.;

ISee18 USC ï 3561(c)(2)

2See 18 USC 1 3571(b)(5)
3See 18 USC j 35834b)(3)
4See 18USC ï 3013(a)(1)(A)(iii)
Case 9:19-mj-08100-WM Document 1 Entered on FLSD Docket 04/01/2019 Page 10 of 10

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
CaseNo lq -6 lo/ -* G
.

UNITED STATES OF AMERICA,

Plaintil,
VS.

YUJING ZHANG,

Defendant.
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1. Did this m atteroriginate from a m atterpending in the M iamiOffice ofthe United

States Attorney's Office priorto July 20, 200817

Yes X No
2. Did thism atteroriginate from a matterpending inthe Nodhern Region ofthe United
StatesAttorney'sOffice (W estPalm Beach Office)onlypriorto December18, 2011?
Yes X No

3. Did this m atteroriginate from a matterpending in the FortPierce O#ice ofthe

United States Alorney's Omce priorto August8, 2014?
Yes X No
Respectfullysubm itted,

ARIANA FAJARDO ORSHAN

I STATES
+

BY :
C.M CM ILLA
SISTANT UNITED STATES AU ORNEY
Admin.No.A5500228
500 S.Australian Ave.,Suite 400
W estPalm Beach,FL 33401
Office: (561)820-8711
John.mcmillan@ usdoj.gov