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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

UNITED STATES OF AMERICA

v.

HEON SEOK LEE

)

)

)

)

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Case No. 12 CR 109

Judge Sharon Johnson Coleman

GOVERNMENT’S RESPONSE TO DEFENDANT’S RULE 33 MOTION

The United States of America by its attorney, Joel R. Levin, Acting United 

States Attorney for the Northern District of Illinois, respectfully submits this 

response to defendant Heon Seok Lee’s motion under Federal Rule of Criminal 

Procedure 33 for a new trial. See R. 180. For the following reasons, the government 

respectfully requests that the Court deny the motion. 

I. BACKGROUND

Defendant Heon Seok Lee was charged by indictment on February 16, 2012, 

with five counts of wire fraud, in violation of 18 U.S.C. § 1343 (Counts 1 through 5), 

and three counts of smuggling mismarked merchandise into the United States, in 

violation of 18 U.S.C. § 545 (Counts 6 through 8). R. 2. In 2015, the government 

obtained defendant’s extradition from the Republic from South Korea, and defendant 

was brought to the United States. Defendant’s trial on the charges contained in the 

indictment began March 6, 2017. After an eight-day trial, a jury returned verdicts of 

guilty on all counts of the indictment. Defendant has now moved for a new trial under 

Federal Rule of Criminal Procedure 33. See R. 180.

The trial evidence proved that, in an effort to combat the Great Recession of 

2008, Congress passed the American Recovery and Reinvestment Act of 2009 

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(“ARRA”). Under ARRA, billions of dollars in stimulus funds went in a number of 

different directions and included the disbursement of funds to municipalities and 

other local governments for the construction and renovation of wastewater treatment 

facilities through clean-water revolving loans and grants administered by states and 

the EPA. In order to receive ARRA funding to upgrade/improve wastewater 

treatment facilities, municipalities had their general contractors and engineering 

firms confirm that the contractors, subcontractors, and vendors provided 

manufactured goods that complied with the “Buy American” provision in ARRA, 

which required that manufactured goods be “substantially transformed” in the 

United States of America. General contractors and engineering firms complied by 

using ARRA certificates, which were typed documents signed by representatives from 

subcontractors and vendors, in which the subcontractors and vendors confirmed that 

they would comply with the requirements of ARRA for the manufactured goods for 

the projects. The general contractors and engineering firms collected these 

certificates from subcontractors and vendors, and, when necessary, provided them to 

the municipalities to confirm ARRA compliance. The federal EPA, in turn, conducted 

audits and reviewed the certificates. 

Defendant was the president and CEO of KTURBO and KTURBO USA 

(collectively, KTURBO). He started, ran and exercised managerial control over both 

companies. He designed and managed the design of KTURBO’s primary product and 

its technology, which consisted of an aeration blower. KTURBO originated in the 

Republic of Korea, where defendant had his main offices, his assembly and 

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manufacturing plant, and over 100 employees. Defendant eventually decided to 

expand operations to the United States where defendant chose to enter the municipal 

wastewater treatment market. 

As the evidence at trial established, defendant sought to fraudulently obtain 

federal stimulus funds that had been distributed to states and municipalities through 

ARRA. Defendant, through KTURBO, bid on and won contracts to provide blowers 

for placement in municipal wastewater treatment facilities and, along the way, 

falsely represented that KTURBO’s aeration blowers would be and were substantially 

transformed in the United States. In truth, as defendant knew and directed, 

KTURBO fully assembled its blowers in the Republic of Korea, but nonetheless placed 

placards stating the blowers were “Assembled in USA”, then shipped the fullyassembled blowers from South Korea to the United States, for distribution to 

municipalities across the country, including Indian Springs, Nevada; Lowell, 

Massachusetts; Mishawaka, Indiana; Ottawa, Illinois; Pendleton, Oregon; and South 

Burlington, Vermont.

To accomplish the fraud, defendant set up a small warehouse and office space 

in Batavia, Illinois, where defendant hired a handful of employees to work as sales 

representatives and putative assemblers. Defendant and his employees then 

represented that KTURBO would use this Batavia facility to manufacture and 

assemble aeration blowers using parts sourced from domestic and foreign suppliers 

for municipal wastewater treatment plants. In truth, defendant saw that 

manufacturing and assembling blowers in the United States was too costly and took 

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too much time in his opinion, leading defendant to decide to have blowers fully 

assembled and tested in South Korea, then shipped to the Batavia facility for a short 

period of time before shipment to municipal wastewater treatment plants across the 

country. 

The trial evidence further established that defendant and others working with 

him and at his direction lied to sales representatives, who helped sell KTURBO 

blowers for ARRA projects, as well as general contractors, project engineers, and 

municipalities who bought aeration blowers from KTURBO, believing and trusting 

that that defendant and KTURBO complied with ARRA. Defendant and his 

employees continuously lied that blowers were assembled in the United States and 

purposely hid the fact that blowers were coming fully assembled from Republic of 

Korea. These lies even made their way to the nameplates welded and riveted on the 

blowers shipped from Korea, each of which falsely proclaimed, “Assembled in the 

USA.” 

On February 24, 2011, law enforcement, pursuant to a search warrant 

authorized by a magistrate judge in the United States District Court for the Northern 

District of Illinois, searched KTURBO’s facility in Batavia, Illinois, seizing blowers 

that had been fully manufactured in the Republic of Korea as well as other relevant 

evidence. A short time after the search, defendant returned to the Republic of Korea, 

where he remained until the government obtained his extradition.

II. FEDERAL RULE OF CRIMINAL PROCEDURE 33

A court may vacate a judgment and grant a new trial upon a defendant’s 

motion “if the interest of justice so requires.” FED. R. CRIM. P. 33; see also United 

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States v. Berg, 714 F.3d 490, 500 (7th Cir. 2013); United States v. Smith, 674 F.3d 

722, 728 (7th Cir. 2012). A new trial is in the interest of justice where “the ubstantial 

rights of the defendant have been jeopardized by errors or omissions during trial.” 

United States v. Kuzniar, 881 F.2d 466, 470 (7th Cir. 1989).

“[A] defendant is entitled to a new trial if there is a reasonable possibility that 

a trial error had a prejudicial effect upon the jury’s verdict.” United States v. Van Eyl, 

468 F.3d 428, 436 (7th Cir. 2006). Rule 33 motions are generally disfavored and courts 

should only grant them in “the most extreme cases.” United States v. Linwood, 142 

F.3d 418, 422 (7th Cir. 1998) (internal marks omitted). “A jury verdict in a criminal 

case is not to be overturned lightly, and therefore a Rule 33 motion is not to be granted 

lightly.” United States v. Santos, 20 F.3d 280, 285 (7th Cir. 1994) (internal marks

omitted). While the court has broad discretion in ruling on a motion under Rule 33, 

the Seventh Circuit has cautioned:

The court may not reweigh the evidence and set aside the verdict simply 

because it feels some other result would be more reasonable.... The evidence 

must preponderate heavily against the verdict, such that it would be a 

miscarriage of justice to let the verdict stand.... Motions for new trial based on 

weight of the evidence are not favored. Courts are to grant them sparingly and 

with caution, doing so only in those really exceptional cases.

United States v. Reed, 875 F.2d 107, 113 (7th Cir. 1989) (internal marks omitted).

III. DEFENDANT’S MOTION FOR A NEW TRIAL LACKS MERIT.

A. The Government Did Not Constructively Amend the Indictment.

“A constructive amendment of an indictment occurs when the evidence at trial 

‘goes beyond the parameters of the indictment in that it establishes offenses different 

from or in addition to those charged by the grand jury.’” United States v. Phillips, 745 

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F.3d 829, 832 (7th Cir. 2014) (quoting United States v. Pigee, 197 F.3d 879, 886 (7th 

Cir. 1999)). While constructive amendment violates the Fifth Amendment, “‘not all 

variations in proof that contradict or supplement verbiage in the indictment rise to 

the level of constructive amendments.’” Id. (quoting Pigee, 197 F.3d at 886). 

Impermissible constructive amendment occurs when “the crime charged in the 

indictment [is] ‘materially different or substantially altered at trial, [so that] it is 

impossible to know whether the grand jury would have indicted for the crime actually

proved.’” Id. (quoting United States v. Trennell, 290 F.3d 881, 888 (7th Cir. 2002)).

Defendant’s arguments to the contrary, no constructive amendment of the indictment 

occurred in this case. 

As defendant argued numerous times pretrial, he again claims that 

constructive amendment of the indictment occurred, suggesting that the indictment 

alleged that defendant had contracts directly with municipalities and the United 

States to provide blowers. See R. 180 at ¶¶1, 6. A fair reading of the plain language 

of the indictment demonstrates that defendant’s arguments lack merit. 

Paragraph 3 of the indictment alleged that defendant and others acting with 

him and at his direction “procured contracts for KTURBO and KTURBO USA to 

provide turbo blowers to municipal wastewater treatment facilities receiving 

stimulus funds.” R. 2 at ¶3. Likewise, the indictment further alleged that defendant 

and his accomplices “entered into and caused to be entered into contracts on behalf 

of KTURBO and KTURBO USA to provide turbo blowers to municipal wastewater 

treatment facilities that were receiving Recovery Act stimulus funds[.]” Id. at ¶4. 

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Neither of these allegations required the government to prove at trial that 

defendant’s contracts were directly with municipalities. Instead, these allegations 

were broad enough to comport with the evidence the government produced at trial, 

namely, that KTURBO and KTURBO USA entered into purchase orders with 

engineering and construction firms—who were working with municipalities—to 

provide turbo blowers to municipal wastewater treatment facilities.1 While the 

indictment included this broader allegation than the evidence proven at trial, that 

does not amount to a constructive amendment. To the contrary, the “government 

simply supplied more technical details that easily fit within the allegations in the 

indictment.” United States v. Alhalabi, 443 F.3d 605, 614 (7th Cir. 2006). Because the 

indictment may naturally be read to include the evidence presented at trial, 

defendant’s claim fails. See Phillips, 745 F.3d at 832. 

Defendant next claims that striking of Paragraph 10 of Count One of the 

indictment—which identified the loss amount—amounted to an impermissible 

constructive amendment of the indictment. See R. 180 at 3. Loss is not an essential 

element of wire fraud. See United States v. Swanson, 394 F.3d 520, 525-26 (7th Cir. 

2005); United States v. Leahy, 464 F.3d 773, 786-87 (7th Cir. 2006) (“The[] [mail and 

wire fraud] statutes do not require the government to prove either contemplated 

harm to the victim or any loss.”); United States v. Howard, 619 F.3d 723, 727 (7th 

Cir. 2010) (“[E]ven if an indictment names particular victims, the government need 

 1 Defendant seemingly acknowledges as much when he observes that the “Indictment 

strongly implied that Defendant had actually entered contracts with the municipalities 

themselves.” R. 180 at 3.

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not prove intent to harm those named victims.”); United States v. Henningsen, 387 

F.3d 585, 590 (7th Cir. 2004) (“[F]raud does not include an element requiring a 

contemplated harm to a specific, identifiable victim.”); United States v. Hausmann, 

345 F.3d 952, 959 (7th Cir. 2003); United States v. Fernandez, 282 F.3d 500, 506-07 

(7th Cir. 2002).

When an allegation is not essential element of the offense, that allegation 

cannot support a claim of constructive amendment. The law in the Seventh Circuit is 

clear on this. In United States v. Tello, 687 F.3d 785 (7th Cir. 2012), the Seventh 

Circuit rejected the claim of a constructive amendment of an alleged RICO 

conspiracy, id. at 794-76. The Court explained that “any allegation as to overt acts, 

including predicate acts of racketeering, that [defendant] may have committed in 

furtherance of the charged conspiracy, would constitute surplusage rather than an 

essential element of the charged conspiracy.” Id. at 796. “Such surplus allegations 

thus would not support a later charge of constructive amendment based on a 

divergence between the acts alleged in the indictment and the acts, if any, 

acknowledged in the guilty plea.” Id.; see also United States v. Franco, 874 F.2d 1136, 

1144 (7th Cir. 1989) (rejecting claim of constructive amendment and noting that the 

defendant “fail[ed] to provide any authority to support his claim that unessential 

allegations contained in the count must be proven beyond a reasonable doubt”); 

United States v. Williams, 798 F.2d 1024, 1032-33 (7th Cir. 1986) (finding no 

constructive amendment where allegations were not “essential elements”). 

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B. The Court Properly Admitted “Flight” Evidence During Trial. 

Before trial, the government moved in limine for a ruling on the issue of 

defendant’s post-search flight from the United States to the Republic of Korea. See R. 

116 at 4-7. Specifically, the government sought to introduce evidence that, for 

approximately three years before law enforcement searched the KTURBO USA 

facility in Batavia, Illinois, defendant regularly traveled for extended periods of time 

to engage in work in the United States. That changed when law enforcement in 

executed a search at the KTURBO USA facility in Batavia, Illinois, on February 24, 

2011. While law enforcement was executing the search, defendant arrived at the 

Batavia facility and spoke to law enforcement. He made a statement to the 

investigating agents and gave them permission to search his laptop computer. 

Several weeks after the search, on March 10, 2011, defendant boarded a plane 

destined for South Korea. Defendant then returned to his native country and he never 

returned to the United States. Over defendant’s objection, the Court granted the 

government’s motion and acknowledged that defendant remained free to present 

evidence “challenging the reasonableness of that inference of guilt at trial. See R. 132 

at 1. At trial, the government presented evidence consistent with its motion, though 

defendant never took the Court’s invitation to challenge the evidence. 

Now, post-trial, defendant argues in cursory fashion that the Court erred in 

allowing this evidence to be admitted at trial. Defendant has not provided any 

additional facts, law or analysis that may support his arguments. To the contrary, 

defendant has a misimpression of the facts: the evidence established that defendant 

fled after the search of the Batavia facility, not because of the indictment. Because 

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defendant has not offered any meaningful reason or basis for the Court to reconsider 

its prior rulings, his motion should be denied. See United States v. Mojica, No. 12 CR 

755-5, 2016 WL 3268991, at *3 (N.D. Ill. June 15, 2016).

C. The Court Properly Limited Defendant Regarding “Substantial 

Transformation” During Closing Arguments and When 

Instructing the Jury. 

Defendant’s motion raises multiple challenges to the Court’s rulings regarding 

substantial transformation. See R. 180 at ¶¶3, 6, 8, 10. Not one has merit. 

First, according to defendant, the Court impermissibly offered him a “binary 

choice between arguing that ARRA did not apply and arguing that KTURBO satisfied 

ARRA’s substantial transformation requirements.” R. 180 at 4. According to 

defendant, the Court committed error because he “had plenty of evidence showing 

that substantial transformation had occurred, and therefore KTURBO met the 

requirements [of ARRA] nonetheless.” Id.

Contrary to defendant’s argument, the Court did permit defendant to argue to 

the jury that KTURBO had completed substantial transformation of its turbo blowers 

in the United States. The Court advised the parties that “this Court is going to allow 

in general [defendant] to make an argument, refer to those terms [substantial 

transformation, etc.] as they have a bearing on credibility and weight, but not to the 

ultimate issues to be decided.” Tr. 1575. The Court explained its ruling on the 

“ultimate issue” question, clarifying that “[defendant] can’t say ... if you find that 

[defendant] substantially complied with X number of factors of substantial 

transformation, then you can’t find him guilty, you cannot argue that.” Tr. 1576. 

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This ruling was proper as it was made in the context of defendant trying to 

argue that the “government has all the burden to prove that, that Mr. Lee violated 

Buy American provision. That’s, that’s their burden. And to, to meet that burden they 

had to actually prove that defendant did not substantially ....” Tr. 1577. What 

defendant was trying to do was add “substantial transformation” to the elements of 

the wire fraud charged against the defendant, see R. 151 at 7; see also R. 180 at ¶6, 

when that was not required under well-settled law regarding the elements of wire 

fraud and the Pattern Criminal Jury Instruction. This, as the Seventh Circuit has 

instructed, is entirely appropriate. See United States v. Wables, 731 F.2d 440, 449 

(7th Cir. 1984) (“holding that the trial court “d[oes] not abuse its discretion by 

requiring the defense counsel to argue consistently with the correct law”); see also 

United States v. Sanchez, 604 F.3d 356, 358-60 (7th Cir. 2010) (same); United States 

v. Doe, 705 F.3d 1134, 1149 (9th Cir. 2013) (“The district court did not forbid Doe from 

making a closing argument or from presenting his public authority theory; it merely 

prevented him from arguing incorrect statements of law, something that is well 

within the court’s discretion.”). Consistent with this law, the Court also properly 

declined to give defendant’s Special Instruction No. 1, see Tr. 1562-66, because it was 

not an element of the charged offense. 

D. The Court Did Not Err in Admitting Coconspirator Statements 

During Trial, and Did Not Err When Instructing the Jury on 18 

U.S.C. § 2. 

Defendant has made the cursory argument that the Court erred by granting 

the government’s motion to admit coconspirator statements of people whom 

defendant claims “were not co-schemers of the defendant.” R. 180 at 4-5, see also id.

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at ¶13. The Court should reject this argument for several reasons. First, defendant 

has not identified a person he believes was impermissibly identified as a co-schemer. 

Second, defendant has not identified a statement he believes was improperly 

admitted under Federal Rule of Evidence 801(d)(2)(E). Likewise, defendant has not 

demonstrated that he made a timely objection to the admission of any such statement 

at trial. See United States v. Franklin, 197 F.3d 266, 270 (7th Cir. 1999) (“When a 

defendant fails to object in a timely fashion to the admission of evidence at trial, the 

defendant forfeits the issue absent a showing of plain error.”). 

Defendant has also argued that the Court erred when it did not “strike the 

charges under 18 U.S.C. § 2.” Section 2, as the Court is aware, is not a standalone 

charge. Instead, it is a theory of liability that a person who aids or abets the 

commission of a crime is liable as a principal. See 18 U.S.C. § 2. United States v. 

Newman, 755 F.3d 543, 545-46 (7th Cir. 2014). “Aiding or abetting is a proper basis 

of conviction in every prosecution.” United States v. Newman, 755 F.3d 543, 545-46 

(7th Cir. 2014) (citing United States v. Moore, 936 F.2d 1508, 1525-28 (7th Cir.1991)). 

Additionally, defendant did not raise an objection to the instruction during the jury 

instruction conference. See Tr. 1523 (“[Government’s Proposed Instruction] No. 21, 

Seventh Circuit Instruction 5.06 is given, there being no objection.”); see also R. 123 

at 22. Accordingly, defendant waived his objection to this instruction. 

E. The Court Properly Rejected Defendant’s Unanimity 

Instruction.

Defendant argues that the Court impermissibly rejected his request for the 

jury to have received an unanimity instruction regarding the false representations 

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alleged to have been made as part of the scheme. See R. 180 at ¶7. This Court’s 

decision to deny the requested instruction is in accordance with Seventh Circuit 

precedent. In United States v. Daniel, 749 F.3d 608 (7th Cir. 2014), the defendant in 

a federal fraud case argued the court should have been instructed with Pattern 

Criminal Jury Instruction 4.04 requiring unanimity as to a specific fraudulent act or 

representation, id. at 613. The Seventh Circuit rejected the argument, holding that 

the trial court did not abuse its discretion in declining to give such an instruction 

because a defendant’s fraudulent representations and omissions are merely “the 

means [the defendant] used to commit an element of the crime[,]” not an element 

themselves. Id. In so holding, the Seventh Circuit joined the three other courts of 

appeals that have addressed this same question and all of which came to the same 

conclusion. See id. (collecting cases). 

F. The Court’s Wiring Jury Instruction Did Not Violate the Law.

Defendant takes issue with the wiring instruction that the Court gave the jury, 

arguing that the government “alleged emails attaching specific communications,” and 

that, as a result, “[t]he Government was required to prove what is alleged.” R. 180 at 

¶9. To begin with, defendant did not raise an objection to this instruction during the 

jury instruction conference, thereby waiving any claim of error post-trial. See Tr. 

1528. 

Even on the merits the argument fails. One sentence of government’s Proposed 

Instruction #29 stated, “Although an item communicated interstate need not itself 

contain a fraudulent representation or promise or a request for money, it must carry 

out or attempt to carry out the scheme,” quoting the Seventh Circuit’s Pattern 

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Criminal Jury Instruction for the use of interstate communication facilities under 18 

U.S.C. § 1343. This instruction was an accurate statement of the law. See United 

States v. Hollnagel, 955 F. Supp. 2d 830 (N.D. Ill. 2013); see also Schmuck v. United 

States, 489 U.S. 705, 712-24 (1989). Because defendant has offered no argument 

indicating how or why this instruction was inappropriately given, the argument 

should be rejected. 

G. The Court Properly Declined to Give Defendant’s Special 

Instruction #3. 

At trial, defendant proffered his Special Instruction #3, which would have 

instructed the jury that, for Counts 6 through 8, which alleged violations of 18 U.S.C. 

§ 545, the government had to prove “that defendant Lee himself imported the blowers 

and not his company.” R. 151 at 15. The Court declined to give the instruction. See

Tr. 1533. Defendant has claimed this was error, but offers no precedent and no 

meaningful argument in support of his claim. To the contrary, the law is settled that 

a person may be part of a joint venture involved in a criminal offense, and need not 

perform every act constituting the crime charged, and that criminal liability under 

18 U.S.C. § 2 extends to those who aid, abet, command, induce or procure the 

commission of a crime. See United States v. Rebolledo-Delgadillo, 820 F.3d 870, 876 

(7th Cir. 2016). In this case, the evidence was more than sufficient to establish that 

defendant knew about the importation of fully-assembled blowers from the Republic 

of Korea to the United States, knew that they were mismarked, and worked to have 

that occur through his machinations both in the United States and abroad. See United 

States v. Garcia, 45 F.3d 196, 199 (7th Cir. 1995). 

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H. The Court Did Not Err in Giving Government’s Instruction 25A 

to the Jury. 

The government proposed Instruction #25A, which read as follows: “A false or 

fraudulent pretense, representation or promise does not have to be made directly to 

the victim of the scheme. Deception of someone else can suffice if it carries out the 

scheme.” Over defendant’s objection, the Court ruled this instruction appropriate and 

gave it to the jury. See Tr. 1574. Defendant re-raises his objection, but has offered no 

reasoning or analysis to support his claim of error. Even if he had, however, the Court 

appropriately gave this instruction as it was appropriate in light of the facts and 

circumstances of this case, and it was an accurate statement of the law of mail and 

wire fraud. United States v. Seidling, 737 F.3d 1155, 1160-62 (7th Cir. 2013) (“This 

Court has found that mail fraud under 18 U.S.C. § 1341 does not require the 

defendant to communicate directly with his victims.”); United States v. Cosentino, 869 

F.2d 301, 304-07 (7th Cir. 1989).

IV. CONCLUSION 

For the reasons stated herein, the government respectfully requests that the 

Court deny defendant’s motion under Federal Rule of Criminal Procedure 33. 

Respectfully submitted,

JOEL R. LEVIN

Acting United States Attorney

By: s/ Patrick M. Otlewski

PATRICK M. OTLEWSKI

MEGAN CUNNIFF CHURCH

Assistant U.S. Attorneys

219 South Dearborn St., Rm. 500

Chicago, Illinois 60604

(312) 353-5300

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Dated: July 14, 2017

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