FILEI)

v.

NAWOMI AWOGA;

MARINA OKE, also known

Fandohan; and

ASSIBA LEA FANDOHAI$

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

as, Marina

NO aOCR -.?g?

UNDER SEAL

Violations: Title 8, United States Codes

Sections 1 324(a) (1) (A) (iii),

a JUL 23 2o2o

"rrJ['?i$'EfSB+"SuRr

UNITED STATES OF AMERICA

I B2a@) (r) (A) (vXI), and Bza@) $) (B) (i);

I Title 18, United States Code, Sections

I rsa01a111), 1b89(ax4), 1b89(d) and 2

couNr oNE IUIICE BTAI(EY

The SPECIAL MAY 2019 GRAND JURY charges:

1. At times material to this indictment:

MEfiIEXN,ATE JUDGE WETSMAN

a. Benin is a country located in West Africa.

b. In June 20L4, Victim A was a l4-year-old Benin citizen and

national.

In June 20L4, Victim B was a L2-year-o1d Benin citizen and

national.

d. Defendant NAWOMI AWOGA is the mother of defendants

MARINA OKE (a.k.a. Marina Fandohan) and ASSIBA LEA FANDOHAN.

e. Defendant NAWOMI AWOGA is a citizen of Benin, who resided

at various times with defendants MARINA OKE at Residence A, located in Country

CIub Hills, Illinois, and ASSIBA LEA FANDOHAN at Residence B, located in Hazel

Crest, Illinois, in the Northern District of Illinois.

1

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A BllB2 visa generally permits individuals to enter the United

States temporarily for purposes of pleasure or tourism. Individuals who enter the

United States on these visas are not permitted to work under the terms of the visa.

An individual who remains in the United States afber expiration of the visa or who

works in violation of the terms of the visa is present in the United States in violation

of immigration laws.

2. Between in or around June 20L4, and continuing until on or about

October 2078, in the Northern District of lllinois, Eastern Division, and elsewhere,

NAWOMI AWOGA,

MARINA OKE a.k.a. Marina Fandohan, and

ASSIBA LEA FANDOHAN,

defendants herein, conspired to conceal, harbor, and shield from detection,

unauthorized aliens as described below.

3. It was part of the conspiracy that, in June 20L4, Victim A and Victim B

left their families in Benin to live with defendant NAWOMI AWOGA in Benin, Africa.

4. It was further part of the conspiracy that, while living with defendant

NAWOMI AWOGA in Benin, defendant AWOGA coached Victim A and Victim B to

make false representations to U.S. Custom Officials regarding their family

relationships and status for the purposes of obtaining a visitor visa to enter the

United States. Specifi.cally, among other false statements, Victim A and Victim B

were directed by defendant AWOGA to identify co-conspirator A and co-conspirator

B as their parents and to state that they were sisters.

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5. It was further part of the conspiracy that, on or about September 9,

2014, defendant AWOGA caused the U.S. government to issue Victim A and Victim

B a classifi.cation BLIB? visa to enter the United States. The visas were valid for six

months upon entry into the United States.

6. It was further part of the conspiracy that the visas were issued under

the false names provided. to Victim A and. Victim B by co-conspirator A, co-conspirator

B, and AWOGA.

7. It was further part of the conspiracy that, on or about September 24,

2014, Victim A and Victim B traveled to the United States with defendant AWOGA,

co-conspirator A and co-conspirator B. Pursuant to their visas, Victim A and Victim

B were required. to leave the United States by March 23,2075.A-fter that date, Victim

A and Victim B were no longer allowed to legally remain in the United States.

8. It was further part of the conspiracy that, afber arriving in the United

States, Victim A and Victim B Iived with defendant MARINA OKE and her family at

Resid"ence A, Iocated in the Northern District of Illinois.

9. It was further part of the conspiracy that in or around November 2014,

Victim B was moved from defendant MARII{A OKE's home to live with defendant

ASSIBA LEA FANDOIIAN and her family at Residence B, Iocated in the Northern

District of Illinois.

10. It was further part of the conspiracy that between August 2017 and

October 2018, afber becoming aware of the investigation, defendants took steps to

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prevent law enforcement from locating Victim A, to include shuttling Victim A among

homes of third parties.

11. Beginning no later than in or around June 2074, and continuing until at

least in or around October 2018, in the Northern District of Illinois, Eastern Division,

and elsewhere,

NAWOMI AWOGA, MARINA OKE a.k.a. Marina Fandohan, and

ASSIBA LEA FANDOHAN,

defendants herein, did conspire with each other and others known and unknown to

the Grand Jury to conceal, harbor, and shield from detection Victim A and Victim B,

in Residences A and B, who the defendants knew and recklessly disregarded the fact

that the aliens had come to, entered, and remained in the United States in violation

of the law, in violation of Title 8, United States Code, Section B2a@)G)(A)(iii);

In violation of Title 8, United States Code, Section 1324(a)(1)(A)(vXI).

4

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COUNT TWO

The SPECIAL MAY 20Lg GRAND JURY further charges:

1. The allegations in paragraphs 1, and 3 through 8 of Count One of this

indictment are incorporated here.

2. Beginning in or around March 24, 20L5, and continuing through on or

about August 9, 2017, in the Northern District of Il1inois, Eastern Division, and

elsewhere,

MARINA OKE, a.k.a. Marina Fandohan,

d.efend.ant herein, for the purpose of private financial gain and for commercial

advantage, concealed, harbored and shielded from detection Victim A, at Residence

A, Country Club Hills, I1linois, and at Business A, Homewood, Illinois, knowing and

in reckless d.isregard of the fact that the alien had come to, entered, or remained in

the United States in violation of law;

In violation of Title 8, United States Code, Sections 1324(a)(1)(A)(iii) and

nza@)G)(B)(0.

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COUNT THREE

The SPECIAL MAY 20Lg GRAND JURY turther charges:

1. The allegations in paragraphs 1, 3 through 7, and 9, of Count One of

this indictment are incorporated here.

2. Beginning in or around March 24, 2015, and continuing through on or

about September 6, 20L6, in the Northern District of lllinois, Eastern Division, and

elsewhere,

ASSIBA LEA FANDOIIAN, and

NAWOMI AWOGA

defendants herein, for the purpose of private financial gain and for commercial

advantage, concealed, harbored and shielded from d.etection Victim B, at Resid"ence

B, Hazel Crest, Illinois, knowing and in reckless disregard of the fact that the alien

had come to, entered, or remained in the United States in violation of law;

In violation of Tit1e 8, United States Code, Sections 1324(a)(1)(AXiii) and

B2a@)G)(BX| and Title 18, United States Code, Section 2.

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COUNT FOUR

The SPECIAL MAY 20Lg GRAND JURY turther charges:

1. The allegations in paragraph 1 of Count One of this indictment are

incorporated here.

2. Beginning in or around September 20L4, and continuing through in or

about August 20L7, in the Northern District of Illinois, Eastern Division, and

elsewhere,

MARINA OKE, a.k.a Marina Fandohan,

defendant herein, knowingly obtained the labor and services of a person, namely

Victim A, by means of: (a) serious harm and threats of serious harm to Victim A or

another person; and @) a scheme, p1an, and pattern intended to cause Victim A to

believe that, if Victim A did not perform such labor and services, Victim A or another

person would suffer serious harm;

In violation of Tit1e 18, United States Code, Sections 1589(a)(1), (a)(4) and (d).

7

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COUNT FIVE

The SPECIAL MAY 2079 GRAND JURY further charges:

1. The allegations in paragraph 1 of Count One of this indictment are

incorporated here.

2. Beginning in or around October 20L4, and continuing through on or

about September 6,2016, in the Northern District of Illinois, Eastern Division, and

elsewhere 2

ASSIBA LEA FANDOIIAN and

NAWOMI AWOGA

defendants herein, knowingly obtained the labor and services of a person, namely

Victim B, by means of: (a) serious harm and threats of serious harm to Victim B or

another person; and (b) a scheme, p1an, and pattern intended to cause Victim B to

believe that, if Victim B did not perform such labor and services, Victim B or another

person would suffer serious harm;

In violation of Title 18, United States Code, Sections 1589(a)(1), (a)(4) and

(d), and 2.

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FORFEITURE ALLEGATION

The SPECIAL MAY 2019 GRAND JURY further alleges:

Upon conviction of an offense in violation of Title 8, United States Code,

Sections L324(a), as set forth in this indictment, defendants shall forfeit to the United

States of America the gross proceeds of such violation, and any property traceable to

such conveyance or proceeds, as provided in Title 18, United States Code, Sections

982(aXG)(A) and Title 8, United States Code, Section 1324(b)(1).

A TRUE BILL:

FOREPERSON

rNrrED srArES At'+soKHJimothv 

J' storino on behalf of the

9

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