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Alexandria Division
KISHORE KONDA,
Defendant. )
(hereinafter "HSI"). HSI isan investigative division ofthe Department ofHomeland Security
(hereinafter "DHS") and the successor to many law enforcement powers of the former
Immigration and Naturalization Service (hereinafter "INS"). I have been a Special Agent with
HSI and INS since June 2002, and am currently assigned to the HSI field office in Fairfax,
Virginia. Prior tothat I was an INS Immigration Inspector at Dulles International Airport from
November 1997 until June 2002. My duties include investigating and enforcing violations of the
immigration and nationality laws of the United States. I am a graduate of the Federal Law
Enforcement Training Center's Criminal Investigator Training Program and have also received
2. This affidavit is submitted in support of a criminal complaint and arrest warrant for
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Case 1:11-mj-00034-TCB Document 3 Filed 01/14/11 Page 2 of 4
Immigration Fraud in violation of Title 18, Unites States Code, Sections 371 and 1546(a).
obtained through the use of law enforcement computerized databases. This affidavit does not
contain every material fact I have learned during the course of this investigation. Rather, this
affidavit contains information necessary to support a finding of probable cause for a criminal
4. Konda is a native and citizen of India who was admitted into the United States as a
5. Konda, Prashanth Goguri (Goguri) and Mannem Reddy (Reddy) are three of the
principal owners of Symmetric Solutions, Inc., which does business as Minerva Indian Cuisine,
and includes other related retail businesses in Virginia, Maryland, and other locations in the
United States.
for Symmetric Solutions, Inc., at a salary of $40,000 per year. Konda signed the Form 1-129
after certifying, under penalty of perjury under the laws of the United States of America, thatthis
petition and the evidence submitted with it are all true and correct. Konda then submitted the
Form 1-129 to U.S. Citizenship and Immigration Services (CIS). Based on the false information
submitted by Konda, the Form 1-129 was approved by CIS on February 12, 2007.
Case 1:11-mj-00034-TCB Document 3 Filed 01/14/11 Page 3 of 4
7. On or about February 17, 2010,1 interviewed M.T., who told me that he was never
employed as a Management Analyst by Symmetric Solutions, and he was not paid $40,000 per
year as stated in the form 1-129. Instead, M.T. was employed as a waiter and restaurant manager
at various Minerva Indian Cuisine restaurants owned by Konda, Goguri and Reddy.
8. From in and around 1998 to in and around 2010, the defendant and his business
Immigration and Naturalization Service) forms 1-129,1-140,1-485, and the Department of Labor
Form ETA 750, on behalf of aliens who were employed by Symmetric Solutions in the restaurant
and retail aspects of the business rather than in the field of computer technology, as fraudulently
9. These applications were submitted by Symmetric Solutions Inc., with addresses listed
in Herndon, Virginia, and Fairfax, Virginia, both within the Eastern District of Virginia, to a CIS
Service Center, which ultimately caused the applications to be adjudicated at the CIS Office in
Fairfax, Virginia.
10. The defendant and the other co-conspirators assisted the aliens in the preparation of
their paperwork submitted to CIS by providing the necessary tax information and employment
documents and in some instances by signing the applications and supporting documentation.
During that time, the defendant and his co-conspirators assisted with the filing of approximately
24 fraudulent employment applications with CIS to secure lawful permanent residence status
and/or HIB Temporary status for aliens who were not eligible to receive those benefits.
11. My investigation revealed that the aliens did not work for Symmetric Solutions in the
positions described in their applications and supporting documentation, but were rather
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employed in restaurants and retail businesses in Virginia, Maryland, and other locations in the
United States.
12. I participated in interviews of Reddy on or about June 21, 2010, and August 25,
2010, in which Reddy told me that he, Konda and Goguri all signed Forms 1-129, and other
professionals to work for Symmetric Solutions, but in fact these aliens were employed as
13. Based upon the above information and upon my training and experience, I have
probable cause to believe that Konda knowingly conspired with others to commit offenses
against the United States, and to defraud the United States in violation of Title 18, Unites States
Code, Section 371, and knowingly subscribed as true (under penalty of perjury under section
1746 of title 28, United States Code) any false statement with respect to a material fact in any
prescribed thereunder, or knowingly presented any such application, affidavit, or other document
which contains any such false statement or which fails to contain any reasonable basis in law or