Defence-Forfeiture-2003

8/7/2019 Defence-Forfeiture-2003

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Response to Tri-Valley University Forfeiture of Properties: Scheme to Defraud

FACTS

The “Sham” claim of Tri-Valley University is a true “Sham”. Since the inception on

March 17th, 2008, Tri-Valley University is able to implement a cutting-edge

technology of class instruction model which is able to live broadcasting every class

meeting with video, audio, chat, desktop sharing, document sharing, and recording

functions. The TV broadcasting capability allows people at work attend class

meeting in their computer in the evening, and house wifes and mothers to attend

the class meeting at their home. Each TVU’s course contents also have good quality

and direct practical industry application. As a matter of fact, from its inception

March 17th, 2008 to Fall of 2009 (Feb17th, 2009 when TVU received approval for

SEVIS to enroll international students), more than one year, Tri-Valley University’s

students, highly educated and majority Ph.D. students, are all American Citizens,

completely have nothing to do with immigration and international student visa, andmore ICE and SEVIS.

17. “In or about April 2008, SU and others, files articles of incorporation for Tri-

Valley University, Inc. in which SU is designated as the Chief Operating Officer, a

director and agent for services of process”

Actually, Tri-Valley University is incorporated on March 17th, 2008, St, Patrick day,

and Dr. Susan Su, the President is the founder and Chief Executive Office.

18, The accusation of Su, file false document for I-17 approval is wrong. According

to I-17 regulation for an unaccredited school, a school will need to provide the

evident of 3 students transferring to and accepted by 3 accredited schools or

graduate 3 students, or have 3 articulation agreements with 3 accredited schools.

At the time of I-17 petitions, TVU did not have any students transferring to other

universities, either did not have 3 graduates. Tri-Valley University enters into

articulation agreement with 3 accredited universities. One is the San Francisco

State University, one is Central Florida University, and one is University of East

Western Medicine. For University of East Western Medicine, an accredited private

school, the President and Founder Ying Chiu Wang, who has the full authority on all

academic programs, both gave the original signatures on the articulationagreement. That is legally perfect! For San Francisco State University, protocol for

each individual course is that TVU need have an articulation office to contact their

articulation office to submit the proposed exchange courses syllabus, that office

then submit to their Dean office for the Dean to review, Dean’s decision then come

back to the office, some paper then to file. Dr. Su taught ENGR 356 and ENGR378 at

SFSU, which are courses taught before by the Dean Dr. Hu at San Francisco State

University. Dr. Su has many technical discussions with Dean Dr. Hu. Dr. Hu knew



Dr. Su very well. Later on when Dr. Su started Tri-Valley University, She actually

invited Dr. Hu to be the Chair of the Advisory Board to which Dr. Hu accepted with

delight. Then Dr. Su E-mailed Dr. Hu, who then are the Chair of Advisor Board and

discussed about TVU’s next stage of development plan to apply for I-17 and to

admit international students, to which Dr. Hu fully supported. With respect to the

courses transferring, Dr. Hu ask Dr. Su to E-mail him all of the VLSI Engineeringcourses syllabus for him to review. Initially Dr. Su thought for the unaccredited

school requirement of 3 accredited schools articulation agreements, each school

only need to articulate one acceptable course. So Dr. Hu selected two courses

CS300 equivalent to ENGR 356, and EE316 Digital System Design with Verilog

equivalent to ENGR 378 at SFSU, he wrote a letter with his original signatures to Dr.

Su, and also ask Dr. Su bring the letter and the Articulation Agreement to the

Director in School of Engineering Dr. Liou who is the executive for this matter for his

signatures. At that time, Dr. Liou was in Suzhou, he signed with his electrical

signature, and later on mailed Dr. Su the hardcopies with his original signatures.

Later on, Dr. Su submitted the articulation agreement to SEVP, the officer at the

SEVP direct Dr. Su to modify the content to be in compliant with the requirement to

accept course in engineering. Dr. Su resubmitted the one to SEVP and E-mail Dr.

Liou for the record. At that time Dr. Liou was the active Director of Engineering, his

signature bear the authorization of the Articulation Agreement. And the Articulation

Agreement is legally valid! At that time, Dr. Liou worked at Suzhou in China, the

Articulation Agreement may not be passed to office for record, maybe the reason

why two years later an ICE agent did not find the right person for verification.

The third articulation is Central Florida University, Department of Statistics and

Computer Science. The Department accepts courses transferring in case by case

bases, reviewed by Dr. Sean Su, who serveda s the graduate advisor at theDepartment at that time. The Department chair asked to contact Dr. Xiao-Gang Su,

who is also Dr. Susan Su’s brother and that time cofounder of the University. Dr.

Sean Xiao-Gang Su reviewed the courses content and found several transferring

courses as listed in the Articulation Agreement. SEVP officer has verified after the

submission. Now it has to be clarified the meaning of Articulation Agreement by

definition is articular, normally for university to enter with another university in

contract format, so that later on students can transfer. However it does not mean

the students already transfer. The ICE officer who is not in the field of education

seems to misunderstand the meaning of the Articulation Agreement. Soon later, the

department suffers from closure due to the budget cut, many people left the

department.

At the time of application the Articulation Agreement has been instructed by an

office from SEVP office to modify the word in a standard TVU Articulation Agreement

to be in compliant with the regulation for an unaccredited school, he later on also

call for the three schools for verification which was the normal verification

procedure before he grant the approval for TVU’s to admit international students.



However now 3 years later, ICE officers tried of verify again, with the Director of

School of Engineering of SFSU working in Suzhui at China. Department at Central of

Florida University was scheduled to close due to budget cut, then force to reopen,

effort to close again, and reopen, many people who processed the previous paper

work already left the department. The ICE officer may not be able to find the right

person to verify, but that does not mean that the contracts are not true. Thearticulation agreements bear the authority’s signatures which are genuine. If the

Dean did not instruct his staff to place in their system or office due to the office

change, it is their university’s operation problem. If the department is closed, they

can not locate their documents, it is also their management problem.

The SEVP representatives verified and approved TVU application at that time. TVU

has the legal authority to admit international students and also listed on SEVP

website for approved schools. TVU’s then admitted international students are all

legal. Now ICE wants to reverse that approval with the “Sham” accusation and act

(they asked SEVIS to terminate out school access however with different reasons).

Now so many good students’ lives are affected and majority TVU’s students are

double master students, or working professionals. If TVU did not receive SEVP

approval for admit international students two year ago, we shall have enough

energy to develop our international level of accreditation of our academic program

and marketing. TVU’s classroom can be accessed at everywhere in the world at

different countries. TVU would have already become a multi-billion university, the

government agency shall be responsible for this lost with the same reasoning here.

19. The statement “DHS approved TVU’s I-17 application which contain false

statement and misrepresentations” is wrong. TVU is a SEVP verified and approved

legitimate School can admit international students. TVU charged qualified

international students to register TVU’s classes and study TVU’s class material with

the same fee as a US students pay. Normally, university will charge international

students for non-residential fee. However TVU has not charged a single extra penny

for international student VISA. TVU only has 100 students who took TVU i20 have

received a VISA, and the fee is $50/student, most of the student coming for

consultant, even the $50 fee is waived. The $900/course fee they paid is to register

and enroll into TVU quality class instruction which is taught by quality instructor in

TVU expensive cutting-edge virtual classroom. They paid fee for each course

($900/course) as anyone else to learn the quality course material. The sham claim

“TVU is sham university which SU and others, are using to provide visa related

documents at enable foreign national to illegally obtain student visas in return fortuition fees” is completely “Sham”. TVU is authorized by SEVP to sponsor full-time

international students visa which is complete legal. Furthermore, not a single cent a

foreign student paid to TVU is to buy a visa or even Fedex a visa related document

I-20 or anything (Separate charge of $35, no profit from this at all, sometime a

FedEx even cost more than $35, we have to switch to priority mail to reduce cost to

us). ICE has no base and right to claim any penny back or take any cent from the





20. Starting in April, one of student assistant Anji Reddy who worked in TVU adm

office, teamed with another student Ram Krista Karra who also have a consultant

company, conducting a large cheating scheme by asking students to make tuition

payment into Ram Krista Karra’s personal account in exchange for student I20 and

CPT approval. TVU had fired these two individuals. After the firing, these two

people spread viscous rumor among VTU students, the President have maked Publicannounce about these two individual’s wrong doing into the entire TVU students.

They continue to threaten TVU student. TVU file a police report. In the fear of a fate

that they deserved, to be frozen bank account and departed from US, those two

individuals continue their vicious attack effort and spread rumor, also went to SF ICE

office to make same false, wrong statements about the University administration.

We believe that ICE agents have committed adultery with the real criminal and

misled by the vicious wrong accusation by the two criminals to conduct such a

“Sham” act.

Regarding student address is the ABS consultant address who is responsible for all

TVU’s initial international students. TVU signed a contract with ABS that they willreceive 20% of each international student’s tuition fee as the referral fee, and theirresponsibility including recruiting, referring students, VISA interview consultant,status change consultant, reinstatement consultant as well as airport pickup andaccommodation. TVU’s first hundred of international students are all taken care of by ABS consultancy. From Application, they are all input the ABS consultancy’s CAaddress. When students arrive in California, they were picked up by ABSconsultancy, temperately stay with them for couple of day. ABS then arranged themto stay at an apt in the same complex which ABS rent and charge the student forrental fee.

That staff’s (Anji Reddy who actually committed stealing money and cheated

student and was fired) misunderstanding of concealing the fact that the studentwho live outside of in California is apparent his limited knowledge andinterpretation. “Conceal a fact” claim is never true (but indeed a vicious attempt totear the university down by that fires staff teamed with another criminal personRam Krista Karra). The University never told any staff in that way. As a matter of fact TVU’s ADM office wrote numerous DMV verification letters to many differentstates of our government agency stating that the student’s residence at a differentstate but attending classes over here. TVU later on hired staff to update studentactual physical address, not the consultant address. With the frequent change of student address and quick growth of admitted students; the staff never completedthe work.

As regulation 8 CFR 214.4 (a) (2) (i) (iii) states, we are actually in compliance withthis regulation: the University communicated with all students through ABS address.Letters mailed to ABS address at: 555 E El Camino Real APT 415, Sunnyvale, CA;ABS members will FedEx to student’s address with their own expense. With thispractice, TVU has indeed honored the controlling regulation: 8 CFR 214.4 (a) (2) (i)(iii), “In the event the student or his or her dependents cannot receive mail at suchphysical residence, the school must provide a mailing address in SEVIS”. The



address input in SEVIS is exact provided by the school, and effective working, and isthe school legally contracted and give the authorization of the responsibility.

21. This claim is a typical verification of the wrong and word of the two criminal

individual fed and misled the ICE agents. First of all, anyone who have the complete

access to every account, for example the President, can not even give a percentage

of how many students are paid through credit cart, and paypal, and cash or check.

Where do these data come from? Also the President never told anyone she process

all American Express Payment from home. What is that for? This time also show the

fact that accusation agent is so blind and also misled by the false accusation of two

criminal people. And further more, the University first year half year started at the

President home at 3518 Ovella Way ( everthi9gn is processed at that home office),

even if she did process American Express payment at home, what is wrong with

that?

22. This is another typical verification the ICE committed adult with the same

criminal person conducting the sick vicious attack to the President. The Presidenthas the authority to supervise each department of the university including

international student affairs. In SEVIS system, only PDSO’s account has the

authority to bring a “cancelled” student back to “initial” state. All of TVU’s

complicate cases of international students are all handled by the President who is

properly retrained as a DSO office, who is also constantly consultant with SEVIS help

desk in the school’s name in resolving each situation properly with SEVIS regulation.

Because TVU’s PSDO only work part-time, the PDSO Sophie Su who is the sister of

the President has give the President the permission to sign the I20 in her behalf.

23. This is a typical verification the ICE committed adult with the same criminal

person conducting the sick vicious attack to the President. After TVU file policereport the Police advice us that every time this people come into the office, we shall

call the police. On that day when Anji Reddy walked into TVU office , the President

plans to call the Police immediately, but for minimum disturbance of the office

operation, the President agree to speak to this individual for couple of minutes. This

student repent to the President that he brought back the money that he (He is

never authorized to collect the fee from student account) collected from the

students and if he did not return, Police found out he will be in much trouble, and

ask for coming back to the office to work, to which the President declined due to the

mess damage and vicious attack he did to TVU. He then left the office, however for

those two students he brought the money to register class, he hided the students E-mail address and the phone number. Both of these two students not even have a

TVU account to enroll into the classroom from our ADM office (in order to create a

TVU account, need the Student’s E-mail address). The President sent him several

reminders to create the students TVU account, which he failed to compliant.

However, the President has too many things to deal with each single day, we

normally rely on SEVIS system automatically terminate the students two months



after the next term starting day, which is perfectly in compliant with the SEVIS

regulation on termination of students record.

24. Same as the “Sham” claim, another real “Sham” item here. The President does

remember the visit of the “airport officer” “Dale”s phone call. She then was

observed by another ICE agent to quickly exit the TVU office and get an item fromher Mercedes Benz—the printer cartridge and office supply item – have absolute

nothing to do with the “a few minute later the ICE agent received the I20”. These

two events have absolutly no connection together. As a matter of fact, after she

received the phone call, she actually gave the ICE agent E-mail address to an office

staff and instruct that office staff to find the student record and sent to the ICE

agent’s address. The signatures has also illustrated in item 22.

25. Same as above item 24.

26. These FACTS about TVU’s financial accounts are true.

27. The way how TVU’s tuition is paid are all published on website, the methods the

tuitions are paid are true. Also many international students paid the first

installment, but never complete the second and third installment payment even

from the previous years. However, little of tuition on non-foreign nationals are not

quite true. TVU total have 5000 students, only 1555 are international active

students. TVU have many students who are US citizen students, Green card holders,

and H1 and H4 VISA holders.

28. In order to build up the university, it is clearly written in TVU’s five-year

Strategic Plan that for at least the first Two year that the President will work for the

university voluntarily without salary, so does the other two family members, her

sister Sophie Su and her husband Vince Wang.

29. TVU is a legally S-corp. business, is licensed to legally operate in Pleasanton

California. To build up the university, the President does not think about her

personal benefit first, but to use the legitimate tuition income to buy an office

building for the university, student apt, Staff house, and finally the Presidential

Residential House. As a S-corp, the President owns the TVU. The President’s

dedication and self-sacrifice to build up the University can not be misunderstood or

twisted as the “Sham” accusation.



ICE bring this baseless allegation and put a red-tape in the school operation for a

Fed investigation, caused hundreds students withdraw from classes, many

instructor request to quit teaching for the current term. Also It cause a profitable

university operation quickly sink into negative in financial debt.

30. TVU’s student enrollment exponentially grow, it is because TVU’s education

model, the very practical industry related academic course content, the live real-

time class instructional model, have nothing to do with the international approval.

There are many university in the bay area, also have international student approval,

and even lower of tuition, but does not grow as successfully as TVU. Students join

TVU learn TVU’s unique valuable education material, courses content.

TVU has not charge any money for the VISA related document I20, the I20 simply

allows a student legally study in US, they can study outside of US. TVU only have

140 or so students take a TVU I20 and gain a student F1 VISA, and also lot of them

transferring to other University when arrive at TVU. For issue a I20 for student to

apply a F1 VISA, the fee TVU charged is $50 Admission Fee, and most of the student

applied form TVU contracted consultant, $50 fee is waived. 90% of TVU student

already have a VISA and for studying a MS degree in US, and transfer to TVU for a

Ph.D. degree. Their VISA status is gained from the previous degree. Student paid

fee is only for registering class to study the course content, they click the course

link to make a payment of each course and enter into the classroom. We have not

even charge any other “tuition” fee, other than each course content, and the course

fee are standard for everyone. Student transferred to TVU after Master for Ph.D. is

because TVU is able to offer them live remote access the class meeting, and allow

them to work while study; and also study their work related course content.

Student referral program is practice by every university in the US. Every TVU

student if they open their home and project the class meeting on the wall is a small

TVU. TVU ‘s referral program is also extended to each TVU student.

33-53 are true, to use the university’s tuition income to buy building for the

university office (405 Boulder Ct, 700-800), Student dormitory (133 Livermore);

Staff House (2890 Victoria Ridge), and the Presidential Residential House (1371

Germano Drive), what wrong is it? The University is a S-corp owned by Dr. Su, all of

the house has to be owned by a person, ---only Dr. Susan Su



Ever since its inception on St. Patrick day on March 17 th, 2008, Tri-Valley University

has been extremely luck in realizing every important implementation only guided by

God grace. For 3 years, the University has gone through the stage of from none (or

scratch) to an existing school, and grown into a multi-million profitable S-corpbusiness in 3 years. But due to this “Sham” investigation and unapproved news

release, students are requesting refund for half a million every single day (student

even dispute for previous years course fee paid by credit card). Within 2 week, the

government turns a woman owned profitable small business into a deep indebt

bankruptcy company. We would also ask for the government to return for the

damage that they did during this “Sham” operation. And the very first thing is:

We would like to request ICE to public acknowledge that the “Sham” claim is a true

“Sham”, and also in deed.

This “Sham” allegation and act laid a ground for a serious lawsuit against the ICE

and government agent. We would like to file a law suit now to the government

agent (ICE and SEVP) for bring thousands of people this “ Sham” mess.

It is the government’s mistakes to cause so many innocent life in a “Sham” mess. (If

these Ice people’s wrong allegation is true, then it is the office 2 years ago who

verify the document made some mistake to give the permission, of legally enroll

international students, so many students’ life is affected, and majority TVU’s

students are double master students, or working professionals. If TVU does not

receive SEVP approval for admit international students, we shall have enough

energy to develop our international level of accreditation of our academic program

and marketing). TVU’s classroom can be accessed at everywhere in the world atdifferent countries. TVU would have already become a multi-billion university, The

government agency is responsible for this lost with the same reasoning here.

With the wrongly “Sham” accusation, any TVU students who has received TVU’s

instruction for the past 3 years, and attend TVU’s quality class, also have a ground

file for credit card dispute for the fee they paid to attend TVU’s classes. This “Sham”

act, put a multi-million profitable small business into a deep in-debt one within two

weeks.

The ICE government shall be responsible to the damage their “Sham” investigation

caused. The President has brought the matte the attention of the White House, thePresident of US.

Documents

Defence-Forfeiture-2003