Preview
FILED: BRONX COUNTY CLERK 01/22/2024 10:00 AM INDEX NO. 801163/2024E
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 01/22/2024
OFFICE OF THE ATTORNEY GENERAL LETITIA JAMES
STATE OF NEW YORK DEPARTMENT OF LAW
BUREAU OF CONSUMER FRAUDS AND PROTECTION Consumer Hotline
28 Liberty Street (800)771-7755
New York, NY 10005 TDD (800)788-9898
Tel: (212)416-8300 | Fax (212)416-8787 http://www.ag.ny.gov
Intake Id 1-762416442
Complaint Bureau
Bureau Where You Filed Your Complaint NYC
Your Information
First Name Gabriel
Last Name Rojas Leon
Your Business/Organization Name
Street Address 4330 Elbertson St
Address Line 2 3 FLR
City/Town ELMHURST
State NY
County NEWY
Zip/Postal Code 11373
Country US
Email Address rojasleon1010@gmail.com
Phone Number 917-375-8103
Alternate Phone Number
Complainant's Information
First Name Elpidia
Last Name Leon Nava
Your Business/Organization Name
Street Address 4330 Elbertson St
Address Line 2 3 FL
City/Town ELMHURST
State NY
County NEWY
Zip/Postal Code 11373
Country US
Email Address rojasleon1010@gmail.com
Phone Number 917-375-8103
Alternate Phone Number
FILED: BRONX COUNTY CLERK 01/22/2024 10:00 AM INDEX NO. 801163/2024E
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 01/22/2024
Subject of Your Complaint
Are you complaining about a person or a company? PERSON
First Name Kofi
Last Name O Amankwaa Esq
Street Address 881 Gerard Ave
Address Line 2 Suite 700
City/Town Bronx
State NY
Zip/Postal Code 10452
Email Address Koamalaw2i@gmail.com
Phone Number
Website
Additional Complaint Information
Location of Incident/Transaction 881 Gerard Ave Suite 700 Bronx, NY 10452
Date of Incident/Transaction 2021-07-21
Name of Product or Service Legal Services
Cost of Product or Service $3,000
Method of Payment CASH
Complaint Description
Around July 2021, my mother and I hired Mr. Kofi Amankwaa (BAR # 2742773) to help us adjust my
mother's immigration status. During my first meeting with Mr. Kofi, he assured me that he would
immediately send paperwork to immigration to help my mother get legal status. Despite me asking, Mr.
Kofi refused to explain in detail what applications he was sending to immigration or what the
process looked like. From July 2021 up to the present, I have been asking what applications he has
been submitting to immigration and how long it would take. At no point in the representation, did
Mr. Kofi or his son Junior, his legal assistant, tell me that they were filing fraudulent
applications. Specifically, they never told me nor my mom that they submitted an application to
immigration where they falsely claimed that my mother was a victim of abuse by her US citizen child,
myself. It was not until I requested my mother's personal file that we realized that they submitted
fraudulent immigration forms, forged letters and documents and submitted fraudulent evidence. For
example, in the I-360, they claimed that my mother is seeking legal status because she is a victim
of abuse by a US citizen child which is holly untrue. They then submitted falsified letters from my
uncle, brother and family friend who allegedly witnessed the abuse my mother endured. However, I
spoke to these people and they confirmed that they never wrote nor signed any of these letters. This
demonstrates that Mr. Kofi and his son submitted fraudulent documentation to immigration on behalf
of my mother. On November 17, 2023, I emailed Mr. Kofi and Junior why they submitted and forged
these documents. To no surprise, they did not respond. I also asked for a full refund and they also
ignored my request. Because of their deceiving practices, my mother is now at risk of being placed
in deportation proceedings and likely being deported and being separated from her family.
Did you sign a contract? Y
Where? 881 Gerard Ave Suite 700 Bronx, NY 10452
When? 2021-07-21
FILED: BRONX COUNTY CLERK 01/22/2024 10:00 AM INDEX NO. 801163/2024E
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 01/22/2024
Was product or service advertised? N
Have you already complained to company/individual? N
Has matter been submitted to another agency or attorney? N
Is court action pending? N
What form of relief are you seeking, e.g., refund, credit, exchange, repair?
Refund and litigation
Manufacturer of Product
Street Address
City/Town
State/Town
Zip/Postal Code
Product Model or Serial Number
Warranty Expiration Date
Did Business Arrange Financing?
Uploaded Documents
User Uploaded Document Names Emailsinteractions.pdf
RFEDOCUMENTSCCF_003528.pdf
i360.pdf
In filing this complaint, I understand that:
The Attorney General is not my private attorney, but represents the public in enforcing laws designed to protect the
public from misleading or unlawful business practices. My filing this complaint does not mean that the Attorney
General has initiated a lawsuit or proceeding on my behalf or that it will do so.
The Attorney General cannot give me legal advice or represent me in court. If I have any questions concerning my
legal rights or responsibilities, I should contact a private attorney.
In order to resolve my complaint, the Attorney General may send a copy of my complaint and any documents I
provide to the person or business about whom I am complaining and I authorize that person or business to release
information concerning my complaint to the Attorney General.
The Attorney General works with other state, local and federal government agencies to investigate complaints and
coordinate law enforcement and may also share my complaint with them. In addition, the Attorney General may use
information from my complaint in legal proceedings to establish violations of law.
Any false statement made in this complaint are punishable as crimes, including under Section 175 and/or Section 210
of the Penal Law.
Signature Elpidia Leon Nava
Relationship Self
Date of Affirmation 11-28-2023
FILED: BRONX COUNTY CLERK 01/22/2024 10:00 AM INDEX NO. 801163/2024E
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 01/22/2024
Petition for or Special Immigrant UscIs
Amerasian, Widow(er),
Form I-360
Department of Homeland Security OMB No. 1615-0020
so U.S. Citizenship and Immigration Services Expires 06/30/2022
For USCIS Use Only Fee Stamp Action Block
Returned
Resubmitted
Received
Relocated
Sent
Remarks: ¡ Petitioner/Applicant Classification
Interviewed
¡ Interviewed Beneficiary
Interviewed
Consulate
¡ 1-485 Filed Concurrently
"A" Date
¡ Bene File Reviewed Priority
To be completed by an ® Select this box if Attorney State Bar Number Attorney or Accredited Representative
Form G-28 or (if applicable) USCIS Online Account Number (if any)
Attorney or Accredited
Representative (if any). G-281 is attached. 27 42773
º START HERE - Type or print in black ink.
Part 1. Information About Person or Organization Filing This Petition
NOTE: You must complete Part 1. as the petitioner if you are filing this petition on behalf of another person. If you are a Violence
Against Women Act (VAWA) self-petitioner or special immigrant juvenile, skip to Part 1., Item Number 7.
1. Your Full Name
Family Name (Last Name) Given Name (First Name) Middle Name
LEON NAVA ELPIDIA
2. USCIS Online Account Number (if any) 3. U.S. Social Security Number (if any)
º º
4. Alien Registration Number (A-Number) (if any) 5. Individual IRS Tax Number (if any)
º A- º
6. Mailing Address
In Care Of Name (if any)
KOFI O AMANKNAA ESQ
Organization Name (if applicable)
IAW OFFICE
Street Number and Name Apt. Ste. Fir. Number
881 GERARD AVE ¡ 700
City or Town State ZIP Code
BRONX NY 10452
Province Postal Code Country
USA
Form I-360 Edition 06/09/20 Page 1 of 19
FILED: BRONX COUNTY CLERK 01/22/2024 10:00 AM INDEX NO. 801163/2024E
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 01/22/2024
Part 1. Information About Person or Organization Filing This Petition (continued)
7. Alternate and/or Safe Mailing Address
If you are a VAWA self-petitioning spouse, child, parent, or a special immigrant juvenile and do not want U.S. Citizenship and
Immigration Services (USCIS) to send notices about this petition to your home, you may provide an alternate and/or safe mailing
address.
In Care Of Name (if any)
SAME
Street Number and Name Apt. Ste. Fir. Number
¡¡¡
City or Town State ZIP Code
Province Postal Code Country
Part 2. Classification Requested
Select only one box.
1. A. ¡ Amerasian
B. ¡ Widow(er) of a U.S. citizen
C. ¡ Special Immigrant Juvenile
D. ¡ Special Immigrant Religious Worker
(1) Will the beneficiary be working as a minister? ¡ Yes ¡ No
E. ¡ Special Immigrant based on employment with the Panama Canal Company, Canal Zone Government, or U.S.
Government in the Canal Zone
F. ¡ Special Immigrant Physician
G. ¡ Special Immigrant G-4 International Organization Employee or Family Member or NATO-6 Employee or Family
Member
H. ¡ Special Immigrant Armed Forces Member
I. ¡ Self-Petitioning Spouse of Abusive U.S. citizen or Lawful Permanent Resident
J. ¡ Self-Petitioning Child of Abusive U.S. citizen or Lawful Permanent Resident
K. ¡ VAWA Self-Petitioning Parent of a U.S. citizen son or daughter
L. ¡ Special Immigrant Afghanistan or Iraq National who worked with the U.S. Armed Forces as a translator
M. ¡ Special Immigrant Iraq National who was employed by or on behalf of the U.S. Government
N. ¡ Special Immigrant Afghanistan National who was employed by or on behalf of the U.S. Government or the
International Security Assistance Force (ISAF) in Afghanistan
O. ¡ Broadcasters
P. ¡ Other
Provide the name of the classification below.
Forrn I-360 Edition 06/09/20 Page 2 of 19
FILED: BRONX COUNTY CLERK 01/22/2024 10:00 AM INDEX NO. 801163/2024E
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 01/22/2024
Part 3. Information About the Person for Whom This Petition Is Being Filed
"beneficiary" "self-petitioner"
NOTE: On this petition, the or means the person for whom this petition is being filed. If you provided
an alternate and/or safe mailing address above, you must also complete Part 3.
1. Your Full Name
Family Name (Last Name) Given Name (First Name) Middle Name
LEON NAVA ELPIDIA
2. Mailing Address
In Care Of Name (if any)
KOFI O AMANKWAA ESQ
Street Number and Name Apt. Ste. Fir. Number
881 GERARD AVE ¡ 700
City or Town State ZIP Code
BRONX NY 10452
Province Postal Code Country
USA
Other Information
3. Date of Birth (mm/dd/yyyy) 4. Country of Birth
MEXICO
5. U.S. Social Security Number (if any) 6. A-Number (if any)
º º A-
7. Marital Status ¡ Single ¡ Married Divorced ¡ Widowed
8.- "none,"
Complete Item Numbers 15. if this person is in the United States. If an item number is not applicable or the answer is leave
the space blank. Provide information below for the passport or other document used at the time of last arrival to the United States.
8. Date of Last Arrival (mm/dd/yyyy) 9. Form I-94 Number or I-95 Crewman's Landing Permit
08/12 /1997 º
10. Passport Number 11. Travel Document Number
12. Country of Issuance for Passport or Travel Document 13. Expiration Date for Passport or Travel Document
MEXICO (mm/dd/yyyy) 05/01/2021
14. Current Nonimmigrant Status 15. Date current status expired, or will expire, as shown on
NO STATUS Form I-94 or I-95 (mm/dd/yyyy)
Part 4. Processing Information
1. If the person listed in Part 3. is outside the U.S., is ineligible to adjust status in the U.S., or does not wish to adjust status in the
U.S., provide the following information about the U.S. Consulate at which the person prefers to apply for an immigrant visa.
U.S. Consulate
A. City or Town
B. Country
Forrn I-360 Edition 06/09/20 Page 3 of 19
FILED: BRONX COUNTY CLERK 01/22/2024 10:00 AM INDEX NO. 801163/2024E
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 01/22/2024
Part 4. Processing Information (continued)
2. If a U.S. address was provided in Part 3., type or print the person's foreign address below. If he or she does not maintain a
foreign address, list the city or town and country of last foreign residence. If his or her native alphabet does not use Roman
letters, type or print his or her name and foreign address in the native alphabet.
A. Your Full Name
Family Name (Last Name) Given Name (First Name) Middle Name
LEON NAVA ELPIDIA
B. Mailing Address
Street Number and Name Apt. Ste. Fir. Number
¡¡¡
City or Town
POCHUTLA
Province Postal Code Country
GUERRERO NEXICO
3. Gender of the beneficiary: ¡ Male ® Female
4. A. Are you filing any other petitions or applications with this one? ® Yes ¡ No
"Yes"
B. If you answered to Item A. in Item Number 4., how many? 3
"Yes"
If you answer to Item Numbers 5. - 6., provide an explanation in the space provided in Part 15. Additional Information.
5. Is the beneficiary in removal proceedings? ¡ Yes ® No
6. Has the beneficiary ever worked in the U.S. without permission? (If you are applying for a special
® Yes ¡ No
immigrant juvenile status, you are not required to answer this item number.)
7. Is an application for adjustment of status attached to this petition? ® Yes ¡ No
Part 5. Information About the Spouse and Children of the Person for Whom This Petition Is Being Filed
NOTE: Depending on the classification you seek, you can either file this petition for another person or for yourself. On this petition,
"beneficiary" "self-petitioner"
the or means the person for whom this petition is being filed, whether that person is yourself or another
person.
1. If you are filing as a self-petitioning spouse, have any of your children filed separate self-petitions? ¡ Yes ¡ No
2. Person 1
Family Name (Last Name) Given Name (First Name) Middle Name
Date of Birth (mm/dd/yyyy) Country of Birth
Relationship A-Number (if any)
º A-
¡ Spouse ¡ Child
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FILED: BRONX COUNTY CLERK 01/22/2024 10:00 AM INDEX NO. 801163/2024E
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Part5. Information About the Spouse and Children of the Beneficiary (continued)
3. Person 2
Family Name (Last Name) Given Name (First Name) Middle Name
Date of Birth (mm/dd/yyyy) Country of Birth
Relationship A-Number (if any)
A-
¡ Child º
4. Person 3
Family Name (Last Name) Given Name (First Name) Middle Name
Date of Birth (mm/dd/yyyy) Country of Birth
Relationship A-Number (if any)
º A-
¡ Child
5. Person 4
Family Name (Last Name) Given Name (First Name) Middle Name
Date of Birth (mm/dd/yyyy) Country of Birth
Relationship A-Number (if any)
º A-
¡ Child
6. Person 5
Family Name (Last Name) Given Name (First Name) Middle Name
Date of Birth (mm/dd/yyyy) Country of Birth
Relationship A-Number (if any)
¡ Child º A-
7. Person 6
Family Name (Last Name) Given Name (First Name) Middle Name
Date of Birth (mm/dd/yyyy) Country of Birth
Relationship A-Number (if any)
º A-
¡ Child
Forrn I-360 Edition 06/09/20 Page 5 of 19
FILED: BRONX COUNTY CLERK 01/22/2024 10:00 AM INDEX NO. 801163/2024E
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 01/22/2024
Part5. Information About the Spouse and Children of the Beneficiary (continued)
8. Person 7
Family Name (Last Name) Given Name (First Name) Middle Name
Date of Birth (mm/dd/yyyy) Country of Birth
Relationship A-Number (if any)
A-
¡ Child º
9. Person 8
Family Name (Last Name) Given Name (First Name) Middle Name
Date of Birth (mm/dd/yyyy) Country of Birth
Relationship A-Number (if any)
º A-
¡ Child
10. Person 9
Family Name (Last Name) Given Name (First Name) Middle Name
Date of Birth (mm/dd/yyyy) Country of Birth
Relationship A-Number (if any)
º A-
¡ Child
Part 6. Complete Only If Filing for an Amerasian
Information About the Mother of the Amerasian
1. Mother's Full Name
Family Name (Last Name) Given Name (First Name) Middle Name
2. A. Is the mother still alive? ¡ Unknown ¡ Yes ¡ No
"Yes"
B. If you answered to Item A. in Item Number 2., provide her address below.
In Care Of Name (if any)
Street Number and Name Apt. Ste. Fir. Number
¡¡¡
City or Town State ZIP Code
3
Province Postal Code Country
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FILED: BRONX COUNTY CLERK 01/22/2024 10:00 AM INDEX NO. 801163/2024E
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 01/22/2024
Part 6. Complete Only If Filing for an Amerasian (continued)
"No"
C. If you answered to Item A. in Item Number 2., provide her date of death (mm/dd/yyyy).
Information About the Father of the Amerasian
If possible, attach a notarized statement from the father regarding parentage. If there is a question you cannot fully answer in the
space provided on this petition, use the space provided in Part 15. Additional Information.
3. Father's Full Name
Family Name (Last Name) Given Name (First Name) Middle Name
4. Date of Birth (mm/dd/yyyy) 5. Country of Birth
6. A. Is the father still alive? ¡ Unknown ¡ Yes ¡ No
"Yes"
B. If you answered to Item A. in Item Number 6., provide his address below.
In Care Of Name (if any)
Street Number and Name Apt. Ste. Fir. Number
¡¡¡
City or Town State ZIP Code
3
Province Postal Code Country
"No"
C. If you answered to Item A. in Item Number 6., provide his date of death (mm/dd/yyyy).
D. Daytime Telephone Number (if any) E. Work Telephone Number (if any)
At the time the Amerasian was conceived:
7. A. The father was in the military (indicate branch of service below).
¡ Army ¡ Air Force ¡ Navy ¡ Marine Corps ¡ Coast Guard
B. Provide the father's service number:
C. ¡ The father was not in the military and was not a civilian employed abroad. (Attach a full explanation of the
circumstances.)
Part 7. Complete Only If Filing as a Widow/Widower
1. Full Name of U.S. Citizen Husband or Wife Who Died
Family Name (Last Name) Given Name (First Name) Middle Name
2. Date of Birth (mm/dd/yyyy) 3. Country of Birth 4. Date of Death (mm/dd/yyyy)
Forrn I-360 Edition 06/09/20 " Page 7 of 19
FILED: BRONX COUNTY CLERK 01/22/2024 10:00 AM INDEX NO. 801163/2024E
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 01/22/2024
Part 7. Complete Only If Filing as a Widow/Widower (continued)
5. At time of death, your spouse was a (Select only one):
A. ¡ U.S. citizen born in the United States
B. ¡ U.S. citizen born abroad to U.S. citizen parents
C. ¡ U.S. citizen through naturalization
Provide A-Number (if any) º A-
(1)
D. ¡ Other (Explain)
6. How many times have you been married?
7. How many times was your spouse married?
8. A. When did you and your spouse get married (mm/dd/yyyy)?
B. Where did you and your spouse get married?
9. A. Did you remarry after the death of your spouse? ¡ Yes ¡ No
"Yes"
B. If you answered to Item A. in Item Number 9., provide the date that you remarried (mm/dd/yyyy).
10. If you are filing as a widow(er), were you legally separated at the time of the U.S. citizen's death? ¡ Yes ¡ No
"Yes"
NOTE: If you answered to Item Number 10., provide an explanation in the space provided in Part 15. Additional
Information.
Part 8. Complete Only If Filing for a Special Immigrant Juvenile
Information About the Juvenile
1. List any other names used:
A. Family Name (Last Name) Given Name (First Name) Middle Name
B. Family Name (Last Name) Given Name (First Name) Middle Name
"No"
Answer the following questionsregarding the person for whom the petition is being filed. If you answer to Item A. in Item
Number 2., provide an explanation in the space provided in Part 15. Additional Information.
2. A. Have you been declared dependent on a juvenile court in the United States OR has a juvenile court ¡ Yes ¡ No
legally committed you to, or placed you under the custody of, an agency, department of a state, or an
individual or entity?
B. Provide the name of the state agency, department, or court-appointed organization or individual with which you are placed
below.
C. Are you currently under the jurisdiction of the juvenile court that made your placement or custody ¡ Yes ¡ No
determination identified in Item B. in Item Number 2. above?
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FILED: BRONX COUNTY CLERK 01/22/2024 10:00 AM INDEX NO. 801163/2024E
NYSCEF DOC. NO. 15 RECEIVED NYSCEF: 01/22/2024
Part 8. Complete Only If Filing for a Special Immigrant Juvenile (continued)
"Yes"
3. A. If you answered to Item C. in Item Number 2. above, are you currently residing in your
court-ordered placement?
B. "No"
If you answered to Item C. in Item Number 2. above, select your reason below.
¡ You were adopted or placed in a permanent guardianship or another permanent living arrangement (other than
reunification with the abusive parents).
¡ You aged-out of the juvenile court's jurisdiction and the order was terminated based on age.
"Other,"
¡ Other. (If you selected provide an explanation in the space provided in Part 15. Additional Information.)
4. A. A juvenile court has determined that reunification with ¡ one or ¡ both of my parents is not viable due to:
¡ Abuse ¡ Neglect ¡ Abandonment
¡ Similar basis under state law (specify):
"one"
B. If you selected in Item A. in Item Number 4., provide the name of that parent below.
5. Has it been determined in judicial or administrative proceedings that it would not be in your best interest ¡ Yes ¡ No
to be returned to your or y