Free Redacted Document - District Court of Delaware - Delaware

` · A Case 1 :07-cr—OOO59-SLR Document 9 Filed O4/24/2007 Page 1 of 3 i
· IN THE UNITED STATES DISTRICT COURT
` FOR THE DISTRICT OF DELAWARE I
UNITED STATES OF AMERICA, :
Plaintiff,
v. Criminal Action N0. 07-
FRANKELY ROBLES GUZMAN,
a/lc/a "Tomas Maldonado Alvarado," : -···—— rj ·._ jj, 1
a/k/a "Amilcar Ahnodovar Cohnenero," : Q ij E-,5 i S
a/k/a "Rafael Cruz R1vera," Z Lil ;,;i1Li »i{_i·ij\,_€.' i_. il`}
Defendant. 2 " "`"E; l mw
t*‘Mr‘“"i
..........INDICTMENT ipa zi my i
The Grand Jury for the Distnict of Delaware charges that: · · Ei·B»E·;E%%?;;%·E_6E·§“"i }
COUNT ONE- 1 .... . _ iE.'.j’L.‘iE;E;E;‘£E. ,...-..--
On or about March 23, 2007, in the Commonwealth and District of Massachusetts, l
FRANKELY ROBLES GUZMAN, defendant herein, an alien and a citizen of the Dominican
Republic, falsely and willfully represented himself to be a citizen of the United States, to wit, he
represented himself to be Tomas Maldonado Alvarado, born oi in Rio Piedras,
p Puerto Rico, with Social Security numbe 1657, all in violation of Title 18, United States
Code, Section 911 .
COUNT TWO A
On or about March 23, 2007, in the Commonwealth and District of Massachusetts,
FRANKELY ROBLES GUZMAN, defendant herein, did knowingly use, without lawful
authority, a means of identification of Tomas Maldonado Alvarado, during and in relation to a
violation of the false representation of citizenship Statute, Title 18, United States Code, Section

Case 1:07-cr—OOO59-SLR Document 9 Filed O4/24/2007 Page 2 of 3
911, as set forth above in Count I, which is incorporated herein by reference, all in violation of
Title 18, United States Code, Section 1028A.
I COUNT THR_iJ_E_
On or about May 21, 2004, in the State and District of Delaware, FRANKELY ROBLES
- GUZMAN, defendant herein, willfully and knowingly made false statements in an application for
a passport with the intent to induce and secure the issuance of a passport under the authority of
the United States for his use, contrary to the laws regulating the issuance of such passports and
the rules prescribed pursuant to such laws, in that in such application the defendant stated that his
name was Amilcar Almodovar Colmenero, and he was born in Rio Piedras, Puerto Rico or
’, all in violation of Title 18, United States Code, Section 1542.
COUNT FOUR
On or about May 21, 2004, in the State and District of Delaware, FRANKLEY ROBLES
GUZMAN, defendant herein, with the intent to deceive and for the purpose of obtaining a United
States passport, falsely represented that a Social Security ntunber was the Social Security number
assigned to him by the Commissioner of Social Security, when, in fact, that number had been
assigned to Amilcar Almodovar Colmenero and the defendant knew it was not the Social
Security number assigned to the defendant, in violation of Title 42, United States Code, Section
408(¤)(7)(B)-
_ COUNT FIVQ
On or about May 21, 2004, in the State and District of Delaware, FRANKELY ROBLES
GUZMAN, defendant herein, did knowingly use, without lawful authority, a means of t
identification of another person, specifically, the name, date of birth, and Social Security number
of Amilcar Almodovar Colmenero, with the intent to commit an unlawful activity that constitutes
2

I Case 1:07-cr—OOO59-SLR Document 9 Filed O4/24/2007 Page 3 of 3 »
a felony violation of federal law, to wit, passport fraud in violation of Title 18, United States
i Code, Section 1542, all in violation of Title 18, United States Code, Section 1028(a)(7).
COUNT SIX
On or about June 18, 2003, in the Commonwealth and Territory of Puerto Rico,
l FRANKELY ROBLES GUZMAN, defendant herein, an alien and a citizen of the Dominican
Republic, falsely and willfully represented himself to be a citizen of the United States, to wit, he
represented himself to be Rafael Cruz Rivera, born or , in Rio Piedras, Puerto
Rico, all in violation of Title 18, United States Code, Section 911.
COUNT SEVEN
On or about June 18, 2003, in the Commonwealth and Territory of Puerto Rico, i
FRANKELY ROBLES GUZMAN, defendant herein, did knowingly possess identification
documents not issued. lawfully for the use of the defendant, to wit, a Social Security card, Puerto
Rican birth certificate, and Puerto Rican driver’s license, which were all in the name Rafael Cruz
A Rivera with `ntent that such documents be used to defraud the United States, as set forth in
Cour¥$§¥v); , which is incorporated herein by reference, all in violation of Title 18, United
States Code, Section 1028(a)(4).
A TRTTR nm ·
lljoreperson
_ COLM F. CONNOLLY .
United States Attorney
BY: E g"
Sophie E. Bryan
Assistant United States Attorney
Dated: April 14, 2007
3