Free Indictment - Redacted - District Court of Delaware - Delaware


File Size: 147.2 kB
Pages: 4
Date: April 27, 2005
File Format: PDF
State: Delaware
Category: District Court of Delaware
Author: unknown
Word Count: 766 Words, 4,910 Characters
Page Size: Letter (8 1/2" x 11")
URL

https://www.findforms.com/pdf_files/ded/34725/17.pdf

Download Indictment - Redacted - District Court of Delaware ( 147.2 kB)


Preview Indictment - Redacted - District Court of Delaware
. Case 1:05-cr-00037-JJF Document 1.7 Filed O4/26/2005 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE ;
p I _ :,_ J
UNITED STATES OF AMERICA, :
Z L ..;I · ‘-- - . - et ` -
Plaintiff, :
v. Criminal Action No. 05- ,
ALIRIO GALLEGO-DUGUE,
ERICA ROMERO, and :
JAMIE NUNEZ, :
Defendants. lp
INDICTMENT '
The Grand Jury for the District of Delaware charges that:
COUNT ONE
On or about April 14, 2005, in the State and District ol`Delaware, Alirio Gallego—Duguc, J,
Erica Romero, and Jamie Nunez, the defendants, did knowingly conspire with each other to, with
intent to defraud, pass and utter counterfeited obligations ofthe United States, eg. counterfeit
$100 Federal Reserve notes, in violation of 18 U.S.C. {$472, and in furtherance ofthe
conspiracy, the defendants committed t.he following overt acts:
a. On or about April I4, 2005, Alirio Gallego—Dugue possessed counterfeit
$100 Federal Reserve notes;
b. On or about April I4, 2005, Erica Romero possessed counterfeit Sl 00
Federal Reserve notes in her purse;
c. On or about April I4, 2005, Jamie Nunez possessed counterfeit $100
Federal Reserve notes in her purse;

_ Case 1:05-cr-00037-JJF Document _17 Filed O4/26/2005 Page 2 of 4
d. On or about April 14, 2005, Erica Romero made several purchases at
stores in North Wilmington, Delaware using counterfeit $100 Federal Reserve notes that she had
received from Alirio Gallcgo-Dugue. Erica Romero received genuine currency as change for her _
purchases and shared the genuine currency with Alirio Gallego—Dugue; and E
c. On or about April 14, 2005, Jamie Nunez, defendant herein, made several
purchases at stores in North \Vi1mington, Delaware using eountcrleit S100 Federal Reserve notes
that she had received from Alirio Gallego-Dugue. .lamie Nunez received genuine currency as
change for her purchases and shared the genuine currency with Alirio Gallego-Dugue;
all in violation ol`Tit1e 18, United States Code, Section 371.
COUNT TWO
On or about April 14, 2005, in the State and District of Delaware, Alirio Gallego—Dugue,
the defendant, with the intent to defraud, did knowingly keep in his possession counterfeit 1
obligations ofthe United States, that is, counterfeit $100 Federal Reserve notes, in violation of
Title 18, United States Code, Section 472.
COUNT THREE
On or about April 14, 2005, in the State and District of Delaware, Erica Romero, the
defendant, with the intent to defraud, did knowingly keep in her possession counterfeit
obligations ofthe United States, that is, counterfeit $100 Federal Reserve notes, in violation of
Title 18, United States Code, Section 472.
COUNT FOUR
On or about April 14, 2005, in the State and District of Delaware, Jamie Nunez, the
defendant, with the intent to defraud, did knowingly keep in her possession counterfeit
-2- g

, Case 1:05-er-00037-JJF Document 1_7 Filed O4/26/2005 Page 3 of 4.
obligations ofthe United States, that is, counterfeit $100 Federal Reserve notes, in violation of
Title 18, United States Code, Section 472.
FORFEITURE ALLEGATIOl\l
Upon conviction ofone or more ofthe offenses alleged in Counts One through Four of
this Indictment, defendants shall forfeit to the United States:
a. pursuant to 18 U.S.C. § 982(a)(2)(B), any property constituting, or derived from,
proceeds obtained, directly or indirectly, as a result ofthe violations charged in Counts One
through Four: and
b. pursuant to 18 U.S.C. § 492 and 28 USC. § 246l(c) all counterfeits ofany coins
or obligations or other securities and any material or apparatus used or fitted or intended to be
used in the making of such counterfeits in violation of 18 U.S.C. § 472.
If any ofthe abovc—deseribcd torfeitable property, as a result of any act or omission ofthe
defendants:
a. cannot be located upon the exercise ofdue diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction ofthe court;
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be divided without
difficulty;
it is the intent ofthe United States, pursuant to 21 U.S.C. § 853(p) as incorporated by 28 U.S.C.
. . r -3-

_ Case 1:05-cr-00037-JJF Document 17 Filed O4/26/2005 Page 4 of 4
§ 246l(e), to seek forfeiture ofuny other property ofsaid defendants up to the value ofthe
forfeitnble property described above.
A TRUE BILL; __ _ Z
-("l I E {
COLM F. INONNOLLY
United Sta A‘ rn `
‘ I /
B ‘ Y
Beth Moskow- j mol
Assistant Unit States Attorney
Dated: April 26, 2005
` D
A ér t 4 es
gg r D * A 2 ,
`· r% “i“"“> ` { it »-·t r if -
‘_ V
·. i t.· Z ¥ rig; » it
.. 1 ~ ‘ A i