Free Redacted Document - District Court of Delaware - Delaware

· · Case 1 :07-cr-00158-GMS D0cum_?[E@ Filed- 1 1/27/2007 Page 1 of 3 · A ·
REDAQ 1 Z A
l E IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA,
Plaintiff { r
A v. Criminal Action No. 07- / 9 3
JULIO GONZALEZ,
1 I Defendant. » F I I- E D
- K
I Nev 27 2007
The Federal Grand Jury for the District of Delaware charges that: mmm COURT
0@‘_ggg]_QE_ DELAWARE
COUNT I
* _ From on or about January 2007 through October 2007, in the State and District of
‘ Delaware, JULIO GONZALEZ, the defendant, did knowingly forge, counterfeit, alter, and falsely
· make a document prescribed by statute or regulation for entry into or as evidence of authorized
stay or employment in the United States, that is, a Resident Alien card (I-551).
All in violation of Title 18, United States Code, Section l546(a). A
B Q COUNT II
_ J From on or about January 2007, through October 2007, in the State and District of
Delaware, JULIO GONZALEZ, the defendant, did knowingly transfer, possess, and use, without
lawful authority, a means of identification of another person during and in relation to a violation
of 18 U.S.C. § 1546(a), as described in Count I, above, incorporated herein by reference.
AH in violation of Title 18, United States Code, Section 1028A. .

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_ COUNT III
From in or about September 2007 through November 15, 2007, in the State and District
of Delaware, JULIO GONZALEZ, the defendant, did knowingly buy and sell a card that was, or
purported to be, issued by the Commissioner of Social Security, and did possess a Social Security _ n
card with the intent to sell it, for the purpose of obtaining for himself and another person a I
payment or any other benefit for which he or such other person· was not entitled, and for the
purpose of obtaining anything of value and for other purposes. I
n All in violation of Title 42, United States Code, Section 408(a)(7)(C).
l COUNT IV - _
From on or about September 2007 through November 15, 2007, in the State and District
F of Delaware, .lULIO GONZALEZ, the defendant, did knowingly transfer, possess, and use,
n without lawful authority, a means of identification of another person during and in relation to a
violation of 42 U.S.C. § 408(a)(7)(C), as described in Count IH, above, incorporated herein by
reference. _
All in violation of Title 18, United States Code, Section 1028A.
. COUNT V .
S From on or about September 18, 2007 through November I5, 2007, in the State and
District of Delaware, JULIO GONZALEZ, the defendant, did knowingly possess with intent to
transfer unlawfully five or more identification documents other than those issued lawfully for the F
useof the defendant, that is, Social Security cards and birth certiiicates; said identification I
documents were or appeared to have been issued by or under the authority ofthe United States; F
I 2

. Case 1 :07-cr-00158-G|\/IS Document 8 Filed 1 1/27/2007 Page 3 of 3 . .
ie - .` ·
and the transfer, possession, and use of said identification documents was in or affected interstate I
or foreign commerce. ‘
All in violation of Title 18, United States Code, Sections 1028(a)(3) and (b)(2)(B).
> · A TRUE BILL:
` Foreperson _ _
COLM F. CONNOLLY '
United States Attorney
BY=
Keith M. Rosen -
Assistant United States Attorney - ·
Dated: November 27, 2007-·‘ `
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