Free Redacted Document - District Court of Delaware - Delaware

Case 1:07-cr-00145-GMS

Document 11

Filed 11/06/2007

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[REDACTED
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE
UNITED S'I'ATES OF AMERICA, Plaintiff v. JOAN SANTIAGO, Defendant.

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Criminal Action No. 07- /YJ'

INDICTMENT
The Federal Grand Jury for the District of Delaware charges that:

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U S GiSPRlCT COUST

INTRODUCTION
1. At times during the period from in or about January 2007 through April 2007, the

defendant JOAN SANTIAGO received parcels through the U.S. mails at a street address in Blades, Delaware. 2. During this period of time, JOAN SANTIAGO utilized this address to receive

numerous packages through the U.S. mail. Among other things, these packages contained collectively approximately four (4) Social Security cards and approximately four (4) birth certificates.

3.

During this period of time, a number of the Social Security cards and birth

certificates sent andlor received by JOAN SANTIAGO have been used by other persons for the purpose of providing proof of citizenship in order to secure or maintain employment in the State of Delaware, including documents in the names of W.T.P. and J.A.N.V.

Case 1:07-cr-00145-GMS

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Filed 11/06/2007

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COUNT I

4.
5.

Paragraphs 1-3 are incorporated herein by reference. From on or about January 2007 through April 2007, in the State and District of

Delaware, the defendant, JOAN SANTIAGO, did knowingly possess with intent to transfer unlawfully five or more identification documents other than those issued lawfully for the use of the defendant, to wit Social Security cards and birth certificates; said identification documents were or appeared to have been issued by or under the authority of the United States; the transfer, possession, and use of said identification documents was in or affected interstate or foreign commerce; and said identification documents were transported in the mail in the course of the unauthorized transfer, possession, and use. All in violation of Title 18, United States Code, Sections 1028(a)(3) and (b)(2)(B).

COUNT I1
6.

Paragraphs 1-3 are incorporated herein by reference. From on or about January 2007 through April 2007, in the State and District of

7.

Delaware, the defendant, JOAN SANTIAGO, 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 card with the intent to sell it, for the purpose of obtaining for himself and another person a 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. All in violation of Title 42, United States Code, Section 408(a)(7)(C).
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Case 1:07-cr-00145-GMS

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COUNT I11
8.
From on or about January 2007 through April 2007, in the State and District of

Delaware, JOAN SANTIAGO, 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 42 U.S.C. 5 reference. All in violation of Title 18, United States Code, Section 1028A. A TRUE BILL: in paragraphs 6-7 above, incorporated herein by

COLM F. CONNOLLY United States Attorney

By:

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Keith M. Rosen Assistant United States Attorney Dated: November 6,2007