Free Redacted Document - District Court of Delaware - Delaware

Case 1:07-cr-00146-GMS

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Filed 11/06/2007

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IN THE UNITED STATES DISTRICT COURT FOR TlIE DISTRICT OF DELAWARE

UNITED STATES OF AMERICA, Plaintiff v. HUGO OLGUIN-LOPEZ, a/Va Hugo Lopez-Olguin, a/Va Anthony R. Sanchez, Defendant.

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Criminal Action No. 07- /96

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INDICTMENT

'The Federal Grand Jury for the District of Delaware charges that:
INTRODUCTION
1.

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U S DISiR!CT CQUET DISTSECI OF IFELAWARE

At various times during the period from in or about November 2005 through

October 2007, the defendant HUGO OLGUIN-LOPEZ received parcels through the U.S. mails at a street address in Seaford, Delaware, and maintained a post office box in Seaford, Delaware. 2. During this period of time, HUGO OLGUIN-LOPEZ utilized the post office box

and the street address to send and receive numerous packages through the U.S. mail. Among other things, these packages contained collectively approximately 36 Social Security cards and approximately 36 birth certificates. 3. During this period of time, a number of the Social Security cards and birth

certificates sent and/or received by HUGO OLGUN-LOPEZ have been used by other persons for the purpose of providii~g proof of citizenship in order to secure or maintain employment in the State of Delaware, including documents in the names of D.S .M., R.M.R.A., I.O.C., C.I.C.M., C.D.C.C., E.D.C.Q., N.A.V., A.R.C.S., and G.V.R.

Case 1:07-cr-00146-GMS

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COUNT I
4. 5. Paragraphs 1-3 are incorporated herein by reference. From in or about Novemebr 2005, through on or about October 3 1,2007, in the

State and District of Delaware, the defendant, HUGO OLGUIN-LOPEZ, 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.
7.

Paragraphs 1-3 are incorporated herein by reference. From in or about November 2005, through on or about October 3 1,2007, in the

State and District of Delaware, the defendant, HUGO OLGUIN-LOPEZ, 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).

Case 1:07-cr-00146-GMS

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COUNT I11 8. Froin in or about November 2005, through on or about October 3 1, 2007, in the

State and District of Delaware, HUGO OLGUJN-LOPEZ, 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. 5 408(a)(7)m, as described in paragraphs 6-7 above, C incorporated herein by reference.

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All in violation of Title 18, United States Code, Section 1028A.

COLM F. CONNO1,I.Y United States Attorney

By:

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

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A TRUE BILL: