Case 1:07-cr-00147-GMS
Document 11
Filed 11/06/2007
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IN THE IJNITED STATES DISTRICT COURT FOR THE DISTRIC'r OF DELAWARE
UNITED STATES OF AMERICA, Plaintiff v. OSCAR LANES, a/Wa Oscar Lainez, Defendant. Criminal Action No. 07- / Y 7
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INDICTMENT
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The Federal Grand Jury for the District of Delaware charges that:
INTRODUCTION
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1.
At various times during the period from in or about July 2005 through October
2007, the defendant OSCAR LAIhTES maintained a post office box in Selbyville, Delaware, and a second post office box in Frankford, Delaware. 2. During this period of time, OSCAR LANES utilized these post office boxes to
send and receive numerous packages through the U.S. mail. Among other things, these packages collectively contained approximately 89 Social Security cards and approximately 89 birth certificates. These packages also contained U.S. currency and money orders that were used to purchase these types of identity documents.
3.
During this period of time, a number of the Social Security cards and birth
certificates sent and/or received by OSCAR LANES have been used by other persons for the purpose of providing proof of citizenship in order to secure or maintain employment in the State
Case 1:07-cr-00147-GMS
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of Delaware, including documents in the names of E.M.S ., H.S .P., H.E.M.R., 1.B.T., J.A.P.A., and A.L.C. COUNT I
4.
Paragraphs 1-3 are incorporated herein by reference. From on or about July 20,2005, through on or about October 3 1,2007, in the
5.
State and District of Delaware, the defendant, OSCAR LAINES, did ltnowingly 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 violati011of Title 18, United States Code, Sections 1028(a)(?)and
COUNT I1
6.
7.
Paragraphs 1-3 are incorporated herein by reference. From on or about July 20,2005, through on or about October 31,2007, in the
State and District of Delaware, the defendant, OSCAR LAINES, 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
Case 1:07-cr-00147-GMS
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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).
COUNT I11
8.
From on or about July 20,2005, through on or about October 3 1, 2007, in the
State and District of Delaware, -thedefendant, OSCAR LAMES, 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. 8 408(a)(7)d, as described in paragraphs 6-7 above, incorporated herein by reference. All in violation of Title 18, United States Code, Section 1028A. A TRUE BILL:
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COLM F. CONNOLLY United States Attorney
By:
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Keith M. Rosen Assistant United States Attorney Dated: November 6,2007
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