t1a b50 pleadings fdr- entire contents- court docs- 1st pgs for ref 514

8/14/2019 T1A B50 Pleadings Fdr- Entire Contents- Court Docs- 1st Pgs for Ref 514

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FindLowWWW.F INDLAW.COM

HE&Snmd/2002R00760IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLANDUNITED STATES OF AMERICA * CRIMINAL NO.

v. * (Obtaining Falsely Made orUnlawfully Obtaining Visa,

RASMI SUBHI SALEH AL SHANNAQ * 18 U.S.C. 1546(a))....oOo....INDICTMENT

The Grand Jury for the District of Maryland charges that:On or about October 3, 2000,

RASMI SUBHI SALEH AL SHANNAQdid obtain from the United States Embassy in Doha, Qatar a UnitedStates nonimmigrant visa knowing that said visa had been falselymade and otherwise unlawfully obtained.

18 U.S.C. Sections 1546(a), 3238

Thomas M. DiBiagioUnited States Attorney

A TRUE BILL

Poreperson

Date


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IN TH E UNITED STATES DISTRICT COURT FOR THEEASTERN DISTRICT OF VIRGINIA

Alexandria DivisionUNITED STATES OF AMERICA ) Criminal Num ber

)v. ) Count 1:18 U.S.C. 1028(f) (conspiracy to commit) identification document fraud)EYAD M. ALRAB ABAH, ) Count 2: 18 U.S.C. 1028(a)(l), (b)(l)(A)(ii),) and (c)(3)(A) (unlawful production of identificationDefendant ) documents), and 2 (aiding and abetting)INDICTMENT

MARC H 2002 TERM - ATALEXANDRIAIntroductory Allegations to Counts 1 and 2

THEGRAND JURY CHARGES THAT:1. To obtain a Virginia identification card or Virginia driver's license, an applicant must

ordinarily present the Virginia Department of Motor Vehicles (DM V) proof of identity andVirginia residence. The DM V requires two official identification documents as proof of identityand on e official or business document as proof of Virginia residence. Prior to September 2 1,2001, however, applicants lacking the required documentary proof of identity an d Virginiaresidence could complete and submit DMV forms DL6 and DL51 in lieu of the requireddocuments.

2. DMV form DL6 is an identity affidavit. Prior to September 21, 2001, the DMVwould accept a properly completed DL6 form in lieu of one of the two identification docum entsrequired to apply for a license or identification card. The form requires the applicant to provideand to swear to his name, address, and basic biographic informa tion. The form further requiresthe sworn, notarized c ertification of an attorney. Through the certification, the attorney swears


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IN THE UNITED STATES DISTRICT COURT FOR THEEASTERN DISTRICT OF VIRGINIA

Alexandria DivisionUNITED STATES OF AMERICA )

)v. ) Criminal Number)ABDEL RAHMAN OMAR TAWFIQ

ALFAURU ))Defendant )

Affidavit in Support of a Criminal Cgm plamt and an Arrest. Warrant ifL , Peter W . Ashooh, being duly sworn, depose an d state: . t

11. I am a special agent with the Federal Bureau of Investigation (FBI), United States ?

Department of Justice, assigned to the Washington Field Office, I have been employed by theFBI as a^special agent since 1984. My primary duties are to investigate Organized Crimematters.

2. This affidavit contains information necessary to support probable cause fo r thisapplication, It is not intended to include each an d every fact an d matter observed by me orknown by the government. The information provided is based on my personal knowledge andobservations during th e course of this investigation, informat ion conveyed to m e by other la wenforcement officials, and my review of records, documents and other physical evidenceobtained during this investigation.

3. This application is submitted in support of a criminal complaint an d arrest warrantcharging Abdel Rahman Omar Tawfiq Alfauru with unlawfully producing an identificationdocument , an d aiding an d abetting the same, in violation of Title 18 , United States Code,Sections 2 and lQ28(a)(l), (b)(l)(A)(ii), and (e)(3)(A). In particular, I believe that Alfauru has


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FindLowW W W . F I N D L A W . C O M i^THE UNITED STATES DISTRICT COURT FO R T HEEASTERN DISTRICT OF VIRGINIA


)v. ) Criminal Number 02-74-A)AGUS BUDIMAN, ))Defendant )

PLEA AGREEMENTPaul J. McN ulty, United States Attorney for the Eastern District of Virginia, an d John T.

Morton, Assistant United States Attorney, and the defend ant, Agus Budiman, and the defen dant'scounsel, William B. Moffitt an d Pleasant S. Brodnax, III, pursuant to Rule 1 l(e) of the FederalRules of Criminal P rocedure, have entered into an agreement, the terms and conditions of whichare as follows:

. The defen dant, Agus Bu diman, agrees to plead guilty to count two of the pendingindictment. Count tw o charges the defendant with iden tification document fraud, in violation ofTitle 18, United States Code, Section 1028(a)(l), (b)(l)(A)(ii), an d (c)(3)(A), and Section 2. Themaximum penalty fo r this offense is a term of fifteen years of imprisonment, a fine of $250,000,a special assessment, and three years of supervised release. The defen dant is aware that thissupervised release term is in addition to any prison term the defendant may receive, an d that aviolation of a term of supervised release could result in the defendan t being returned to prison forthe full term of supervised release. Upon the Court's acceptance of this plea, the United Stateswill move to dismiss the remaining count of the indictment (count one) against this defenda nt.

. Before sentencing in this case, the defendan t agrees to pay a mandatory specialassessment of one hundred dollars ($100.00) per count of conviction.


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IN THE UNITED STATES DISTRICT CO URT FOR THEEASTERN DISTRICT O F VIRGINIA


)v. ) Criminal Number 02-74-A)AGUS BUDIMAN, ))Defendant )

STATEMENT OF FACTSThe U nited States and the defendant, Agus Budiman, agree that had this matter

proceeded to trial, the United States w ould have proven the following facts beyond a reasonabledoubt:

1. The defendant, Agus Budiman, is a citizen of Indonesia currently in the United Statesunlawfully. The defendant 's mother tongue is Indonesian, although he speaks an d understandsEnglish.

2. Virginia identification cards and Virginia driver's licenses are identificationdocuments made an d issued by and under the authority of the Commonwealth of Virginia. Theirproduction is in and effects interstate commerce.

3. To obtain a Virginia driver's license or identification card, an applicant m ustordinarily present the Virginia Department of Motor Vehicles (DMV) documentary proof ofVirginia residence. Prior to September 21, 2001, however, an applicant lacking docum entaryproof of Virginia residence could complete and submit DMV form DL51 in lieu of the requiredproof.

4. DMV form DL51 is a residency certification. Prior to September 21, 2001, the DMVwould accept a properly completed DL51 form in lieu of documentary proof of V irginia


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A O 9 1 (Rav. I V g S i C M m l nI L K

2 6 9 1 =United States Di.shn.ci CourtE A S T E R N D I S T R I C T O F V I R G I N I A

CLERK. US, DISTRICT COURTALEXANDRIA. VII6INIA

UNITED STATES OF AMERICAV.

MOBAJVCEOABDICRIMINAL COMPLAINTOiO>fc ^ALCASE NUMBER:Q/-

I. .tha undersigned complainant being duly sworn state the following is true and comet to the D e s t of myknowledge and belief. From I n or Q b O U t _flflftjltf 1399 through JmeIQOt in Arilntton County tad Aleiindrtain the gariera District of Vlndria (he defendant didknowingly t& A utUtwfnlly mite,ntter,ud possess ftrjed twaittrO f Stateand political ntbdhrfiton ttcrcufndof anorgftulzntlon, with Intent to dectlvc wathvpinnn,orgurfzatfia, ud goTtrmnent

In vtoletlon of THJ , . United State* Cede. 3lon(s)I further state that I am a(n) Sataa AMiit and that this complaint la based on ha ollowing facts:

SeeAttached Afin&tft

Continuedon tho attached shaat andmada a part hereofAU8A- Robert A. SpencerSworn to 3*for me and subscribed (n my presence,

September 23. 2001DM*

_NamaATItts

RawIMr>na - Jr.. UnllTltts olJmDo'al OfRcarilad Snla Maattrrao Judg

Kevin W . A i h b ySpiciil Agent.Federal Bureau of Investigation

t1a b50 pleadings fdr- entire contents- court docs- 1st pgs for ref 514

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