Free Redacted Document - District Court of Delaware - Delaware

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0 F Y
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, : -
Plaintiff
_ v. Criminal Action N0. 086%
SHARON G. AGUAYO-RIVERA, and
JOSE ANTONIO TORRES, :
Defendants.
INDICTMENT
_ The Federal Grand Jury for the District of Delaware charges that:
- INTRODUCTION
1. At various times during the period from in or about May 2005 through March
2006, the defendants SHARON G. AGUAYO-RIVERA and JOSE ANTONIO TORRES
maintained a post office box in Laurel, Delaware, as well as street addresses in Laurel, Delaware,
and Seaford, Delaware.
2. During this period of time, SHARON G. AGUAYO-RIVERA and JOSE
ANTONIO TORRES utilized the post office box and these street addresses to send and receive
numerous packages through the U.S. mail. Among other things, these packages collectively
contained at least 80 Social Security cards and 80 Puerto Rican birth certificates, as well as two
_ (2) New York birth certificates (and corresponding Social Security cards) and one (1)
Massachusetts birth certificate (and corresponding Social Security card). These packages also
contained money orders that were used to purchase these types of identity documents.

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3. During this period of time, a number of the Social Security cards and birth
certificates sent and/or received by SHARON G. AGUAYO-RIVERA and JOSE ANTONIO
TORRES 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 C.A.N.L., A.O.D.A., E.J.A.H., M.A.S.R., F.L.O.A., M.H.T., J .C.P.B., J .A.C.R.,
· D.D.R.B., J.L.G.R., J.C.R.R., J.C.V., A.S.M., AND F.R.O.
COUNT I
4. Paragraphs 1-3 are incorporated herein by reference.
5. From in or about May 2005 through in or about March 2006, in the State and
District of Delaware and elsewhere, the defendants, SHARON G. AGUAYO-RD/ERA and
JOSE ANTONIO TORRES, did knowingl it conspire to possess with intent to transfer unlawfully
five or more identification documents other than those issued lawfirlly for their use, 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), (b)(2)(B), and (f).
COUNT II
6. Paragraphs 1-3 are incorporated herein by reference.
7. From i1r or about May 2005 through in or about March 2006, in the State and
District of Delaware and elsewhere, the defendants, SHARON G. AGUAYO-RIV ERA and
JOSE ANTONIO TORRES, did knowingly possess with intent to transfer unlawfully five or

_A Case 1 :08-cr-OOOS4—GIV|S Document 7 Filed O4/O1/2008 Page 3 of 4
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 l028(a)(3), (b)(2)(B)
and 2.
I COUNT III I
8. Paragraphs 1-3 are incorporated herein by reference. A
9. From in or about May 2005 through in or about March 2006, in the State and
District of Delaware and elsewhere, the defendants, SHARON G. AGUAYO-RIVERA and
JOSE ANTONIO TORRES, 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 himfherself and another person a payment or any
other benefit for which s/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) and Title 18,
United States Code, Section 2.

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COUNT IV
10. From in or about May 2005 through in or about March 2006, in the State and
District of Delaware and elsewhere, the defendants, SHARON G. AGUAYO-RIVERA and
JOSE ANTONIO TORRES, 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. §
408(a)(7)(Cj, as described in paragraphs 8-9 above, incorporated herein by reference.
All in violation of Title 18, United States Code, Sections 1028A and 2.
bf { Q an A n A A TRUE BILL: A l
COLM F. CONNOLLY S I l 0
United States Attorney
By:_
Keith M. Rosen A
Assistant United States Attorney =
Dated: li, 2003 V y A S A 1
.fZQ`Z3` U

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