Factual Basis for Guilty Plea. The parties agree that the facts constituting the offenses to which he is pleading guilty are as follows: XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX is a citizen and national of Mexico, who is unlawfully present in the United States and resided in San Antonio, Texas. XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX has been previously deported from the United States to Mexico. From on or about November 2009, and continuing until January 10, 2012, in the Western District of Missouri and elsewhere, defendant XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX knowingly and willfully conspired, combined, confederated and agreed with defendants XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX, XXXXXX DE XX XXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXXXX XXXXXXX-XXXXXX a/k/a “Xxxxx,” XXXXXX DARISEO XXXXXXXX-XXXXXX, XXXXX XXXXXX XXXXXXXXX-FLORES a/k/a “Xxxxxx,” XXXX XXX a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx,” XXXXXX XXXX-XXXXXXXXX, XXXXXX XXXXXXXXX-XXXXX a/k/a “Xxxx,” XXXXXXXXXXX XXXXXXX, XXXXXX XXXXXXXXX, XXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others, to violate the laws of the United States, specifically, to commit the following offenses: a) Transporting illegal aliens in violation of 8 U.S.C. § 1324(a)(1)(A)(ii); b) Unlawful production of an identification document in violation of 18 U.S.C. § 1028(a)(1); c) Unlawful transfer of the means of identification of another person in violation of 18 U.S.C. § 1028(a)(7); and, d) Social security fraud in violation of 42 U.S.C. § 408(a)(7). It was part of the conspiracy that illegal aliens would travel from across the United States to St. Xxxxxx, Missouri, to obtain either a Missouri driver’s or nondriver’s license at the St. Xxxxxx license office, with unlawfully obtained birth certificates and Social Security cards. From November 2009, until January 10, 2012, it is estimated that over 3,500 Missouri driver and nondriver licenses have been unlawfully issued to illegal aliens as part of this conspiracy. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX and others would accompany illegal aliens into the St. Xxxxxx license office, under the guise of being translators, in order to assist them with obtaining a Missouri driver’s or nondriver’s license that was in the name of another person who was listed on unlawfully obtained birth certificates and Social Security cards. It was further part of the conspiracy that illegal aliens would request assistance from XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX and XXXXXXX XXXXXXXX, XXXXX XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,” XXXXX XXXXXX XXXXXXXXX-FLORES a/k/a XXXXXXXX and others would usually instruct and assist the illegal aliens to practice memorizing the names on the birth certificates, the names of the parents on the birth certificates, the dates of birth, the social security numbers and also practice signing the name similar to the signature that appeared on the Social Security card. XXXXXXXX, XXXX XXX a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx” and others would sometimes alter the Social Security cards by chemically removing the signatures from the Social Security cards to allow the illegal alien to sign the cards. XXXXXXXX and others would assist the illegal aliens prepare for potential questions from the license office employees. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX and others would assist the illegal aliens who did not live in Missouri, by providing them with a Missouri residential address to use in order to obtain the Missouri driver’s or nondriver’s license. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX and others would usually collect money from the illegal aliens for the document sets and Missouri driver’s or nondriver’s license. The money would usually then be paid to ELDER XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,” or XXXXXX DARISEO XXXXXXXX-XXXXXX who would then pay XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, or XXXXXX DE LA XXXX. The illegal aliens were usually charged between $1,500 and $1,600 for the document sets and the Missouri driver’s and nondriver’s licenses. From November 2009, until the date of this Indictment it is estimated that over $5,250,000 in gross proceeds have been paid by illegal aliens to members of this conspiracy. It was part of the conspiracy that XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX and XXXXXX DE LA XXXX would obtain state issued birth certificates, usually from the State of Texas, and they would also obtain a Social Security card in the name of the individual on the birth certificate, so they would have a matching document set. It was further part of the conspiracy that XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX and XXXXXX DE LA XXXX would purchase birth certificates and social security cards from individuals, who were willing to sell their identification documents to XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, XXXXXX DE LA XXXX and others. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX and others would usually receive birth certificates and Social Security cards from XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, XXXXXX DE XX XXXX, XXXXX XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,” and others via U.S. express mail packages. On July 11, 2011, an express mail package was sent from “Xxxxxx Xxxxxx 00000 Xxxxxx Xx Xxx 148, San Antonio, TX 78233,” to “Xxxxxxxxx Xxxxx, 000 Xxxxx Xx., Xxxxxxxx, XX 00000,” via U.S. Mail. XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX knowingly sent this package via the U.S. Mail to ELDER XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,”, knowing that the package contained the means of identification other real people, and that they were not false or fictitious identities when they were transferred. Inside the package was a manila envelope with the name “Flaco” written on the outside. Inside the envelope was a white envelope also with the name “Flaco” written on the outside. Inside the white envelope were six sets of Texas birth certificates with matching Social Security cards. The Social Security Cards were in the names of Xxxx Xxxxxxxxx, Xxxxx Xxxx Xxxxxxxx, Xxxxx Xxxxxx, Xxxxxxx Xxxxx Xxxxx, Xxxxxx Xxxxxxx Xxxxxxx and Xxxxx Xxxxxxx XXX. XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX transferred these means of identification without lawful authority to do so, and for the purpose that they be used to commit felony offenses, including but not limited to social security fraud. The package was delivered on July 12, 2011, to 000 Xxxxx Xx., Xxxxxxxx, Xxxxxxxx. ELDER XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,” answered the door and accepted delivery of the package. On July 14, 2011, an express mail package was sent from “Xxxxxx Xxxxxx, 00000 Xxxxxx Xx., Lot 148, San Antonio, TX 78233” to “Xxxxxxxxx Xxxxx, 000 X. Xxxxxxxx St., Carthage, MO 64836,” via U.S. Mail. Inside the package was a manila envelope with the name “Flaco” written on the outside. Inside the envelope were six document sets, four were Texas birth certificates, there was one Alabama and one California birth certificate, and matching Social Security cards. The package was delivered on July 15, 2011. On September 19, 2011, an express mail package was sent from “Xxxxxx Xxxxxx, 00000 Xxxxxx xx. lot. 000, Xxx Xxxxxxx XX 00000,” to “Xxxxxxx Xxxxxx, 0000 0xxx., Xxxxx Xxxxxx, MO 64505,” via U.S. Mail. Inside the package was a sealed and folded in half express mail package containing two document sets with Texas birth certificates and matching Social Security cards. The package was delivered on September 20, 2011, to the residence at 0000 0xx Xxx., Xx. Xxxxxx, Missouri. The defendant agrees all proceeds contained in Bank account # 0000 0000 0000 in the defendant’s name with the Bank of America, and $1,124 in U.S. currency recovered from the defendant at the time of his arrest are property that is subject to forfeiture by the United States, the defendant also agrees that the sum of at least $5,250,000 is also subject to forfeiture, in that all of these items represent proceeds from the above-described criminal activity and are subject to forfeiture.
Appears in 1 contract
Samples: Plea Agreement
Factual Basis for Guilty Plea. The parties agree that the facts constituting the offenses to which he is pleading guilty are as follows: XXXXXX XXXXXXXXX XXXXX XXXXX XXXXXX-XXXXXXXXX is a citizen and national of Mexico, who is unlawfully present in the United States and resided in San Antonio, Texas. XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX has been previously deported from the United States to Mexico. From on or about November 2009, and continuing until January 10, 2012, in the Western District of Missouri and elsewhere, defendant XXXXXX XXXXXXXXX XXXXX XXXXX XXXXXX-XXXXXXXXX knowingly and willfully conspired, combined, confederated and agreed with defendants XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX, XXXXXX DE XX XXXX, XXXXX XXXXX XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXXXX XXXXXXX-XXXXXX a/k/a “Xxxxx,” XXXXXX DARISEO XXXXXXXX-XXXXXX, XXXXX XXXXXX XXXXXXXXX-FLORES a/k/a “Xxxxxx,” XXXX XXX a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx,” XXXXXX XXXX-XXXXXXXXX, XXXXXX XXXXXXXXX-XXXXX a/k/a “Xxxx,” XXXXXXXXXXX XXXXXXX, XXXXXX XXXXXXXXX, XXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others, to violate the laws of the United States, specifically, to commit the following offenses:
a) Transporting illegal aliens in violation of 8 U.S.C. § 1324(a)(1)(A)(ii);
b) Unlawful production of an identification document in violation of 18 U.S.C. § 1028(a)(1);
c) Unlawful transfer of the means of identification of another person in violation of 18 U.S.C. § 1028(a)(7); and,
d) Social security fraud in violation of 42 U.S.C. § 408(a)(7). It was part of the conspiracy that illegal aliens would travel from across the United States to St. Xxxxxx, Missouri, to obtain either a Missouri driver’s or nondrivernon-driver’s license at the St. Xxxxxx license office, with unlawfully obtained birth certificates and Social Security cards. From November 2009, until January 10, 2012, it is estimated that over 3,500 Missouri driver and nondriver non-driver licenses have been unlawfully issued to illegal aliens as part of this conspiracy. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX and others would accompany illegal aliens into the St. Xxxxxx license office, under the guise of being translators, in order to assist them with obtaining a Missouri driver’s or nondrivernon-driver’s license that was in the name of another person who was listed on unlawfully obtained birth certificates and Social Security cards. It was further part of the conspiracy that illegal aliens would request assistance from XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX and XXXXXXX XXXXXXXX, XXXXX XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,” XXXXX XXXXXX XXXXXXXXX-FLORES a/k/a “Xxxxxx,” XXXX XXX a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx,” XXXXXX XXXX-XXXXXXXXX and others in obtaining birth certificates and Social Security cards in the names of others. These birth certificates and Social Security cards would then be used by the illegal aliens to obtain Missouri XXXXXXXX and others would usually instruct and assist the illegal aliens to practice memorizing the names on the birth certificates, the names of the parents on the birth certificates, the dates of birth, the social security numbers and also practice signing the name similar to the signature that appeared on the Social Security card. XXXXXXXX, XXXX XXX a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx” and others would sometimes alter the Social Security cards by chemically removing the signatures from the Social Security cards to allow the illegal alien to sign the cards. XXXXXXXX and others would assist the illegal aliens prepare for potential questions from the license office employees. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX and others would assist the illegal aliens who did not live in Missouri, by providing them with a Missouri residential address to use in order to obtain the Missouri driver’s or nondrivernon-driver’s license. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX and others would usually collect money from the illegal aliens for the document sets and Missouri driver’s or nondrivernon-driver’s license. The money would usually then be paid to ELDER XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,” or XXXXXX DARISEO XXXXXXXX-XXXXXX who would then pay XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, or XXXXXX DE LA XXXX. The illegal aliens were usually charged between $1,500 and $1,600 for the document sets and the Missouri driver’s and nondrivernon-driver’s licenses. From November 2009, until the date of this Indictment it is estimated that over $5,250,000 in gross proceeds have been paid by illegal aliens to members of this conspiracy. It was part of the conspiracy that XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX and XXXXXX DE LA XXXX would obtain state issued birth certificates, usually from the State of Texas, and they would also obtain a Social Security card in the name of the individual on the birth certificate, so they would have a matching document set. It was further part of the conspiracy that XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX and XXXXXX DE LA XXXX would purchase birth certificates and social security cards from individuals, who were willing to sell their identification documents to XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, XXXXXX DE LA XXXX and others. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX and others would usually receive birth certificates and Social Security cards from XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, XXXXXX DE XX XXXX, XXXXX XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,” and others via U.S. express mail packages. On July 11February 28, 2010, XXXXXX XXXXXXXXX sent a wire transfer to XXXXX XXXXX XXXXXX-XXXXXXXXX, in the amount of $450, reference number 40700166, which was received on March 1, 2010. On September 19, 2011, an express mail package was sent from “Xxxxxx Xxxxxx 00000 Xxxxxx Xx Xxx 148000, Xxxxx Xxxxxx, San Antonio, TX Antonio tx 78233,” to “Xxxxxxxxx XxxxxAuto Credit A to Z, 000 Xxxxx 0000 Xx Xxxxxx Xx., Saint Xxxxxx, MO 64505,” via U.S. Mail. Inside the package was a single Texas birth certificate. The package was delivered on September 20, 2011, to XXXXXXX XXXXXXXXX at 0000 Xx. Xxxxxx Xxx., St. Xxxxxx, Missouri. On October 24, 2011, an express mail package was sent from “Xxxxx Xxxxxx 0000 Xxxxxxx Xx. 0000, Xxxxxxx, XX 00000,” to “Xxxxxx Xxxxxxxx, 000 Xxx Xx. Xxx 0 Xxxxxxxx, XX 00000,” via U.S. Mail. XXXXXX XXXXXXXXX XXXXX XXXXX XXXXXX-XXXXXXXXX knowingly sent this package via the U.S. Mail to ELDER XXXXXXX XXXXXXXXXXXXX DARISEO XXXXXXXX-XXXXXX a/k/a “Flaco,”XXXXXX, knowing that the package contained the means of identification other real people, and that they the documents were not false or fictitious identities when they were transferred. Inside the package was a manila envelope sealed white business envelope, which contained two document sets with the name “Flaco” written on the outside. Inside the envelope was a white envelope also with the name “Flaco” written on the outside. Inside the white envelope were six sets of Texas birth certificates with certificates, and matching Social Security cards. The Social Security Cards were in the names of Xxxxx Xxxxxxx Xxxx Xxxxxxxxx, Xxxxx Xxxx Xxxxxxxx, Xxxxx Xxxxxx, Xxxxxxx Xxxxx Xxxxx, Xxxxxx Xxxxxxx Xxxxxxx and Xxxxx Xxxxxxx XXXXxxxxxx. XXXXXX XXXXXXXXX XXXXX XXXXX XXXXXX-XXXXXXXXX transferred these means of identification without lawful authority to do so, and for the purpose that they be used to commit felony offenses, including but not limited to social security fraud. The package was delivered on July 12October 25, 2011, to 000 Xxxxx Xxx Xx., Xxxxxxxx, Xxxxxxxx. ELDER XXXXXXX XXXXXXX, and XXXXXX DARISEO XXXXXXXX-XXXXXX a/k/a “Flaco,” answered the door and accepted delivery of the package. On July 14, 2011, an express mail package was sent from “Xxxxxx Xxxxxx, 00000 Xxxxxx Xx., Lot 148, San Antonio, TX 78233” to “Xxxxxxxxx Xxxxx, 000 X. Xxxxxxxx St., Carthage, MO 64836,” via U.S. Mail. Inside retrieved the package was a manila envelope with from the name “Flaco” written on the outside. Inside the envelope were six document sets, four were Texas birth certificates, there was one Alabama and one California birth certificate, and matching Social Security cards. The package was delivered on July 15, 2011. On September 19, 2011, an express mail package was sent from “Xxxxxx Xxxxxx, 00000 Xxxxxx xx. lot. 000, Xxx Xxxxxxx XX 00000,” to “Xxxxxxx Xxxxxx, 0000 0xxx., Xxxxx Xxxxxx, MO 64505,” via U.S. Mail. Inside the package was a sealed and folded in half express mail package containing two document sets with Texas birth certificates and matching Social Security cards. The package was delivered on September 20, 2011, to the residence at 0000 0xx Xxx., Xx. Xxxxxx, Missourimailbox. The defendant agrees all proceeds contained in Bank account # 0000 0000 0000 in that the defendant’s name with the Bank sum of America, and at least $1,124 in U.S. currency recovered from the defendant at the time of his arrest are 5,250,000 is property that is subject to forfeiture by the United States, the defendant also agrees that the sum of at least $5,250,000 is also subject to forfeiture, in that all of these items represent it represents the proceeds from the above-described criminal activity and are is subject to forfeiture.
Appears in 1 contract
Samples: Plea Agreement
Factual Basis for Guilty Plea. The parties agree that the facts constituting the offenses to which he is pleading guilty are as follows: XXXXXX XXXXXXXXX XXXXXX-XXX X. XXXXXXXXX is a citizen and national of MexicoUnited States citizen, who is unlawfully present in the United States and resided in San AntonioSt. Xxxxxx, Texas. XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX has been previously deported Missouri, and from the United States to Mexico. From on or about November 2009, and continuing until January 10, 2012, in the Western District of Missouri and elsewhere, defendant XXXXXX XXXXXXXXX XXXXXX-XXX X. XXXXXXXXX knowingly and willfully conspired, combined, confederated and agreed with defendants XXXXXX XXXXXXXXX, XXXXXXX X. XXXXXX, XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX, XXXX XXXXXXXX, XXXXXX DE XX XXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXXXX XXXXXXX-XXXXXX a/k/a “XxxxxFlaco,” XXXXXX DARISEO XXXXXXXX-XXXXXX, XXXXX XXXXXX XXXXXXXXX-FLORES a/k/a “Xxxxxx,” XXXX XXX XXXXXXXXX XXXXXX-XXXXX a/k/a “Xxxxx Xxxx Xxxxxx-XxxxxxXxxx,” XXXXXX XXXX-XXXXXXXXX, XXXXXX XXXXXXXXX-XXXXX a/k/a “Xxxx,” XXXXXXXXXXX XXXXXXX, XXXXXX XXXXXXXXX, XXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others, to violate the laws of the United States, specifically, to commit the following offenses:
a) Transporting crime of transporting illegal aliens in violation of 8 U.S.C. § 1324(a)(1)(A)(ii);
b) Unlawful production of an identification document in violation of 18 U.S.C. § 1028(a)(1);
c) Unlawful transfer of the means of identification of another person in violation of 18 U.S.C. § 1028(a)(7); and,
d) Social security fraud in violation of 42 U.S.C. § 408(a)(7). It was part of the conspiracy that illegal aliens would travel from across the United States to St. Xxxxxx, Missouri, to obtain either a Missouri driver’s or nondrivernon-driver’s license at the St. Xxxxxx license office, with unlawfully obtained birth certificates and Social Security cards. From November 2009, until January 10, 2012, it is estimated that over 3,500 Missouri driver and nondriver non-driver licenses have been were unlawfully issued to illegal aliens as part of this conspiracy. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX XXXXXXXX, XXXXXXXXXXX XXXXXXX, XXXXXX XXXXXXXXX, XXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others would accompany illegal aliens into the St. Xxxxxx license office, under the guise of being translators, in order to assist them with obtaining a Missouri driver’s or nondrivernon-driver’s license that was in the name of another person who was listed on unlawfully obtained birth certificates and Social Security cards. It was further part of the conspiracy that illegal aliens would request assistance from XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX and XXXXXXXX, XXXXXXX XXXXXXXX, XXXXXX XXXXXXXXX, XXXXXXX XXXXXXXXX, XXXXX XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,” XXXXX XXXXXX XXXXXXXXX-FLORES a/k/a XXXXXXXX “Xxxxxx,” XXXX XXXXXXXXX XXXXXX-XXXXX a/k/a “Xxxx,” XXXXXX XXXX-XXXXXXXXX, XXXXXX XXXXXXXXX-XXXXX a/k/a “Xxxx,” and others in XXXXXXXX, XXXXXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others would usually instruct and assist the illegal aliens to practice memorizing the names on the birth certificates, the names of the parents on the birth certificates, the dates of birth, the social security numbers and also practice signing the name similar to the signature that appeared on the Social Security card. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX, XXXX XXX XXXXXXXXX XXXXXX-XXXXX a/k/a “Xxxxx Xxxx Xxxxxx-XxxxxxXxxx,” and others would sometimes alter the Social Security cards by chemically removing the signatures from the Social Security cards to allow the illegal alien to sign the cards. XXXXXXXX It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX, XXXXXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others would assist the illegal aliens to prepare for potential questions from the license office employees. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX XXXXXXXX, XXXXXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others would assist the illegal aliens who did not live in Missouri, by providing them with a Missouri residential address to use in order to obtain the Missouri driver’s or nondrivernon-driver’s license. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX XXXXXXXX, XXXXXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others would usually collect money from the illegal aliens for the document sets and Missouri driver’s or nondrivernon-driver’s license. The money would usually then be paid to ELDER XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,” or XXXXXX DARISEO XXXXXXXX-XXXXXX who would then pay XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, or XXXXXX DE LA XXXX. The illegal aliens were usually charged between $1,500 and $1,600 for the document sets and the Missouri driver’s and nondrivernon-driver’s licenses. From November 2009, until the date of this Indictment the indictment it is estimated that over $5,250,000 in gross proceeds have been paid by illegal aliens to members of this conspiracy. It was part of the conspiracy that XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX and XXXXXX DE LA XXXX would obtain state issued birth certificates, usually from the State of Texas, and they would also obtain a Social Security card in the name of the individual on the birth certificate, so they would have a matching document set. It was further part of the conspiracy that XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX and XXXXXX DE LA XXXX would purchase birth certificates and social security cards from individuals, who were willing to sell their identification documents to XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, XXXXXX DE LA XXXX and others. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX and others would usually receive birth certificates and Social Security cards from XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, XXXXXX DE XX XXXX, XXXXX XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,” and others via U.S. express mail packages. On July 11February 28, 2010, XXXXXX XXXXXXXXX sent a wire transfer to XXXXX XXXXX XXXXXX-XXXXXXXXX, in the amount of $450, reference number 40700166, which was received on March 1, 2010. On January 24, 2011, an express mail package was sent XXXXXX XXXXXXXXX knowingly transported illegal aliens from “the Motel 6 in St. Xxxxxx, Missouri, to the St. Xxxxxx Xxxxxx 00000 Xxxxxx Xx Xxx 148license office. On January 24, San Antonio2011, TX 78233,” to “Xxxxxxxxx Xxxxx, 000 Xxxxx Xx., Xxxxxxxx, XX 00000,” via U.S. Mail. XXXXXX XXXX XXXXXXXXX XXXXXX-XXXXXXXXX knowingly sent this package via the U.S. Mail to ELDER XXXXXXX XXXXXXX-XXXXXX XXXXX a/k/a “FlacoXxxx,”, knowing that the package contained the means of identification other real people, and that they were not false or fictitious identities when they were transferred. Inside the package was a manila envelope with the name “Flaco” written on the outside. Inside the envelope was a white envelope also with the name “Flaco” written on the outside. Inside the white envelope were six sets of Texas birth certificates with matching Social Security cards. The Social Security Cards were in the names of Xxxx Xxxxxxxxx, Xxxxx Xxxx Xxxxxxxx, Xxxxx knowingly transported illegal aliens from St. Xxxxxx, Xxxxxxx Xxxxx XxxxxMissouri, Xxxxxx Xxxxxxx Xxxxxxx and Xxxxx Xxxxxxx XXXto North Carolina. XXXXXX On February 21, 2011, XXXX XXXXXXXXX XXXXXX-XXXXXXXXX transferred these means of identification without lawful authority to do so, and for the purpose that they be used to commit felony offenses, including but not limited to social security fraud. The package was delivered on July 12, 2011, to 000 Xxxxx Xx., Xxxxxxxx, Xxxxxxxx. ELDER XXXXXXX XXXXXXX-XXXXXX XXXXX a/k/a “FlacoXxxx,” answered the door and accepted delivery of the package. On July 14, 2011, an express mail package was sent knowingly transported illegal aliens from “Xxxxxx Xxxxxx, 00000 Xxxxxx Xx., Lot 148, San Antonio, TX 78233” North Carolina to “Xxxxxxxxx Xxxxx, 000 X. Xxxxxxxx St., Carthage, MO 64836,” via U.S. Mail. Inside the package was a manila envelope with the name “Flaco” written on the outside. Inside the envelope were six document sets, four were Texas birth certificates, there was one Alabama and one California birth certificate, and matching Social Security cards. The package was delivered on July 15, 2011. On September 19, 2011, an express mail package was sent from “Xxxxxx Xxxxxx, 00000 Xxxxxx xx. lot. 000, Xxx Xxxxxxx XX 00000,” to “Xxxxxxx Xxxxxx, 0000 0xxx., Xxxxx Xxxxxx, MO 64505,” via U.S. Mail. Inside the package was a sealed and folded in half express mail package containing two document sets with Texas birth certificates and matching Social Security cards. The package was delivered on September 20, 2011, to the residence at 0000 0xx Xxx., Xx. St. Xxxxxx, Missouri. On February 22, 2011, XXXXXX XXXXXXXXX knowingly transported illegal aliens from the Motel 6 in St. Xxxxxx, Missouri, to the St. Xxxxxx license office. In particular, XXXXXXXXX knowingly transported Xxxxx Xxxxxxxx Xxxxxxx-Xxxxxxxxx, an illegal alien who had come to, entered and remained unlawfully in the United States. XXXXXXXXX transported the illegal alien within the United States to further her unlawful presence and for the purpose of private financial gain. On February 22, 2011, in the Western District of Missouri XXXX XXXXXXXXX XXXXXX-XXXXX a/k/a “Xxxx,” knowingly transferred without lawful authority, a means of identification of another person, to wit, a Texas birth certificate in the name of Xxxxxxxx Xxxxx Xxxxxxxxx, in connection with, an unlawful activity that constitutes a violation of Federal law, to wit, false representation of United States citizenship in violation of 18 U.S.C. § 911, and the means of identification were transported in and affected interstate commerce, and the offense involved the transfer of an identification document that was a birth certificate. On February 22, 2011, in the Western District of Missouri, XXXX XXXXXXXXX XXXXXX-XXXXX a/k/a “Xxxx,” knowingly possessed a Social Security card with the intent to sell or alter it, to wit, a Social Security card in the name of Xxxxxxxx Xxxxx Xxxxxxxxx, for the purpose of obtaining anything of value from any person or for any other purpose. On February 22, 2011, in the Western District of Missouri, XXXXXX XXXXXXXXX and XXXX XXXXXXXXX XXXXXX-XXXXX a/k/a “Xxxx,” knowingly and without lawful authority, produced an identification document, to wit, a Missouri nondriver’s license in the name of Xxxxxxxx Xxxxx Xxxxxxxxx, the production of the identification was in and affected interstate commerce, and the offense involved the production of an identification document that was a Missouri nondriver’s license or personal identification card. On February 22, 2011, in the Western District of Missouri, XXXXXX XXXXXXXXX and XXXX XXXXXXXXX XXXXXX-XXXXX a/k/a “Xxxx,” knowingly transferred, possessed and used without lawful authority, a means of identification of another person, to wit, a Missouri nondriver’s license in the name of Xxxxxxxx Xxxxx Xxxxxxxxx, during and in relation to a felony offense, that being the unlawful production of an identification document. XXXXXX XXXXXXXXX and XXXX XXXXXXXXX XXXXXX-XXXXX a/k/a “Xxxx,” knew that the unlawfully produced identification document was produced with the means of identification of another real person and that the person was not a fictitious person. On February 23, 2011, XXXX XXXXXXXXX XXXXXX-XXXXX a/k/a “Xxxx,” knowingly transported illegal aliens from St. Xxxxxx, Missouri, to North Carolina. The defendant agrees all proceeds contained in Bank account # 0000 0000 0000 in that the defendant’s name with the Bank sum of America, and at least $1,124 in U.S. currency recovered from the defendant at the time of his arrest are 5,250,000 is property that is subject to forfeiture by the United States, the defendant also agrees that the sum of at least $5,250,000 is also subject to forfeiture, in that all of these items represent it represents proceeds from the above-described criminal activity and are is subject to forfeiture.
Appears in 1 contract
Samples: Plea Agreement
Factual Basis for Guilty Plea. The parties agree that the facts constituting the offenses offense to which he she is pleading guilty are as follows: XXXXXX XXXXXXXXX XXXXXX-X. XXXXXXXXX is a citizen and national of MexicoUnited States citizen, who is unlawfully present in the United States and resided in San AntonioSt. Xxxxxx, Texas. XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX has been previously deported from the United States to MexicoMissouri. From on or about November 2009, and continuing until January 10, 2012, in the Western District of Missouri and elsewhere, defendant XXXXXX XXXXXXXXX XXXXXX-X. XXXXXXXXX knowingly and willfully conspired, combined, confederated and agreed with defendants XXXXXX X. XXXXXXXXX, XXXXXXX X. XXXXXX, XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX, XXXXXX DE XX XXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXXXX XXXXXXX-XXXXXX a/k/a “XxxxxFlaco,” XXXXXX DARISEO XXXXXXXX-XXXXXX, XXXXX XXXXXX XXXXXXXXX-FLORES a/k/a “Xxxxxx,” XXXX XXX XXXXXXXXX XXXXXX-XXXXX a/k/a “Xxxx” “Xxxxx Xxxx Xxxxxx-Xxxxxx,” ”, XXXXXX XXXX-XXXXXXXXX, XXXXXX XXXXXXXXX-XXXXX a/k/a “Xxxx,” XXXXXXXXXXX XXXXXXX, XXXXXX XXXXXXXXX, XXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others, to violate the laws of the United States, specifically, to commit the following offenses:
a) Transporting illegal aliens in violation of 8 U.S.C. § 1324(a)(1)(A)(ii);
b) Unlawful production of an identification document in violation of 18 U.S.C. § 1028(a)(1);
c) Unlawful transfer of the means of identification of another person in violation of 18 U.S.C. § 1028(a)(7); and,
d) Social security fraud in violation of 42 U.S.C. § 408(a)(7). It was part of the conspiracy that illegal aliens would travel from across the United States to St. Xxxxxx, Missouri, to obtain either a Missouri driver’s or nondrivernon-driver’s license at the St. Xxxxxx license office, with unlawfully obtained birth certificates and Social Security cards. From November 2009, until January 10, 2012, it is estimated that over 3,500 Missouri driver and nondriver non-driver licenses have been unlawfully issued to illegal aliens as part of this conspiracy. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX XXXXXXXX, XXXXXXXXXXX XXXXXXX, XXXXXX XXXXXXXXX, XXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others would accompany illegal aliens into the St. Xxxxxx license office, under the guise of being translators, in order to assist them with obtaining a Missouri driver’s or nondrivernon-driver’s license that was in the name of another person who was listed on unlawfully obtained birth certificates and Social Security cards. It was further part of the conspiracy that illegal aliens would request assistance from XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX and XXXXXXXX, XXXXXXX XXXXXXXX, XXXXX XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,” XXXXX XXXXXX XXXXXXXXX-FLORES a/k/a XXXXXXXX “Xxxxxx,” XXXX XXXXXXXXX XXXXXX-XXXXX a/k/a “Xxxx” “Xxxxx Xxxx Xxxxxx-Xxxxxx”, XXXXXX XXXX-XXXXXXXXX, XXXXXX XXXXXXXXX-XXXXX a/k/a “Xxxx,” XXXXXXXXXXX XXXXXXX, XXXXXX XXXXXXXXX, XXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others in obtaining birth certificates and Social Security cards in the names of others. These birth certificates and Social Security cards would then be used by the illegal aliens to obtain Missouri driver’s or non-driver’s licenses, all of which could then be used by the illegal aliens to remain unlawfully in the United States, to unlawfully obtain employment and for other unlawful purposes. XXXXXXX XXXXXXXXX and others would usually instruct and assist the illegal aliens to practice memorizing the names on the birth certificates, the names of the parents on the birth certificates, the dates of birth, the social security numbers and also practice signing the name similar to the signature that appeared on the Social Security card. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX, XXXX XXX XXXXXXXXX XXXXXX-XXXXX a/k/a “Xxxx” “Xxxxx Xxxx Xxxxxx-Xxxxxx” and others would sometimes alter the Social Security cards by chemically removing the signatures from the Social Security cards to allow the illegal alien to sign the cards. XXXXXXXX It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX, XXXXXXXXXXX XXXXXXX, XXXXXX XXXXXXXXX, XXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others would assist the illegal aliens prepare for potential questions from the license office employees. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX XXXXXXXX, XXXXXXXXXXX XXXXXXX, XXXXXX XXXXXXXXX, XXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others would assist the illegal aliens who did not live in Missouri, by providing them with a Missouri residential address to use in order to obtain the Missouri driver’s or nondrivernon-driver’s license. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX XXXXXXXX, XXXXXXXXXXX XXXXXXX, XXXXXX XXXXXXXXX, XXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others would usually collect money from the illegal aliens for the document sets and Missouri driver’s or nondrivernon-driver’s license. The money would usually then be paid to ELDER XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,” or XXXXXX DARISEO XXXXXXXX-XXXXXX who would then pay XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, or XXXXXX DE LA XXXX. The illegal aliens were usually charged between $1,500 and $1,600 for the document sets and the Missouri driver’s and nondriver’s licenses. From November 2009, until the date of this Indictment it is estimated that over $5,250,000 in gross proceeds have been paid by illegal aliens to members of this conspiracy. It was part of the conspiracy that XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX and XXXXXX DE LA XXXX would obtain state issued birth certificates, usually from the State of Texas, and they would also obtain a Social Security card in the name of the individual on the birth certificate, so they would have a matching document set. It was further part of the conspiracy that XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX and XXXXXX DE LA XXXX would purchase birth certificates and social security cards from individuals, who were willing to sell their identification documents to XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, XXXXXX DE LA XXXX and others. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX and others would usually receive birth certificates and Social Security cards from XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, XXXXXX DE XX XXXX, XXXXX XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,” and others via U.S. express mail packages. On July 11, 2011, an express mail package was sent from “Xxxxxx Xxxxxx 00000 Xxxxxx Xx Xxx 148, San Antonio, TX 78233,” to “Xxxxxxxxx Xxxxx, 000 Xxxxx Xx., Xxxxxxxx, XX 00000,” via U.S. Mail. XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX knowingly sent this package via the U.S. Mail to ELDER XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,”, knowing that the package contained the means of identification other real people, and that they were not false or fictitious identities when they were transferred. Inside the package was a manila envelope with the name “Flaco” written on the outside. Inside the envelope was a white envelope also with the name “Flaco” written on the outside. Inside the white envelope were six sets of Texas birth certificates with matching Social Security cards. The Social Security Cards were in the names of Xxxx Xxxxxxxxx, Xxxxx Xxxx Xxxxxxxx, Xxxxx Xxxxxx, Xxxxxxx Xxxxx Xxxxx, Xxxxxx Xxxxxxx Xxxxxxx and Xxxxx Xxxxxxx XXX. XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX transferred these means of identification without lawful authority to do so, and for the purpose that they be used to commit felony offenses, including but not limited to social security fraud. The package was delivered on July 12, 2011, to 000 Xxxxx Xx., Xxxxxxxx, Xxxxxxxx. ELDER XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,” answered the door and accepted delivery of the package. On July 14, 2011, an express mail package was sent from “Xxxxxx Xxxxxx, 00000 Xxxxxx Xx., Lot 148, San Antonio, TX 78233” to “Xxxxxxxxx Xxxxx, 000 X. Xxxxxxxx St., Carthage, MO 64836,” via U.S. Mail. Inside the package was a manila envelope with the name “Flaco” written on the outside. Inside the envelope were six document sets, four were Texas birth certificates, there was one Alabama and one California birth certificate, and matching Social Security cards. The package was delivered on July 15, 2011. On September 19, 2011, an express mail package was sent from “Xxxxxx Xxxxxx, 00000 Xxxxxx xx. lot. 000, Xxx Xxxxxxx XX 00000,” to “Xxxxxxx Xxxxxx, 0000 0xxx., Xxxxx Xxxxxx, MO 64505,” via U.S. Mail. Inside the package was a sealed and folded in half express mail package containing two document sets with Texas birth certificates and matching Social Security cards. The package was delivered on September 20, 2011, to the residence at 0000 0xx Xxx., Xx. Xxxxxx, Missouri. The defendant agrees all proceeds contained in Bank account # 0000 0000 0000 in the defendant’s name with the Bank of America, and $1,124 in U.S. currency recovered from the defendant at the time of his arrest are property that is subject to forfeiture by the United States, the defendant also agrees that the sum of at least $5,250,000 is also subject to forfeiture, in that all of these items represent proceeds from the above-described criminal activity and are is subject to forfeiture.
Appears in 1 contract
Samples: Plea Agreement
Factual Basis for Guilty Plea. The parties agree that the facts constituting the offenses to which he is pleading guilty are as follows: XXXXXX XXXX XXXXXXXXX XXXXXX-XXXXXXXXX XXXXX, a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx,” “Xxxx XXX,” is a citizen and national of MexicoGuatemala, who is unlawfully present in the United States and resided in San Antonio, Texas. XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX has been previously deported from the United States to MexicoNorth Carolina. From on or about November 2009, and continuing until January 10, 2012, in the Western District of Missouri and elsewhere, defendant XXXXXX XXXX XXXXXXXXX XXXXXX-XXXXXXXXX XXXXX, a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx,” “Xxxx XXX,” knowingly and willfully conspired, combined, confederated and agreed with defendants XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX, XXXXXX DE XX XXXX, XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXXXX XXXXXXX-XXXXXX a/k/a “XxxxxFlaco,” XXXXXX DARISEO XXXXXXXX-XXXXXX, XXXXX XXXXXX XXXXXXXXX-FLORES a/k/a “Xxxxxx,” XXXX XXX a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx,” XXXXXX XXXX-XXXXXXXXX, XXXXXX XXXXXXXXX-XXXXX a/k/a “Xxxx,” XXXXXXXXXXX XXXXXXX, XXXXXX XXXXXXXXX, XXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others, to violate the laws of the United States, specifically, to commit the following offenses:
a) Transporting illegal aliens in violation of 8 U.S.C. § 1324(a)(1)(A)(ii);
b) Unlawful production of an identification document in violation of 18 U.S.C. § 1028(a)(1);
c) Unlawful transfer of the means of identification of another person in violation of 18 U.S.C. § 1028(a)(7); and,
d) Social security fraud in violation of 42 U.S.C. § 408(a)(7). It was part of the conspiracy that illegal aliens would travel from across the United States to St. Xxxxxx, Missouri, to obtain either a Missouri driver’s or nondrivernon-driver’s license at the St. Xxxxxx license office, with unlawfully obtained birth certificates and Social Security cards. From November 2009, until January 10, 2012, it is estimated that over 3,500 Missouri driver and nondriver non-driver licenses have been unlawfully issued to illegal aliens as part of this conspiracy. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX XXXXXXXX, XXXXXXXXXXX XXXXXXX, XXXXXX XXXXXXXXX, XXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others would accompany illegal aliens into the St. Xxxxxx license office, under the guise of being translators, in order to assist them with obtaining a Missouri driver’s or nondrivernon-driver’s license that was in the name of another person who was listed on unlawfully obtained birth certificates and Social Security cards. It was further part of the conspiracy that illegal aliens would request assistance from XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX and XXXXXXXX, XXXXXXX XXXXXXXX, XXXXX XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,” XXXXX XXXXXX XXXXXXXXX-FLORES a/k/a XXXXXXXX “Xxxxxx,” XXXX XXXXXXXXX XXXXXX-XXXXX, a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx,” “Xxxx XXX,” XXXXXX XXXX-XXXXXXXXX, XXXXXX XXXXXXXXX-XXXXX a/k/a “Xxxx,” XXXXXXXXXXX XXXXXXX, XXXXXX XXXXXXXXX, XXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others in obtaining birth certificates and Social Security cards in the names of others. These birth XXXXXXX XXXXXXXXX and others would usually instruct and assist the illegal aliens to practice memorizing the names on the birth certificates, the names of the parents on the birth certificates, the dates of birth, the social security numbers and also practice signing the name similar to the signature that appeared on the Social Security card. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX, XXXX XXX XXXXXXXXX XXXXXX-XXXXX, a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx,” “Xxxx XXX,” and others would sometimes alter the Social Security cards by chemically removing the signatures from the Social Security cards to allow the illegal alien to sign the cards. XXXXXXXX It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX, XXXXXXXXXXX XXXXXXX, XXXXXX XXXXXXXXX, XXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others would assist the illegal aliens to prepare for potential questions from the license office employees. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX XXXXXXXX, XXXXXXXXXXX XXXXXXX, XXXXXX XXXXXXXXX, XXX XXXXXXXXX, XXXXXXX XXXXXXXXX and others would assist the illegal aliens who did not live in Missouri, by providing them with a Missouri residential address to use in order to obtain the Missouri driver’s or nondrivernon-driver’s license. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX and others would usually collect money from the illegal aliens for the document sets and Missouri driver’s or nondrivernon-driver’s license. The money would usually then be paid to ELDER XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,” or XXXXXX DARISEO XXXXXXXX-XXXXXX who would then pay XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, or XXXXXX DE LA XXXX. The illegal aliens were usually charged between $1,500 and $1,600 for the document sets and the Missouri driver’s and nondrivernon-driver’s licenses. From November 2009, until the date of this Indictment indictment it is estimated that over $5,250,000 in gross proceeds have been paid by illegal aliens to members of this conspiracy. It was part of the conspiracy that XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX and XXXXXX DE LA XXXX would obtain state issued birth certificates, usually from the State of Texas, and they would also obtain a Social Security card in the name of the individual on the birth certificate, so they would have a matching document set. It was further part of the conspiracy that XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX and XXXXXX DE LA XXXX would purchase birth certificates and social security cards from individuals, who were willing to sell their identification documents to XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, XXXXXX DE LA XXXX and others. It was further part of the conspiracy that XXXXXX XXXXXXXXX, XXXXXXX XXXXXX, XXXXXXX XXXXXXXXX, XXXX XXXXXXXX, XXXXXXXXX XXXXXXXX, XXXXXXX XXXXXXXX and others would usually receive birth certificates and Social Security cards from XXXXXX XXXXXXXXX XXXXXX-XXXXXXXXX, XXXXX XXXXX XXXXXX-XXXXXXXXX, XXXXXX DE XX XXXX, XXXXX XXXXXXX XXXXXXX-XXXXXX a/k/a “Flaco,” and others via U.S. express mail packages. On July 11January 24, 2011, an express mail package was sent XXXXXX XXXXXXXXX knowingly transported illegal aliens from “the Motel 6 in St. Xxxxxx, Missouri, to the St. Xxxxxx Xxxxxx 00000 Xxxxxx Xx Xxx 148license office. On January 24, San Antonio2011, TX 78233,” to “Xxxxxxxxx Xxxxx, 000 Xxxxx Xx., Xxxxxxxx, XX 00000,” via U.S. Mail. XXXXXX XXXX XXXXXXXXX XXXXXX-XXXXXXXXX knowingly sent this package via the U.S. Mail to ELDER XXXXXXX XXXXXXX-XXXXXX XXXXX, a/k/a “Flaco,”, knowing that the package contained the means of identification other real people, and that they were not false or fictitious identities when they were transferred. Inside the package was a manila envelope with the name “Flaco” written on the outside. Inside the envelope was a white envelope also with the name “Flaco” written on the outside. Inside the white envelope were six sets of Texas birth certificates with matching Social Security cards. The Social Security Cards were in the names of Xxxx Xxxxxxxxx, Xxxxx Xxxx Xxxxxxxx, Xxxxx Xxxxxx-Xxxxxx,” “Xxxx XXX,” knowingly transported illegal aliens from St. Xxxxxx, Xxxxxxx Xxxxx XxxxxMissouri, Xxxxxx Xxxxxxx Xxxxxxx and Xxxxx Xxxxxxx XXXto North Carolina. XXXXXX On February 21, 2011, XXXX XXXXXXXXX XXXXXX-XXXXXXXXX transferred these means of identification without lawful authority to do soXXXXX, and for the purpose that they be used to commit felony offenses, including but not limited to social security fraud. The package was delivered on July 12, 2011, to 000 Xxxxx Xx., Xxxxxxxx, Xxxxxxxx. ELDER XXXXXXX XXXXXXX-XXXXXX a/k/a “FlacoXxxxx Xxxx Xxxxxx-Xxxxxx,” answered the door and accepted delivery of the package. On July 14, 2011, an express mail package was sent from “Xxxxxx Xxxxxx, 00000 Xxxxxx Xx., Lot 148, San Antonio, TX 78233” to “Xxxxxxxxx Xxxxx, 000 X. Xxxxxxxx St., Carthage, MO 64836Xxxx XXX,” via U.S. Mail. Inside the package was a manila envelope with the name “Flaco” written on the outside. Inside the envelope were six document sets, four were Texas birth certificates, there was one Alabama and one California birth certificate, and matching Social Security cards. The package was delivered on July 15, 2011. On September 19, 2011, an express mail package was sent knowingly transported illegal aliens from “Xxxxxx Xxxxxx, 00000 Xxxxxx xx. lot. 000, Xxx Xxxxxxx XX 00000,” North Carolina to “Xxxxxxx Xxxxxx, 0000 0xxx., Xxxxx Xxxxxx, MO 64505,” via U.S. Mail. Inside the package was a sealed and folded in half express mail package containing two document sets with Texas birth certificates and matching Social Security cards. The package was delivered on September 20, 2011, to the residence at 0000 0xx Xxx., Xx. St. Xxxxxx, Missouri. The defendant agrees all proceeds contained in Bank account # 0000 0000 0000 In Particular, XXXX XXXXXXXXX XXXXXX-XXXXX, a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx,” “Xxxx XXX,” knowingly transported Xxxxx Xxxxxxxx Xxxxxxx-Xxxxxxxxx, an illegal alien who had come to, entered and remained unlawfully in the defendant’s United States. XXXX XXXXXXXXX XXXXXX-XXXXX, a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx,” “Xxxx XXX,” transported the illegal alien within the United States to further her unlawful presence and for the purpose of private financial gain. On February 22, 2011, XXXXXX XXXXXXXXX knowingly transported illegal aliens from the Motel 6 in St. Xxxxxx, Missouri, to the St. Xxxxxx license office. On February 22, 2011, in the Western District of Missouri, XXXX XXXXXXXXX XXXXXX-XXXXX, a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx,” “Xxxx XXX,” knowingly transferred without lawful authority, a means of identification of another person, to wit, a Texas birth certificate in the name of Xxxxxxxx Xxxxx Xxxxxxxxx, in connection with, an unlawful activity that constitutes a violation of Federal law, to wit, false representation of United States citizenship in violation of 18 U.S.C. § 911, and the means of identification were transported in and affected interstate commerce, and the offense involved the transfer of an identification document that was a birth certificate. On February 22, 2011, in the Western District of Missouri, XXXX XXXXXXXXX XXXXXX-XXXXX, a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx,” “Xxxx XXX,” knowingly possessed a Social Security card with the Bank intent to sell or alter it, to wit, a Social Security card in the name of AmericaXxxxxxxx Xxxxx Xxxxxxxxx, for the purpose of obtaining anything of value from any person or for any other purpose. On February 22, 2011, in the Western District of Missouri, XXXXXX XXXXXXXXX and XXXX XXXXXXXXX XXXXXX-XXXXX, a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx,” “Xxxx XXX,” knowingly and without lawful authority, produced an identification document, to wit, a Missouri nondriver’s license in the name of Xxxxxxxx Xxxxx Xxxxxxxxx, the production of the identification was in and affected interstate commerce, and the offense involved the production of an identification document that was a Missouri nondriver’s license or personal identification card. On February 22, 2011, in the Western District of Missouri, XXXXXX XXXXXXXXX and XXXX XXXXXXXXX XXXXXX-XXXXX, a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx,” “Xxxx XXX,” knowingly transferred, possessed and used without lawful authority, a means of identification of another person, to wit, a Missouri nondriver’s license in the name of Xxxxxxxx Xxxxx Xxxxxxxxx, during and in relation to a felony offense, that being the unlawful production of an identification document. XXXXXX XXXXXXXXX and XXXX XXXXXXXXX XXXXXX-XXXXX, a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx,” “Xxxx XXX,” knew that the unlawfully produced identification document was produced with the means of identification of another real person and that the person was not a fictitious person. On February 23, 2011, XXXX XXXXXXXXX XXXXXX-XXXXX, a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx,” “Xxxx XXX,” knowingly transported illegal aliens from St. Xxxxxx, Missouri, to North Carolina. XXXX XXXXXXXXX XXXXXX-XXXXX, a/k/a “Xxxxx Xxxx Xxxxxx-Xxxxxx,” “Xxxx XXX,” agrees that the sum of at least $1,124 5,250,000 in U.S. currency recovered from the defendant at the time of his arrest are is property that is subject to forfeiture by the United States, the defendant also agrees that the sum of at least $5,250,000 is also subject to forfeiture, in that all of these items represent it represents proceeds from the above-described criminal activity and are is subject to forfeiture.
Appears in 1 contract
Samples: Plea Agreement
