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HE&Snmd/2002R00760

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND

UNITED STATES OF AMERICA * CRIMINAL NO.

v. *
(Obtaining Falsely Made or
Unlawfully 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 SHANNAQ

did obtain from the United States Embassy in Doha, Qatar a United

States nonimmigrant visa knowing that said visa had been falsely

made and otherwise unlawfully obtained.

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

Thomas M. DiBiagio
United States Attorney

A TRUE BILL

Poreperson

Date
 IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

UNITED STATES OF AMERICA ) Criminal Number

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

INDICTMENT

MARCH 2002 TERM - AT ALEXANDRIA

Introductory Allegations to Counts 1 and 2

THE GRAND 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 (DMV) proof of identity and
Virginia residence. The DMV requires two official identification documents as proof of identity
and one official or business document as proof of Virginia residence. Prior to September 21,
2001, however, applicants lacking the required documentary proof of identity and Virginia
residence could complete and submit DMV forms DL6 and DL51 in lieu of the required
documents.
2. DMV form DL6 is an identity affidavit. Prior to September 21, 2001, the DMV
would accept a properly completed DL6 form in lieu of one of the two identification documents
required to apply for a license or identification card. The form requires the applicant to provide
and to swear to his name, address, and basic biographic information. The form further requires
the sworn, notarized certification of an attorney. Through the certification, the attorney swears
 IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

UNITED STATES OF AMERICA )

)
v. ) Criminal Number
)
ABDEL RAHMAN OMAR TAWFIQ
ALFAURU )
)
Defendant )

Affidavit in Support of a Criminal Cgmplamt and an Arrest. Warrant

if
L, Peter W. Ashooh, being duly sworn, depose and state: . t
1
1. 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 the

FBI as a^special agent since 1984. My primary duties are to investigate Organized Crime

matters.

2. This affidavit contains information necessary to support probable cause for this

application, It is not intended to include each and every fact and matter observed by me or

known by the government. The information provided is based on my personal knowledge and

observations during the course of this investigation, information conveyed to me by other law

enforcement officials, and my review of records, documents and other physical evidence

obtained during this investigation.

3. This application is submitted in support of a criminal complaint and arrest warrant

charging Abdel Rahman Omar Tawfiq Alfauru with unlawfully producing an identification

document, and aiding and 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
FindLow
WWW.FINDLAW.COM i^ THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

UNITED STATES OF AMERICA )

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

PLEA AGREEMENT
Paul J. McNulty, United States Attorney for the Eastern District of Virginia, and John T.
Morton, Assistant United States Attorney, and the defendant, Agus Budiman, and the defendant's
counsel, William B. Moffitt and Pleasant S. Brodnax, III, pursuant to Rule 1 l(e) of the Federal
Rules of Criminal Procedure, have entered into an agreement, the terms and conditions of which
are as follows:
. The defendant, Agus Budiman, agrees to plead guilty to count two of the pending
indictment. Count two charges the defendant with identification document fraud, in violation of
Title 18, United States Code, Section 1028(a)(l), (b)(l)(A)(ii), and (c)(3)(A), and Section 2. The
maximum penalty for 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 defendant is aware that this
supervised release term is in addition to any prison term the defendant may receive, and that a
violation of a term of supervised release could result in the defendant being returned to prison for
the full term of supervised release. Upon the Court's acceptance of this plea, the United States
will move to dismiss the remaining count of the indictment (count one) against this defendant.
. Before sentencing in this case, the defendant agrees to pay a mandatory special
assessment of one hundred dollars ($100.00) per count of conviction.
 IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

UNITED STATES OF AMERICA )

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

STATEMENT OF FACTS
The United States and the defendant, Agus Budiman, agree that had this matter
proceeded to trial, the United States would have proven the following facts beyond a reasonable
doubt:
1. The defendant, Agus Budiman, is a citizen of Indonesia currently in the United States
unlawfully. The defendant's mother tongue is Indonesian, although he speaks and understands
English.
2. Virginia identification cards and Virginia driver's licenses are identification
documents made and issued by and under the authority of the Commonwealth of Virginia. Their
production is in and effects interstate commerce.
3. To obtain a Virginia driver's license or identification card, an applicant must
ordinarily present the Virginia Department of Motor Vehicles (DMV) documentary proof of
Virginia residence. Prior to September 21, 2001, however, an applicant lacking documentary
proof of Virginia residence could complete and submit DMV form DL51 in lieu of the required
proof.
4. DMV form DL51 is a residency certification. Prior to September 21, 2001, the DMV
would accept a properly completed DL51 form in lieu of documentary proof of Virginia
 IL K
AO 91 (Rav. IVgSi CMmln
2691=
CLERK. US, DISTRICT COURT
United States Di.shn.ci Court ALEXANDRIA. VII6INIA

EASTERN DISTRICT OF VIRGINIA

UNITED STATES OF AMERICA

V. CRIMINAL COMPLAINT

MOBAJVCEOABDI OiO£>£fc ^£AL

CASE NUMBER: Q / -

I. .tha undersigned complainant being duly sworn state the following is true and comet to the Dest of my
knowledge and belief. From In or QbOUt _flflftjltf 1399 through Jme IQOt in Arilntton County tad Aleiindrta

in the gariera District of Vlndria (he defendant did

knowingly t&A utUtwfnlly mite, ntter, ud possess • ftrjed twaittr Of » State and political ntbdhrfiton ttcrcuf nd of an
orgftulzntlon, with Intent to dectlvc wathv pinnn, orgurfzatfia, ud goTtrmnent

In vtoletlon of THJ« , . United State* Cede. 3««lon(s)

I further state that I am a(n) Sataa AMiit and that this complaint la based on tha following facts:

See Attached Afin&tft

Continued on tho attached shaat and mada a part hereof

AU8A- Robert A. Spencer

Kevin W.Aihby
Sworn to »3*for» me and subscribed (n my presence, Spiciil Agent.
Federal Bureau of Investigation

September 23. 2001

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