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HE&Snmd/2002R00760
v. *
(Obtaining Falsely Made or
Unlawfully Obtaining Visa,
RASMI SUBHI SALEH AL SHANNAQ * 18 U.S.C. § 1546(a))
....oOo....
INDICTMENT
did obtain from the United States Embassy in Doha, Qatar a United
States nonimmigrant visa knowing that said visa had been falsely
Thomas M. DiBiagio
United States Attorney
A TRUE BILL
Poreperson
Date
IN THE UNITED STATES DISTRICT COURT FOR THE
Alexandria Division
INDICTMENT
Alexandria Division
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
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
Alexandria Division
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
Alexandria Division
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
V. CRIMINAL COMPLAINT
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
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