SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF THE BRONX

THE PEOPLE OF THE STATE OF NEW YORK

INDICTMENT NO:
GJ NO:

-against-

43876-2014

Hector Ramirez
Ana Cuevas,
Defendants

COUNTS:
FORGERY IN THE SECOND DEGREE, P.L. 170.10 (2), 35 Cts.
CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE, P.L. 170.25, 35 Cts.
FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, P.L. 175.10, 35 Cts
OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, P.L. 175.35 (1), 35 Cts.
TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE P.L. 175.25, 35 Cts.
ILLEGAL VOTING E.L. 17-132 (4), 32 Cts.
ILLEGAL VOTING E.L. 17-132 (8), 35 Cts.

ROBERT T. JOHNSON
DISTRICT ATTORNEY

A True Bill

Foreperson

FIRST COUNT:
THE GRAND JURY OF THE COUNTY OF THE BRONX, by this indictment, accuses the
defendants of the crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10
(2) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

SIXTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised
is not qualified to vote thereat.

to vote or offer or attempt to vote at an election, knowing that he

SEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot bearing the name

NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot bearing the name

TENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot bearing the name
.

ELEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot bearing the name

TWELFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot bearing the name

THIRTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that he

is not qualified to vote thereat.

FOURTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

FIFTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being a
second absentee ballot bearing the name

, date and time stamped by the New York City

Board of Elections on September 9, 2014 at 8:54pm.

SIXTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: a second absentee ballot bearing the name

, date

and time stamped by the New York City Board of Elections on September 9, 2014 at 8:54pm.

SEVENTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: a second absentee ballot bearing the name
, date and time stamped by the New York City Board of Elections on September 9, 2014
at 8:54pm.

EIGHTEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being a second absentee ballot bearing the name
, date and time stamped by the New York City Board of Elections on September 9, 2014 at
8:54pm.

NINETEENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County of the
Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not have
the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove, mutilate,
destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed with,
deposited in, or otherwise constituting a record of a public office or public servant, that being a second
absentee ballot bearing the name

, date and time stamped by the New York City Board of

Elections on September 9, 2014 at 8:54pm.

TWENTIETH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised
is not qualified to vote thereat.

TWENTY-FIRST COUNT:

to vote or offer or attempt to vote at an election, knowing that he

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County of the
Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the name of
another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act in
connection with a second absentee vote cast or attempted to be cast bearing the name

date and time stamped by the New York City Board of Elections on September 9, 2014 at 8:54pm.

TWENTY-SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

TWENTY-THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

TWENTY-FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

TWENTY-FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

TWENTY-SIXTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

TWENTY-SEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that she is

not qualified to vote thereat.

TWENTY-EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

TWENTY-NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

THIRTIETH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name
.

THIRTY-FIRST COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

THIRTY-SECOND COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

THIRTY-THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

THIRTY-FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election,

knowing that he is not qualified to vote thereat.

THIRTY-FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name
.

THIRTY-SIXTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being a
second absentee ballot application bearing the name

, date and time stamped

by the New York City Board of Elections on September 4, 2014 at 5:47pm.

THIRTY-SEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: a second absentee ballot application bearing the name
, date and time stamped by the New York City Board of Elections on September 4, 2014 at
5:47pm.

THIRTY-EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: a second absentee ballot application bearing the
name

, date and time stamped by the New York City Board of Elections on

September 4, 2014 at 5:47pm.

THIRTY-NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being a second absentee ballot application bearing the name
, date and time stamped by the New York City Board of Elections on
September 4, 2014 at 5:47pm.

FORTIETH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being a
second absentee ballot application bearing the name

, date and time stamped

by the New York City Board of Elections on September 4, 2014 at 5:47pm.

FORTY-FIRST COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised
knowing that he is not qualified to vote thereat.

FORTY-SECOND COUNT:

to vote or offer or attempt to vote at an election,

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with a second absentee vote cast or attempted to be cast bearing the name
, date and time stamped by the New York City Board of Elections on September 4, 2014 at
5:47pm.

FORTY-THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

FORTY-FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

FORTY-FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

FORTY-SIXTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

FORTY-SEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

FORTY-EIGHTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that she

is not qualified to vote thereat.

FORTY-NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

FIFTIETH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

FIFTY-FIRST COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

FIFTY-SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

FIFTY-THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

FIFTY-FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

FIFTY-FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that he is

not qualified to vote thereat.

FIFTY-SIXTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

FIFTY-SEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

FIFTY-EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

FIFTY-NINTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

SIXTIETH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

SIXTY-FIRST COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

SIXTY-SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that he is

not qualified to vote thereat.

SIXTY-THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

SIXTY-FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

SIXTY-FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

SIXTY-SIXTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

SIXTY-SEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

SIXTY-EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

SIXTY-NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that she

is not qualified to vote thereat.

SEVENTIETH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

SEVENTY-FIRST COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

SEVENTY-SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

SEVENTY-THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

SEVENTY-FOURTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

SEVENTY-FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

SEVENTY-SIXTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that he is

not qualified to vote thereat.

SEVENTY-SEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

SEVENTY-EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

SEVENTY-NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

EIGHTIETH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

EIGHTY-FIRST COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

EIGHTY-SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

EIGHTY-THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

EIGHTY-FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

EIGHTY-FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

EIGHTY-SIXTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

EIGHTY-SEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

EIGHTY-EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

EIGHTY-NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that he is

not qualified to vote thereat.

NINETIETH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

NINETY-FIRST COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

NINETY-SECOND COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

NINETY-THIRD COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

NINETY-FOURTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

NINETY-FIFTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

NINETY-SIXTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that she is

not qualified to vote thereat.

NINETY-SEVENTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

NINETY-EIGHTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

NINETY-NINTH COUNT:
AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

ONE HUNDREDTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

ONE HUNDRED AND FIRST COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

ONE HUNDRED AND SECOND COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND THIRD COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

ONE HUNDRED AND FOURTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND FIFTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

ONE HUNDRED AND SIXTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

ONE HUNDREDTH AND SEVENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

ONE HUNDRED AND EIGHTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND NINTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

.to vote or offer or attempt to vote at an election, knowing that she is

not qualified to vote thereat.

ONE HUNDRED AND TENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

ONE HUNDRED AND ELEVENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDREDTH AND TWELFTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

ONE HUNDRED AND THIRTEENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

ONE HUNDRED AND FOURTEENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

ONE HUNDRED AND FIFTEENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND SIXTEENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

ONE HUNDRED AND SEVENTEENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND EIGHTEENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

ONE HUNDRED AND NINTEENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

ONE HUNDRED AND TWENTIETH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

ONE HUNDRED AND TWENTY-FIRST COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND TWENTY-SECOND COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that

she is not qualified to vote thereat.

ONE HUNDRED AND TWENTY-THIRD COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

ONE HUNDRED AND TWENTY-FORTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot bearing the name

ONE HUNDRED AND TWENTY-FIFTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot bearing the name

ONE HUNDRED AND TWENTY-SIXTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot bearing the name
.

ONE HUNDRED AND TWENTY-SEVENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot bearing the name

ONE HUNDRED AND TWENTY-EIGHTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot bearing the name

ONE HUNDRED AND TWENTY-NINTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that

she is not qualified to vote thereat.

ONE HUNDRED AND THIRTIETH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

ONE HUNDRED AND THIRTY-FIRST COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND THIRTY-SECOND COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

ONE HUNDRED AND THIRTY-THIRD COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

ONE HUNDRED AND THIRTY-FORTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

ONE HUNDRED AND THIRTY-FIFTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND THIRTY-SIXTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that he

is not qualified to vote thereat.

ONE HUNDRED AND THIRTY-SEVENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

ONE HUNDRED AND THIRTY-EIGHTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND THIRTY-NINTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

ONE HUNDRED AND FORTIETH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

ONE HUNDRED AND FORTY-FIRST COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

ONE HUNDRED AND FORTY-SECOND COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND FORTY-THIRD COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that

she is not qualified to vote thereat.

ONE HUNDRED AND FORTY-FOURTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

ONE HUNDRED AND FORTY-FIFTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the
County of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to
defraud, deceive or injure another, did falsely make, complete or alter a written instrument which was or
purported to be or which was calculated to become, or to represent if completed, a public record, or an
instrument filed or required or authorized by law to be filed in or with a public office or public servant,
that being a second absentee ballot application bearing the name

, date and time

stamped by the New York City Board of Elections on September 2, 2014 at 2:38pm.

ONE HUNDRED AND FORTY-SIXTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the
County of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the
knowledge that it was forged and with intent to defraud, deceive or injury another, did utter or possess a
forged instrument, that being a public record, or an instrument filed or required or authorized by law to be
filed in or with a public office or public servant, to wit: a second absentee ballot application bearing the
name
2, 2014 at 2:38pm.

, date and time stamped by the New York City Board of Elections on September

ONE HUNDRED AND FORTY-SEVENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the
County of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to
defraud and with the intent to commit another crime or to aid or conceal the commission thereof, did make
or cause a false entry in the business records of an enterprise, to wit: a second absentee ballot application
bearing the name

, date and time stamped by the New York City Board of Elections on

September 2, 2014 at 2:38pm.

ONE HUNDRED AND FORTY-EIGHTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being a second absentee ballot application bearing the name
, date and time stamped by the New York City Board of Elections on September 2,
2014 at 2:38pm.

ONE HUNDRED AND FORTY-NINTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being a
second absentee ballot application bearing the name
New York City Board of Elections on September 2, 2014 at 2:38pm.

, date and time stamped by the

ONE HUNDRED AND FIFTIETH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that

she is not qualified to vote thereat.

ONE HUNDRED AND FIFTY-FIRST COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with a second absentee vote cast or attempted to be cast bearing the name
, date and time stamped by the New York City Board of Elections on September 2, 2014 at
2:38pm.

ONE HUNDRED AND FIFTY-SECOND COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot bearing the name

ONE HUNDRED AND FIFTY-THIRD COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot bearing the name

ONE HUNDRED AND FIFTY-FOURTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot bearing the name
.

ONE HUNDRED AND FIFTY-FIFTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot bearing the name

ONE HUNDRED AND FIFTY-SIXTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot bearing the name

ONE HUNDRED AND FIFTY-SEVENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that

she is not qualified to vote thereat.

ONE HUNDRED AND FIFTY-EIGHTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

ONE HUNDRED AND FIFTY-NINTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND SIXTIETH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

ONE HUNDRED AND SIXTY-FIRST COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

ONE HUNDRED AND SIXTY-SECOND COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

ONE HUNDRED AND SIXTY-THIRD COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND SIXTY-FOURTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that he is

not qualified to vote thereat.

ONE HUNDRED AND SIXTY-FIFTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

ONE HUNDRED AND SIXTY-SIXTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND SIXTY-SEVENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

ONE HUNDRED AND SIXTY-EIGHTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

ONE HUNDRED AND SIXTY-NINTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

ONE HUNDRED AND SEVENTIETH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND SEVENTY-FIRST COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that

she is not qualified to vote thereat.

ONE HUNDRED AND SEVENTY-SECOND COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

ONE HUNDRED AND SEVENTY-THIRD COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot bearing the name

ONE HUNDRED AND SEVENTY-FOURTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot bearing the name

ONE HUNDRED AND SEVENTY-FIFTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot bearing the name
.

ONE HUNDRED AND SEVENTY-SIXTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot bearing the name

ONE HUNDRED AND SEVENTY-SEVENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot bearing the name

ONE HUNDRED AND SEVENTY-EIGHTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that

she is not qualified to vote thereat.

ONE HUNDRED AND SEVENTY-NINTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

ONE HUNDRED AND EIGHTIETH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND EIGHTY-FIRST COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name
.

ONE HUNDRED AND EIGHTY-SECOND COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

ONE HUNDRED AND EIGHTY-THIRD COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

ONE HUNDRED AND EIGHTY-FOURTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND EIGHTY-FIFTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing

that he is not qualified to vote thereat.

ONE HUNDRED AND EIGHTY-SIXTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

ONE HUNDRED AND EIGHTY-SEVENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot bearing the name

ONE HUNDRED AND EIGHTY-EIGHTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot bearing the name

ONE HUNDRED AND EIGHTY-NINTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot bearing the name
.

ONE HUNDRED AND NINETIETH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot bearing the name
.

ONE HUNDRED AND NINETY-FIRST COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot bearing the name

ONE HUNDRED AND NINETY-SECOND COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing

that he is not qualified to vote thereat.

ONE HUNDRED AND NINETY-THIRD COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

ONE HUNDRED AND NINETY-FOURTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND NINETY-FIFTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

ONE HUNDRED AND NINETY-SIXTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

ONE HUNDRED AND NINETY-SEVENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

ONE HUNDRED AND NIENTY-EIGHTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

ONE HUNDRED AND NINETY-NINTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that she

is not qualified to vote thereat.

TWO HUNRDREDTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

TWO HUNDRED AND FIRST COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the
County of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to
defraud, deceive or injure another, did falsely make, complete or alter a written instrument which was or
purported to be or which was calculated to become, or to represent if completed, a public record, or an
instrument filed or required or authorized by law to be filed in or with a public office or public servant,
that being a second absentee ballot application bearing the name

, date and time stamped

by the New York City Board of Elections on September 4, 2014 at 2:02pm.

TWO HUNDRED AND SECOND COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the
County of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the
knowledge that it was forged and with intent to defraud, deceive or injury another, did utter or possess a
forged instrument, that being a public record, or an instrument filed or required or authorized by law to be
filed in or with a public office or public servant, to wit: a second absentee ballot application bearing the
name
2014 at 2:02pm.

, date and time stamped by the New York City Board of Elections on September 4,

TWO HUNDRED AND THIRD COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the
County of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to
defraud and with the intent to commit another crime or to aid or conceal the commission thereof, did make
or cause a false entry in the business records of an enterprise, to wit: a second absentee ballot application
bearing the name

, date and time stamped by the New York City Board of Elections on

September 4, 2014 at 2:02pm.

TWO HUNDRED AND FOURTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being a second absentee ballot application bearing the name
, date and time stamped by the New York City Board of Elections on September 4, 2014
at 2:02pm.

TWO HUNDRED AND FIFTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being a
second absentee ballot application bearing the name
York City Board of Elections on September 4, 2014 at 2:02pm.

, date and time stamped by the New

TWO HUNDRED AND SIXTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that she

is not qualified to vote thereat.

TWO HUNDRED AND SEVENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with a second absentee vote cast or attempted to be cast bearing the name

date and time stamped by the New York City Board of Elections on September 4, 2014 at 2:02pm.

TWO HUNDRED AND EIGHTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot bearing the name

TWO HUNDRED AND NINTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot bearing the name

TWO HUNDRED AND TENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot bearing the name
.

TWO HUNDRED AND ELEVENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot bearing the name

TWO HUNDRED AND TWELFTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot bearing the name

TWO HUNDRED AND THIRTEENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that she

is not qualified to vote thereat.

TWO HUNDRED AND FOURTEENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

TWO HUNDRED AND FIFTEENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

TWO HUNDRED AND SIXTEENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

TWO HUNDRED AND SEVENTEENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

TWO HUNDRED AND EIGHTEENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

TWO HUNDRED AND NINETEENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

TWO HUNDRED AND TWENTIETH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that she is

not qualified to vote thereat.

TWO HUNDRED AND TWENTY-FIRST COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

TWO HUNDRED AND TWENTY-SECOND COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot bearing the name

TWO HUNDRED AND TWENTY-THIRD COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot bearing the name

TWO HUNDRED AND TWENTY-FOURTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot bearing the name
.

TWO HUNDRED AND TWENTY-FIFTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot bearing the name

TWO HUNDRED AND TWENTY-SIXTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot bearing the name

TWO HUNDRED AND TWENTY-SEVENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that she is

not qualified to vote thereat.

TWO HUNDRED AND TWENTY-EIGHTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

TWO HUNDRED AND TWENTY-NINTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot application bearing the name

TWO HUNDRED AND THIRTIETH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot application bearing the name

TWO HUNDRED AND THIRTY-FIRST COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name
.

TWO HUNDRED AND THIRTY-SECOND COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot application bearing the name
.

TWO HUNDRED AND THIRTY-THIRD COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot application bearing the name

TWO HUNDRED AND THIRTY-FOURTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that he is

not qualified to vote thereat.

TWO HUNDRED AND THIRTY-FIFTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

TWO HUNDRED AND THIRTY-SIXTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,
deceive or injure another, did falsely make, complete or alter a written instrument which was or purported
to be or which was calculated to become, or to represent if completed, a public record, or an instrument
filed or required or authorized by law to be filed in or with a public office or public servant, that being an
absentee ballot bearing the name

TWO HUNDRED AND THIRTY-SEVENTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,
in violation of Penal Law 170.25 committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that
it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,
that being a public record, or an instrument filed or required or authorized by law to be filed in or with a
public office or public servant, to wit: an absentee ballot bearing the name

TWO HUNDRED AND THIRTY-EIGHTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law
175.10 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and
with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a
false entry in the business records of an enterprise, to wit: an absentee ballot bearing the name
.

TWO HUNDRED AND THIRTY-NINTH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in
violation of Penal Law 175.35 (1) committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written
instrument contained a false statement or false information and with intent to defraud the state or any
political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a
public office or public servant with the knowledge or belief that it would be filed with, registered or
recorded in or otherwise become a part of the records of such public office or public servant, public
authority or public benefit corporation, that being an absentee ballot bearing the name

TWO HUNDRED AND FORTIETH COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal
Law 175.25 committed as follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not
have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,
mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed
with, deposited in, or otherwise constituting a record of a public office or public servant, that being an
absentee ballot bearing the name

TWO HUNDRED AND FORTY-FIRST COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,
commanded or advised

to vote or offer or attempt to vote at an election, knowing that he is

not qualified to vote thereat.

TWO HUNDRED AND FORTY-SECOND COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the
crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (8) committed as
follows:
The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County
of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the
name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act
in connection with an absentee vote cast or attempted to be cast bearing the name

ROBERT T. JOHNSON
District Attorney

GJ #43876-14
Filed:

NA

No.

THE PEOPLE OF THE STATE OF NEW YORK

- against-

HECTOR RAMIREZ
ANA CUEVAS
Defendants
__________________________________________

INDICTMENT
FORGERY IN THE SECOND DEGREE, P.L. 170.10 (2), 35 Cts.
CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE, P.L. 170.25, 35 Cts.
FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, P.L. 175.10, 35 Cts
OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, P.L. 175.35 (1), 35 Cts.
TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE P.L. 175.25, 35 Cts.
ILLEGAL VOTING E.L. 17-132 (4), 32 Cts.
ILLEGAL VOTING E.L. 17-132 (8), 35 Cts.

Pishoy Yacoub
Assistant District Attorney,
Bronx County District Attorneys Office
Rackets Bureau

ADJOURNED TO PART ______ ON __________