IN  THE  UNITED  STATES  DISTRICT  COWT  FOR  THE

                                     EASTERN  DISTRICT  OF VIRGINIA

                                               Alexadria  Division

UNITED  STATES  OF  AMERICA                           > j
                     V.                               )  Criminal  Number  01-412-A

LUfS  A.  MARTINEZ-FLORES,

                     Defendant

                                              PLEA  AGREEMENT

        Paul  J. McNulty,  United  States Attorney  for  the  Eastern  Distict  of Virginia,  and

Morton,  Assistant  United  States Attorney,  and the  defendant,  Luis  A.  h&utktez-Florcs,  and

defcr&nt"s  COUJW~, Jeffrey  D.  Zimmerman,  pursuant  to  Rule  1 l(e)  of the Federal  Rules  of

Criminal  Procedure,  have  entered  into  an agreement,  the terms  ad  conditions  of which  are

follows:

             1.  The  defendant,  Luis  A.  Maxtincz-Flares,  agrees to plead  guilty  to the

indictment.  The  pending  indictment  charges the  defendant  tith  identification  document 

violation  of Title  18, United  States Code,  Section  2 and  Section  102&(a)(l),  @)(l)(A)@), 

(c)(3)(A).  The  maxin  mm  penalty  for  this  offense  is a term  of fifteen  years  of

fine  Of $2%,000,  a special  assessment,  and three  years of supervised  release.  The  defendmt 

awar@ that  this  supervised  release  term  is in  addition  to any prison  ttxm  the defendant 

receive,  and that  a violation  of a term  of supervised  relcasa  could  result  in  the 

returned  to prison  for  the  full  term  of supervised  release.

        2.  Before  sentencing  in  this  case, the  defendant  agrees to  pay  a mandatory  special

=sesssrnent of one hundred  dollars  ($100.00)  per  count  of conviction.



        3.  The  defendant  is aware that  thha defendant's  sentence  will  be imposed  in 

                          IN  THE  UNITED  STATES  DISTRICT  COURT  FOR  THE

                                   EASTERN  DISTRICT  OF VIRGINIA

                                             ,4lexmdria     bivision

UP4ITED  STATES  OF  AMERICA

                   V.                                 )  Criminal  Number      b  I -  \&$  -H

LUIS  A.  MARTINEZ-FLOKES.                            ;

                   Defendant

                   Affidavit  in  Suucort  oPa  Criminal  Comtslaint  and  an Arrest  Warrant

         1, JESUS H.  Gomez,  being  duly  sworn,      depose  and state:

         1.  I  am  a special  agent  with  the Federal  Bureau  of Investigation  (FBI),  United 

Department  of Justice,  assigned  to  the Washington  Field  Office.  I have  been  employed  by

FBI  as a special  agent  since  February  1999.  My  primary  duties  are to investigate  large 

conspiracies.

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

application.  It  is not  intondcd  to  inchide  every  fact  or matter  observed  by me  or known 

government.  The  information  provided  is based  on my  personal  knowledge  and  observations

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

officials,  a~nd my  review  of records,  documents  and other  physical  evidence  obtained 

investigation.

         3.  This  application  is submitted  in  support  of a criminal  coJnplainl  and an arrest

charging  Lois  A.  Martinez-Flores  (Martinez)  with  identification  document  fraud,  in 

Title  1 S, `United  States  Code,  Sections  2 and  lOZS(a)(  l),  (b)(l)(A)(n),  and  (c)(3)(A). 

particular,  I  believe  that  on  August  1, 2001,  Martinez  assisted two  men,  Hani  Hanjour 



aad malid  Almihdhw  (Almihdhar)  to  obtain  a Virginia  Depxtment  of Motor  Vehicles  @MY)