IN THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF VIRGINIA
Alexandria Division
UNITED STATES OF AMERICA ) Criminal Number
>
V. > Count 1: 18 U.S.C. 5 1028(f) (conspiracy to
> identification document fraud)
AGUS BUDIMAN, Count 2: 18 U.S.C. 6 1028(a)(l), (b)(l)(A)(ii),
; and (c)(3)(A) (unlawful production of
Defendant > documents), and 5 2 (aiding and abetting)
INDICTMENT
FEBRUARY 2002 TERM - AT ALEXANDRIA
Introductorv Allegations to Counts 1 and 2
THE GRAND JURY CHARGES THAT:
1. A Virginia driver's license and a Virginia identification card are identification
documents made and issued by and under the authority of the Commonwealth of Virginia.
2. To obtain a Virginia driver's license or identification card, an applicant
ordinarily present the Virginia Department of Motor Vehicles (DMV) documentary proof of
Virginia residence. Prior to September 2 1,200 1, however, an applicant lacking documentary
proof of Virginia residence could complete and submit DMV form DL5 1 in lieu of the
proof.
3. DMV form DL5 1 is a residency certification. Prior to September 2 1,200 1,
would accept a properly completed DL5 1 form in lieu of documentary proof of Virginia
residence. The form requires the applicant to provide and to swear to his name and place and
length of Virginia residence. The form further requires the sworn certification of a
resident. Through the certification, the Virginia resident swears that he is personally
with the applicant and that the applicant lives at the Virginia address listed on the form.
certification must be made in the presence of a notary public or a DMV employee, and the
or DMV employee must sign and date the form as well.
count 1
Conspiracy to Commit Identification Fraud
THE GRAND JURY FURTHER CHARGES THAT:
On or about November 4,2000, in Arlington, Virginia, within the Eastern District of
Virginia, the defendant, AGUS BUDIMAN, knowingly and unlawfully conspired with a person
known to the grand jury to produce an identification document without lawful authority when
SNIPPETS:
IN THE UNITED STATES DISTRICT COURT FOR THE
A Virginia driver's license and a Virginia identification card are identification
To obtain a Virginia driver's license or identification card, an applicant must ordinarily
Prior to September 2 1,200 1, however, an applicant lacking documentary proof of Virginia
The form requires the applicant to provide and to swear to his name and place and length of
The form further requires the sworn certification of a Virginia resident.
certification must be made in the presence of a notary public or a DMV employee, and the
THE GRAND JURY FURTHER CHARGES THAT:
known to the grand jury to produce an identification document without lawful authority when
Specifically, on or about November 4,2000, the defendant agreed to assist an unindicted
The purpose of the conspiracy was to obtain a Virginia identification document by fraud
On or about November 4,2000, the unindicted coconspirator applied for a Virginia
On or about November 4,2000, in Arlington, Virginia, within the Eastern District of Virginia,
Specifically, on November 4,2000, the defendant willfully caused agents of the Virginia DMV
Assistant United States Attorney Chief,
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