Affidavit of Special Agent Christina Rosen in Support of a Criminal Complaint (No. 1:26-mj-05083, D. Mass.)

Summary

The affidavit of Department of Labor Office of Inspector General Special Agent Christina Rosen in support of a criminal complaint against Arvaro Montero Diaz, No. 1:26-mj-05083-JGD, in the U.S. District Court for the District of Massachusetts, filed March 6, 2026 as Document 1-5. It supports charges under 7 U.S.C. § 2024(b) for SNAP benefits, 18 U.S.C. §1343 and aggravated identity theft under 18 U.S.C. §1028A. The affidavit states that the defendant, posing as a victim identified as A.R.H., received $12,525 in Massachusetts SNAP benefits between February 2021 and June 2025 and filed CARES Act Pandemic Unemployment Assistance and unemployment insurance claims, including $6,603 issued on the PUA claim. It relies on driver's license photographs and a fingerprint comparison to identify the defendant.

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“Affidavit of Special Agent Christina Rosen in Support of a Criminal Complaint (No. 1:26-mj-05083, D. Mass.).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/complaint-no-1-26-mj-05083-dkt-1-5-d-mass-34e4450f36/, SHA-256 ba9d18d450716908131c6bb90132d2d698ee59c1e3edb07c4e1b1555b2040ee7.

Full text

Case 1:26-mj-05083-JGD Document 1-5 Filed 03/06/26 Page 1 of 12

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AFFIDAVIT OF SPECIAL AGENT CHRISTINA ROSEN IN SUPPORT OF
A CRIMINAL COMPLAINT

I, Christina Rosen, having been sworn, state:
Introduction and Agent Background

1. I am employed as a Special Agent with the United States Department of Labor,

Office of Inspector General, Office of Investigations (“DOL OIG”) in Boston, Massachusetts. My

responsibilities as a Special Agent with DOL OIG include investigating fraud, waste and abuse of

Department of Labor programs, employees, and departments. I have been employed by the United

States government as a Special Agent since October 2007. I am a graduate of the Criminal

Investigator Training Program of the Federal Law Enforcement Training Center in Glynco,

Georgia, and have received extensive training in criminal investigation procedures and criminal

law. In 2005, I graduated from Northeastern University with a Bachelor’s degree in Criminal

Justice. In 2006, I graduated from Boston University with a Master’s degree in Criminal Justice.

2. I am currently assigned to the HSI New England Document and Benefit Fraud Task

Force (“DBFTF”), a specialized field investigative group comprised of personnel from various

state, local, and federal agencies with expertise in detecting, deterring, and disrupting organizations

and individuals involved in various types of document, identity, financial, and benefit fraud

schemes. I have conducted investigations of several types of criminal activity, including work visa

fraud, unemployment insurance fraud, CARES Act fraud, false claims fraud, employee benefits

fraud, identity theft, and money laundering. As part of this task force, I am responsible for

conducting investigations involving, but not limited to, the manufacturing, counterfeiting,

alteration, sale, and use of identity documents and other fraudulent documents to evade law

enforcement or for other criminal activity. Due to my training and experience, as well as

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conversations with other law enforcement officers, I am familiar with the methods, routines, and

practices of document counterfeiters, vendors, and persons who fraudulently obtain or assume

false identities.

3. I have participated in various aspects of investigations into the use and manufacture

of fraudulent documents, including conducting physical surveillance, surveillance of controlled

purchases involving undercover agents and/or cooperating witnesses, the introduction of

undercover agents, the execution of search warrants, the effecting of arrests, and the debriefing of

defendants, informants, and witnesses.

Purpose of Affidavit

4. I submit this affidavit in support of an application for a criminal complaint charging

Arvaro Montero Diaz with a violation of 7 U.S.C. § 2024(b), Illegal Acquisition or Use of

Supplemental Nutrition Assistance Program (“SNAP”) Benefits, 18 U.S.C. §1343, Mail Fraud,

and 18 U.S.C. §1028A, Aggravated Identity Theft. 1

5. This affidavit is based on my personal knowledge, information provided to me by

other law enforcement officers and federal agents, and my review of records described herein.

This affidavit is not intended to set forth all of the information that I have learned during this

investigation but includes only the information necessary to establish probable cause for the

requested criminal complaint.

Background Information on SNAP

6. SNAP is a government benefit funded by the American taxpayer. Congress enacted

SNAP to “promote the general welfare, to safeguard the health and well-being of the nation’s

1
I have reviewed this individual’s Alien file, or A-file, and it is my understanding that he filed for
a provisional waiver to file for adjusted status (a Form I601A) but that the provisional waiver was
denied

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population by raising levels of nutrition among low-income households.” 7 U.S.C. § 2011. This

program seeks to enable low-income households to obtain a more nutritious diet by increasing

their food purchasing power.

7. Under the program, eligible households receive food stamps in the form of credits

to an electronic benefit card to buy food from retail food stores that participate in SNAP. Food

stamp benefits are obligations of the United States and redeemable at face value by the Secretary

through the facilities of the Treasury of the United States. 7 U.S.C. § 2024(d). USDA administers

SNAP nationally. Individuals or families that are in need of SNAP benefits may apply for

assistance through the Massachusetts Department of Transitional Assistance (“DTA”).

8. To qualify for SNAP in Massachusetts, the applicant must be a resident of

Massachusetts, meet the financial eligibility requirements, and be a United States citizen or an

eligible non-citizen, such as Lawful Permanent Resident (“LPR”) who has earned, or can be

credited with, 40 quarters of work. An applicant for SNAP benefits must also provide proof of

their identity, i.e., the applicant must be the person who they claim to be. An applicant must also

furnish a Social Security number or provide proof that the applicant has applied for one.

9. Massachusetts uses the Electronic Benefit Transfer (“EBT”) system for SNAP

benefits. The EBT system uses plastic debit cards, which are automatically credited with the

recipient’s appropriate amount of benefits during certain times of each month. To access benefits,

the recipient presents the card at an authorized retailer’s location. The card is swiped through an

electronic terminal device (commonly and hereinafter referred to as an “EBT terminal”) which

reads coded information on the card’s magnetic strip. The transaction amount is deducted from the

EBT card’s balance and deposited into the retailer’s account.

10. An applicant for SNAP benefits must provide complete and accurate information

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both at the time of application and on an ongoing basis in order to properly assess initial and

continued eligibility for benefits. All applicants must acknowledge this in the application. It is

unlawful to knowingly use, transfer, acquire, alter, or possess SNAP benefits in any manner

contrary to Title 7 of United States Code or the regulations issued by the USDA. It is unlawful to

knowingly use, transfer, acquire, alter, or possess SNAP benefits in any manner contrary to Title 7

of United States Code or the regulations issued by the USDA.

Massachusetts Unemployment Benefits

11. In the Commonwealth of Massachusetts, Unemployment Insurance (“UI”) benefits

are funded by the UI Trust Fund, which is comprised of monies obtained by state-imposed taxes

on employers, and federal funds. The Department of Unemployment Assistance (DUA) is

responsible for administering the UI program in Massachusetts.

12. On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act

(“CARES Act”) was signed into law. The CARES Act provided additional monies and benefit

weeks for UI claims, as well as created a new temporary federal unemployment insurance program

called Pandemic Unemployment Assistance (“PUA”). PUA provided unemployment benefits for

individuals who were not eligible for UI or other types of unemployment (e.g., individuals who

are self-employed, independent contractors, gig economy workers). All COVID-19 UI claims, and

PUA claims, were eligible to receive additional monies and additional benefit weeks from

temporary federal programs created by the CARES Act.

13. If a claimant was eligible for UI, they were not eligible for PUA, and vice versa.

Probable Cause

14. The HSI New England DBFTF is currently investigating a group of undocumented

persons who are believed to have obtained stolen identities of United States citizens, most of whom

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reside in Puerto Rico, and used those identities to obtain identity documents and public benefits

that they would not otherwise be eligible to receive, such as Social Security numbers (“SSN”),

SNAP, Supplemental Security Income (“SSI”), MassHealth, Unemployment, and United States

passports.

15. In January 2025, federal agents conducted an analysis of SNAP recipient data to

detect identities (names, dates of birth, and Social Security numbers) receiving SNAP benefits in

multiple states during a specific time period. It is unlawful for a person to receive SNAP benefits

in more than one state in any month.

16. In March 2023, a person or persons using the identity of A.R.H. 2 received SNAP

benefits in both Massachusetts and Puerto Rico simultaneously. An identity receiving SNAP and

other government benefits in more than one state simultaneously is an indicator of identity theft.

17. According to MA DTA records, on or about September 4, 2020, an individual

claiming to be A.R.H. completed a provisional report which confirmed his information was up to

date. On the application, the applicant represented himself as A.H.R. with the date of birth xx-xx-

1985 3 and a mailing address in Lowell, MA. Included in the MA DTA records is a photocopy of

a Puerto Rico driver’s license in the name of A.L.R.H., with date of birth xx-xx-1985, and bearing

license number xxxxx17 (see image below). It is unclear which application this driver’s license is

attached to but it appears to correspond with the September 4, 2020 provisional report.

2
The identity of victim A.R.H. is known to the government. The initials of the victim’s full name
are A.L.R H. In order, these initials represent the victim’s first name, middle name, paternal last
name, and maternal last name. To protect the victim’s privacy, only the initials “A.L.R.H.”,
“A.R.H.”, “A.H.R.”, and “A.R.” are used in this affidavit to reflect the variations of the victim’s
full name.
3
The DOB has been partially redacted herein. The redacted DOBs referenced in the Affidavit
are identical unless otherwise noted.

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18. According to MA DTA, between February 2021 and June 2025, the individual

posing as A.R.H. received $12,525 in SNAP benefits from Massachusetts.

Use of the Victim A.R.H. Identity at the MA RMV

19. On or about October 16, 2016, an individual submitted an application to the MA

Registry of Motor Vehicles (“RMV”) to convert an out of state driver’s license from New

Hampshire. On the application the individual provided the name A.L.R.H., date of birth xx-xx-

1985, SSN xxx-xx-9489, and an address in Lowell, MA. The individual also provided a copy of

his NH driver’s license as proof of identification. As a result, MA driver’s license Sxxxx999 was

issued. On November 2, 2016, the license was revoked due to identified fraud.

20. On May 6, 2024, an individual submitted an application to the MA RMV for a Real

ID driver’s license. The individual provided the name Arvaro Alberto Montero Diaz, date of birth

xx-xx-1985, and an address in Lowell, MA. As a result, driver’s license SAxxx1267 was issued

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and was merged with account Sxxxx9999, which belonged to the individual purporting to be

A.R.H., and which had been previously identified as fraudulent by the MA RMV.

21. I have compared the MA driver’s license photograph of Arvaro Alberto Montero

Diaz (SAxxx1267) to the MA driver’s license photograph of the individual purporting to be

A.L.R.H. and believe they depict the same person.

A.L.R.H., Sxxxx9999 Arvaro Montero Diaz, SAxxx1267

Pandemic Unemployment Assistance Fraud

22. On or about July 12, 2020, a claim for Pandemic Unemployment Assistance

(“PUA”) was filed for A.R. with the MA Department of Unemployment Assistance (“DUA”). In

this claim, A.R. stated his “place of employment was closed because of COVID-19” and his

employment was first affected by COVID-19 on March 5, 2020. A.R. further indicated he had

filed for Unemployment Insurance (“UI”) but had been denied. A.R. identified he earned $15,000

in 2019 and had not earned more than $89 a week between March 1, 2020 and July 11, 2020.

38. On his application, A.R. listed date of birth xx-xx-1985, SSN xxx-xx-9489, and a

home and mailing address in Lowell, MA. A.R. also certified he was a U.S. citizen and requested

that all PUA benefits be deposited directly into a Bancorp Bank checking account ending in 7073.

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39. Prior to submitting this application, A.R. provided email arvarof1@hotmail.com

and cell phone number xxx-xxx-6124 4. Arvaro Alberto Montero Diaz utilized email

arvarof1@hotmail.com 5 in his MA RMV application for SAxxx1267. The email address itself

begins with this individual’s first name (“Arvaro”).

40. DUA placed an Identity Verification Issue on the claim. In response, on the same

day, A.R. uploaded documents to support the A.R. PUA claim which included mail from MA DTA

to show proof of address, a Social Security card 6, a Puerto Rico birth certificate, and the same

Puerto Rico driver’s license submitted to MA DTA which is referenced in paragraph 17. Upon

review of the submitted documentation, MA DUA verified the identity.

41. On or about June 14, 2020, DUA issued a total of $6,603 (9 weeks of benefits) on

this claim into Bancorp Bank checking account ending in 7073.

42. On or about June 20, 2020, DUA issued a notification to A.R. stating he is not

eligible for PUA as he is eligible for UI.

COVID-19 Unemployment Insurance Fraud

43. On or about June 29, 2020, a claim for COVID-19 UI was filed for A.R. with MA

DUA 7. The application lists date of birth xx-xx-1985, SSN xxx-xx-9489, a mailing and residential

address in Lowell, MA, phone number xxx-xxx-6124, and email address alvarof1@hotmail.com.

4
Arvaro Montero Diaz provided this phone number in his I-601A Application for Provisional
Unlawful Presence Waiver with United States Customs and Immigration Services (“USCIS”).
5
Arvaro Montero Diaz provided this email in his I-601A Application for Provisional Unlawful
Presence Waiver with USCIS.
6
This exact SSA card was also submitted to MA RMV in support of A.L.R.H. license
SXXXX9993.
7
A search of MA DUA UI claims also located two historical UI claims filed for A.R. in 2014 and
2016.

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This application claims A.R. is a U.S. Citizen that worked 40 hours a week in MA as a barber 8. In

addition, the A.R. claim requests correspondence from DUA in Spanish and via the US mail.

44. Due to the COVID-19 emergency, the traditional one week wait period for

eligibility verification was waived. As such, on or about July 30, 2020, DUA determined the A.R.

claim would be eligible for a weekly benefit allowance of $193, plus any additional CARES Act

monies and/or extended weeks (i.e. Federal Pandemic Unemployment Compensation, Lost Wage

Assistance-FEMA, and Pandemic Emergency Unemployment Compensation).

45. In support of his UI application, A.R. submitted to DUA, via the United States

Postal Service, multiple documents to secure benefit monies. In particular, on or about August 10,

2021, A.R. mailed in a response to DUA’s request for corrected wage and employer information

regarding disputed information on this claim. As part of these records, DUA scanned the envelope

in which the document was mailed to A.R. This envelope had a return mailing address of R.A. in

Lowell, Massachusetts.

46. From on or about August 4, 2020 to on or about September 8, 2021, after submitting

weekly certifications 9 every week stating A.R. was willing and able to work, DUA issued

approximately $22,895 on the A.R. UI claim. A.R. first requested these benefits be issued on a

Bank of America debit card, but after one payment requested the monies be deposited into a

Bancorp Bank checking account ending in 7073.

Criminal History in Victim’s Name

47. The individual posing as A.R.H was arrested in the name of the victim, A.R.H., on

8
The UI application identifies additional prior employment in Massachusetts to include, but not
limited to, being a personal care aide and a production worker at other employers.
9
Weekly certifications on this claim were submitted electronical via the MA UI Online portal on
or about August 2, 2020 to on or about September 5, 2021.

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July 1, 2014 in Lowell, MA for Distribution of a Class A Substance (Heroin). This charge was

dismissed on February 3, 2015.

Victim Interview

48. On February 27, 2026, the individual I believe to be the real A.R.H. and his father

(A.R.H.’s father) were each interviewed separately by telephone by an agent with whom I am

working on this investigation. A.R.H.’s father explained he has lived in Lawrence, MA since 2003

and provided his date of birth: xx-xx-1962. A.R.H.’s father stated A.R.H. lived in Lawrence, MA

around 2014 but he now resides in Puerto Rico. He stated A.R.H. was a victim of identity theft and

recalled an issue A.R.H. had at the Lawrence, MA RMV where he was almost arrested. A.R.H.’s

father stated A.R.H. also had issues with his taxes.

49. Later that same day A.R.H. was interviewed. A.R.H. confirmed his date of birth is

xx-xx-1985 and his SSN is xxx-xx-9489, and he provided a current address in Puerto Rico. A.R.H.

stated he moved to Lawrence, MA when he was approximately 14 years old and also lived in New

Bedford, MA for a short time before returning to Puerto Rico in 2018. A.R.H. recalled receiving

food stamps in MA.

50. A.R.H. recalled that in around 2004 or 2005 he went to the MA RMV in Lawrence

and was told that someone else was using his identity and that he was unable to obtain a driver’s

license. He stated that federal agents later showed up at his house in Lawrence, MA and confronted

him about the RMV fraud. A.R.H. stated he was almost arrested.

51. A.R.H. explained that his credit in Puerto Rico has been negatively impacted due

to identity theft issues, preventing him from purchasing a house or car and resulting in denial of

all types of loans. He stated that he hopes to resolve these matters, as he has been attempting to do

so for many years.

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Imposter’s True Identity

52. As explained below, investigators have confirmed that the fingerprints obtained

from the individual using the A.R.H. identity were made by the same individual as the fingerprints

of a national and citizen from the Dominican Republic, Arvaro Alberto Montero Diaz.

53. According to the Dominican Republic Cedula database, Montero Diaz is a national

and citizen of the Dominican Republic with a date of birth xx-xx-1985, and a Cedula bearing

number xxx-xxxx053-3. The Cedula record includes fingerprint impressions and the image of

Montero Diaz below.

Arvaro Alberto Montero Diaz - Dominican Republic Cedula Identification Photo

54. When Montero Diaz, using the A.R.H. identity, was arrested by Lowell Police on

or about July 1, 2014, they obtained his fingerprint impressions. These were submitted to the

Federal Bureau of Investigations (“FBI”).

55. The HSI Forensic Laboratory performed a fingerprint examination comparing the

fingerprints from Montero Diaz’s Cedula and the FBI fingerprint card obtained as a result of

Montero Diaz’s arrest by Lowell Police. The laboratory determined that both sets of fingerprints

were made by the same individual.

56. Based on the foregoing information, I believe the imposter’s true identity is Arvaro

Alberto Montero Diaz, citizen and national of the Dominican Republic, rather than A.L.R.H.,

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whom he claimed to be in seeking Massachusetts SNAP benefits, and in obtaining CARES Act

unemployment benefits (PUA & UI).

Conclusion

57. Based on the foregoing, I submit that there is probable cause to believe that:

a. between February 2021 through June 2025, Arvaro Montero Diaz, posing as

A.R.H., knowingly acquired through fraudulent means $12,525 in Massachusetts

SNAP benefits, in violation of 7 U.S.C. § 2024(b);

b. between August 4, 2020 and on or about September 8, 2021, Arvaro Montero Diaz,

posing as A.R.H., devised a scheme to defraud, and for the purpose of executing

such scheme did cause to be delivered any matter by the Postal Service, in violation

of 18 U.S.C. §1343, and

c. Arvaro Montero Diaz, posing as A.R.H., did, during and in relation to the scheme

to defraud, knowingly use, without lawful authority, a means of identification of

another person, in violation of 18 U.S.C. §1028A.

Sworn to under the pains and penalties of perjury,

___________________________________
Special Agent Christina Rosen
U.S. Department of Labor- OIG

Mar 6, 2026
SWORN before me telephonically pursuant to Fed. R. Crim. P. 4.1 this ___ day of March, 2026.

___________________________________
HONORABLE JUDITH G. DEIN
UNITED STATES MAGISTRATE JUDGE

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