Sealed Complaint — United States v. Teodoro Abreu, No. 1:24-mj-02904

Summary

A Sealed Complaint, Document 1 in Case 1:24-mj-02904-UA, filed August 9, 2024, in the U.S. District Court for the Southern District of New York, against Teodoro Abreu, citing violations of 18 U.S.C. §§ 1028A, 1542, and 2. Dua Quraishi, a Special Agent with the United States Department of State's Diplomatic Security Service, swears to the charges. Count One charges passport fraud and Count Two charges aggravated identity theft, each on or about October 28, 2022. The affidavit describes a 2022 passport application, a 2002 passport application and a 2014 application to the New York City Taxi & Limousine Commission, and reports interviews on September 19, 2023 and March 27, 2024. It asks for an arrest warrant.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Text recognized from a scanned document; may contain errors.

Case 1:24-mj-02904-UA Document1 Filed 08/09/24 Page1of7

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK

UNITED STATES OF AMERICA SEALED COMPLAINT
V. Violations of 18 U.S.C. §§ 1028A,
1542, and 2.
TEODORO ABREU,
COUNTY OF OFFENSE:
Defendant. BRONX

SOUTHERN DISTRICT OF NEW YORK: 2 4 MAG 2 9 0 4

DUA QURAISHI, being duly sworn, deposes and says that she is a Special Agent with the
United States Department of State’s Diplomatic Security Service, and charges as follows:

COUNT ONE
(Passport Fraud)

1. On or about October 28, 2022, in the Southern District of New York and elsewhere,
TEODORO ABREU, the defendant, willfully and knowingly made a false statement in an
application for a passport with intent to induce and,secure the issuance of a passport under the
authority of the United States, for his own use and the use of another, contrary to the laws
regulating the issuance of passports and the rules prescribed pursuant to such laws, and used and
attempted to use, and furnished to another for use a passport the issue of which was secured by
reason of a false statement, to wit, ABREU submitted a United States passport application with
false information about his identity, including a false name, date of birth, and social security
number.

(Title 18, United States Code, Sections 1542 and 2.)

COUNT TWO
(Aggravated Identity Theft)

2. On or about October 28, 2022, in the Southern District of New York and elsewhere,
TEODORO ABREY, the defendant, knowingly transferred, possessed, and used, without lawful
authority, a means of identification of another person, during and in relation to a felony violation
enumerated in Title 18, United States Code, Section 1028A(c), to wit, ABREU used and
transferred the name, date of birth, and social security number of another person during and in
relation to the passport fraud violation charged in Count One of this Complaint.

(Title 18, United States Code, Sections 1028A(a)(1), 1028A(b), and 2.)

The bases for my knowledge and for the foregoing charges are, in part, as follows:
Case 1:24-mj-02904-UA Document1 Filed 08/09/24 Page 2 of 7

3. I am a Special Agent with the United States Department of State’s Diplomatic
Security Service (“DSS”). I have been employed by DSS since 2022. Prior to my employment as
a Special Agent with DSS, I was a Victim Specialist for the Federal Bureau of Investigation
(“FBI”) for approximately one-and-a-half years and, before that, I was an Evidence Technician for
the FBI for approximately one year. In my current capacity, I have been assigned to investigate
passport fraud, among other offenses, and have received training applicable to the investigation of
such offenses. I have been personally involved in the investigation of this matter, and I base this
affidavit on that experience, on my conversations with other law enforcement officials, and on my
examination of various reports and records. Because this affidavit is being submitted for the
limited purpose of demonstrating probable cause, it does not include all the facts I have learned
during the course of my investigation. Where the contents of documents and the actions,
statements, and conversations of others are reported herein, they are reported in substance and in
part, except where otherwise indicated.

The Defendant’s Identity

4, Based on my conversations with other law enforcement officials, my examination
of law enforcement reports and records, criminal history records, and my personal involvement in
this investigation, I know, among other things, the following about TEODORO ABREU, the
defendant:

a. ABREU was born on or about December 4, 1963 in the Dominican
Republic. In or about 1994, ABREU entered the United States illegally at an unknown place. In
or about 1997, ABREU’s status in the United States was adjusted to that of a lawful permanent
resident.

b. On or about March 5, 1997, ABREU was issued a passport by the
Dominican Republic that contained the photograph in Image 1. On or about March 20, 1997, the
United States Immigration and Naturalization Service (“INS”) issued ABREU an employment
authorization card, which contained the photograph in Image 2. On or about December 21, 1998,
ABREU pled guilty in Lynn District Court in Lynn, Massachusetts to assault and battery in
violation of Mass. Gen. Laws 265 § 13A. ABREU was sentenced to a term of 18 months’
imprisonment. On or about March 9, 1999, ABREU was removed from the United States. Image
3 is a photograph of ABREU on or about the date of his removal.

Image 2 Image 3
Case 1:24-mj-02904-UA Document1 Filed 08/09/24 Page 3of7

Cc, On several! official forms between in or about 1997 and in or about 1999,
ABREU signed his name in a distinctive manner, writing just his first name (“Teodoro”) with a
loop around it. For example, Image 4 shows ABREU’s signature on his Dominican passport,
which was issued on or about March 5, 1997. Image 5 depicts ABREU’s signature on a
Massachusetts state court advice of rights form in connection with ABREU’s guilty plea, which
ABREU signed on or about December 21, 1998. Image 6 shows an INS form, which ABREU
signed on or about the date of his removal from the United States in or about March 1999.

Image 4 Image 5 Image 6

The 2022 Fraudulent Passport Application

5. Based on my conversations with other law enforcement officials, my examination
of various reports and records, and my personal involvement in this investigation, among other
things, I have learned the following:

a. On or about October 28, 2022, an individual who, for the reasons described
below I believe to be TEODORO ABREU, the defendant, executed and submitted a DS-11 form
to apply for a U.S. Passport at a United States Postal Service branch in the Bronx, New York (the
“2022 Fraudulent Passport Application”).

b, On the 2022 Fraudulent Passport Application, ABREU falsely (1) listed his
name as the name of another person (the “Victim”); (2) provided the Victim’s date of birth (the
“Victim DOB”), not ABREU’s; (3) listed a place of birth, Puerto Rico, which was the Victim’s
place of birth, not ABREU’s; and (4) supplied the Victim’s social security number (the “Victim
SSN”), not ABREU’s. ABREU listed an individual who shares the same last name as ABREU as
ABREU’s emergency contact. ABREU also provided an address in the Bronx as his permanent
address (the “ABREU Address”) which, based on my participation in this investigation, I have
learned is ABREU’s residence.

c. In support of the 2022 Fraudulent Passport Application, ABREU submitted
the passport photograph shown in Image 7, as well as a New York State Identification Card with
a particular JID number (the “NYS ID Number”), which was also listed under the Victim’s name,
and which displayed the photograph shown in Image 8.
Case 1:24-mj-02904-UA Document1 Filed 08/09/24 Page 4of7

Image 7 Image 8

d. Based on my comparison of the individual depicted in Images 1, 2, and 3
with the individual depicted in Images 7 and 8, { believe that they depict the same person, that is,
ABREU.

e. ABREU signed the 2022 Fraudulent Passport Application in the same,
distinctive manner in which ABREU had signed several official forms in his own name between
approximately 1997 and 1999, as shown supra in Images 4, 5, and 6. That is, ABREU signed the
2022 Fraudulent Passport Application by signing the Victim’s first name (“Manuel”) and drawing
a loop around the name, as shown in Image 9. In the New York State Identification Card shown
in Image 8, ABREU appears to have used the same, distinctive signature when signing the Victim’s
name.

—ippiicnits LegabhStermtre = age 16 and older

Image 9

The 2002 Fraudulent Passport Application

6. Based on my participation in this investigation, my review of law enforcement
reports and records, and my conversations with law enforcement officers, among other things, I
have learned the following:

a. On or about October 15, 2002, at the Charleston Passport Center in or
around Charleston, South Carolina, an individual whom I believe to be TEODORO ABREU, the
defendant, executed and submitted a DS-11 form to apply for a U.S. Passport (the “2002
Fraudulent Passport Application”).

b. The 2002 Fraudulent Passport Application was submitted using the Victim’s
personal information, including the Victim’s name, the Victim DOB, the Victim SSN, and the
Victim’s place of birth. As his emergency contact, ABREU listed an individual who shares the
Case 1:24-mj-02904-UA Documenti1 Filed 08/09/24 Page5of7

same last name as ABREU. Accompanying the 2002 Fraudulent Passport Application was a
photograph of an individual that appears to be ABREU (Image 10), as well as a photocopy of a
New York State Driver’s License issued in or about 2002 in the Victim’s name, but which again
appears to depict ABREU and lists the NYS ID Number (Image 11). I have learned that the 2002
Fraudulent Passport Application was flagged for potential fraud and did not result in a passport
being issued.

c. On or about December 10, 2014, an individual whom I believe to be
ABREU applied to the New York City Taxi & Limousine Commission (“TLC”) for a TLC Driver’s
License, using the Victim’s identifying information—including the Victim’s name, the Victim
DOB, and the Victim SSN (the “2014 Fraudulent TLC Application”). TLC records contain a
photograph of the applicant, i.e., ABREU, which is shown below in Image 12. Furthermore, TLC
records indicate that ABREU used the NYS ID Number in the 2014 Fraudulent TLC Application.
The Victim was in BOP custody at the time ABREU submitted the 2014 Fraudulent TLC
Application. See infra n.1.

Image 10 Image i Image 12

d. Based on my comparison of the individual depicted in Images 1, 2, and 3,
with the individual depicted in Images 10, 11, and 12, I believe that they depict the same person,
that is, ABREU. Furthermore, based on the fact that the individual who submitted the 2002
Fraudulent Passport Application, the 2014 Fraudulent TLC Application, and the 2022 Fraudulent
Passport Application all used the same NYS ID Number in their applications, | believe that those
individuals are all the same person, i.e., ABREU. ©

€. Accordingly, I believe that ABREU has used the Victim’s identity since at
least on or about October 15, 2002, to, among other things, apply for U.S. passports (2002 and
2022) and for a TLC Driver’s License (2014).

Victim Interview

7. Based on my participation in this investigation, my conversations with other law
enforcement agents, and my review of law enforcement reports and records, I know that, on or
about September 19, 2023, certain law enforcement agents interviewed the Victim in Puerto Rico.
I have learned the following, among other things, about that interview. !

| In or about 2014, the Victim appears to have been convicted of illegally receiving firearms,
in violation of 18 U.S.C. § 922(a)(3), and conspiring to do the same, in violation of 18 U.S.C.
Case 1:24-mj-02904-UA Document1 Filed 08/09/24 Page 6of7

a. The Victim stated that his identity has been compromised for many years.

b. The Victim confirmed that he did not submit the 2022 Fraudulent Passport
Application. More specifically, while the Victim identified the personal information in the 2022
Fraudulent Passport Application as his, neither the photograph nor the signature were the Victim’s,
and the Victim had not authorized anyone to use his personal information to submit such an
application.

c. The Victim explained that he had never applied for a U.S. Passport and that
the only time he had lived in the United States (as opposed to Puerto Rico) was while serving a
sentence in the custody of the BOP.

d. The Victim reviewed four photographs of individuals who law enforcement
had determined, based on their investigation, used the Victim’s identifying information in the past,
including the photograph of ABREU depicted in Image 7. The Victim stated that he knew none
of the people pictured other than himself. The Victim then signed an official interview form,
including both his first and last name. The Victim’s signature appears different from the Victim’s
purported signature on the 2022 Fraudulent Passport Application, as shown supra in Image 9.

e. Based on my conversations with other law enforcement officers who
participated in the interview of the Victim, I have learned that the Victim bears no resemblance to
the individual who is depicted in the photographs submitted in connection with the 2022
Fraudulent Passport Application (Image 7) and the fraudulent New. York State Identification Card
(Image 8), i.e., ABREU.

f. Based on my own review of photographs taken of the Victim during his time
in BOP custody between approximately 2013 and 2017 (see supra n.1) and from a Puerto Rican
criminal justice database, I also believe that the Victim bears no resemblance to ABREU.

Defendant Interview

8. On or about March 27, 2024, I and other law enforcement officers conducted a
voluntary interview with TEODORO ABREU, the defendant, at the ABREU Address. During that
interview, ABREU stated, in substance and in part, the following, among other things:

a. ABREU first stated that he alone had filled out the 2022 Fraudulent Passport
Application and that the name, address, signature, photograph, and other information listed, ie.,
the Victim’s personal information, was ABREU’s true and accurate personal information.

b. ABREU later explained, however, that this was untrue. Instead, ABREU
stated that his real name was Rony Varga, before admitting that it was actually TEODORO
ABREU. ABREU admitted that he had been born and raised in the Dominican Republic. ABREU

§ 371, and was sentenced to serve several years in prison. Federal Bureau of Prisons (“BOP”)
records indicate that the Victim was incarcerated from in or about 2013 until in or about 2017.
Case 1:24-mj-02904-UA Document1 Filed 08/09/24 Page 7 of 7

claimed that a different individual (“Individual-1”) had filled out the 2022 Fraudulent Passport
Application, that ABREU had no knowledge of the application’s contents, and that ABREU had
simply signed it. ABREU claimed that he had come to the United States for the first time
approximately a year and a half ago, i.e., around October 2022. ABREU stated that he obtained
the Victim’s personal information from Individual-1 in exchange for approximately $1,300 and
had adopted the Victim’s identity as ABREU’s.

WHEREFORE, I respectfully request that a warrant be issued for the arrest of TEODORO
ABREU, the defendant, and that he be arrested, and imprisoned or bailed, as the case may be.

Dua Quraishi
Special Agent
Diplomatic Security Service

United States Department of State

this ay of August 2024.

THE TONORABLE JENNIFER E. WILLIS
United States Magistrate Judge

Southern District of New York


File and source

File

1.pdf

Size

443,256 bytes

SHA-256

a10a39499558cf81629b37b642dd14470d7a545dc8ba818bce2b1700a44b104b

Our copy

1.pdf

Original

No public link identified.