unlawfully, knowingly, and intentionally combine, conspire, confederate, and agree with eachother and others, both known and unknown
the grand jury,
devise and intend to devise amaterial scheme and artifice to defraud the Social Security Administration and the State
obtain property by means
material false and fraudulent pretenses,representations, and promises, in violation
Title 18, United States Code, Section 1349.
Overt Acts In Furtherance
the conspiracy, and to accomplish its object, at least one
theconspirators committed, or caused
be committed, in the District
Oregon, the following overtacts, among others:
or before July 22, 2010 , defendant
fabricated birth and prenatal records in the name
Winter Rain Waters.
On or about July 22, 2010, defendant
SNOW causedan application for a birth certificate for Winter Rain Waters along withfabricated birth and prenatal records to be submitted
Human Services Center for Health Statistics.
or about February 7, 2011, defendants
appeared in Lane County CircuitCourt in case number 16-10-28278, and falsely testified that SNOW wasWinter Rain Waters, causing that court to order that the birth
WinterRain Waters be registered by the State Registrar Vital Records.
or about June 30, 2011, defendant
submitted an application for a Social Security number to the Social
Case 6:12-cr-00196-AA Document 6 Filed 05/17/12 Page 2 of 8 Page ID#: 9