indictment - ramirez, hector & cuevas, ana redacted

SUPREME COURT OF THE STATE OF NEW YORK

COUNTY OF THE BRONX

THE PEOPLE OF THE STATE OF NEW YORK

INDICTMENT NO:

GJ NO: 43876-2014

-against-

Hector Ramirez

Ana Cuevas,

Defendants

COUNTS:

FORGERY IN THE SECOND DEGREE, P.L. 170.10 (2), 35 Cts.

CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE, P.L. 170.25, 35 Cts.

FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, P.L. 175.10, 35 Cts

OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, P.L. 175.35 (1), 35 Cts.

TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE P.L. 175.25, 35 Cts.

ILLEGAL VOTING E.L. 17-132 (4), 32 Cts.

ILLEGAL VOTING E.L. 17-132 (8), 35 Cts.

ROBERT T. JOHNSON

DISTRICT ATTORNEY

A True Bill

Foreperson

FIRST COUNT:

THE GRAND JURY OF THE COUNTY OF THE BRONX, by this indictment, accuses the

defendants of the crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10

(2) committed as follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County

of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud,

deceive or injure another, did falsely make, complete or alter a written instrument which was or purported

to be or which was calculated to become, or to represent if completed, a public record, or an instrument

filed or required or authorized by law to be filed in or with a public office or public servant, that being an

absentee ballot application bearing the name .

SECOND COUNT:

AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendants of the

crime of CRIMINAL POSSESSION OF A FORGED INSTRUMENT IN THE SECOND DEGREE,

in violation of Penal Law 170.25 committed as follows:


of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with the knowledge that

it was forged and with intent to defraud, deceive or injury another, did utter or possess a forged instrument,

that being a public record, or an instrument filed or required or authorized by law to be filed in or with a

public office or public servant, to wit: an absentee ballot application bearing the name .

THIRD COUNT:


crime of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, in violation of Penal Law

175.10 committed as follows:


of the Bronx, on or about and between August 14, 2014 and September 9, 2014, with intent to defraud and

with the intent to commit another crime or to aid or conceal the commission thereof, did make or cause a

false entry in the business records of an enterprise, to wit: an absentee ballot application bearing the name

.

FOURTH COUNT:


crime of OFFERING A FALSE INSTRUMENT FOR FILING IN THE FIRST DEGREE, in

violation of Penal Law 175.35 (1) committed as follows:


of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that a written

instrument contained a false statement or false information and with intent to defraud the state or any

political subdivision, public authority, or public benefit corporation of the state, did offer or present it to a

public office or public servant with the knowledge or belief that it would be filed with, registered or

recorded in or otherwise become a part of the records of such public office or public servant, public

authority or public benefit corporation, that being an absentee ballot application bearing the name

.

FIFTH COUNT:


crime of TAMPERING WITH PUBLIC RECORDS IN THE FIRST DEGREE, in violation of Penal

Law 175.25 committed as follows:


of the Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not

have the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove,

mutilate, destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed

with, deposited in, or otherwise constituting a record of a public office or public servant, that being an


SIXTH COUNT:


crime of ILLEGAL VOTING, in violation of New York State Election Law 17-132 (4) committed as

follows:


of the Bronx, on or about and between August 14, 2014 and September 9, 2014, procured, aided, assisted,

commanded or advised to vote or offer or attempt to vote at an election, knowing that he

is not qualified to vote thereat.

SEVENTH COUNT:



follows:


of the Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the

name of another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act

in connection with an absentee vote cast or attempted to be cast bearing the name .

EIGHTH COUNT:


crime of FORGERY IN THE SECOND DEGREE, in violation of Penal Law 170.10 (2) committed as

follows:






absentee ballot bearing the name .

NINTH COUNT:








public office or public servant, to wit: an absentee ballot bearing the name .

TENTH COUNT:







false entry in the business records of an enterprise, to wit: an absentee ballot bearing the name

.

ELEVENTH COUNT:










authority or public benefit corporation, that being an absentee ballot bearing the name .

TWELFTH COUNT:









absentee ballot bearing the name .

THIRTEENTH COUNT:



follows:





FOURTEENTH COUNT:



follows:





FIFTEENTH COUNT:



follows:





filed or required or authorized by law to be filed in or with a public office or public servant, that being a

second absentee ballot bearing the name , date and time stamped by the New York City

Board of Elections on September 9, 2014 at 8:54pm.

SIXTEENTH COUNT:








public office or public servant, to wit: a second absentee ballot bearing the name , date

and time stamped by the New York City Board of Elections on September 9, 2014 at 8:54pm.

SEVENTEENTH COUNT:







false entry in the business records of an enterprise, to wit: a second absentee ballot bearing the name

, date and time stamped by the New York City Board of Elections on September 9, 2014

at 8:54pm.

EIGHTEENTH COUNT:










authority or public benefit corporation, that being a second absentee ballot bearing the name

, date and time stamped by the New York City Board of Elections on September 9, 2014 at

8:54pm.

NINETEENTH COUNT:




The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County of the

Bronx, on or about and between August 14, 2014 and September 9, 2014, knowing that they did not have

the authority of anyone entitled to grant it, and with the intent to defraud, did knowingly remove, mutilate,

destroy, conceal, make a false entry in, or falsely alter any record or other written instrument filed with,

deposited in, or otherwise constituting a record of a public office or public servant, that being a second

absentee ballot bearing the name , date and time stamped by the New York City Board of

Elections on September 9, 2014 at 8:54pm.

TWENTIETH COUNT:



follows:





TWENTY-FIRST COUNT:



follows:

The defendants, Hector Ramirez and Ana Cuevas, acting in concert with each other, in the County of the

Bronx, on or about and between August 14, 2014 and September 9, 2014, fraudulently signed the name of

another upon an absentee voters envelope or aided in doing or attempting to do a fraudulent act in

connection with a second absentee vote cast or attempted to be cast bearing the name ,

date and time stamped by the New York City Board of Elections on September 9, 2014 at 8:54pm.

TWENTY-SECOND COUNT:



follows:







TWENTY-THIRD COUNT:









TWENTY-FOURTH COUNT:








.

TWENTY-FIFTH COUNT:











.

TWENTY-SIXTH COUNT:










TWENTY-SEVENTH COUNT:



follows:



commanded or advised to vote or offer or attempt to vote at an election, knowing that she is

not qualified to vote thereat.

TWENTY-EIGHTH COUNT:



follows:





TWENTY-NINTH COUNT:



follows:







THIRTIETH COUNT:








public office or public servant, to wit: an absentee ballot application bearing the name

.

THIRTY-FIRST COUNT:








.

THIRTY-SECOND COUNT:











.

THIRTY-THIRD COUNT:










THIRTY-FOURTH COUNT:



follows:



commanded or advised to vote or offer or attempt to vote at an election,

knowing that he is not qualified to vote thereat.

THIRTY-FIFTH COUNT:



follows:




in connection with an absentee vote cast or attempted to be cast bearing the name

.

THIRTY-SIXTH COUNT:



follows:





filed or required or authorized by law to be filed in or with a public office or public servant, that being a

second absentee ballot application bearing the name , date and time stamped

by the New York City Board of Elections on September 4, 2014 at 5:47pm.

THIRTY-SEVENTH COUNT:








public office or public servant, to wit: a second absentee ballot application bearing the name


5:47pm.

THIRTY-EIGHTH COUNT:







false entry in the business records of an enterprise, to wit: a second absentee ballot application bearing the

name , date and time stamped by the New York City Board of Elections on

September 4, 2014 at 5:47pm.

THIRTY-NINTH COUNT:










authority or public benefit corporation, that being a second absentee ballot application bearing the name

, date and time stamped by the New York City Board of Elections on

September 4, 2014 at 5:47pm.

FORTIETH COUNT:








with, deposited in, or otherwise constituting a record of a public office or public servant, that being a

second absentee ballot application bearing the name , date and time stamped

by the New York City Board of Elections on September 4, 2014 at 5:47pm.

FORTY-FIRST COUNT:



follows:



commanded or advised to vote or offer or attempt to vote at an election,

knowing that he is not qualified to vote thereat.

FORTY-SECOND COUNT:



follows:




in connection with a second absentee vote cast or attempted to be cast bearing the name


5:47pm.

FORTY-THIRD COUNT:



follows:







FORTY-FOURTH COUNT:









FORTY-FIFTH COUNT:








.

FORTY-SIXTH COUNT:











.

FORTY-SEVENTH COUNT:










FORTY-EIGHTH COUNT:



follows:



commanded or advised to vote or offer or attempt to vote at an election, knowing that she


FORTY-NINTH COUNT:



follows:





FIFTIETH COUNT:



follows:







FIFTY-FIRST COUNT:









FIFTY-SECOND COUNT:








.

FIFTY-THIRD COUNT:











.

FIFTY-FOURTH COUNT:










FIFTY-FIFTH COUNT:



follows:



commanded or advised to vote or offer or attempt to vote at an election, knowing that he is


FIFTY-SIXTH COUNT:



follows:





FIFTY-SEVENTH COUNT:



follows:







FIFTY-EIGHTH COUNT:









FIFTY-NINTH COUNT:








.

SIXTIETH COUNT:











.

SIXTY-FIRST COUNT:










SIXTY-SECOND COUNT:



follows:





SIXTY-THIRD COUNT:



follows:





SIXTY-FOURTH COUNT:



follows:







SIXTY-FIFTH COUNT:









SIXTY-SIXTH COUNT:








.

SIXTY-SEVENTH COUNT:











.

SIXTY-EIGHTH COUNT:










SIXTY-NINTH COUNT:



follows:



commanded or advised to vote or offer or attempt to vote at an election, knowing that she


SEVENTIETH COUNT:



follows:





SEVENTY-FIRST COUNT:



follows:







SEVENTY-SECOND COUNT:









SEVENTY-THIRD COUNT:








.

SEVENTY-FOURTH COUNT:











.

SEVENTY-FIFTH COUNT:










SEVENTY-SIXTH COUNT:



follows:





SEVENTY-SEVENTH COUNT:



follows:





SEVENTY-EIGHTH COUNT:



follows:







SEVENTY-NINTH COUNT:









EIGHTIETH COUNT:








.

EIGHTY-FIRST COUNT:











.

EIGHTY-SECOND COUNT:










EIGHTY-THIRD COUNT:



follows:





EIGHTY-FOURTH COUNT:



follows:







EIGHTY-FIFTH COUNT:









EIGHTY-SIXTH COUNT:








.

EIGHTY-SEVENTH COUNT:











.

EIGHTY-EIGHTH COUNT:










EIGHTY-NINTH COUNT:



follows:





NINETIETH COUNT:



follows:





NINETY-FIRST COUNT:



follows:







NINETY-SECOND COUNT:









NINETY-THIRD COUNT:








.

NINETY-FOURTH COUNT:











.

NINETY-FIFTH COUNT:










NINETY-SIXTH COUNT:



follows:



commanded or advised to vote or offer or attempt to vote at an election, knowing that she is


NINETY-SEVENTH COUNT:



follows:





NINETY-EIGHTH COUNT:



follows:







NINETY-NINTH COUNT:









ONE HUNDREDTH COUNT:








.

ONE HUNDRED AND FIRST COUNT:











.

ONE HUNDRED AND SECOND COUNT:










ONE HUNDRED AND THIRD COUNT:



follows:





ONE HUNDRED AND FOURTH COUNT:



follows:







ONE HUNDRED AND FIFTH COUNT:









ONE HUNDRED AND SIXTH COUNT:








.

ONE HUNDREDTH AND SEVENTH COUNT:











.

ONE HUNDRED AND EIGHTH COUNT:










ONE HUNDRED AND NINTH COUNT:



follows:



commanded or advised .to vote or offer or attempt to vote at an election, knowing that she is


ONE HUNDRED AND TENTH COUNT:



follows:





ONE HUNDRED AND ELEVENTH COUNT:



follows:



decei

indictment - ramirez, hector & cuevas, ana redacted

Documents

forged instrument

public records

false instrument

hector ramirez ana cuevas

defendants counts

violation of penal law

public servant

public office