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False sheriff's identification using the name Lisa Chenoa and Ashana Chenoa's birth date
During rebuttal, the government described the false sheriff's identification as using Lisa Chenoa's name and Ashana Chenoa's birth date for Daniela's border crossing. It argued that Raniere directed a plan using a real person's identifying information.
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The government argued that using Chenoa's surname and birth date satisfied the means-of-identification requirement for the identity-theft allegation in Racketeering Act 1.