Defendant found in possession of 50+ separate valid ID's from 50+ different persons (1st Degree felony). Question: Do I need to specifically name each of the 50+ persons in the indictment? For example: ...w/out the effective consent of JOHN DOE, obtain and possess identifying info of JOHN DOE, to-wit: US SSN card... -----for each of the 50+ persons...
Thanks for any help.

I do not have the answer offhand myself but a DPS Trooper in our jurisdiction made a similar arrest of a person in possession of 38 counterfeit credit cards, the cards bearing his name or his alias but the embossed numbers and the magnetic strip all being to valid victim accounts issued by American Express. If anyone has the answer please let us know here or by private message.

I am attaching a copy of an indictment in which only the necessary persons were identified. The enhancement facts were simply stated in accord with the statute. For a description of the facts of the case and how lack of consent was proved based on the presumption see Brief. If every victim must testify, then generally the enhancement provision just will not be used.

Thank you so much! Exactly what I am dealing with and the example of your indictment is a big help. Have a great rest of the week. -Stephen