I have defendant who was in possession of 20+ pieces of ID information from ~ 19 individuals. How would you file indictment? 19 counts with items possessed pertaining to each individual? One big paragraph listing all? Some other option? I would like to have as streamlined a jury charge as possible (assuming he doesn't plea).

One big paragraph according to the TDCAA Charging Manual.

Applying the recently analysis of the CCA in Jones v. State (2010 Tex. Crim. App. Lexis 1208, PD-0499-09, PD-0500-09), the gravamen of the offense is the obtaining, possessing, transferring or using each piece of information. That construction of the statute is bolstered by both the gradation of punishment based on the number of items (helpful but not dispositive per Jones) and the presumption of intent for 3 or more items.

Now, Jones dealt with False statement to obtain credit or property and not Fraudulent use of identifying information, but the application of the reasoning seems sound.

Reading all of 32.51 PC in light of Jones and general principles of statutory construction, I would say each individual piece of information is an allowable unit of prosecution and I would charge it as one big paragraph.

Just my $0.02