I have a case in which the suspects were found in possession of various types of identifying information for roughly 691 people. I don't have any names or confirmation as to whether these are all real people. (dead or alive) Assuming I can come up with the names and social security numbers, driver's licenses or other ID for fifty actual persons, how do I plead this? Do I include all fifty names? Do I have to include all fifty names? If I do list all the names, do I have to separate them into type of id, eg name and social security number for x, y, and z and name and date of birth for a, b, and c?

Thanks!

A good starting point is always the TDCAA Charging Manual written by Jeffrey Van Horn. If you do not have access to it, e-mail your fax number to me.