FILED
AUG 16 2018
PETER A. MOORE; JR., CU!RK

US DIS~LiRT, EONC ,
BY
•
DEPCLK

UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA
WESTERN DIVISION
NO.

0:J8-{)2-0032A -J 60

UNITED STATES OF AMERICA

v.
I N F 0 R MA T I 0 N
ROSEMARIE ANGELIKA HARRIS
a/k/a "Rosemarie Angelika
McLaurin"
The United States Attorney charges that:
General Allegations
At all times relevant to this Information:
1.

The Immigration and Nationality Act

(INA)

governs the

immigration laws of the United States.
2.

The

term

"alien"

means

any person not

a

citizen or

national of the United States.
3.

Pursuant

to

the

INA,

aliens

are

not

permitted

to

permanently reside in the United States unless they are lawful
permanent residents.
4.

The defendant,

ROSEMARIE ANGELIKA HARRIS, was an alien

born in West Berlin, Germany.
S.

On December 3, 2014,

the defendant, ROSEMARIE ANGELIKA

HARRIS, was granted lawful permanent resident status in the United
States.
1

 Since

6.

ANGELIKA

December

HARRIS

I

has

3,

2014,

neither

the

applied

defendant,
for

ROSEMARIE

United

States

citizenship, been naturalized as a United States citizen, nor has
met the criteria for derivation of United States citizenship.
7.

On October 1, 2016, the North Carolina Board of Elections

registered

the

defendant,

ROSEMARIE

ANGELIKA HARRIS,

to

vote

despite not having signed the registration application.
8.

The defendant, ROSEMARIE ANGELIKA HARRIS, was assigned

a polling place located in Cumberland County, North Carolina.
9.

, The defendant, ROSEMARIE ANGELIKA HARRIS, voted in the

General Election of 2016 in Cumberland County, North Carolina.
10.

Cumberland County is located in the Eastern District of

North Carolina.

[remainder of page intentionally blank]

2

 COUNT ONE

On or about November 8, 2016, in the Eastern District of North
Carolina, the defendant, ROSEMARIE ANGELIKA HARRIS, also known as
"Rosemarie Angelika McLaurin,"

an alien,

knowing she was not a
\

United States citizen, did knowingly vote in an election held in
part for the purpose of electing a candidate for the off ice of
President,

Vice

Representatives,

President,

and

Member

in violation of Title 18,

Section 6ll(a).

ROBERT J. HIGDON, JR.
United States Attorney

BY: SEBASTIAN KIELMANOVICH
Assistant United States Attorney

8-15-2018
DATE

\

of

the

House

of

United States Code,

 IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF NORTH CAROLINA
AFFIDAVIT

BACKGROUND

1.

I,

Jahaira Torrens

(hereinafter "your affiant"),

am a

Special Agent (S/A) of the Department of Homeland Security (OHS),
under Irruuigration and Customs Enforcement (ICE), Homeland Security
Investigations

(HSI),

formerly

known

Naturalization Service

(INS) .

ICE-HSI

Detective

S/A,

I

was

a

as

the

Irruuigration

and

Previous to my appointment as an
with

the

Puerto

Rico

Police

Department for approximately fifteen years. As part of my duties
I

conducted

tnvestigations

trafficking,

identity theft,

related

to

controlled

public corruption,

substances

violent crimes,

and other violations. I have been a S/A with the federal government
for approximately nine years. I am currently assigned to th1e ICEHSI Resident Agent in Charge, Raleigh, North Carolina Field Office
(ICE-HSI .RAC/RA). I have training and experience in the application
for and service of arrest and search warrants. My duties routinely
include the investigation of violations of Titles 8, 18, 19, 21,
and 31 of the United States Code.
2.

This

information

affidavit

against

is

Rosemarie

"Rosemarie Angelika McLaurin,"

made

Angelika

support
Harris,

of

a

also

(hereinafter "HARRIS")

1

SK

in

criminal
known

as

for voting

 by alien,

in violation of Title 18,

United ·States Code,

Section

611 (a) .
3.

This affidavit is submitted for the limited purpose of

establishing probable cause that HARRIS committed the offense of
voting by alien,

in violation of Title 18,

Section 611 (a) .

For this reason,

United States Code,

your aff iant has not included

details of every aspect of this investigation,

rather only such

information as necessary. Your affiant is thoroughly familiar with
the

information

contained

in

this

affidavit,

either

through

personal investigation or discussions with other law enforcement
officers

who

have

interviewed

individuals

or

obtained information which they in turn have

peisonally

have

reported to your

affiant.
PROBABLE CAUSE

4.

Government databases reflect the following information

relative to HARRIS:
a.

HARRIS is an alien born in West Berlin, Germany.

b.

On

December

3,

2014,

HARRIS

was

granted

lawful

permanent resident status in the United States.
c.

Since December 3, 2014, HARRIS has neither applied

for United States citizenship, been naturalized as a United States
citizen, nor has met the criteria for derivation of United States
citizenship.

2

SK

 d.

On October 1,

2016,

the North Carolina Board of

Elections registered HARRIS to vote

despite not having signed the

registration application.
e.

HARRIS

was

assigned

a

polling

place

located

in

Cumberland County, North Carolina.
f.

HARRIS voted in the General Elections of 2016 in
I

Cumberland County, North Carolina.

[remainder of page intentionally blank]

3

SI\

 CONCLUSION

5.

Based on the foregoing, I, Jahaira Torrens, believe that

there is ample probable cause to conclude that Rosemarie Angelika
Harris,

also known as "Rosemarie Angelika McLaurin," was not a

citizen of the United States at the time she voted and is thus
guilty of voting by alien, in violation of Title 18, United States
Code, Section 611(a). Your affiant respectfully asks that the Court
issue a warrant ordering her arrest for such crime.

aira
ecial Agent
Homeland Security Investigations

~

On this
day of August 2018, Special Agent Jahaira Torrens
appeared before me via reliable electronic means, was placed under
oath, and attested to the contents of this Affidavit.

United States Magistrate Judge
Eastern District of North Carolina

4

SK