evidence was “fairly overwhelming” that Wilson acted knowingly and willfully, and certainly sufficient to support his convictions for theft of government funds. Tr. Trans., Doc. 106, p. 102-103. B. Aggravated Identity Theft and ■ “Means of Identification” Wilson further argues the evidence was insufficient to sustain his convictions for aggravated identity theft. He claims the use of the victims’ names on the refund checks, with no other identifying information, is not sufficient to identify a specific individual, and thus cannot constitute a “means of identification” under 18 U.S.C. § 1028A. We disagree. This issue is one of statutory interpretation. We must determine whether the use of someone’s name and forged signature on a United States Treasury check sufficiently iden Cir.2008) (<HOLDING>). While there can usually “be no plain error
holding that the statute qualifies as an exemption 3 statute holding that a defendants use of a persons name and social security number without permission constituted the use of a means of identification without lawful authority holding a forged signature constitutes the use of that persons name and thus qualifies as a means of identification under the statute holding that a party failed to meet this burden when he presented no corroborating evidence by the persons who could have given testimony regarding the execution of the deed such as the person signing as witness to his signature and the notary public who subscribed as having notarized his signature or a handwriting expert in support of the contention that his signature to the deed was forged holding that even with substantial mitigation disbarment was warranted for an attorney who had forged his chents signature on a will when the chent died without signing and then submitted this forged document into court