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AO 91 (Rev. 11/11) Criminal Complaint AUSA Caitlin Walgamuth (312) 353-5311UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
v.CASE NUMBER:
UNITED STATES OF AMERICA
EDNER FLORES (also known as "Edner FloresJr.")
CRIMINAL COMPLAINT
I, the complainant in this case, state that the following is true to the best ofmy knowledge and belief.
On or about January 25, 2021, at Chicago, in the Northern District of Illinois, Eastern Division, thedefendant violated:
Code Section
Title 18, United States Code, Section2113(a)
Offense Description
attempted by force and violence, and by intimidationto take from the person or presence of a bankemployee money belonging to, and in the care,custody, control, management, and possession ofPNCBank located at 3337 W. North Avenue, Chicago,Illinois, the deposits ofwhich were then insured by theFederal Deposit Insurance Corporation.
This criminal complaint is based upon these facts:
___x__ Continued on the attached sheet.
Special Agent, Federal Bureau of Investigation(FBI)
Pursuant to Fed. R. Crim. P. 4.1, this Complaint is presented by reliable electronic means. The above-named agent provided a sworn statement attesting to the truth of the Complaint and Affidavit by telephone.
Date: January 26,2021Judge's signature
City and state: Chicago, Illinois HEATHER K. MCSHAIN, U.S. Magistrate JudgePrinted name and title
21CR55
FILED1/26/2021
THOMAS G. BRUTON
CLERK, U.S. DISTRICT COURT
Case: 1:21-cr-00055 Document #: 1 Filed: 01/26/21 Page 1 of 9 PageID #:1
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
AFFIDAVIT
I, WARDYODER, being duly sworn, state as follows:
1. I am a Special Agent with the Federal Bureau of Investigation (FBI),
and have been so employed for eleven years. My current responsibilities include the
investigation of violent crimes, including, among others, kidnaping, bank robbery,
and the apprehension of violent fugitives.
2. This affidavit is submitted in support of a criminal complaint alleging
that Edner FLORES ("FLORES") has violated Title 18, United States Code, Section
2113(a). Because this affidavit is being submitted for the limited purpose of
establishing probable cause in support of a criminal complaint charging FLORES
with attempted bank robbery, I have not included each and every fact known to me
concerning this investigation. I have set forth only the facts that I believe are
necessary to establish probable cause to believe that the defendant committed the
offense alleged in the complaint.
3. This affidavit is based on my personal knowledge, information provided
to me by other law enforcement agents who have knowledge of the events and
circumstances described herein, interviews of bank employees and witnesses, review
of documents provided by bank personnel and other witnesses, and review of the
bank's video surveillance images.
Case: 1:21-cr-00055 Document #: 1 Filed: 01/26/21 Page 2 of 9 PageID #:2
FACTS SUPPORTING PROBABLE CASE
4. As detailed below, on or about January 25,2021, at approximately 11:45
a.m., FLORES entered a PNC Bank located at 3337 W. North Avenue, Chicago,
Illinois (the "Bank"), approached a bank teller ("Teller 1"), handed Teller 1 a note that
stated he was "armed" and demanded money. Teller 1 hit the silent alarm and was
able to stall by requesting FLORES's identification, which he provided to Teller 1.
Responding law enforcement arrested FLORES as he stood in front of Teller l's teller
station inside the Bank. After his arrest, FLORES waived his Miranda rights and
admitted he attempted to rob the Bank.
5. The FBI has confirmed that the deposits of PNC Bank were insured by
the Federal Deposit Insurance Corporation ("FDIC") at the time of the attempted
bank robbery.
January 25, 2021Attempted Bank Robbery
6. As part of the investigation, law enforcement interviewed Teller 1.
According to a law enforcement interview with Teller 1, on or about January 25,2021,
Teller 1 was employed by the Bank and was working at a teller station at the Bank.
At approximately 11:45 a.m., a Hispanic male (the "Robber") arrived at the Bank.
According to Teller 1, the Robber appeared to be in his late-20s to early-30s,
approximately 5'5" tall, approximately 160 pounds, wearing a dark hooded jacket
with the hood up over his head, a blue and white disposable surgical mask, and off-
white colored work gloves with grey dots.
2
Case: 1:21-cr-00055 Document #: 1 Filed: 01/26/21 Page 3 of 9 PageID #:3
7. According to Teller 1, when the Robber entered the Bank, he waited in
line to see a Bank teller. When Teller 1 finished with his/her customer, he/she called
for the next customer, the Robber. According to Teller 1, the Robber approached
Teller 1 and handed Teller 1 a white PNC Bank deposit ticket that had a message
written on it that said: "$10,000" "No die Packs" "Armed." According to Teller 1,
he/she realized he/she was being robbed. Teller 1 activated the silent alarm at his/her
teller station. In an effort to stall until law enforcement arrived, Teller 1 then asked
the Robber, in effect, if he wanted to make a deposit or withdrawal and, according to
Teller 1, the Robber replied that he wanted a withdrawal. In response, Teller 1
handed the Robber a blue withdrawal slip and observed the Robber write "$10,000"
on the withdrawal ticket before handing it back to Teller 1. According to Teller 1,
Teller 1 then asked the Robber for his ATM Card and a form of identification. In
response, the Robber handed Teller 1 an identification card. According to Teller 1,
the Robber was still standing at Teller 1's teller window when law enforcement
arrived at the Bank.
8. Based on my reVIew of law enforcement reports and the body-worn
camera footage of the responding Chicago Police Department ("CPD")officers, CPD
officers entered the Bank and a bank employee pointed out the Robber, who was still
standing at a teller station in front of a bank teller, later identified as Teller 1. The
CPD officers approached the Robber and took him into custody at approximately
11:57 a.m., without incident. According to a CPD report, a knife was recovered from
the Robber's jacket pocket at the time of his arrest.
3
Case: 1:21-cr-00055 Document #: 1 Filed: 01/26/21 Page 4 of 9 PageID #:4
9. Based on my review of Bank surveillance stills, the Robber wore a dark-
colored hooded jacket with the hood up, a light-colored face mask, gray-colored gloves,
and a black cap under the hooded jacket. A still image taken from Bank surveillance
footage depicting the Robber is below.
4
Case: 1:21-cr-00055 Document #: 1 Filed: 01/26/21 Page 5 of 9 PageID #:5
10. The white and blue PNC slips the Robber wrote on were recovered by
law enforcement from Teller l's teller station. The photograph below depicts the two
deposit slips.
DEPOSIT TICKET
0.PNCBANK (ZOCASH •
11. After the Robber's arrest, law enforcement also recovered the
.x-----::NAL 10 ~L rEC
~I ~
identification the Robber provided Teller 1 from Teller l's teller station. A photograph
ACCOUNT NUMBER
Dll CHECKORTOTAL FROM·o HERSIDE
of the identification card is below. As shown, the identification card is a temporary
~ FOR CREOIT TO THE AC~OUN_T NA"lED HEREON
~ DATE \ . LS' 7._D--z._ \::;; ~IX:
~ NAME _
SUB TOTAL •
LESS CASHREceiVED ••
o CHECKING 0 SAVINGS
o CONSUMER 0 BUSINESS
fORM162269
NET DEPOSIT $ 10 .•00TlI'S D~SJr IS ACCEJOT£O 5U8J(Cl TO V(IIIiI'JCATION .VID TO THE RUlU '''.1) I='rGln.••.1fO·~s Of Hi S 15.:.,,1(
or,.OSITS •••••• '."Of B£ AVAILABLE fOR r •• tMro •.••.'£ ",HHOJIAWAL
~PNCBANl<ACCOUNT NUMBER
11..3~Sk1B~r
NON-NEGOTIABLE
Checking/Savings Withdrawal TicketREGIONAL 10 Date I. Z s: - 2. /
I )$ /0, 000 •
FORM162753
5
Case: 1:21-cr-00055 Document #: 1 Filed: 01/26/21 Page 6 of 9 PageID #:6
Illinois Secretary of State Identification Card issued on or about January 22,2021 to
EDNER FLORES JR.1
Jesse White • Illinois Secretary of StateOlIVer':, Llcensellden fiC<ltlon Card Number'
Name EDNER FLORES JR
Dato I:;;;u£:d' 01/2212021 322DV0376
KEEP THIS RECEIPT UNTIL YOUR PERMANENT CARD ARRIVES IN THE MAIL.You ShOU~d receive your Driver's license I CLP lID Card within 15 business days
from the date ISsued I above) unl h '\ ess you ave received correspondence stating otherwise.
YOU WILL NOT RECEIVE YOUR NEWDOCUMENT THE U S pos CARD IF YOU DO NOT LIVE AT THE ADDRESS LISTED BELOW ON THIS
ILLINOIS LA.W RE~UIRE~ y'OU T~ OFFICE CANNOT FORWARD DRIVER'S LICENSE, CLP OR 10 CARDS,NOTIFY THE SECRETARY OF STATE'S OFFICE OF AN ADDRESS CHANGE,
i it To ch.ck the delivery atatus of your card,v a 'WWVw.CYberdriveiliinoia.com or call (217) 782-7044,
'III \ 1lI1111 1IIII11 \11 \11111111111-'lrlllllll1J 1111Iff n111111" 111113520062016405657
oSEPARAlf YOUR TEMPORARY CREOE'IiTJAt ArpE'RFORAnoIoiS ('
lLLINOIS
FOR IDENTIFICATION PURPOSES ONLY.- -MOT A LICENSE TO ORNE
':"'(
Identification of EDNER FLORES as the Robber
12, Shortly after CPD officers took custody of the Robber in the Bank, law
enfOl'cement at the scene compared the Robber's physical description with the
1 FLORES's date of birth, m'iver's license number, and adm'ess have been redacted from thephotograph.
6
Case: 1:21-cr-00055 Document #: 1 Filed: 01/26/21 Page 7 of 9 PageID #:7
photograph of FLORES on the identification card the Robber handed Teller 1 and
observed the photograph accurately depicted the Robber.
13. Law enforcement databases subsequently confirmed that the
identification card the Robber provided Teller 1 matched FLORES's Illinois Secretary
of State Identification Card records.
14. According to law enforcement reports, the Robber was photographed
and fingerprinted by CPD following his arrest. Law enforcement databases confirmed
the Robber's fingerprints matched existing criminal arrest records for EDNER
FLORES with a date of birth that matches the Illinois Secretary of State records for
FLORES.2
15. In response to law enforcement questions, the Robber identified himself
as EDNER FLORES with a date of birth in 1986, which matched the date of birth of
FLORES in Illinois Secretary of State records.
16. Based on the information above, law enforcement identified the Robber
as FLORES.
Post-Arrest Interview
17. On or about the afternoon of January 25, 2021, an FBI agent and task
force officer interviewed FLORES at the CPD 19th District. The interview was audio
and video recorded. In summary, after providing a written Miranda waiver,
2 FLORES'scriminal arrest records also contain a seconddate ofbirth with the same birthmonth and birth year (but a different date) as the date ofbirth listed in FLORES'sIllinoisSecretaryofState records.
7
Case: 1:21-cr-00055 Document #: 1 Filed: 01/26/21 Page 8 of 9 PageID #:8
FLORES confessed that he attempted to rob the Bank. FLORES was shown a still
image of the Robber from the Bank's video surveillance system and identified the
Robber in the photograph as himself.
CONCLUSION
18. Based on the foregoing facts, I respectfully submit that there is probable
cause to believe that, on or about January 25, 2021, EDNER FLORES (aka "Edner
Flores Jr."), attempted by force and violence, and intimidation, to take from the
person and presence of a bank employee money belonging to, and in the care, custody,
control, management, and possession ofPNC Bank, located at 3337 W. North Avenue,
Chicago, Illinois, the deposits of which were then insured by the FDIC, in violation of
Title 18, United States Code, Section 2113(a).
FURTHER AFFIANT SAYETH NOT.
w~~Special Agent,Investigation
Federal Bureau of
SWORN TO AND AFFIRMED by telephone January 26, 2021.
Honorable HEATHER K. MCSHAINUnited States Magistrate Judge
8
Case: 1:21-cr-00055 Document #: 1 Filed: 01/26/21 Page 9 of 9 PageID #:9