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Case 6:18-mj-00067-MC Document 1 Filed 03/22/18 Page 1 of 10

FILED 22 f'ffi •1913:43 USDC·ORE


AO 91 (Rev. 08/09) Criminal Complaint

UNITED STATES DISTRICT COURT


for the
District of Oregon

United States of America )


v. )
) Case No. 6:18-MJ -,fK3r;tw I - MC-
)
CURTIS MAYNARD BOYD )
AMBER NICOLE MARTIN )
Defendant(s)

CRIMINAL COMPLAINT

I, the complainant in this case, state that the following is true to the best of my knowledge and belief.
On or about the date(s) of July through October 2017 in the county of Deschutes in the
_ _ _ _ _ _ District of --~O_r~eg~o~n_ _ _ , the defendant(s) violated:

Code Section Offense Description


18 U.S.C. § 1708 Theft or Receipt of Stolen Mail
18 U.S.C. § 1344
Bank Fraud
18 U.S.C. § 1028A
Aggravated Identity Theft.

This criminal complaint is based on these facts:


See attached affidavit of U.S. Postal Inspector Agent Scott Helton, which is attached hereto and incorporated herein by
this reference.

0 Continued on the attached sheet.

Scott Helton, U.S. Postal Inspector


Printed name and title

Sworn to before me and signed in my presence.

Date: 03/22/2018

City and state: Eugene, Oregon Jolie A. Russo, U.S. Magistrate Judge
Printed name and title
Case 6:18-mj-00067-MC Document 1 Filed 03/22/18 Page 2 of 10

DISTRICT OF OREGON, ss: AFFIDAVIT OF SCOTT HELTON

Affidavit in Support of a Criminal Complaint and Arrest Warrant

I, Scott Helton being duly sworn, do hereby depose and state as follows:

Introduction and Agent Background

1. I am a U.S. Postal Inspector employed by the U.S. Postal Inspection Service, and

have been so employed since March 2003. I am assigned to the Portland Oregon Domicile in the

Seattle Division of the Postal Inspection Service. My training and experience includes a

Bachelor of Science degree in Sociology and Criminology certificate from the University of

Utah, a Doctorate of Jurisprudence degree from Willamette University College of Law, and 12

weeks of basic Postal Inspector training. I am currently a member in good standing of the

Oregon State Bar. As a U.S. Postal Inspector, I am authorized to investigate crimes involving

offenses relating to the United States Postal Service (U.S.P.S.). During the course of my

employment with the Inspection Service, I have conducted or participated in criminal

investigations involving homicide, robbery, assault, burglary, mail theft, identity theft, credit

card fraud, bank fraud, wire fraud, mail fraud, the unlawful mailing of dangerous controlled

substances, the fraudulent use of stolen or forged Postal Money Orders, and the fraudulent use of

stolen credit card information to purchase merchandise, and the shipping of that merchandise

through the U.S. Mail. I have applied for and received search warrants in the investigation of

offenses relating to the U.S.P.S. I have participated in executing federal and state search

warrants.

2. I make this affidavit in support of a criminal complaint charging Curtis Maynard


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Boyd and Amber Nicole Martin with violations of (1) Title 18, United States Code, Section 1708

- Theft or receipt of stolen mail matter generally, and (2) Title 18, United States Code, Section

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1344- Bank Fraud, and (3) Title 18 United States Code, Section 1028A-Aggravated Identity

Theft.

3. The facts set forth in this affidavit are based on the following: my own personal

knowledge; knowledge obtained from other individuals during my participation in this

investigation, including other law enforcement officers; interviews of witnesses; my review of

records related to this investigation; communications with others who have knowledge of the

events and circumstances described herein; and information gained through my training and

experience. Because this affidavit is submitted for the limited purpose of establishing probable

cause in support of a criminal complaint for Curtis Maynard Boyd and Amber Nicole Martin, it
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I does not set forth each and every fact that I or others have learned during the course of this

investigation.

Applicable Law

4. Title 18, United States Code, Section 1708 - Theft or Receipt of Stolen Mail

Matter Generally, provides that "Whoever steals, takes, or abstracts, or by fraud or deception

obtains, or attempts so to obtain, from or out of any mail, post office, or station thereof, letter

box, mail receptacle, or any mail route or other authorized depository for mail matter, or from a

letter or mail carrier, any letter, postal card, package, bag, or mail, or abstracts or removes from

any such letter, package, bag, or mail, any article or thing contained therein, or secretes,

II embezzles, or destroys any such letter, postal card, package, bag, or mail, or any article or thing

contained therein. . . shall be fined under this title or imprisoned not more than 5 years, or both."

..I~ 5. Title 18, United States Code, Section 1344 - Bank Fraud provides that "Whoever

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knowingly executes, or attempts to execute, a scheme or artifice to defraud a financial institution;

or to obtain any of the moneys, funds, credits, assets, securities, or other property owned by, or
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under the custody or control of, a financial institution, by means of false or fraudulent pretenses,

representations, or promises; shall be fined not more than $1,000,000 or imprisoned not more

than 30 years, or both."

6. Title 18 United States Code, Section 1028A - Aggravated Identity Theft provides

that "Whoever, during and in relation to any felony violation enumerated in subsection (c),

knowingly transfers, possesses, or uses, without lawful authority, a means of identification of

another person shall, in addition to the punishment provided for such felony, be sentenced to a

term of imprisonment of 2 years."

Statement of Probable Cause

7. I know from my training and experience that perpetrators of mail theft and band

fraud, in order to obtain financial gain, thieve mail to obtain bank checks, bank issued credit

cards, bank account information including account and routing numbers. Mail thieves often alter

bank checks stolen from the U.S. mail and fraudulently negotiate the checks to obtain financial

gain. Mail thieves also frequently use bank information obtained from mail theft to fraudulently

make bank checks they then negotiate for financial gain. Mail thieves also use bank issued credit

cards fraudulently to obtain financial gain. I know that mail thieves often obtain personal

identification information from stolen U.S. mail, and then use that personal identification

information to make fraudulent identification documents to apply for credit to obtain financial

gam.

8. I know that mail thieves often work in concert with other mail thieves and trade

ll stolen mail, bank checks, bank issued credit cards, and personal identification information with

other mail and identity thieves for money or illegal drugs. I know that mail and identity thieves

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purchase goods and services with money and credit obtained from the personal identification

information stolen from the mail.

9. I know that perpetrators of mail theft and identity theft often store evidence of

mail theft or the ill-gotten gains of their criminal activity at various locations including their

principal residences.

Investigation of Curtis Maynard Boyd and Amber Nicole Martin

10. In the course of my assignment, I have investigated mail theft in Central Oregon,

including mail thefts in Bend, Madras, and Redmond Oregon. I learned from Deschutes County

Sheriffs Deputy J. Minton that on August 22, 2017, he took a report number 2017-00264153

from a Bend, Oregon resident, Victim 1. Victim 1 ordered a new box of bank checks from Selco

Community Credit Union that were mailed to his residence; however, Victim 1 did not receive

the checks. Victim 1 learned that his Selco checking account was overdrawn when he attempted

to negotiate a check and it was declined for insufficient funds. I learned that Victim 1 reported

to Deputy Minton that nine checks were drawn on his account between July 31, 2017 and August

18, 2017. Furthermore, Victim 1 also learned that on four of the checks, the name "Shelli Jo

Phillips" was printed above Victim 1's name, but Victim 1 had ordered the checks with only his

name printed on the checks. On two returned fraudulent check, the Washington State

identification number "PEOLLSJ320MH" was written on the checks.

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11. On one returned fraudulent check, the Washington State identification number

"PEOLLSJ328MH" was written on the check

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SHELLI 10 PHILLIPS w~~~l.-~S3~~M.\\


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12. Deputy Minton learned and told me that there are no Washington State driver

license numbers or state issued identification cards corresponding to those numbers. A total of

$1,970 was fraudulently withdrawn from Victim l's Selco Credit Union account.

13. Deputy Minton told me that in September 2016, he obtained video images of an

attempted July 31, 2017 negotiation of one of Victim l's checks at the Bend, Oregon Walmart

store. The video images show a male and female person attempting the transaction; the female

presenting the check from her purse. The couple exited the store after the negotiation was

rejected and entered a dark colored SUV. Deputy Minton also visited the Redmond, Oregon

Walmart store and learned that on July 29, 2017 the same couple successfully negotiated a check

drawn on Victim 1's account for $210.68. Video images depicted the same couple with one

other female person who exited the store after the transaction and walked to a dark colored Jeep

Cherokee, with no front license plate, extra wide tires with alloy rims and front tum signals that

were unusually yellow in color. Deputy Minton took the still photos from the video surveillance

and disseminated the photos to law enforcement professionals in the Deschutes County Sheriffs

Office and the Bend, Oregon Police Department. Within an hour, several other deputies and

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officers contacted Deputy Minton and told him they believed the photos from Walmart depicted

Amber Nicole Martin. Deputy Minton then compared Martin's most recent Deschutes County

Jail booking photo from June 2017, with the surveillance photos from Walmart and confirmed

the surveillance photos depicted Amber Nicole Martin. I have reviewed the still photos and

compared them to images of Amber Nicole Martin and I believe that Amber Nicole Martin is the

person in the video and in the still photos.

14. Deputy Minton consulted Facebook and learned that Amber Nicole Martin

appeared to be in a relationship with Curtis Boyd. Photos posted on Facebook depict Boyd and

were substantially similar to Boyd's most recent Deschutes County Jail booking photo from

August 2017. The Facebook photos also show Boyd with a Smokey the Bear tattoo surrounded

by two pine trees located on his left forearm. Deputy Minton noted that in the surveillance

photos from the Redmond, Oregon Walmart show the male person leaving the store and a

portion of a tattoo is visible on the male person's left forearm appears to show a tree; while the

entire tattoo is not visible on the surveillance photo, the description matched Curtis Boyd's

description. I have reviewed the still photos and compared them to the images of Curtis

Maynard Boyd and I believe the tattoo on Boyd's left forearm is in substantially the same

location as the tattoo on the individual from the video surveillance.

15. Deputy Minton told me that on October 5, 2017, he learned that a check from

Victim l's Selco Credit Union account was negotiated at Home Depot in Redmond on July 29,

2017, for $701.66.

16. Deputy Minton told me he learned that Boyd and Martin were associated with a

Jeep Cherokee bearing Washington license plate number BRC3476 and researched in law

enforcement databases where that vehicle had recently been stopped in Deschutes County, and

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then drove those areas in an attempt to locate the Jeep Cherokee. Deputy Minton told me he

found the vehicle at 1453 NE Tucson Way, Bend, Oregon 97701, parked in front of the number

four unit. The building at that location is a four-plex multifamily unit, and Deputy Minton told

me he confirmed with neighbors that Boyd and Martin lived in unit number four.

17. Deputy Minton told me that based on the information he collected during his

investigation he applied for and was granted a Search Warrant from the State of Oregon Circuit

Court for Deschutes County on October 10, 2017. The warrant was signed by the Honorable

Bethany P. Flint, Judge. Deputies from the Deschutes County Sheriff's Office served the

warrant on October 10, 2017, and recovered stolen US mail, credit cards, and bank checks.

Many of the checks had been altered, with payee information erased physically and chemically.

18. I reviewed the mail recovered from the search of 1453 NE Tucson Way, Apt. 4,

Bend, Oregon 97701. A total of 1,015 US Postal Service customers' mail was recovered in the

residence. The total dollar amount on bank checks recovered from the residence is $178,007.80.

In addition, 39 different checks recovered were blank and 11 of those checks had been altered

with different payee names. 36 separate credit cards were recovered from the residence.

19. Included in the recovered checks were blank checks from Victim l's Selco

Community Credit Union account printed with his address and altered checks bearing the names

Shelli Jo Philips and Victim 1that are the same as those used fraudulently by Curtis Maynard

Boyd and Amber Nicole Martin.

Conclusion

20. Based on the foregoing, I have probable cause to believe, Curtis Maynard Boyd

and Amber Nicole Martin violated Title 18, United States Code, Section 1708 - Theft or Receipt

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of Stolen Mail Matter Generally, Title 18, United States Code, Section 1344 - Bank Fraud, and

Title 18 United States Code, Section 1028A - Aggravated Identity Theft.

21. Prior to being submitted to the Court, this affidavit, the accompanying

application, and the requested arrest warrant were all reviewed by Assistant United States

Attorney (AUSA) Gavin W. Bruce, and AUSA Bruce advised me that in his opinion the affidavit

and application are legally and factually sufficient to establish probable cause to support the

issuance of the requested criminal complaint and arrest wa

U.S. Postal Inspector, USPIS

Subscribed and sworn to before me this dJJ. day of March 2018.

United States Magistrate Judge

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