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Case 1:11-cr-00133-JEB Document 5 Filed 04/29/11 Page 1 of 7

UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA

UNITED STATES OF AMERICA : CRIMINAL NO.


:
v. : MAGISTRATE NO. 11-MJ-185
:
JEROME THOMAS, : VIOLATIONS:
: 18 U.S.C. § 2113(a)
Defendant. : (Bank Robbery)
: 18 U.S.C. § 981(a)(1)(C)
: 28 U.S.C. § 2461(c)
: (Criminal Forfeiture)

INFORMATION

The United States Attorney charges that:

COUNT ONE

On or about November 23, 2009, within the District of Columbia, the defendant, JEROME

THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from

the person or presence of another, money belonging to and in the care, custody, control,

management, and possession of Chevy Chase Bank, the deposits of which were insured by the

Federal Deposit Insurance Corporation.

(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))

COUNT TWO

On or about January 6, 2010, within the District of Columbia, the defendant, JEROME

THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from

the person or presence of another, money belonging to and in the care, custody, control,

management, and possession of Chevy Chase Bank, the deposits of which were insured by the

Federal Deposit Insurance Corporation.

(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))
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COUNT THREE

On or about March 8, 2010, within the District of Columbia, the defendant, JEROME

THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from

the person or presence of another, money belonging to and in the care, custody, control,

management, and possession of Chevy Chase Bank, the deposits of which were insured by the

Federal Deposit Insurance Corporation.

(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))

COUNT FOUR

On or about March 12, 2010, within the District of Columbia, the defendant, JEROME

THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from

the person or presence of another, money belonging to and in the care, custody, control,

management, and possession of PNC Bank, the deposits of which were insured by the Federal

Deposit Insurance Corporation.

(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))

COUNT FIVE

On or about March 25, 2010, within the District of Columbia, the defendant, JEROME

THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from

the person or presence of another, money belonging to and in the care, custody, control,

management, and possession of Chevy Chase Bank, the deposits of which were insured by the

Federal Deposit Insurance Corporation.

(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))

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COUNT SIX

On or about April 21, 2010, within the District of Columbia, the defendant, JEROME

THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from

the person or presence of another, money belonging to and in the care, custody, control,

management, and possession of Chevy Chase Bank, the deposits of which were insured by the

Federal Deposit Insurance Corporation.

(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))

COUNT SEVEN

On or about April 26, 2010, within the District of Columbia, the defendant, JEROME

THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from

the person or presence of another, money belonging to and in the care, custody, control,

management, and possession of Chevy Chase Bank, the deposits of which were insured by the

Federal Deposit Insurance Corporation.

(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))

COUNT EIGHT

On or about May 11, 2010, within the District of Columbia, the defendant, JEROME

THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from

the person or presence of another, money belonging to and in the care, custody, control,

management, and possession of PNC Bank, the deposits of which were insured by the Federal

Deposit Insurance Corporation.

(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))

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COUNT NINE

On or about May18, 2010, within the District of Columbia, the defendant, JEROME

THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, attempt

to take from the person or presence of another, money belonging to and in the care, custody,

control, management, and possession of PNC Bank, the deposits of which were insured by the

Federal Deposit Insurance Corporation.

(Attempted Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))

COUNT TEN

On or about January 12, 2011, within the District of Columbia, the defendant, JEROME

THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from

the person or presence of another, money belonging to and in the care, custody, control,

management, and possession of Capital One Bank, the deposits of which were insured by the Federal

Deposit Insurance Corporation.

(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))

COUNT ELEVEN

On or about January 18, 2011, within the District of Columbia, the defendant, JEROME

THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from

the person or presence of another, money belonging to and in the care, custody, control,

management, and possession of PNC Bank, the deposits of which were insured by the Federal

Deposit Insurance Corporation.

(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))

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COUNT TWELVE

On or about March 16, 2011, within the District of Columbia, the defendant, JEROME

THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from

the person or presence of another, money belonging to and in the care, custody, control,

management, and possession of SunTrust Bank, the deposits of which were insured by the Federal

Deposit Insurance Corporation.

(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))

CRIMINAL FORFEITURE ALLEGATION

1. The allegations set forth in Counts One through Eight and Counts Ten through

Twelve of this Information are re-alleged as though set forth fully herein and incorporated by

reference for the purpose of alleging forfeiture to the United States of America pursuant to the

provisions of Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United States Code,

Section 2461(c).

2. As a result of the offenses alleged in Counts One through Eight and Counts Ten

through Twelve of this Information, the defendant, JEROME THOMAS, shall forfeit to the United

States any and all property, real or personal, constituting, or derived from, proceeds obtained directly

or indirectly, as a result of the offenses alleged in Counts One through Eight and Counts Ten through

Twelve of this Information, including, but not limited to:

(a) Money Judgment:

(i) at least $21,101, which represents a sum of money constituting, or derived from,
proceeds obtained, directly or indirectly, as a result of the offenses alleged in Counts
One through Eight and Counts Ten through Twelve of this Information, in violation
of Title 18, United States Code, Section 2113(a).

By virtue of the commission of the felony offenses charged in Counts One through Eight and Counts

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Ten through Twelve of this Information, any and all interest that JEROME THOMAS has in the

property constituting, or derived from, proceeds obtained directly or indirectly as the result of the

offenses alleged in Counts One through Eight and Counts Ten through Twelve of this Information,

is vested in the United States and hereby forfeited to the United States pursuant to Title 18, United

States Code, Section 981(a)(1)(C), and Title 28, United States Code, Section 2461(c).

3. If any of the property described above as being subject to forfeiture, as a result of any act or

omission of the defendant:

a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third person;

c. has been placed beyond the jurisdiction of the Court;

d. has been substantially diminished in value; or

e. has been commingled with other property that cannot be subdivided without
difficulty;

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it is the intention of the United States, pursuant to Title 18, United States Code, Section

981(a)(1)(C), and Title 28, United States Code, Section 2461(c), and incorporating by reference

Title 21, United States Code, Section 853(p), to seek forfeiture of any other property of said

defendant up to the value of said property listed above as being subject to forfeiture.

(Criminal Forfeiture, in violation of Title 18, United States Code, Section 981(a)(1)(C),
and Title 28, United States Code, Section 2461(c))

Respectfully Submitted,

RONALD C. MACHEN JR.


United States Attorney
D.C. Bar No. 447889

By: __________/s/__________________
CATHERINE K. CONNELLY
Assistant United States Attorney
Massachusetts Bar No. 649430
Violent Crimes and Narcotics Trafficking Section
555 Fourth Street, NW, 4th Floor
Washington, D.C. 20530
(202) 252-7732
Catherine.Connelly2@usdoj.gov