Case 1:24-mj-01251-DLC Document 3-1 Filed 05/08/24 Page 1 of 20

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AFFIDAVIT OF SPECIAL AGENT ERIC MERCER IN SUPPORT OF

AN APPLICATION FOR A COMPLAINT

I, Special Agent Eric Mercer, being first duly sworn, hereby depose and state as follows:

INTRODUCTION AND AGENT BACKGROUND

1. I am a Special Agent with the Bureau of Alcohol, Tobacco, Firearms and

Explosives (“ATF”) and have been so employed since January 2020. I am currently assigned to

the Bridgewater, Massachusetts Field Office. Prior to my employment with the ATF, I was

employed as a Trooper with the New Hampshire State Police from 2018 to 2020. As an ATF

Special Agent, I have training and experience regarding investigations involving firearms and

narcotics trafficking and the possession of firearms by prohibited persons, including felons,

parolees, narcotics users, and narcotics traffickers. I have additionally received training and

experience conducting investigations involving the possession and use of firearms in violent crime

and narcotics offenses. I have executed search and arrest warrants.

2. I am aware that 18 U.S.C. § 1951(a) makes it a crime to obstruct, delay, or affect

commerce by robbery or to conspire to do the same. I am also aware that 18 U.S.C. § 2 provides

that whoever aids, abets, counsels, commands, induces, or procures the commission of a crime is

punishable as a principal.

3. I am aware that 18 U.S.C. § 844(i) makes it a crime to maliciously damage or

destroy (or attempt to destroy), by means of fire or an explosive, any building, vehicle, or other

real or personal property used in interstate or foreign commerce or in any activity affecting

interstate or foreign commerce.

4. I am aware that 18 U.S.C. § 371 makes it a crime to conspire to commit any offense

against the United States.

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5. I am also aware that 18 U.S.C. § 922(g)(1) makes it a crime for a person convicted

of a crime punishable by a term of imprisonment exceeding one year from knowingly possessing

a firearm or ammunition in or affecting interstate commerce.

6. I make this affidavit in support of an application for a complaint charging the

following:

i. Steven MADISON (“MADISON”) (YOB 1986) with:

1. affecting commerce by robbery and conspiring to do the same in violation

of 18 U.S.C. § 1951(a);

2. maliciously damaging or destroying, by means of fire or an explosive, any

building, vehicle, or other real or personal property used in interstate or

foreign commerce in violation of 18 U.S.C. § 844(i);

3. conspiracy in violation of 18 U.S.C. § 371; and

4. being a felon in possession of a firearm and ammunition in violation of 18

U.S.C. § 922(g)(1);

ii. Christopher WHITE (“WHITE”) (YOB 1986) with:

1. affecting commerce by robbery and conspiring to do the same in violation

of 18 U.S.C. § 1951(a);

2. maliciously damaging or destroying, by means of fire or an explosive, any

building, vehicle, or other real or personal property used in interstate or

foreign commerce in violation of 18 U.S.C. § 844(i);

3. conspiracy in violation of 18 U.S.C. § 371;and

4. being a felon in possession of a firearm and ammunition in violation of 18

U.S.C. § 922(g)(1);
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iii. Quentin MCDONALD (YOB 1989) (“MCDONALD”)

1. affecting commerce by robbery and conspiring to do the same in violation

of 18 U.S.C. § 1951(a);

2. maliciously damaging or destroying, by means of fire or an explosive, any

building, vehicle, or other real or personal property used in interstate or

foreign commerce in violation of 18 U.S.C. § 844(i); and

3. conspiracy in violation of 18 U.S.C. § 371.

7. The statements in this affidavit are based in part on information provided by other

law enforcement officers, statements of witnesses, information gleaned from third parties, and on

other aspects of my investigation of this matter. Since this affidavit is being submitted for the

limited purpose of securing a complaint, 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 for the complaint. I am also incorporating by reference an affidavit previously

submitted in support of search warrants in this investigation attached hereto as Exhibit A., which

has been redacted to remove addresses, the names of uncharged or otherwise uninvolved

individuals, and/or minors.

PROBABLE CAUSE TO BELIEVE A CRIME HAS BEEN COMMITTED

Robbery at the Bay Coast Bank

8. Based on my review of a Swansea Police Department report (Arrest Warrant Report

# 24-9-WA) and review of surveillance video obtained from the bank and the courier’s vehicle, on

February 19, 2024, just after 12:36 p.m., a courier arrived in a Ford Explorer at the Bay Coast

Bank in Swansea, Massachusetts and parked underneath the awning next to the overnight deposit

bin. Bay Coast Bank was closed because February 19, 2024 was Presidents’ Day.

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9. According to the Swansea PD report recounting an interview with the courier after

the incident, the courier reported that he worked for a company that provided secure cash

transportation services for licensed cannabis companies. A review of records from the courier’s

company shows that the courier had made multiple cash pickups from cannabis dispensaries that

morning at several locations in southern and western Massachusetts, including Provincetown,

Wellfleet, Plymouth, Middleborough, and Fall River. The Fall River location had been the

courier’s most recent pickup before driving to Bay Coast Bank. According to a review of the

manifests, the courier was carrying approximately $436,200.89 in cash for deposit at the Bay Coast

Bank and another area bank that morning. Just over $373,000 of this amount was cash that had

been picked up by the courier in the stop at a dispensary in Fall River immediately preceding the

attempted deposit at the Bay Coast Bank.

10. Investigators have reviewed video surveillance from the Bay Coast Bank and the

dashcam recovered from Ford Explorer driven by the courier. At approximately 12:38 P.M., the

videos show a U-Haul van with an Arizona registration (“the U-Haul Van”) enter the bank parking

lot and pull alongside the Ford Explorer. A Black male wearing dark colored sweatpants, a dark

colored sweatshirt, black gloves, a camouflaged vest (similar to a ballistic style vest), and a mask

covering his face (“Suspect 1”) approached the courier from the passenger side of the U-Haul Van

brandishing a firearm and pointed it at the courier. Suspect 1 had a zip-tie pre-positioned on his

left arm. The courier can be seen raising his hands and backing away. The image below is a screen

captured image from the Bay Coast Bank’s video system, depicting Suspect 1’s approach to the

courier.

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11. The videos show a second individual, Suspect 2, subsequently back the U-Haul Van

into an angled position that, based on my training and experience, was done to block the view of

what was happening from any customers that might be seeking to use the other ATM and to assist

in the quick loading of the stolen cash. Suspect 2 then exited the U-Haul Van and immediately

picked up the two bags on the ground and transferred them into the U-Haul Van. Suspect 2 was

wearing dark colored sweatpants, a dark Champion sweatshirt, a white undershirt visible from

below the sweatshirt, black gloves, a black hat, and a white surgical type of mask. Suspect 2 had

on black sneakers with white soles. Suspect 2 then can be seen opening the trunk of the Explorer

and transferring two additional bags into the U-Haul Van.

12. During this time, the videos show Suspect 1 appearing to direct the courier to get

onto his knees with his hands on top of his head. Suspect 1 then approached the courier and used

the zip-tie to restrain the courier’s hands behind his back. Suspect 1 then escorted the courier back

to his feet, at which point Suspect 1 unsuccessfully attempted to remove the courier’s firearm.

Suspect 2 then approached and attempted to remove the firearm as well, but was ultimately

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unsuccessful. After approximately 1-2 minutes, Suspect 1 and Suspect 2 forced the courier into

the rear driver’s side of the Ford Explorer. The below image is a screen captured image from the

Bay Coast Bank’s video system, depicting Suspect 1 and Suspect 2 attempting to remove the

courier’s firearm.

13. Then, the videos show that Suspect 1 removed an item consistent with pepper spray

from his pocket, reached out towards the courier with his right hand, and then sprayed the pepper

spray in the direction of the courier’s face. Suspect 1 closed the door to the Ford Explorer. Suspect

2 then got into the driver’s seat of the U-Haul Van, and Suspect 1 boarded the U-Haul Van through

the rear doors.

14. According to the interview with the courier, the courier reported having been in

fear for his life and believed the Suspects were going to kidnap him and/or cause him additional

harm during the robbery. After the Suspects returned to the U-Haul Van, they drove it away in the

direction of nearby Route 118. During this time, the courier said that he was able to free his right

hand from the zip-tie restraints, draw his firearm, and fire three rounds at the U-Haul Van as it

fled. The courier then called 911. The videos show the courier inside of the Ford Explorer, remove

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one of his hands from the zip-tie restraints, draw his firearm, and fire four rounds in the direction

of the U-Haul Van as it drove off. When Swansea PD responded to the 911 call and arrived at Bay

Coast Bank, officers also saw the courier in extreme discomfort from having been pepper sprayed.

The courier also had a clear zip-tie around one wrist at this time.

15. A review of the available videos prior to the robbery shows the Suspects had

conducted a practice run at the Bay Coast Bank’s drop box at or around 10:52 A.M.—just under 2

hours before the robbery. The U-Haul Van was observed driving into the Bay Coast Bank’s

parking lot and through the area of the Interactive Teller Machine (ITM) and after-hours drop bin.

The U-Haul Van then drove to the parking lot for Prime Storage, located at 262 Swansea Mall

Drive (next door to the bank), and pre-positioned in a location from which the occupants could

watch the activity at the bank and await the courier’s arrival.

U-Haul Van Fire on Reed Street

16. According to my review of Swansea PD reports, Swansea PD received reports of a

U-Haul van on fire on Reed Street in the area of the “Quarter Mile.” The “Quarter Mile” is a

commonly used nickname for the stretch of Reed Street that runs parallel to Route 195. The

Quarter Mile is a section of road that does not have any businesses or residences on it. According

to Google Maps, the “Quarter Mile” area where this fire was reported is located a short distance

away from Route 118 and the Bay Coast Bank located at 330 Swansea Mall Drive (approximately

one mile away). Based on the short time frame between the robbery calls and the calls reporting

the U-Haul on fire, as well as the close proximity between the Bay Coast Bank and location of the

U-Haul, it was believed by officers on scene that this was the U-Haul Van used during the

commission of the robbery at Bay Coast Bank.

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17. According to the Swansea PD report, when Swansea PD responded to Reed Street,

officers saw the U-Haul Van fully engulfed in flames. Below is a screenshot of video captured of

the U-Haul Van on fire:

18. The U-Haul Van was later identified as a white 2023 Ford Transit van bearing

Arizona registration: AM35900 and owned by U-Haul Moving and Storage. Swansea PD officers

spoke with several witnesses on scene. One witness, a male, reported he was traveling home,

northbound on Reed Street from the Cumberland Farms, when he noticed the U-Haul Van on the

east side of the road. The male witness observed the front of the U-Haul Van beginning to smoke

and pulled over on Reed Street. He also reported seeing two Black or Hispanic males removing

items from the U-Haul Van and believed they were likely trying to salvage possessions from a

possible vehicle fire. The U-Haul Van then became engulfed in flames, and he observed the two

males board a dark colored Jeep Grand Cherokee. The Jeep, as it drove away, nearly struck the

male before leaving the area of Reed Street.

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19. Another witness, a female, reported she was walking her dog on Reed Street when

she observed the black Jeep driving in her direction at a high rate of speed. The female eyewitness

reported she observed a passenger in the Jeep, but was only able to describe that he was a male

wearing a black hoody type sweatshirt.

20. The Swansea Fire Department responded to, and extinguished, the U-Haul Van fire

on Reed Street. During the investigation of the fire scene, according to the Swansea Arrest Warrant

Report, law enforcement recovered a cannister of pepper spray on the ground directly next to the

U-Haul Van.

Identification of the Getaway Jeep

21. Investigators learned that another civilian witness present on Reed Street had a

dashboard video camera that recorded during the relevant time period. Investigators reviewing the

dash camera footage saw the U-Haul Van was stopped on the right side of Reed Street just north

of the Swansea Water Department facility and at least one individual moving in and out of the U-

Haul Van on the passenger’s side.

22. Then, a dark colored Jeep Grand Cherokee pulled up and drove past the U-Haul

Van. The Jeep pulled to the side of Reed Street directly in front of the U-Haul Van and came to a

stop. To the left of the Jeep’s license plate was a sticker or decal, consistent with that of a New

England Patriot’s logo. The photographs below are screen captured images from the

aforementioned dash camera footage.

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23. In my review of the video surveillance footage at the location of the robbery at the

Bay Coast Bank, I did not see this Jeep Grand Cherokee appear on the footage, which is evidence

that the Suspects were in communication with the driver of the Jeep to coordinate the pickup after

the robbery, enabling them to destroy the U-Haul Van.

24. In an effort to identify the Jeep Grand Cherokee that the Suspects utilized as a

“getaway” car on Reed Street, investigators sent the dash camera footage to the New England State

Police Information Network (NESPIN) for further analysis. The dash camera footage was

enhanced by a digital forensic analyst, who forwarded the enhanced images from the footage to

investigators. After image enhancement, the license plate on the Jeep appears to be Massachusetts

registration: 2FSS99. The registration (2FSS99) was queried and based on a review of records

from the Massachusetts Registry of Motor Vehicle (RMV), the registered owner was identified a

person who, based on a review of CJIS and inmate records is believed to be the sister of

MCDONALD. The Jeep was registered at an address in Brockton, MA, where MCDONALD lives

with his sister and her family.

Theft of the U-Haul Van

25. After the fire, investigators contacted U-Haul Moving & Storage about the U-Haul

Van and learned that it had been stolen in the early morning hours of February 19, 2024 after

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having been returned after hours the evening before to a U-Haul location in Abington,

Massachusetts.

26. I and other ATF agents visited U-Haul’s Abington location and met with the store

manager and assistant manager. During this meeting, a U-Haul representative confirmed that the

vehicle was returned after hours at 6:24 P.M. on Sunday, February 18, 2024 and the key had been

deposited in a drop box.

27. Agents, including myself, subsequently reviewed the video surveillance system and

observed that the video showed two unidentified individuals at approximately 12:30 A.M. on

February 19, 2024 walk northbound from Bedford Street (Route 18) into the U-Haul parking lot.

One of the individuals was wearing a dark sweatshirt with white lettering across the chest and dark

colored sweatpants. The other individual was wearing a dark colored sweatshirt and lighter, gray

colored sweatpants. Based on their physical build and their clothing, I believe these are the same

individuals who later robbed the courier at the Bay Coast Bank.

28. The video shows both individuals continue to walk northbound across the parking

lot towards the shed and afterhours drop off area. From approximately 12:31 A.M. to 12:35 A.M.,

both individuals remain in the area of the shed and the key drop box and their movements are

consistent with manipulating the drop box to try to retrieve a key. At approximately 12:35 A.M.,

both individuals walked to the west side of the shed and boarded the U-Haul Van. The U-Haul

Van then drove out of the parking lot, making a right hand turn northbound on Route 18.

Status of MADISON and WHITE as Felons

29. Based upon a review of public records, I am aware that MADISON has knowledge

that he has been convicted in the Plymouth Superior Court for multiple charges, including armed

home invasion and masked armed robbery for which the possible sentence would (and did) exceed
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one year. In that case, Docket No. 1283CR00244, MADISON was convicted of a total of 10

charges on January 13, 2014 and was sentenced to 8 years to 8 years and one day in state prison

(for masked armed robbery and assault and battery by means of a dangerous weapon), 2 ½ years

concurrent for unlawfully possessing a firearm, and 5 years of probation from and after the

conclusion of the incarceration on the remaining seven counts. In that case, MADISON was co-

defendants with MCDONALD.

30. Based upon a review of public records, I am aware that WHITE has knowledge that

he has been convicted in the Taunton District Court for two counts of receiving stolen property in

excess of $250 for which the possible sentence would (and did) exceed one year. In that case,

Docket No. 0931CR003362, WHITE was sentenced on March 17, 2010 for those counts and other

charges to a split sentence of 2 years in the house of corrections, with 6 months to serve and the

balance suspended for 2 years.

31. Additionally, on March 10, 2011, WHITE was convicted in New Bedford District

Court (Docket No. 1033CR007345, for one count of larceny over $250 (a state sentence which

carries a maximum possible sentence of 2 years in the house of correction or 5 years in state prison)

on March 10, 2011 and sentenced to 90 days in the house of correction.

IDENTIFICATION OF MADISON, WHITE, AND MCDONALD

32. I obtained search warrants for timing advance data related to the devices that

connected to cellular towers servicing: (i) the U-Haul location in Abington when the U-Haul Van

was stolen, (ii) the location of the Bay Coast Bank in Swansea during two time periods ahead of

and during the robbery, and (iii) the area where the U-Haul Van was found on fire at Reed Street

in Swansea after the robbery.

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33. Based on a review and analysis of the produced records, T-Mobile timing advance

data showed that one device connected with area towers during all four requested location/time

windows (“Device 1”). T-Mobile had timing advance data showing that an additional two devices

connected with area towers for two of the location/time windows: in the area of the U-Haul store

in Abington when the U-Haul Van was stolen and in the area of Reed Street after the robbery

(“Devices 2 and 3”). See Exhibit A, Par. 33-36.

34. Based on a review of records from Apple and CashApp, Device 1 belonged to

WHITE. Device 2, based on a review of T-Mobile, Apple, and CashApp records, belonged to

MCDONALD. And, T-Mobile records showed that Device 3 belonged to MADISON. See Exhibit

A, Par. 37-44.

35. I obtained a search warrant for additional cell site location information and timing

advance data for the three phone numbers associated with these three devices. In summary, a

review of the available data shows that during the relevant time periods, all three devices connected

with towers consistent with them being present at the theft of the U-Haul, at the robbery, and at

the burning of the U-Haul. In addition, I also reviewed call detail records for all three phone

numbers and observed that MADISON communicated with WHITE and MCDONALD at critical

times. See Exhibit A, Par. 45-73.

36. For example, on the evening of February 18, 2024, WHITE, MADISON and

MCDONALD’S phones connected with towers consistent with them being at their residences.

MADISON and MCDONALD’S phones, between 11:30 P.M. and 12:00 A.M., then began

connecting with towers in Raynham, near WHITE’S residence, suggesting all three had met. All

three devices, by 12:35 A.M. on the morning of February 19, 2024, had left the Raynham area and

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traveled to the area of the U-Haul in Abington. MADISON called MCDONALD at 12:36 A.M.,

consistent with when the theft of the U-Haul Van was completed.

37. A review of the location records and call detail records show that on the morning

of February 19, MADISON’S phone connected with towers consistent with traveling to WHITE’S

apartment in Raynham. Afterwards, the records show tower connections consistent with

MADISON and WHITE traveling to Swansea. Records for MCDONALD’S phone shows that his

phone traveled from his home in Brockton to Swansea that morning as well.

38. At approximately 12:36 P.M., MADISON called MCDONALD. This time is

consistent with the initial approach of the suspects to the courier at Bay Coast Bank. At 12:42

P.M., MADISON called MCDONALD again, which is consistent with the completion of the

robbery and the flight of the U-Haul Van to the Reed Street area for the rendezvous with the

getaway Jeep. Based on the call history and the location information, I believe that WHITE and

MADISON were Suspects 1 and 2 who robbed the courier at the Bay Coast Bank in Swansea. I

believe that MCDONALD aided and abetted MADISON and WHITE by planning the robbery

with them, transporting them to the theft of the U-Haul Van in Abington, and helping them escape

by driving the getaway Jeep to and away from the fire at Reed Street.

39. T-Mobile records showed that WHITE and MCDONALD’S phone connected with

towers consistent with a route of travel back from Swansea to WHITE’s residence in Raynham,

arriving by 2:00 P.M. By 3:03 P.M., MCDONALD’s phone was connecting with towers in the

Brockton area again.

40. MADISON’S phone, however, continued to connect with the Swansea T-Mobile

towers until 4:20 P.M., when it connected with a tower in Brockton, but this time with a different

device. Based on a review of T-Mobile records and surveillance video, I know that MADISON
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went at that time to a T-Mobile store in Brockton and paid $900 in cash to engage in several

transactions, including the purchase of a different phone. Three days later, on February 22, 2024,

records show that MADISON switched devices yet again. See Exhibit A, par. 76-80

Additional Evidence Leading to Identification of MADISON

41. I and other investigators have further reviewed the Bay Coast Bank’s video

surveillance and observed Suspect 2 appears to have a distinct scar from the left side of his neck

towards his left ear. During this investigation, I have reviewed a photograph I obtained from

CrimeTracer, which is a database that aggregates information from various police and law

enforcement sources. This database contained a photograph of MADISON in which he appears to

have the same scar on the left side of his neck towards his left ear as Suspect 2. The photograph

and a still from the Bay Coast Bank’s video surveillance of Suspect 2 on February 19, 2024 are

below.

42. On May 8, 2024, I and other officers executed a search warrant at MADISON’S

home in Bridgewater, Massachusetts and located MADISON there. I observed MADISON had

the same distinctive scar on the left side of his neck.

43. I have also seen MADISON wearing a sweatshirt similar to that worn by Suspect 2

at the Bay Coast Bank on a previous occasion. Based on my review of bodycam footage from a
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Raynham Police response to a motor vehicle accident on January 9, 2024, I observed MADISON

and WHITE together as occupants of a vehicle involved in an accident. During that encounter,

MADISON was wearing a dark colored sweatshirt with the Champion logo written across the chest

and Nike sweatpants. The Champion sweatshirt appeared to be the same color and style of the

sweatshirt worn by SUSPECT 2 during the robbery at the Bay Coast Bank on February 19, 2024.

MADISON additionally provided his phone number, ending-3729 (MADISON’s Phone), to

responding Raynham Police units.

44. Also, during the execution of the search warrant at MADISON’S home on May 8,

2024, officers located a similar black Champion brand sweatshirt.

Additional Evidence Leading to Identification of WHITE

45. On the date of the robbery, records from WHITE’S landlord indicate that he owed

$14,200 in rent. Based on a review of records and speaking with an employee of the landlord,

WHITE paid $5,700 in cash between approximately 4:30 and 5:30 P.M. on February 19, 2024 (just

hours after the robbery). On February 29, 2024, WHITE paid an additional $8,500 in cash to bring

his balance to $0. This was the first time that his rental account had a $0 balance since January

2023.

46. T-Mobile records also show that two days after the robbery, WHITE’s T-Mobile

account switched devices on February 21, 2024 after several transactions involving over $1,300 in

cash.

SEARCH WARRANTS EXECUTED MAY 8, 2024

47. On May 8, 2024, I and other law enforcement officers executed search warrants at

MADISON’S residence in Bridgewater, Massachusetts, WHITE’S residence in Raynham,

Massachusetts, and MCDONALD’S residence in Brockton, Massachusetts.

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Results from MADISON’S Residence

48. At MADISON’S residence, three phones were located believed to belong to

MADISON. Two were found in his bedroom and one was found in another bedroom on a charger.

At this time, I called the -3729 phone number on two occasions (the number associated with

MADISON that had a device that was present at the time/location of the U-Haul Van theft in

Abington and the burning of the U-Haul Van in Swansea), and observed the iPhone on the charger

in the other bedroom rang.

49. In the bedroom occupied by MADISON and his girlfriend, officers located a

jewelry box under the bed that contained several items of jewelry, including a men’s Rolex watch.

In the foyer, officers located a suitcase that contained a Rolex box and an appraisal report dated

February 20, 2024, the day after the robbery, that contained a photo of the watch and an estimated

value of $47,500.

50. In several locations thought the home, officers located cash in various

denominations, that was estimated to be at least $5,000, but it is still be counted.

51. In MADISON’s bedroom, officers located a dark hooded sweatshirt with the

Champion logo across the chest. Based on my review of it, this shirt is consistent with that shirt

worn by Suspect 2 at the Bay Coast Bank on February 19, 2024 and by MADISON on January 9,

2024.

52. On the dining room table of the home, officers located a safe. Using a key found

on a keychain which also had keys for two vehicles registered to MADISON, officers located a

Taurus G2C 9 mm pistol with an extended magazine and a baggie of ammunition that containing

approximately 12 rounds. I have consulted with ATF interstate nexus experts and it is their opinion

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that the Taurus G2C 9mm pistol was not manufactured in the Commonwealth of Massachusetts,

and therefore it had to have traveled in and/or affected interstate commerce.

53. Also, in the safe, officers discovered a large bag of a white powdered substance

consistent with cocaine. Investigators subsequently field tested the substance utilizing a TruNarc

Narcotics Analyzer, which yielded a positive result for the presumptive presence of cocaine.

Investigators located another small a clear knotted baggie containing a similar white powder

substance consistent with cocaine.

Results from WHITE’S Residence

54. During execution of the search warrant WHITE was identified the sole occupant of

this apartment. Investigators located an iPhone in the bedroom where WHITE was located. When

officers called -0645 (the number associated with the device that was found in all four

locations/time frames), this iPhone rang.

55. Officers located zip ties in the apartment, concealed within a sock. The sock was

located in one of the apartment closets. Investigators noted while the zip-ties were black, they

appeared to be pre-staged in a manner consistent with restraints, similar to that of Suspect 1 at the

Bay Coast Bank. Investigators also recovered two black masks that are consistent in color and

style to that worn by Suspect 1 during the robbery.

56. Also in the bedroom, officers found one Glock 27 .40 caliber pistol. The firearm

was loaded with three 3 rounds of ammunition and other ammunition was found throughout the

apartment. Investigators located additional ammunition in the apartment. I have consulted with

ATF interstate nexus experts and it is their opinion that the Glock 27, .40 caliber pistol, was not

manufactured in the Commonwealth of Massachusetts, and therefore it had to have traveled in

and/or affected interstate commerce.

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57. In the kitchen of the apartment, investigators found several bags containing a white

substance consistent with cocaine. One of the bags weighed approximately 406 grams (with

packaging). Investigators subsequently field tested the substance utilizing a TruNarc Narcotics

Analyzer, which yielded a positive result for the presumptive presence of cocaine.

Results from MCDONALD’S Residence

58. At the execution of the search warrant at MCDONALD’S residence, MCDONALD

was encountered at the residence. When detained at the residence, investigators located a mobile

phone on his person. Investigators subsequently called the -9466 number (identified as being

associated with the device that was present at towers near the U-Haul Van theft in Abington and

at the burning of the U-Haul Van after the robbery), and observed the device rang.

59. In the bedroom of MCDONALD’S sister, officers located a container containing at

over $6,000 in cash.

CONCLUSION
60. Based on the foregoing, I submit there is probable cause to believe that on or about

February 19, 2024, MADISON, WHITE, and MCDONALD did rob and conspire to rob the courier

at the Bay Coast Bank in Swansea in the District of Massachusetts, by obstructing, delaying and

affecting, in any way and degree, commerce and the movement of any article and commodity in

commerce, by robbery as defined in 18 U.S.C. § 1951; that is, by taking and obtaining property,

consisting of money and other valuable items, from the owners of the property against his will by

means of actual and threatened force, violence, and fear of injury, in violation of 18 U.S.C. § 1951

and 18 U.S.C. § 2.

61. There is further probable cause to believe that MADISON, WHITE, and

MCDONALD, on or about February 19, 2024, in Swansea, in the District of Massachusetts, did

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 Case 1:24-mj-01251-DLC Document 3-1 Filed 05/08/24 Page 20 of 20

maliciously damage or destroy (or attempt to destroy), by means of fire or an explosive the U-Haul

Van, a vehicle used in interstate or foreign commerce in violation of 18 U.S.C. § 841(i) and 18

U.S.C. § 2, and did conspire to do the same in violation of 18 U.S.C. § 371.

62. There is further probable cause to believe that MADISON, on or about May 8,

2024, in Bridgewater, in the District of Massachusetts, knowing that he was previously convicted

in a court of a crime punishable by imprisonment for a term exceeding one year did knowingly

possess, in and affecting commerce, a firearm and ammunition, that is a Taurus G2C 9 mm

handgun, in violation of 18 U.S.C. § 922(g)(1).

63. Finally, there is further probable cause to believe that on or about May 8, 2024, in

Raynham, in the District of Massachusetts, WHITE, knowing that he was previously convicted in

a court of a crime punishable by imprisonment for a term exceeding one year did knowingly

possess, in and affecting commerce, a firearm and ammunition, that is a Glock 27 .40 caliber

handgun, in violation of18 U.S.C. § 922(g)(1).

64. For the foregoing reasons, I request that the Court issue the above criminal

complaints.

Eric H. Mercer
Special Agent
Bureau of Alcohol, Tobacco, Firearms and Explosives

Sworn to before me via telephone in accordance with Fed. Rule Crim. P. 4.1 on May ____, 2024.

_________________________________________
HONORABLE DONALD L. CABELL
CHIEF UNITED STATES MAGISTRATE JUDGE

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