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JOHN W. HUBER, United States Attorney (#7226) ?ruts
CARL D. LESIIEUR, Assistant United States Atrorney (#16087)Btry rorues,
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Attorneys for the united States of America
Office of the United States Attorney
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111 South Main Street, Suite 1800
Salt Lake City, Utah 84111-2116
Telephone: (801) 524-5682
Emaii: carl.lesueur@usdoj.gov

IN THE IINITED STATES DISTRICT COURT


DISTzuCT OF UTAH, CENTRAL DIVISION

LINITED STATES OF AMERICA, caseNo Z, igrl t3Z-DBp


Plaintiff, COMPLAINT

vs.

JOSSHUA PEREZ RIVAS, JOAO SILVA Judge Dustin B. Pead


ROBERTS ON, STARLIN GARCIA
CARABALLO, PEDRO RTVERO
VELAZQUEZ, And, LUIS MENDEZ MATA

Defendants.

Before the Honorable Dustin B. Pead, United States Magishate Court Judge for the

District of Utah, appeared the undersigned, who on oath deposes and says:

COUNT I
18 U.S.C. $ 1030(a)(a)

On or about February 25,2018 in the Central Division of the District of Utah,

JOSSHUA PEREZ RIVAS, JOAO SILVA ROBERTSON, STARLIN GARCIA

CARABALLO, PEDRO RIVERA VELAZQUEZ, aIILUIS MENDEZ MATA


the defendants herein, did knowingly and with intent to defraud, access a protected

computer - specifically, the computer controlling a Deseret First Credit Union ATM at

9325 Yillage Shop Drive in Sandy, Utah - without authorization and in excess of

authonzedaccess and by means of such conduct further the intended fraud and obtain

money, and did conspire to do so, attempt to do so, and aid and abet others in doing so;

ail in violation of Sections 2, 1030(a)(4) and 1030(b), Title 18 of the United States Code.

COI,INT II
18 U.S.C. S 2113(b)

On or about February 25,2018 in the Central Division of the District of Utah,

JOSSHUA PEREZ RIVAS, JOAO SILVA ROBERTSON, STARLIN GARCIA

CARABALLO, PEDRO RIVERA VELAZQUEZ, ANd LUIS MENDEZ MATA

the defendants herein, did take and carry away, with intent to steal and purloin, money

belonging to and in the care, custody, control, management, and possession of Deseret

First Credit Union, a credit union insured by the National Credit Union Administration

Board and did conspire to do so, attempt to do so, and aid and abet others in doing so; all

in violation of Sectio ns 2, 37 1 and 211 3 (b), Title 1 8 of the United States Code.

This complaint is made on the basis of investigation consisting of the following:

1. On or about February 20,2018, someone attempted to purchase airiine tickets

from American Airlines for Defendants JOSSHUA PEREZ RIVAS, STARLIN GARCIA

CARABALLO, LUIS MENDEZ MATA, ANd PEDRO RIVERO VELAZQTJEZ


travelling on February 23,2078, all using the same IP address and using the same email

address. The same email address used to attempt those purchases had previously been

used to purchase airline tickets for JOAO SILVA ROBERTSON, and the IP address had

been used in connection with prior passenger records created for SILVA ROBERTSON.

2. On or about February 23,z}l},Defendants JOSSHUA PEREZ RIVAS,

STARLIN GARCIA CARABALLO, PEDRO RIVER OYELAZQTJEZ,ANd LUIS

MENDEZ MATA were observed arriving at Salt Lake City International Airport and

meeting together with JOAO SILVA ROBERTSON, and entering into avanety of rental

CAIS.

3. From February 23,2018 to February 25,2018, I and other law enforcement agents

surveilled the vehicles and occupants thereof, including the Defendants JOSSHUA

PEREZ RiVAS, JOAO SILVA ROBERTSON, STARLIN GARCIA CARABALLO,

PEDRO zuVERO VELAZQTJEZ, ANd LUIS MENDEZ MATA.

4. During this period, we observed the Defendants engage in multiple maneuvers that

appeared calculated to counter surveillance, such as exiting a highway, conductin g a v-

furn, and resuming the originai route.

5. In addition, on February 25,2018, we observed the vehicles rented and occupied

by the Defendants and their coconspirators converge on Liberty Park in Salt Lake City

Utah, where they parked. The occupants, including the Defendants, exited the vehioles

and appeared to hold a meeting in the middle of the park.

6. The meeting participants then returned to their respective vehicles. Several of


those vehicles then drove to multiple sites where ATMs are located, particularly in the

Old Mill areaflear a Ziot's Bank ATM and a Mountain America Credit Union ATM.

i. The vehicles occupied by the Defendants and others then circled back to Liberty

Park, where the occupants exited and appeared to have another discussion. After this

exchange, the individuals appeared to exchange some equipment or materials from one

car to another.

8. Thereafter, the Defendants and all the cars and all their occupants left Liberty Park

and returned to the Old Mill area in Cottonwood Heights near the Zion's Bank ATM and

a Mountain America Credit Union ATM. While en route they engaged in a couple more

evasive maneuvers, each time returning to the direction of the ATMs until they

approached, at which time one of the vehicles veered directly up to the Z,iot's Bank

ATM, while the other vehicles pulled off to wait in the vicinity. An individual exited

the vehicle rented by PEDRO RIVERO VELAZQUEZ andwas observed approaching

the Zion's Bank ATM. Another individual was observed exiting one of the other

vehicles and approaching the nearby Mountain America Credit Union ATM on foot.

9. Zion's Bank subsequently called to report an attempted breach of their ATM at

that location.

10. A customer drove up behind the car rented by PEDRO RIVERO VELAZQTJEZ,

and the individual at the ATM retumed to the vehicle and the vehicle, and the other

suspect vehicles all immediately ieft the vicinity and proceeded to afl area on94th South.

1 1. At a Deseret First Credit Union at 9325 Village Shop Drive in Sandy, Utah, the
car rented by PEDRO RIVERO VELAZQIIEZwas observed at the ATM. As law

enforcement agents approached the bank, the ATM was displav:rng a screen that indicated

the software system of the ATM had been breached. Agents approached the suspect

vehicle and found the ATM dispensing cash, and arrested the individual in the car and

found electronic equipment and a bag full of cash.

lZ. The ATM dispensing cash and the electronic equipment observed in the vehicle

was consistent with a bank robbery method known as 'Jackpotting," where perpetrators

physically breach the ATM to install hardware infected with malware that enables a

coconspirator to direct the ATM to dispense cash without accounting or security

measures. In this marrner, the ATM can be directed to simply empty out all of its cash.

13. A technician reviewed the ATM and determined there was a dongle for attachtng a

keyboard to the ATM computer that should not have been there, as well as some cables,

and two hard drives that had been installed and did not belong to the ATM, and that the

compartment that heid the hard drive that should be in the ATM had been forcefully

opened. Each of these breaches are also consistent with the unauthorized access of the

ATM computer in a'Jackpotting" breach.

14. Each of the Defendants was found either at the vehicle in front of the Deseret First

Credit Union ATM at the time law enforcement agents approached and the ATM was

dispensing cash, or nearby in the parking lot in what appeared to be countersurveillance

positions, except for LUIS MENDEZ MATA. ,

15. According to witnesses, LUIS MENDEZ MATA was in a vehicle parked at a gas
station nearby for the purpose of monitoring the progress of the jackpotting from a

distance. LUIS MENDEZ MATA, or someone matching his description, had been

observed earlier in the day atthe meetings in Liberty Park andat one point entering the

same vehicle thatlater in the evening was found in front of the ATM as it was dispersing

cash because of the jackpotting heist.

Based on the foregoing information, youl affiant respectfully requests that

warrant's of arrest be issued for De for violations of 18 U.S.C. $$ 1030(a)(a) and

(b), an 18 U.S.C $ 2113(b)

Special Agent Step I Olsen

SUB RIB SWORN to before me this 26th day of February, 2018.

Uniied strate CourtJudge

APPRO

JOHN W. HUBER