Professional Documents
Culture Documents
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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
H
111 South Main Street, Suite 1800
Salt Lake City, Utah 84111-2116
Telephone: (801) 524-5682
Emaii: carl.lesueur@usdoj.gov
vs.
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)
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)
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.
from American Airlines for Defendants JOSSHUA PEREZ RIVAS, STARLIN GARCIA
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.
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
4. During this period, we observed the Defendants engage in multiple maneuvers that
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
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 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.
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
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
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
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
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
APPRO
JOHN W. HUBER