Case 9:19-mj-08013-BER Document 1 Entered on FLSD Docket 01/29/2019 Page 1 of 7

AO 91(Rev.08/09) CriminalComplaint

U NITED STATES D ISTRICT CO wu oc

forthe FILED BY ..
Southern DistrictofFlorida
1AN 28 2018
United StatesofAm erica ) ANGELA E.NOBLE
V. ) CLERK U S DIST.CT.
RODRICK DOMONIQUE JONES ) CaseNo. 19-801 BER S.D.OFFLX.-W.P.B'
)
)
)

CR IM IN A L C O M PLAINT

1,the complainantin thiscase,statethatthefollowing istrue tothe bestofmy knowledge and belief.

Onoraboutthedatets)of 4/14/16throuqh2/17/18 inthecountyof Palm Beach inthe
Southern Districtof Florida ,thedefendantts)violated:
CodeSection OffenseDescrètion
18U.S.C.Section2113(a)and(d) BankRobbery

Thiscriminalcom plaintisbased on thesefacts'

.

Please see attached affidavit.

V Continuedontheattachedsheet.

/
mplainant'
ssi
gnature

DANIEL J.SZCZEPANSKI,SpecialAgentFBI
Printed nam eandtitle

Swornto beforemeand signed inmy presence.

*

D ate: 01/29/2019
Judge'
5,signature

City and state: U .S.M a istrateJud e BRUCE REINHART

Printed nam eandtitle
Case 9:19-mj-08013-BER Document 1 Entered on FLSD Docket 01/29/2019 Page 2 of 7

AFFIDAVIT OF
DAN IEL SZCZEPA NSM ,SPECIAL A GENT
FEDER AL BUR EAU OF INVESTIGATIO N

1,DanielJ.Szczepanski,being duly sworn,do state and attestasfollow s:

1. lam aSpecialAgent(SA)withtheFederalBureauoflnvestigation (FBI),and1havebeen
soemployedsinceJanuary2006. lam currentlyassignedtoPB-2,theViolentCrimesandM ajorOffender
Squad ofthePalm Beach County ResidentAgency.Ihaveprimarily been assigned to investigationsdealing
with bank robberies,fugitives,violentcrim es,and othersophisticated schem es.Based on my experienceas
a federal law enforcem ent officer, I have conducted investigations of, and have been instructed in
investigative techniquesconcerning bank robberiesand conspiraciesto comm ittheseoffenses,in violation
ofTitle l8,United StatesCode,Section 21l3.Based upon experience,lhave also becom e wellversed in,
and fam iliarw ith,the m ethodology utilized in bank robberies and the uniquepatternsemployed by bank
robbers.
Thisaffidavitis based upon m y own personalknowledge ofthe facts and circum stances
surrounding the investigation and inform ation provided to m e by other law enforcementofficers.This
affidavitdoesnotpurportto contain alltheinformation known to me aboutthiscase butaddressesonly that
inform ation necessary to supporta finding of probable cause forthe issuance of a crim inal complaint
chargingRODRICK DOM ONIQUE JONES (hereinafterJONES),withBankRobbery,inviolationofTitle
l8,UnitedStatesCode,Section2113(a)and (d).
TheUnited Statesisinvestigating four(4)bank robberies,t'wo (2)ofwhich were armed
bank robberiesand the othertwo (2)bank robberiesthe unidentified subject(UNSUB)indicated in his
dem and notethathehad agun.Therespectivebank robberiestook place inthe Southern DistrictofFlorida.
Thus,theinvestigationconcernsviolationsofTitle l8,UnitedStatesCode,Sections2113(a)and (d).
On A pril 14,2016,atapproximately 3:50pm ,an unidentified black m ale,entered Chase
bank located at525 NE 7th Street,Delray Beach,FL.The UN SUB waswearing a black long-sleeved shirt
with a white t-shirtundetneath;m ulticolored necktie'
,khakicolored pants;and a green baseballcap.The
dem and note stated,''DON 'T W ALK A W AY,''which wasprinted in allcapsand in blue ink.The dem and
note said to give him m oney,ifnothe would startshooting.Asthevictim tellerread the dem and note,the
UN SUB removed a black,sem i-autom atic handgun nearhis waistband with hisrighthand and placed the
weapon on the tellercounter.The tellertold the UN SUB they needed more time because the money was
com ing outofthem achine.The UN SUB then said,''You betterhurl'y up'
'and m ade ahand gesturetowards
theteller.Thevictim tellerprovidedthesubjectwith $l,000.00,whichwasverified withthepostrobbery
audit.Atthe tim e of the robbel'y,the FederalDeposit lnsurance Corporation insured deposits at Chase
Case 9:19-mj-08013-BER Document 1 Entered on FLSD Docket 01/29/2019 Page 3 of 7

Bank.
On M ay l9,2016,atapproximately 3:58pm ,an unidentified black male,entered Chase
bank located at 5955 SE FederalHighway,Stuart,Florida,approached the bank teller and presented a
dem and note.TheUN SUB worea dark colored baseballhat,black long sleevebutton-down shirt,and blue
jeanpants.Thedemand note suted something to theeffectof,Do notwalk tzwtz-p/1J/tzvcagunlGiveme
allthe money and nobody gets hurtlDo not/ry to be a hero.1'
m serious.The victim teller provided the
subjectwith $20,400.00 in US currency. Atthe time ofthe robbery,the FederalDepositInsurance
Corporation insured depositsatChase Bank.
On June 22,20l7,at approxim ately 4:24pm ,an unidentified black male entered Chase
bank located at525N E 7thStreet,D elray Beach,Florida,approachedthebank tellerandpresenteda dem and
note. Thenotestated,tr ivemeallthemoney.Thisisnojoke.1haveagun.''TheUNSUB woreagray
New York Yankees baseballhat,a striped shortsleeved polo shirt,dark colored pantsand dark colored
sneakers.Afterpassingthedemand note,thesubjectliftedhisshirtand showedthetellera handgun that
wastucked in hiswaistband.Thesubjectreceived $4,000 in UScurrencybeforetleeingthebank.Atthe
time ofthe robbery,the FederalDepositlnsurance Corporation insured depositsatChase bank.
Shortly afterthe robbery,a bank employee wentto lock the frontdoorofthe bank. The
employeewatchedthe subjectwalk towardsLorneand SonsFuneralHome.Duringtheinvestigation,an
em ployee ofthe funeralhom e was interview ed.The employee stated thatatsom etime around 4:30pm or
4:45pm heobserved an olderm odelwhite sedan parked in the rearparking area ofthe funeralhom e. He
walked outand viewed the license plate.ltwas a Florida license plate and he believed itcontained the
characters W 37.During the investigation,surveillance video was reviewed from area businesses.Video
surveillance showsawhite four-doorsedan entering the rearparking lotofLorne and SonsFuneralHom e
justpriortotherobbery,then exitingthefuneralhomeparkingjustafterthetimeoftherobbely. Separate
surveillancevideofrom anearbybusinessshowsthesubjectwalkingfrom thisvehicletowardthebankand
then from the direction ofthe bank back to this vehicle afterthe robbery. A surveillance photograph of
thewhite four-doorsedanwasexamined by 1aw enforcem entand wasbelieved to be a2003to2008M azda
6 with distinctchrome rimsand centerpillarinserts.
On February l7,20l8,atapproximately 1:47pm ,an unidentified blackm aleentered Chase
bank located at5955 SE FederalH ighw ay,Stuart Florida,approached the bank teller and presented a
dem and note. The demand note referred to having a gun and wanting hundreds. The UNSUB was
wearing a plaid shilt bluejeans,baseballhatand glasses. He received $2,600 in US currency. The
subjectfledthebankandwalkedtowardsBeall'sOutletlocatedonthenortheastareaoftheshoppingplaza.
During the investigation surveillance video was reviewed from area businesses. Approxim ately t'
w enty
2
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minutespriorto the robbery,agold vehiclewasseen parking in thevery north sideoftheplaza facingCove

Road. The vehicle leftapproximately fourorfive minutes after the robbery. The subjectwas seen
walkingtowardsthisareabythebank em ployee. Asthe vehiclepassed therearofthe Publix Superm arket,
itappeared on surveillance video. Atthetim e ofthe robbery,the FederalDepositInsurance Com oration
insured depositsatChase bank.
9. A photograph ofthe gold vehicle was exam ined by law enforcementand wasbelieved to
be 1997 to 2001 LexusES300. Law enforcementconducted a database search forblack m ales in Palm
Beach County owning a 1997 to 2001 gold Lexus ES300. ltwas discovered thatRODRICK JONES
owned a gold 1999 LexusES300 fourdoor. A query ofJON ES'Facebook profile showed a gold Lexus
with the same rim sasthe onesin the surveillance video.
10. Departm entofM otorVehiclesrevealed thatJON ES istheregistered ownerofa 1999 gold
LexusES300,fourdoor,V1N JT8BF28G 1X0161275,bearing Florida license plate Y I9GJP.
A physicalsurveillance was conducted around JONES'residence. A gold LexusES300
bearing Florida license plate Y I9GJP was observed in a parking space ofhis apartm entcomplex. The
vehicle hasa stickerin therightrearpassenger'sdoorw indow . The vehicle from the Publix surveillance
video ofthe day ofthe robbery haswhatappearsto bethe sam e stickerin the same location.
Departm entofM otor Vehiclesalso revealed that JONES was the registered ownerofa
2004 white M azda 6,fourdoor,Vm IYVFP8OC 145N33735,bearing Florida license plate Y79LW Y.On
April6,20l8,titleto therespective vehicle wastransferred to D.A .,who residesin Delray Beach.Records
revealed thenew Floridalicense plate associated w ith the white M azda 6 isFloridatag Z57lSZ.
A physicalsurveillance wasconducted in Delray Beach and the 2004 white M azda6,four
door,sedan was observed parked outside the address associated with the registered owner ofthe vehicle
(D.A.)bearingFloridalicenseplateZ57ISZ.Therespectivevehiclehadthesamedistinctchromerimsand
centerpillarasdepicted from the sulweillance video from the June 22,2017 robbery.
l4. On Augustl7,20l8,investigatorsexecuted an authorized search warrantissued outofthe
Southern DistrictofFlorida,at553 CypressDrive,Lake Park,FL 33403,theresidence ofJONES.During
the search, the following cellular telephones w ere seized'
, a white Sam sung Galaxy Note 4 cellular
telephone,bearing internationalmobile equipmentidentitication (1M El)#354594/06/448869/9,
.a black
Sam sung cellular telephone,bearing IM EI#355604/08/149105/2,
'and a white Samsung Galaxy Note 4
cellulartelephone,bearing17EC//256691519004721014 (TARGET PHONE),includingany S1M cardsor
m emory cards contained therein.The TARGET PHON E w as seized from the nightstand in JON ES'
bedroom .Additionally,the 1999 gold LexusES300,fourdoor,Vm JT8BF28G lX0l6l275,w ith the same
distinctrimswasseized.
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A subsequent search warrant for the respective cellular devices was issued out of the
Southern Districtof Florida.A forensic analysis revealed thatthe TA RGET PHONE,a white Sam sung
Galaxy N ote 4 cellulartelephone,bearing 13EC//256691519004721014,was assigned telephone number
561-670-3289,which wasoperated by SprintCorporation.
16. Based on a forensic review oftheTARGET PHON E,on April14,2016 atapproxim ately
l8:40 UTC (2:40pm EST)therewerethree(3)Google Earth imagesthatwerecaptured on theTARGET
PHON E,which contained satellite im ages ofthe area nearthe Chase Bank located at525 N E 7th Street,
Delray Beach.Two (2)oftheimageswereaerialsatelliteimagesneartheLorneandSonsFuneralHome,
which is located eastofthe Chase Bank acrossthe street.The third photograph isan aerialsatellite im age
ofFederalHighway,justnorthofGeorgeBush Blvdandnorth oftheChaseBank.Asnoted in paragraph
4,Chase Bank locatcd at525 NE 7thStreet, Delray Beach,Florida was robbed atapproxim ately 3:50pm,
which wasapproximately one hourand ten m inutes afterthe screen shotscapturing aerialsatellite images
on the TARGET PHON E.The bank robbery suspecttled thebank on foot,traveled eastbound through the
parking.lotofLorne and SonsFuneralHom e.
l7. As noted in paragraph 6,the Chase Bank located at 525 N E 7th Street, Delray Beach,
Florida,wasrobbed again on June 22,2017,a day afterthe TARGET PHON E had conducted numerous
internetsearchesforChase Banks.Thisw asthe second tim e thisbranch wasrobbed,and the suspecttled
thescenetowardstheLorfleand SonsFuneralHome.lnvestigatorsobtained surveillancevideofrom nearby
businesses capturing a white,four-door,M azda 6 w ith distinctchrome rim sand centerpillar,entering the
Lorneand SonsFuneralHomeparking lotjustpriortotherobberyandexitingtheparking 1otshortly after
therobbery. The location ofwherethevehiclewasparked isconsistentwith the satellite imagesfound on
theTARGET PHONE,w hich were captured approxim ately an hourpriorto the firsttim e thisbranch was
robbed.
l8. Pursuantto a search warrant issued outofthe Southern DistrictofFlorida forJONES'
Facebook account,recordsrevealed a photograph ofthe same whiteM azda 6 w ith chrome rim sand center
pillaron JON ES'Facebook account.In addition,DepartmentofM otorVehicle recordsrevealed JONES
wastheregistered ownerofa2004whiteM azda6.TheFacebook search warrantalso revealed aphotograph
ofJONES w earing agray New York Yankeesbaseballhat,which issimilartothe baseballhatseen in bank
sulweillancephotographsfrom the robbery.
As noted in paragraph 5,the Chase Bank located at5955 SE FederalHighway,Stuarq
Florida,w as robbed on M ay 19,2016,at approximately 3:58pm .Based on a review of the forensic
exam ination ofthe TARGET PHONE,an image from Google Eal'
th was captured on M ay l9,2016 at
approximately l5:30 UTC (11:30am EST).Therespectiveimagewasanaerialsatelliteview ofSE Cove
4
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Road in Stuart,Florida.lnvestigators confirmed thatthe respective branch was within the satellite view
captured on the TARGET PHON E.This im age was captured approximately 4.5 hours prior to the bank
robbery.
20. This bank was robbed again on February l7,20l8,at approxim ately l:47pm, by an
individual investigators believe to be the sam e person.As noted in paragraph 8,approxim ately t'wenty
minutespriorto therobbery,agold vehicle wasseen parking in thevery north sideoftheplazafacing Cove
Road. The vehicle leftapproximately fouror five minutes afterthe robbery. The subjectwas seen
w alking towardsthisareaby thebank em ployee. Asthevehicle passedtherearofthePublix Superm arket,
itappeared on surveillance video. Based on a comparison ofthevarioussurveillance photographsand/or
video oftheGold Lexus,investigatorsbelievethisisthesam eLexusES300 thatwasseized pursuantto the
search warrantatJON ES'residence on August 17,2018.
2l. Based on a review ofthe forensicexam ination ofthe TARGET PHONE and based on the
surveillance photographsand video from the fourbank robberies,itappearsthe same person comm itted
each ofthedescribed robberies. Thisbeliefisfounded upon variousevidencediscovered onthe TARGET
PHONE linking the TARGET PHON E to the robberies as outlined above.In addition, based on the
similaritiesin the physicaldescription ofthe bank robbergiven by witnessesand contirm ed through bank
surveillancephotographs,asto each oftherobberies,sim ilaritiesinthe clothing w orn by therobberin each
robbely (including the baseball hat) and similarities in the method of each robbery's commission,
investigatorsbelieve the sam e person comm itted each ofthe robberiesdescribed above.
22. Based upon the foregoing,lrespectfully subm itthatthere isprobablecause to believethat
RODRICK DOM ONIQUE JONES,by threatofforce and violenceand intimidation,did take,items of
valuebelongingtotheabovenamedbank,inviolationofTitlel8,United StatesCode,Section2113(a)and
(d).
FURTHER YOURAFFIANTSAYETHNAUGHT.f z' ' '
y
' .e
y
.. ,
. ''- '.- .
*

S/A ANIEL J.SZCZEPAN SKI,

FederalBureau oflnvestigation

Sworn to meand subscribed beforemethi y ofJanuary , 9 atW estPalm Beach,

Florida. x

UCE REINH RT
United StatesM agistrateJudge
Case 9:19-mj-08013-BER Document 1 Entered on FLSD Docket 01/29/2019 Page 7 of 7

UN ITED STA TE S D ISTR ICT CO UR T

SO U TH ER N D ISTR IC T O F FLO RID A

PEN A LTY SH EET

C ase N o: 19-8013-BER

D efendant'sN am e:R O D R ICK D .JO NE S

COUN T VIOLATION U.S.CO DE M AX.PENALTY

I BankRobbery l8:21l3(a)and(d) 25years

SR:5years
$250,000 fine
$100 specialassessm ent