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Case: 1:19-cr-00268 Document #: 19 Filed: 06/20/19 Page 1 of 6 PageID #:51

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UNITED STATES DISTRICT COURT
THCIMASG. BRUTOhI
NORTHERN DISTRICT OF ILLINOIS
CLERK, I,.,.S, DISTRICT COURT
EASTERN DIVISION

UNITED STATES OF AMERICA

No \4cr>Vf
V.
Violations: Title 18, United States
MARIO BANKS, JR. Code, Sections 1951(a) and
e2a(c)(1)(A)

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COUNT ONE C{JIUS{INGS

The SPECIAL MAY 2019 GRAND JURY charges:

On or about November 4, 2018, at Lincolnwood, in the Northern District of

Illinois, Eastern Division,

MARIO BANKS, JR.,

defendant herein, did obstruct, delay and affect "commerce," and the movement of

articles and commodities in commerce, by "robbery," as defined in Title 18, United

States Code, Section 1951(b), in that the defendant did unlawfully take and obtain

United States currency from the person and in the presence of an employee of Bucky's

Express Mobil, located at 640L North Cicero Avenue, Lincolnwood, Illinois, against

the employee's will, by means of actual and threatened force, and fear of injury to

that employee;

In violation of Title 18, United States Code, Section 1951(a).

 Case: 1:19-cr-00268 Document #: 19 Filed: 06/20/19 Page 2 of 6 PageID #:52

COUNT TWO

The SPECIAL MAY 2019 GRAND JURY further charges:

On or about November 4, 2018, at Lincolnwood, in the Northern District of

Illinois, Eastern Division,

MARIO BANKS, JR.,

defendant herein, did use, carty, and brandish a firearm during and in relation to a

crime of violence for which he may be prosecuted in a court of the United States,

namely, a robbery affecting commerce in violation of Title 18, United States Code,

Section 1951(a), as charged in Count One of this Indictment;

In violation of Title 18, United States Code, Section 924(c)(1)(A).

 Case: 1:19-cr-00268 Document #: 19 Filed: 06/20/19 Page 3 of 6 PageID #:53

COUNT THREE

The SPECIAL MAY 2019 GRAND JURY further charges:

On or about February 16, 2019, at Skokie, in the Northern District of Illinois,

Eastern Division,

MARIO BANKS, JR.,

defendant herein, did obstruct, delay and affect "commerce," and the movement of

articles and commodities in commerce, by "robbery," as defined in Title 18, United

States Code, Section 1951&), in that the defendant did unlawfully take and obtain

United States currency from the person and in the presence of an employee of Shell

Oil, located at 3301 Howard Street, Skokie, Illinois, against the employee's will, by

means of actual and threatened force, and fear of injury to that employee;

In violation of Title 18, United States Code, Section 1951(a).

 Case: 1:19-cr-00268 Document #: 19 Filed: 06/20/19 Page 4 of 6 PageID #:54

COUNT FOUR

The SPECIAL MAY 2079 GRAND JURY further charges:

On or about February 16, 2019, at Skokie, in the Northern District of Illinois,

Eastern Division,

MARIO BANKS, JR.,

defendant herein, did use, carry; and brandish a firearm during and in relation to a

crime of violence for which he may be prosecuted in a court of the United States,

namely, a robbery affecting commerce in violation of Title 18, United States Code,

Section 1951(a), as charged in Count Three of this Indictment;

In violation of Title 18, United States Code, Section 924(c)(1)(A).

4
 Case: 1:19-cr-00268 Document #: 19 Filed: 06/20/19 Page 5 of 6 PageID #:55

COUNT FIVE

The SPECIAL MAY 20Lg GRAND JURY further charges:

On or about February 19, 20L9, at Lincolnwood, in the Northern District of

Illinois, Eastern Division,

MARIO BANKS, JR.,

defendant herein, did obstruct, delay and affect "commerce," and the movement of

articles and commodities in commerce, by "robbery," as defined in Title 18, United

States Code, Section 1951(b), in that the defendant did unlawfully take and obtain

United States currency from the person and in the presence of an employee of Bucky's

Express Mobil, located at 6401North Cicero Avenue, Lincolnwood, Illinois, against

the employee's will, by means of actual and threatened force, and fear of injury to

that employee;

In violation of Title 18, United States Code, Section 1951(a).

 Case: 1:19-cr-00268 Document #: 19 Filed: 06/20/19 Page 6 of 6 PageID #:56

COUNT SD(

The SPECIAL MAY 2079 GRAND JURY further charges:

On or about February 19, 2019, at Lincolnwood, in the Northern District of

Illinois, Eastern Division,

MARIO BANKS, JR.,

defendant herein, did use, carry and brandish a fi"rearm during and in relation to a

crime of violence for which he may be prosecuted in a court of the United States,

namely, a robbery affecting commerce in violation of Title 18, United States Code,

Section 1951(a), as charged in Count Five of this Indictment;

In violation of Title 18, United States Code, Section 924(c)(1XA).

A TRUE BILL:

FOREPERSON

UNITED STATES ATTORNEY