IN THE UNITED STATES DISTRICT COURT FOR THE

EASTERN DISTRICT OF VIRGINIA

Alexandria Division

UNITED STATES OF AMERICA

v.

LEONARDO DARNELL ZANDERS,

CLYDE AUSTIN GRAY, JR.,

LENNIER MCLEOD,

WENONA LATRICE WHITE,

SYDNEY ANTHONY CHARLES,

SHONYA MICHELLE YOUNG,

DARRYL EARL PRICE,

SYLVESTER VAUGHN,

GEORGE LEE REID, and

CLAIRE BARKER,

Defendants.

Case No: 1:09^-5^3

AFFIDAVIT IN SUPPORT OF CRIMINAL

COMPLAINT AND ARREST WARRANTS

Your affiant, William J. Aiello, being duly sworn, deposes and states as follows:

INTRODUCTION

1. I am employed as a postal inspector of the United States Postal Inspection Service

and have been so employed since February 2007. I am currently assigned to the External

Crimes Unit at the Richmond Field Office in Richmond, Virginia. I also serve on the

Metro-Richmond Identity Theft Task Force. In my capacity as a postal inspector, I

investigate suspected violations of federal criminal statutes involving mail theft, identity

theft, and financial institution fraud. I am also responsible for conducting complex

investigations that include extensive document review and analysis; witness interviews;

and the preparation, presentation, and service of criminal complaints, arrest warrants, and

search warrants. Before I began my career as a postal inspector, I was a police officer

with the Henrico County Police Department in Richmond, Virginia, where I investigated

various financial and identity theft crimes.

2. This affidavit is based upon my conversations with other law enforcement agents

and sources, interviews, and my examination of various transcripts, reports, and other

records. Any facts and opinions cited in this affidavit, that were seen, heard, or

concluded by a law enforcement officer other than your affiant, have been related to your

affiant by the officer who had personal knowledge thereof. All information attributed to

other officers has been related to your affiant, and I believe it to be factual and truthful.

This affidavit does not include all the facts that have been learned during the course of

the investigation, but sets forth only the facts that your affiant believes are necessary to

establish probable cause.

3. This affidavit is submitted in support of a criminal complaint and arrest warrants

for Leonardo Darnell Zanders, Clyde Austin Gray Jr., Lennier McLeod, Wenona Latrice

White, Sydney Anthony Charles, Shonya Michelle Young, Darryl Earl Price, Sylvester

Vaughn, George Lee Reid, and Claire Barker. Based on the information detailed below,

your affiant submits that there is probable cause to believe the above listed individuals

conspired knowingly, willfully, and unlawfully to execute a scheme and artifice to obtain

moneys, funds, and credits under the custody or control of a financial institution by

means of false and fraudulent pretenses, representations, and promises in violation of

Title 18, United States Code, Sections 1344 and 1349 (Conspiracy to Commit Bank

Fraud).

THE ONGOING CONSPIRACY

4. Beginning in or about January 2007 and continuing to the present, the proposed

defendants and other known and unknown co-conspirators devised a scheme to defraud

individuals and financial institutions. The basis of the scheme was to use stolen personal

identifying information, bank and bank record information, personal checks, and other

access devices belonging to individual victims, to impersonate those victims at various

bank branches throughout the country. The basis of the scheme was learned from

individuals arrested for similar crimes who have worked with the co-conspirators in the

past as well as documentary and photographic evidence. The arrested individuals

provided information to law enforcement officers during interviews.

5. The co-conspirators would employ various techniques for obtaining victims' bank

account information, personal checks, credit cards, driver's licenses and other identifying

documents. The co-conspirators have used techniques such as pick pocket theft, mail

theft, theft from businesses and corrupt employees at professional offices to obtain these

documents. The co-conspirators in this case would then make or obtain counterfeit

driver's licenses and/or counterfeit military identification cards. The counterfeit licenses

and identification cards would contain the name of a victim and the photograph of a co-

conspirator. The co-conspirators would then create packets containing the checks and

other identifying documents and bank account information along with the fraudulent

identification documents with the co-conspirator's picture on them. These packets would

then be sent via U.S. Postal Service Express Mail, Federal Express overnight delivery,

and UPS overnight delivery to various locations throughout the United States. The

packages were sent either to a hotel or to another shipping facility address. In most cases

the name of the sender on the packages was the same as the name of the addressee.

6. The investigation revealed that once the co-conspirators retrieved the packages

that had been sent to various cities within the United States, they entered financial

institutions and committed bank fraud. This bank fraud would be accomplished by using

a counterfeit driver's license or military identification card along with a stolen debit or

credit card as forms of identification. The co-conspirators would then conduct a split

deposit transaction. The split deposit transaction is a transaction where the co-

conspirator first makes a deposit into one victim's account by writing a personal check to

that victim account from another identity theft victim's bank account. The purpose of

this deposit is to falsely inflate the victim's account balance and/or identify the specific

account number. This deposit would then be followed by a series of counter withdrawals,

check-cashing, or electronic withdrawals. In each case of split deposit transactions there

were multiple victims. Once the co-conspirators were successful in obtaining funds from

a target financial institution, they would perform multiple fraudulent transactions at other

branches of that financial institution in the same geographical area.

7. In each case of split deposit transactions the co-conspirators entered the financial

institution's branches with counterfeit identity documents, stolen checks, and other access

devices belonging to victims from the Washington, D.C area or the Chicago, Illinois area.

LEONARDO DARNELL ZANDERS

8. During the course of the investigation it was discovered that on September 16,

2007, a Federal Express (hereafter referred to as "FedEx") shipping facility located at

17170 Westview Road, South Holland, Illinois, refused to send three packages that

Zanders was attempting to send. The clerk at the facility, later identified Zanders through

a photo lineup as the sender of the packages. The clerk refused to send the packages

because the sender violated FedEx corporate policies and procedures by using the

shipping facility address as the sender address on one of the packages. Zanders

immediately left the facility leaving the packages behind. A supervisor for FedEx opened

the packages in accordance with its corporate policies and procedures prior to contacting

FedEx security and law enforcement. The packages contained stolen personal checks,

identifications, bank cards, credit cards, and other similar documents. The packages also

contained counterfeit military identification cards and driver's licenses.

9. The two packages were being sent by Zanders to Zanders at a La Quinta Inn in

Jacksonville, Florida. The packages contained stolen identification and other bank

related items belonging to fourteen victims from the Virginia and Washington, D.C.,

area. Identifiers and bank account information of one of the 14 victims was later

determined to be compromised by Confidential Informant 1 ("CI-1"). The third package

was sent supposedly from "Clyde Gray" using the FedEx facility address to "Clyde

Gray" at another FedEx shipping facility located at 1501 Eckington Place, N.E.,

Washington, D.C. Clyde Gray was identified as Clyde Austin Gray, Jr., a known co-

conspirator in this bank fraud scheme. The package contained five stolen identifications

and other bank-related items belonging to victims from Virginia and the Washington,

D.C. area. Along with the stolen personal identifiers referenced above were seven

counterfeit driver's licenses or military identifications in the names of each of the five

victims. Of the seven counterfeit driver's licenses or military identifications, two

contained photos of a person your affiant has positively identified from an arrest photo as

Wenona White.

10. Based on evidence gathered during the investigation, including the information

provided by CM, you affiant obtained and executed a federal search warrant at the

residence of Zanders on February 4, 2009. During this search, agents recovered several

photocopied personal checks written to AmerAssist, a business located in Columbus,

Ohio, and provided to Zanders by Confidential Informant 2 ("CI-2"). Also located

during the search was a photocopied personal check written to a second business, located

in the Washington, D.C. area. Agents recovered driver's licenses, credit and debit cards,

personal checks, and other personal identifying information belonging to approximately

36 victims from Virginia, Maryland, Washington, D.C, North Carolina, California,

Florida, Illinois, Wisconsin, Georgia, and Arizona. The licenses, credit cards, and checks

were rubber banded together in "packets" similar to those found in the FedEx packages

recovered in September 2007. Also found during the search were small identification-

sized pictures of known co-conspirator Teresa Johnson, who was arrested with Zanders in

Illinois in January 2009 for a pick pocket theft. Also recovered were photographs of two

unknown co-conspirators as well as equipment and materials used for making counterfeit

driver's licenses and credit cards.

CLYDE AUSTIN GRAY. JR.

11. In December 2008, CM provided information to Special Agent Ryan Petrasek of

the U.S. Secret Service regarding the ongoing investigation into the above-described

conspiracy. CM has intimate knowledge of the means by which the co-conspirators are

obtaining stolen bank account information and personal identifiers of the victims in this

case. CI-1 stated that during approximately the last year, it had provided somewhere

between ten and 20 sets of personal identifiers and bank account information to a person

known as "Clyde" who lives in Waldorf, Maryland. CI-1 further stated it had met with

"Clyde" on at least 20 occasions over the past year to exchange this stolen information.

CI-1 was shown a photo lineup containing a picture of Clyde Austin Gray, Jr. by Special

Agent Petrasek. It positively identified the picture of Clyde Austin Gray, Jr. as "Clyde"

the person to whom it had provided victim account and identifier information. CI-1

stated Gray would pay it between $200 and $500 each time it provided compromised

personal identifiers and bank account information to Gray. It further stated it had met

Gray on several occasions in Waldorf, Maryland, to exchange money and information.

CI-1 stated that Gray resides in Waldorf, Maryland. During the course of the

investigation to date, it was determined that CI-1 gave Gray the personal identifiers and

bank account information of 37 victims. The 37 victims, as well as their financial

institutions, have incurred a fraud loss of more than $385,000 by way of split deposit

transactions in multiple states.

12. Based on the evidence gathered during the investigation, including the

information provided by CI-1, Special Agent Petrasek obtained and executed a federal

search warrant at Gray's residence on February 4, 2009. During this search, agents

recovered several photocopied personal checks written to a business located in

Washington, D.C. and provided to Gray by CI-1. Also located during the search were 13

photocopied personal checks written to the Combined Federal Campaign for the National

Capital Area located in Washington, D.C. Agents recovered driver's licenses, credit and

debit cards, personal checks, and other personal identifying information belonging to

approximately 85 victims from Virginia, Maryland, Washington, D.C., North Carolina,

California, Florida, Ohio, Illinois, Texas, and Tennessee. The licenses, credit cards and

checks were rubber banded together in packets similar to those found in the FedEx

packages recovered in September 2007, Also found during the search were small

identification-sized pictures of known co-conspirators George Reid, Confidential

Informant 3 ("CI-3")> Shonya Young, and Darryl Price as well as several unknown co-

conspirators.

13. Of the 85 victims whose identifying information was found during the search of

Gray's residence, four were previously identified as being victims of split deposit

transactions. The personal checks and identifiers of a victim herein referred to as "R.S."

were found in Gray's residence. Those checks drawn on the Harris Bank account of R.S.

were cashed and deposited using the Wachovia Bank account belonging to a victim

herein referred to as "B.A." in Raleigh, North Carolina. Your affiant positively

identified, from bank surveillance photos, Wenona White as the person who entered

Wachovia Bank and conducted those split deposits. Victim R.S. was the victim of a pick

pocket theft in Palatine, Illinois, and victim B.A. was the victim of a pick pocket theft in

Fairfax, Virginia.

14. Wachovia is a financial institution whose deposits are insured by the Federal

Deposit Insurance Corporation.

LENNIER MCLEOD

15. The investigation revealed that on March 14, 2007, McLeod entered the Bank of

America branch located at 4501 Tamiami Trail Lane, Naples, Florida. McLeod

conducted a bank fraud scheme by impersonating a victim herein referred to as "C.C."

8

Based on the investigation it has been corroborated that C.C.'s personal check was found

in the drawer of a Combined Federal Campaign employee. C.C. stated that a check

#2324 drawn on Bank of America account belonging to C.C, dated November 16, 2006,

was the only check it had written and mailed that year that was not cashed. McLeod

deposited check #7250 in the amount of $2,900 drawn on the First Union Bank account

of a victim herein referred to as "P.S." made payable to C.C. McLeod then cashed a

counter check in the amount of $6,200 drawn on the account of C.C. Consequently Bank

of America suffered the loss of the $6,200. Surveillance photos of the transaction were

captured by Bank of America, and McLeod was positively identified, based on an arrest

photo, by your affiant as the person purporting to be C.C.

16. During the same period of time, subpoenaed records show that Gray sent a

Western Union wire transfer in the amount of $700 from Florida to the Combined Federal

Campaign employee whose desk the check belonging to C.C. was recovered from.

17. Bank of America and First Union Bank are financial institutions whose deposits

are insured by the Federal Deposit Insurance Corporation.

WENONA LATRICE WHITE

18. The investigation revealed that on October, 16, 2007, White entered the Bank of

America branch located at 1055 Dunn Avenue, Jacksonville, Florida. White performed a

bank fraud scheme by impersonating a victim herein referred to as "C.R.C." Based on

the investigation it has been corroborated that CI-1 compromised C.R.C.'s personal and

bank account information and admitted to giving it to Gray. White used a counterfeit

Washington, D.C. driver's license in the name of C.R.C. with C.R.C.'s true name, date of

birth, and address. White then cashed check number 349 in the amount of $4,500 drawn

on the closed First Guaranty Bank account of a victim herein referred to as "W.H."

(deceased), made payable to C.R.C. Consequently, Bank of America suffered a loss of

the $4,500. Surveillance photos of the transaction were captured by Bank of America,

and White was positively identified, based on an arrest photo, by your affiant as the

person purporting to be C.R.C.

19. On October, 16, 2007, Zanders wired via Western Union a money transfer of

$2,800 from Jacksonville, Florida to Gray in Waldorf, Maryland.

20. On October, 17,2007, White entered the Wachovia Bank branch located at 1031

Atlantic Beach Boulevard, Atlantic Beach, Florida. White engaged in a bank fraud

scheme by impersonating a victim herein referred to as "S.V." S.V. had reported her

identity stolen by a pick pocket to the Alexandria, Virginia, Police Department on

September 21, 2007. White used a counterfeit Virginia driver's license in the name of

S.V. with S.V.'s true name, date of birth, and address. White then deposited check

number 348 in the amount of $3,200 drawn on the closed First Guaranty Bank account of

W.H., made payable to S.V. White then cashed a counter check drawn on the account of

S.V. in the amount of $3,800. Consequently, Wachovia suffered a loss of the $3,800.

Surveillance photos of the transaction were captured by Wachovia Bank, and White was

positively identified, based on an arrest photo, by your affiant as the person purporting to

be S.V.

21. Wachovia, Bank of America and First Guaranty are financial institutions whose

deposits are insured by the Federal Deposit Insurance Corporation.

22. In March 2009, CI-2 provided information to Special Agent Petrasek and your

affiant regarding this investigation. CI-2 has intimate knowledge of the means by which

10

the co-conspirators are obtaining stolen bank account and personal identifiers of the

victims in this case. CI-2 stated it had provided, during a six month time period in 2008,

an unknown number of personal identifiers and bank account information to Leonardo

Zanders. CI-2 admitted it had provided this information to Zanders by telephone every

week for several months. CI-2 further stated it had met Zanders through Wenona White.

CI-2 was shown a photo lineup containing a picture of Leonardo Zanders by Special

Agent Petrasek. CI-2 positively identified the picture of Leonardo Zanders as the person

to whom it had provided victim account and identifier information. CI-2 stated Zanders

had agreed to pay it between $200 and $500 for each set of compromised personal

identifiers and bank account information. CI-2 admitted to receiving Federal Express and

U.S. Mail packages from Zanders periodically as well as receiving several Western

Union Wire Transfers from Zanders. CI-2 further stated it was present at several banks in

Ohio and Pennsylvania when Zanders and White used stolen information to conduct split

deposit transactions. CI-2 was approached by Zanders and provided with a counterfeit

North Carolina driver's license with CI-2's photo and the true name, date of birth and

address of a victim herein referred to as "N.C." as well as N.C.'s true social security card.

These identification documents were provided to CI-2 by Zanders for use in conducting

split deposit transactions. CI-2 provided those identifications to Special Agent Petrasek.

During the course of the investigation to date, the number of victims whose information

was compromised by CI-2 has been determined to be 15.

SYDNEY ANTHONY CHARLES

23. In April 2009, CI-3 provided information to Special Agent Petrasek regarding this

investigation. CI-3 stated it had received stolen personal identifying documents, bank

11

account information, and counterfeit identifications with its picture on it directly from

Sydney Charles. CI-3 was shown a photo lineup with Sydney Charles's picture in it by

Special Agent Petrasek. CI-3 positively identified Charles as the person who was

providing CI-3 with the stolen and counterfeit items that CI-3 then used to conduct split

deposit transactions in several states throughout the United States. CI-3 stated it had

worked directly with another known co-conspirator, Shonya Young, in conducting the

split deposit transactions throughout the west coast. CI-3 stated that Young was the

girlfriend of Charles and had introduced them and travelled with them all over the

country conducting this fraud. CI-3 admitted to conducting split deposit transactions

with Young and Charles in at least 13 different cities in California, Nevada and

Washington. CI-3 stated Charles obtained the stolen identifications and bank information

directly from a guy name "Big Head." The nickname "Big Head" has been verified by

law enforcement as the nickname used for Gray. CI-3 further stated it had received

Federal Express packages directly from "Big Head" in Washington, D.C., containing

stolen identifications, counterfeit identifications with CI-3's picture on them and stolen

credit cards and checks. CI-3 stated the fraudulently obtained funds from the transactions

were split four ways. One quarter would go to each of Charles, CI-3, and Charles's

driver, known as Knight. The other one quarter would be sent via Western Union Money

Order to "Big Head" in Washington, D.C. CI-3 stated the last split deposit transaction it

conducted with Charles and Young was in the Seattle, Washington area in January 2009.

24. In January 2008, Federal Express Investigators in Maryland requested the

assistance of the Montgomery County Police Narcotics Unit because they had intercepted

what they believed to be a FedEx package containing narcotics. The package was sent

12

from San Francisco, California by "Anthony Harris" to a co-conspirator at his residence

in Maryland. Federal Express investigators, following Federal Express procedures and

protocol, opened the package. The package contained stolen personal checks,

photocopied personal checks, identifications, bank cards, credit cards and other similar

documents. The documents included counterfeit Virginia, Illinois and Maryland driver's

licenses with the victim's information and a picture of Charles on each one. The stolen

and counterfeit items were rubber banded together in packets very similar to the packets

found in the FedEx package recovered in Illinois in September 2007. There were four

packets that include a photocopied personal check written from those four victims to a

business in Washington, D.C. Based on the investigation, it has been corroborated that

CI-1 compromised the personal and bank information of all four of those victims and

admitted to providing the information to Gray. Also found in the FedEx package rubber

banded next to one of the counterfeit driver's licenses was a photocopied check written to

the Combined Federal Campaign for the National Capital Area in Washington, D.C. This

location was identified as a point of compromise.

SHONYA MICHELLE YOUNG

25. The investigation revealed that on November 13, 2008, Young entered the Bank

of America branch located at 4148 Monterey Highway, San Jose, California. Young

performed a bank fraud scheme by impersonating a victim herein referred to as "M.M."

Based on the investigation it has been corroborated that CI-1 compromised M.M.'s

personal and bank account information and admitted to giving it to Gray. Young used a

counterfeit District of Columbia driver's license in the name of M.M. with M.M.'s true

name, date of birth, and address. Young deposited check #470 in the amount of $4,866

13

drawn on the Wells Fargo Bank account of a victim herein referred to as "M.S." made

payable to M.M. M.S. reported being the victim of a pick pocket theft in Arizona.

Young then cashed a counter check drawn on the account of M.M. in the amount of

$4,800. On November 14, 2008, Young entered the Bank of America branch located at

4120 San Pablo Avenue, Emeryville, California. Young performed a bank fraud scheme

by impersonating M.M. Young deposited an Ace Cash Express Money Order in the

amount of $26 and check #5917 in the amount of $634 drawn on the US Bank account of

a victim herein referred to as "G.H.H." made payable to M.M. G.H.H. reported being the

victim of a pick pocket theft in Arizona.

26. On November 14, 2008, Young entered the Bank of America branch located at

2546 San Pablo Avenue, Berkley, California. Young deposited check #471 in the amount

of $247 drawn on the Wells Fargo account of M.S. made payable to M.M. Young then

entered the Berkley Main Banking Center and deposited an Ace Cash Express Money

Order in the amount of $26 made payable to M.M. Young then deposited check #5916 in

the amount of $6,351 drawn on the US Bank account of G.H.H. made payable M.M.

27. On November 17, 2008, Young entered the Bank of America branch located at

2905 Stevens Creek Boulevard, Santa Clara, California. Young deposited a Safeway

money order in the amount of $23 made payable to M.M. Young then cashed a counter

check drawn on the account of M.M. in the amount of $6,000. Consequently, Bank of

America suffered the loss of the $10,800. Surveillance photos of the transactions were

captured by Bank of America, and Young was positively identified, based on an arrest

photo, by your affiant as the person purporting to be M.M.

14

28. Bank of America, Wells Fargo and US Bank are financial institutions whose

deposits are insured by the Federal Deposit Insurance Corporation.

DARRYL EARL PRICE

29. The investigation revealed that on February 21, 2008, Price entered the Bank of

America branch located in Orlando, Florida. Price attempted to perform a bank fraud

scheme by impersonating a victim herein referred to as "W.T." Based on the

investigation it has been corroborated that CI-1 compromised W.T.'s personal and bank

account information and admitted to giving it to Gray. Price used a counterfeit Virginia

driver's license and a counterfeit military identification in the name of W.T. with W.T.'s

true name, date of birth, and address. Price then attempted to cash check number 976 in

the amount of $4800 drawn on the Chase Bank account of a victim herein referred to as

"E.G." made payable to W.T. E.G. was the victim of a pick pocket in Wilmette, Illinois.

The teller refused the transaction and seized the identifications and the Chase check. The

items were submitted to the US Postal Inspection Service Forensic Laboratory for finger

print analysis and development. The laboratory obtained one viable latent print and

submitted it to AFIS (Automated Fingerprint Identification System). A match was

confirmed that the latent print belonged to "Anthony Reynolds" with the FBI number

532125XA3. Anthony Reynolds is an alias for Price, and that FBI number belongs to

Darryl Earl Price. Surveillance photos of the transaction were captured by Bank of

America, and Price was positively identified, based on an arrest photo, by your affiant as

the person posing as W.T.

30. On May 6, 2008, Price entered the SunTrust Bank branch located at 2250 M

Street, N.W., Washington, D.C. Price performed a bank fraud scheme by impersonating

15

a victim herein referred to as "H.G." Based on the investigation it has been corroborated

that CI-1 compromised H.G.'s personal and bank information and admitted to giving it to

Gray. Price used a counterfeit Maryland driver's license in the name of H.G. with H.G.'s

true name, date of birth, and address. Price then deposited check number 5687 in the

amount of $2,400 drawn on the PNC Bank account of a victim herein referred to as

"G.H.C." made payable to H.G. G.H.C. was the victim of a pick pocket in Bethesda,

Maryland. Price then cashed check number 9548 drawn on the BB & T Bank account of

a victim herein referred to as "D.T." in the amount of $3,500. D.T. was the victim of a

pick pocket in Alexandria, Virginia. Price then entered the SunTrust Bank branch

located at 1150 Connecticut Avenue, N.W., Washington, D.C. and deposited check

number 9545 in the amount of $1,000 drawn on the BB & T Bank account of D.T. made

payable to H.G. Price then cashed check number 276 in the amount of $4,300 drawn on

the Provident Bank account of a victim herein referred to as "G.C." made payable to H.G.

G.C. was the victim of a pick pocket in Fairfield, Pennsylvania. Consequently, SunTrust

suffered the loss of the $7,800. Surveillance photos of the transactions were captured by

SunTrust, and Price was positively identified, based on an arrest photo, by your affiant as

the person purporting to be H.G.

31. Bank of America, SunTrust, PNC, BB & T, Chase and Provident Bank are

financial institutions whose deposits are insured by the Federal Deposit Insurance

Corporation.

SYLVESTER VAUGHN

32. The investigation revealed that on March 6, 2008, Vaughn entered the SunTrust

branch located at 2250 M Street, N.W., Washington, D.C. Vaughn performed a bank

16

fraud scheme by impersonating a victim herein referred to as "M.G." Based on the

investigation it has been corroborated that CI-1 compromised M.G.'s personal and bank

information and admitted to giving it to Gray. Vaughn used a counterfeit Maryland

driver's license in the name of M.G. with M.G.'s true name, date of birth, and address.

Vaughn then deposited a U.S. Postal Money Order in the amount of $50 into the

SunTrust account of M.G. made payable to M.G. Vaughn then cashed check number

2448 drawn on the Bank of America account of a victim herein referred to as "J.B." in

the amount of $4,700 made payable to M.G. J.B. reported being the victim of a pick

pocket theft in Washington, D.C.

33. Vaughn then entered the SunTrust Bank branch located at 1150 Connecticut

Avenue, N. W., Washington, D.C. Vaughn conducted another split deposit transaction by

impersonating M.G. Vaughn deposit check number 1050 drawn on the Wachovia

account of a victim herein referred to as "K.H." for $1,500 made payable to M.G.

Vaughn then cashed check number 2449 drawn on the Bank of America account of J.B.

in the amount of $4,500 made payable to M.G.

34. Vaughn then entered the SunTrust branch located at the corner of 19th and K

streets, N.W., Washington, D.C. and attempted to deposit check number 216 drawn on

the Bank of America account of a victim herein referred to as "J.P." in the amount of

$1,000 made payable to M.G. J.P. reported being the victim of a pick pocket theft in

Washington, D.C. Vaughn then attempted to cash check number 1084 drawn on the

Chevy Chase Bank account of a victim herein referred to as "A.H." in the amount of

$4,900 made payable to M.G. A.H. reported being a victim of a pick pocket theft to the

Fairfax, Virginia Police Department on February 26, 2008. The attempts were

17

unsuccessful and the teller retained the checks and counterfeit identifications.

Consequently SunTrust suffered a loss of $9,200. Surveillance photos of the transactions

were captured by SunTrust, and Vaughn was positively identified, based on an arrest

photo, by your affiant as the person purporting to be M.G.

35. SunTrust, Bank of America, Wachovia and Chevy Chase Bank are financial

institutions whose deposits are insured by the Federal Deposit Insurance Corporation.

GEORGE LEE REID

36. The investigation revealed that on August 12,2008, Reid entered the Bank of

America branch located 6495 New Hampshire Avenue Hyattsville, Maryland. Reid

conducted a bank fraud scheme by impersonating a victim herein referred to as "K.N.".

K.N. reported being the victim of a pick pocket theft in Washington, D.C. Reid used a

counterfeit Maryland driver's license in the name of K.N. with K.N.'s true name, date of

birth, and address. Reid cashed a Wachovia Bank starter check number 91 in the amount

of $3,500 made payable to K.N.

37. August 13, 2008, Reid entered the Bank of America branch located at Landover

Hills in Hyattsville, Maryland. Reid performed a bank fraud scheme by impersonating

K.N. Reid deposited check number 1537 in the amount of $900 drawn on the SunTrust

Bank account of a victim herein referred to as "D.H." made payable to K.N. D.H.

reported being the victim of a pick pocket theft in Washington, D.C. Reid then cashed

two personal checks number 1221 and 1227 drawn on the Chevy Chase Bank account of

a victim herein referred to as "L.C." in the amount of $4,500 each. L.C. reported being

the victim of a pick pocket theft on the Orange Bus Line in Northern Virginia in August

2008. Reid then deposited check number 2789 in the amount of $900 drawn on the

18

Wachovia Bank account of a victim herein referred to as "B.B." made payable to K.N.

B.B. reported being the victim of a pick pocket theft in Washington, D.C. Consequently,

Bank of America suffered the loss of the $12,500. Surveillance photos of the transactions

were captured by Bank of America, and Reid was positively identified, based on an arrest

photo, by your affiant as the person purporting to be K.N.

38. On October 29,2008, Reid was charged in Washington D.C. Superior Court for

identity theft offenses stemming from the use of B.B. 's personal checks. Special Agent

Ryan Petrasek and D.C. Police Detective Vincent Tucci interviewed Reid. Reid

confessed to impersonating K.N. at a Bank of America branch in Landover Hills,

Maryland by depositing checks drawn on the Wachovia account of B.B. Reid stated he

had been conducting this type of bank fraud scheme since 2006 and has obtained as much

as $50,000 in one day. Reid further confessed to impersonating a victim herein referred

to as "M.W." at a SunTrust branch in Washington D.C., impersonating a victim herein

referred to as "G.I." at a Bank of America branch in Washington, D.C, and

impersonating a victim herein referred to as "J.T.H." at a PNC Bank branch in Maryland

between October 27 and October 28, 2008. Based on the investigation, it is has been

corroborated that CI-1 compromised the personal and bank information of M.W., G.I.,

and J.T.H and admitted to giving it to Gray.

39. Bank of America, SunTrust, PNC and Wachovia are financial institutions whose

deposits are insured by the Federal Deposit Insurance Corporation.

CLAIRE BARKER

40. The investigation revealed that on October 8, 2008, Barker entered the Wachovia

Bank located at 1001 Franklin Avenue, Garden City, New York and performed a bank

19

fraud scheme by impersonating a victim herein referred to as "E.S." Based on the

investigation, it has been corroborated that CI-1 compromised E.S.'s personal and bank

information and admitted to giving it to Gray. Barker used a counterfeit Virginia driver's

license in the name of E.S with E.S.'s true name, date of birth, and address. Barker then

cashed check number 229 in the amount of $5,500 drawn on the Austin Bank of Chicago

account of a victim herein referred to as "E.B." made payable to E.S. E.B. reported

having checks stolen out of her residence in Chicago, Illinois. Consequently, Wachovia

Bank suffered the loss of the $5,500. Surveillance photos of the transaction were captured

by Wachovia, and Barker was positively identified, based on an arrest photo, by your

affiant as the person purporting to be E.S.

41. On October 9, 2008, Barker entered the Wachovia Bank branch located at 355

Plandome Road, Manhasset, New York. Barker attempted to perform a bank fraud

scheme by impersonating E.S. Barker used a counterfeit Virginia driver's license in the

name of E.S. with E.S.'s true name, date of birth, and address. Barker then attempted to

cash check number 231 in the amount of $7,200 drawn on the Austin Bank of Chicago

account of E.B. made payable to E.S. The teller noticed that Barker matched a

photographic lookout of a suspect in a rash of identity thefts in the local area and

contacted the Nassau County, New York Police Department.

42. On October 9,2008, Barker was arrested in Manhasset, New York, shortly after

leaving the Wachovia Bank branch located at 355 Plandome Road for attempted identity

theft charges stemming from the use of E.S.'s personal identifiers. Detective Browne and

Detective Jankowski of the Nassau County Police Department conducted an interview of

Barker. Barker confessed to impersonating E.S. at Wachovia Bank located at 1001

20

Franklin Avenue, Garden City, New York by cashing checks drawn on the Wachovia

account of E.S. Barker admitted that she had conducted this type of bank fraud scheme

in the conspiracy under investigation in California, Florida, New York and Washington,

D.C. since 2006.

43. Wachovia and Austin Bank are financial institutions whose deposits are insured

by the Federal Deposit Insurance Corporation.

ACTS WITHIN THE EASTERN DISTRICT OF VIRGINIA

44. As part of the conspiracy, the co-conspirators obtained the personal identification

and bank account information of multiple victims by pick pocketing in various locations

within the Eastern District of Virginia. These acts of pick pocketing included: (1) that of

victim "B.A.," referred to in Paragraph 13, above, in Fairfax, Virginia, within the Eastern

District of Virginia, on or around May 25, 2007; (2) that of victim "S.V.," referred to in

paragraph 20, above, in Alexandria, Virginia, within the Eastern District of Virginia, on

or around September 21, 2007; (3) that of victim "D.T.," referred to in Paragraph 30,

above, in Alexandria, Virginia, within the Eastern District of Virginia, in or around May

2008; (4) that of victim "A.H.," referred to in Paragraph 34, above, in Fairfax, Virginia,

within the Eastern District of Virginia, on or around February 26, 2008; and (5) that of

victim "L.C.," referred to in Paragraph 37, above, in Northern Virginia, within the

Eastern District of Virginia, in or around August 2008.

CONCLUSION

45. Based on the foregoing, your affiant respectfully submits that there is probable

cause to believe that Leonardo Darnell Zanders, Clyde Austin Gray Jr., Lennier McLeod,

Wenona Latrice White, Sydney Anthony Charles, Shonya Michelle Young, Darryl Earl

21

Price, Sylvester Vaughn, George Lee Reid, and Claire Barker conspired knowingly,

willfully, and unlawfully to execute a scheme and artifice to obtain moneys, funds, and

credits under the custody or control of a financial institution by means of false and

fraudulent pretenses, representations, and promises in violation of Title 18, United States

Code, Sections 1344 and 1349 (Conspiracy to Commit Bank Fraud).

Postal Ips^ctor William J. Aiello U.S. Postal Inspection Service

Approved by: AUSA Timothy D. Belevetz

Sworn to and subscribed before me

this ?4^ day of June 2009.

Ivan D. Davis

United States Magistrate Judge

22