‘ho REV 508 ComeG@AReMRE-Cr-01075 Document 1 Filed 12/91/20985A Matted ort (312) 460-6207
z UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF INOIS, EASTERN DIVISION —_
UNTEO STATES OF AMERICA suMINAL COMPLAINT
: ILED nuused!AGISTRATE JUDGE SCHENKIER
DEC $1 2008
ee haga ger O8(R 1075
correct to the best of my knowledge and baliet. On or about Dscembsr 29,2008 in Lake County, athe
Norte _Distret of __ iis Aefendat() di, nt ay mat te)
ty force and vilenss a isimidation lke from the person and presence of bank employees at Harris Bank,
1190 North McHenry oud, Bulla Grove, Hina, proximately $13,652.00 in United Sines Currency
Selongingto and inthe cae, custedy, conta, management ard posession of Harris Bank, the deposits of
‘hich were then insured bythe Federal Deposit Insurance Corpovation,
in violation of Tide__L8._ United tates Code, Sections) 21136 =
| further tate hat Ia a_ Speci Axent withthe Fedral Bugsy of Invgstigation and that this complain i based
the following fats:
See atached fda.
Continued on the atachod shoe and made par Nero X_ Yes __No
‘Sworn to before te and subscr dad in my presence,
Sides Ssh, Ul Stes aireCase 108-c1-01075 Document + Filed 12/31/2008 Page 2 of 5
STATEOFILLINO'S
> ss
COUNTY OF COOK
AFFIDAVIT
|, Craig J. Heidenreich, being duly sworn, do hereby state and depose as follows:
{lam a Special Agent with dhe Federal Bureau of Investigation ("FBI") aad have been so
‘employed for approximately three years. lam currently assigned tothe violent eximes squad of
FBI's Rotiing Meadows office. My duties include the investigation of bank robberies and
other violent crimes,
2. make this atidavit based upon my personal knowledge, my patcipation inthis
‘investigation, reports {have read, and conversations Ihave had with others who have personal
rowtedge ofthe evens and circumstances desribed herein, The information below i provided
forthe limited purpose of establishing probable cause tha on or about December 29,2008,
ROBERT MADAY id, by force and volene, and intimidation, take from the person and
‘Presence oF hank employees, approximately $13,652,00 in United States Currency bolonging to
and in he care, custo, conto, management, an possession ofthe Hats Bank, located at
1190 North McHenry oad, Bufflo Grove, Minos Haris Bank”, the deposits of which were
then insured hy the Federal Deposit Insurance Corporation (FDIC), in violation of Title 18,
United States Code, Section 2113(a). Because the information set forth below is forthe limited
Purpose of establishing probable cause in suppor of a eimial complain, it does not contain al
the fats of which [arm aware relate to this investigation
3 On December 25,2008, a approximately 1:20 P.M. Employee A, a man working aCase 1:08-cr-01075 Document 1 Filed 12/91/2008 Page 3of5
aris Bank, observed a white male the “Robbet") enter the bank. According to Employee A,
the Robber was wearing light green pants, black shoes blak jacket, and black kit ski mask
‘Aesording to Employee A, the Robber approached Employee A and told him and the other Haris
Bank employees moto move. According to Employee A, the Robber then opened the left side of
the Robbers jacket and displayed what appeared to Employee A to be the but of aback
handgun in the jacket’ interior pocket. The Rober then approached the teller couster and
oslered Employees Band C to empty thee tele drawers. Acconding o Employee B, the Robber
‘opened his jacket asi displaying someting inside it. Employee B gave the Robber ll of the
Unived
tes Curreney (USC) from Employee B's drawer, which included a pack often bait
bills. Employee C als gave the Robber all ofthe USC from Employee C's deawe, which
included a separate pck of ea tit bills Employees A, B, and C observed the Robber place the
USC into a black hag and then exit Harts Bank with the bag containing the money. Employees
Band C desribed the Robber asa white male wearing a dark colored jacket anda black ki
‘mask that was pulled down 30 that ony one ofthe Robes eyes was visible. An audit ofthe
teller drawers of Employees B and C showed that $13,652.00 had been taken bythe Rob.
4 _Atapproximately 3:45 P.M, on Desemer 29,2008, a City of Schaumburg Police Officer
Stopped. light blue Pestaefoursdor veiele on Martingale Road, about one quarter mile south
of Schaumburg Road, in Schaumburg, Iiois. This vehicle had been clocked at 82 miles pet
he rear ofthe vehicle, and
‘our (MPID, in a 40 MPH zone, displayed expired registration tag
filed to display a front license plate. The driver ofthis vehicle, late identified as ROBERT
MADAY, was a white nale wearing ligt green pants and black shoes.
MADAY was unable to produce a valid driver's license and, when asked for proof of