Case 3:09-cr-00119-JAJ-TJS Document 2 Filed 12/16/09 Page 1 of 4

IN THE UNITED STATES DISTRICT COURT RECEIVED

FOR THE SOUTHERN DISTRICT OF IOWA
DEC 16 2009
) CLERI(U.S D
SUiJlhcHN Dis~TCOURT
UNITED STATES OF AMERICA,

)
"1ltl, OFIOWA
Plaintiff, ) Criminal No.3: 09-cr-119
)
v. )
) INDICTMENT

VERKISHA LATRICE BURNS,

) T. 18 U.S.C. §§ 21 13(a), 21 13(d)
KA TELYN MARIE CURTIS
)
T. 18 U.S.C. § 924(c)
a/k/a Katalyn Maria Curtis, ) T. 18 U.S.C. § 2
RA YLON DESHON JONES,
) T. 18 U.S.C. § 371

)
Defendants. )
)
)

THE GRAND JURY CHARGES:

COUNT 1
(Bank Robbery)

That on or about October 5, 2009, in and about Washington County in the Southern

District ofIowa, the defendants, VERKISHA LATRICE BURNS, KATELYN MARIE CURTIS,

a/k/a Katalyn Maria Curtis, and RA YLON DESHON JONES, by force and violence, and by

intimidation, did take and attempt to take from the person and presence of another,

approximately $3,760 in United States currency belonging to and in the care, custody, control

and possession of West Chester Savings Bank, 1060 West Monroe Street, Washington, Iowa, the

deposits of which were then insured by the Federal Deposit Insurance Corporation, and in

committing such offense, the defendants, VERKISHA LATRICE BURNS, KA TELYN MARIE

CURTIS, a/k/a Katalyn Maria Curtis, and RA YLON DESHON JONES, did assault and put in

jeopardy the life of another person by the use of a dangerous weapon.

This is a violation of Title 18, United States Code, Sections 21 13(a), 21 13(d), and 2.
 Case 3:09-cr-00119-JAJ-TJS Document 2 Filed 12/16/09 Page 2 of 4

THE GRAND JURY FURTHER CHARGES:

COUNT 2

(Possession of Firearms in Furtherance of Violent Crime)

That on or about October 5, 2009, in and about Washington County in the Southern

District of Iowa, and elsewhere, the defendants, VERKISHA LATRICE BURNS, KATELYN

MARIE CURTIS, a/k/a Katalyn Maria Curtis, and RAYLON DESHON JONES, did knowingly

possess a firearm in furtherance of, and carry a firearm during and in relation to, a crime of

violence, that is, a violation of Title 18, United States Code, Sections 2113(a) and 2113(d), as set

forth in Count 1 ofthis Indictment, which is a felony prosecutable in a court of the United States,

and did brandish said firearm in the course of that crime.

This is a violation of Title 18, United States Code, Sections 924(c) and 2.

THE GRAND JURY FURTHER CHARGES:

COUNT 3

(Conspiracy to Commit Bank Robbery)

That on or about October 5,2009, in and about Washington County in the Southern

District of Iowa, and elsewhere, the defendants, VERKISHA LATRICE BURNS, KATELYN

MARIE CURTIS, a/k/a Katalyn Maria Curtis, and RAYLON DESHON JONES, did knowingly

and intentionally conspire with other persons to commit certain offenses against the United

States, that is, bank robbery in violation of Title 18, United States Code, Sections 2113(a) and

2113(d).
 Case 3:09-cr-00119-JAJ-TJS Document 2 Filed 12/16/09 Page 3 of 4

OVERT ACTS

In furtherance of the conspiracy, and to effect the objects thereof, the following overt acts,

among others, were committed by the defendants, VERKISHA LATRICE BURNS, KATELYN

MARIE CURTIS, a1k/a Katalyn Maria Curtis, and RAYLON DESHON JONES, as co­

conspirators, in the Southern District ofIowa and elsewhere:

1. During the period ofthe conspiracy, the defendants, VERKISHA LATRICE

BURNS and KATEL YN MARIE CURTIS, alk/a Katalyn Maria Curtis, traveled to Washington,

Iowa, with the intent to rob a bank, picking up RAYLON DESHON JONES in Washington,

Iowa, when they arrived.

2. During the period of the conspiracy, the defendant, VERKISHA LATRICE

BURNS, stole a pair of gloves to use in the robbery.

3. During the period ofthe conspiracy, the defendant, RAYLON DESHON JONES,

selected West Chester Savings Bank as the target because another bank was too busy.

4. During the period of the conspiracy, the defendants, VERKISHA LATRICE

BURNS, KATEL YN MARIE CURTIS, a1k/a Katalyn Maria Curtis, and RAYLON DESHON

JONES, circled West Chester Savings Bank in their car several times and parked offsite to help

effectuate the robbery and their get-away.

5. During the period ofthe conspiracy, the defendant, KATELYN MARIE CURTIS,

a1k/a Katalyn Maria Curtis, entered West Chester Savings Bank to case the bank and count the

number of individuals in the bank.

6. During the period of the conspiracy, the defendant, VERKISHA LATRICE

BURNS, entered West Chester Savings Bank and robbed the bank at gunpoint, taking $3,760 in

 Case 3:09-cr-00119-JAJ-TJS Document 2 Filed 12/16/09 Page 4 of 4

United States currency belonging to and in the care, custody, control and possession of West

Chester Savings Bank.

7. During the period of the conspiracy, the defendant, RAYLON DESHON JONES,

advised his co-conspirators on the fastest way to leave town.

This is a violation of Title 18, United States Code, Section 371.

A TRUE BILL.

/s/

FOREPERSON

Nicholas A. Klinefeldt

United States Attorney

By: ,->:/s;:. . / _

Joel W. Barrows

Assistant United States Attorney