. - / # / ..--', : . .

PROB 22 DOCREI' NUMI' (R )ER (Tl'an. Ctp?z?'# ev. 0ô/l:) TRANSFER OF JURISDICTION 4 , l 4CR00 l 36- 007

O * '1' N M B - ot '

. . / .

NAME AND ADDRESS OF DISTRICT DIVISION

PROBATIONER/SUPERVISED REI-EASEE:

Eastern District of Texas Sherman Division

B e n l 1 y 1., C C D 0 C , J 1. . 

NAME OF SEN l EN(. , . a j yj c J u r;. G jy

Tlne Honorable M arcia A . Crone

U .S . District Jud e

DA'rES 0F PROBATION/SUPERVISED FROM 'r()

RELEASE:

A ugust 2, 2019 A ugust 1 , 2024

OFFENSE

Count 1 : Conspiracy to Commit Bank Fratld - i-ILtO MY tJ.t;. 1 8 U.S.C. j 1 349 and

Count 2 1 : Aggravated Identity Theft - 1 8 U.S.C. j 1 028(A)

M

PART 1 - ORDER TRANSFERRING JURISDICTION

CLERK U S. DISQ Cm LJNITED S'I-A'rES Dlsrltlc'r couRT I'0R l.i1E t'Eastern District of Texas'' s. D. oF Fuk. - F-rt txun.

IT IS HEREBY ORDERED that pursuant to 18 U.S.C. j 3605 the jurisdiction of the pl-obationer or supervised

releasee named above be transferred wgth the records of the Coull to the United States District Coul-t fol. the Southern

District of Florida u on that Court's order of acce tancc of 'urisdiction.

.z...'-- y

.xx.. .u.2

Dale f../. S. J.)?'-!'n'/c'/ Jtêdge

PA RT 2 - O RDER ACCEPTING JUR ISDICTIO N

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLO RIDA

IT IS HEREBY ORDERE D that jurisdiction over the above-named pl-obatiolpel-/stlpel'vised releasee be accepted

and assumed by this Court froltl alpd after the entt'y of this order.

g J

feclijie D /c Ullited * ates Dis ' ' ? Jlldge

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UNITED STATES D ISTRICT COURT

EASTERN D ISTRICT O F TEXAS SHERM AN D IV ISION

UN ITED STATES O F A M ERICA

BENNY LEE DO E, JR.

Date of Original Judgment: 1/14/2016

Reastln f0r Am endm ent:

Reduction of Sentencc for Changed Circum stances

(l7ed.R.Crim.P.35(b))

THE DEFENDANT:

Z pleaded guilty to countts)

pleaded guilty to countts) before a U.S.

Z Magistrate Judge, which was accepted by the

court. 1 and 21 of the Indictm ent

Q pleaded nolo contendere to countts) which was

acce ted b the court

ET was found guilty on countts) after a plea of not

u i lt

A M EN D ED

9 JUDG M ENT IN A CRIM INAL CASE

j

j

j Case Number: 4:14-CR-00136-M AC-DDB(7)

j USM N um ber: 22780-078

j John Daniel O liphant

j Defendant's Attorncy

The defendant is adjudicated guilty of these offenses:

Title & Section / Nature of O ffense

l 8: l 349.5- Conspiracy To Commit Bank Fraud

1 8: l ()28A.I7 Aggravatud Identity Thttft

Offe n se E n d ed

08/1 3/20 1 4

1 0/25/20 1 .3

Count

l

21

The defendant is sentenced as provided in pages 2 through 1 0 of this judgment. The sentence is imposed pursuant to the Sentencing

Reform Act of 1 984.

EEI The defendant has been found not guilty on countts)

X countts) a1l remaining Z is Zl are dismissed on the motion of the United States

It is ordered that the defendant must notify the United States attonney for this district within 30 days of any change of name.

residence, or mailing address until al1 fines, restitution, costs, and special assessments imposed by this judgment are fully paid. If

ordered to pay restitution, the defendant must notify the court and United States attorney of material changes in economic

circum stances.

M av 23. 2017

Date of I mpos iti on of Judgment

Signature of- Judge

M ARCIA CRO NE

UNITED STATES DISTR ICT JUDGE

Name and Titlc of Judge

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AO 24513 (Rev. 'I'XN 1 0/ 1 2) .1 udgment in a Criminal Case

DEFENDANT:

CASE NUM BER:

Judgment -- Iàagc 2 0 j- l 0

BENN Y LEE DOE, JR

4:14-CR-00136-M AC-DDB(7)

IM PR ISO NM EN T

The defendant is hereby committed to the custody of the United States Bureau of Prisons to be imprisoned for a total term of:

67 M ONTHS* - 43 months as to count l and 24 months as to count 2 1 of the Indictment. to be served consecutively.

Z The court makes the following recommendations to the Bureau of Prisons:

The Court recomm ends that the defendant receive appropriate drug treatment while imprisoned and that

defendant be incarcerated in FCI, M arianna, FL, if available and defendant is eligible. W hile incarcerated, it is

recom mended that the defendant participate in the lnmate Financial Responsibility Program at a rate determ ined

by the Bureau of Prisons staff in accordance with the requirem ents of the lnm ate Financial Responsibility

Program .

(Z The defendant is remanded to the custody of the United States Marshal.

Z The defendant shall surrender to the United States Marshal for this district:

as notified by the United States Marshal.

The defendant shall surrender for service of sentence at the institution designated by the Bureau of Prisons:

Z before 2 p.m. on

EEl as notified by the United States Marshal.

Z as notifsed by the Probation or Pretrial Services Office.

On

R ET U R N

l have executed this judgment as follows:

at , with a certified copy of this judgment.

t.JNl-î'ED S7'A'1'ES M ARSHAL

By

D E Pt J 'rY U N I ' 1- L 1) S'I ' A7'L S M AltS I-IAL

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Juclgnlent -- Pagt! .3 01- 1 ()

DEFENDANT:

CASE N UM BER:

SU PER V ISE D R EL EA SE

Upon release from imprisonment, the defendant shall be on supervised release for a term of: 5 YEARS.

BENNY LEE DOE, JR

4:14-CR-00136-M AC-DDB(7)

The defendant must repol't to the probation ofsce in the district to which the defendant is released within 72 hours of release

from the custody of the Bureau of Prisons.

The defendant shall not commit another federal, state or Iocal crime.

The defendant shall not unlawfully possess a controlled substance. The defendant shall refrain from any unlawful use of a controlled

substance. The defendant shall submit to one drug test within 1 5 days of release from imprisonment and at least two periodic drug

tests thereafter, as determined by the court.

The above drug testing condition is suspended, based on the court's determination that the defendant poses a 1ow risk of future

substance abuse. llu'hec'k. lfappllcable.)

Z The defendant shall not possess a srearm, ammunition, destructive device, or any other dangerous weapon. (l-heck. l/cwp/pcw:/(?.?

Z The defendant shall cooperate in the collection of DNA as directed by the probation officer. (l-heck. (fappllcablev)

((((lj The defendant shall comply with the requirements of the Sex Offender Registration and Notification Act (42 U.S.C. j 1 690 1 , el

-$'a/.) as directed by the probation officer, the Bureau of Prisons, or any state sex offender registration agency in which he or she

resides, works, is a student. or was convicted of a qualifying offense. (l-heck. yr//pp//c'rp??/t,x?

Z The defendant shall participate in an approved program for domestic violence. (l-heck. y:?/p/?/?cw/?&a.?

lf this judgment imposes a fine or restitution, it is a condition of supervised release that the defendant pay in accordance with

the Schedule of Payments sheet of this judgmenl.

The defendant must comply with the standard conditions that have been adopted by this court as well as with any additional

conditions on tlle attached page.

STAND ARD CON DITIO NS O F SUPERV ISIO N

l . the defendant shall not leave the judicial district without the permission of the court or probation oflicer.'

2 . the defendant shal l report to the probation officer in a manner and frequency (1 irected hy the coul-t o1* probat i on offi cer:

3 . tl-lc dcfendant slAal l answer truthfu 1 ly al l i ncl u iries by the probation officer and fo l low the i nstrtlctions of the pro hat ion ofticer:

4. the defendant shall support his or her dependents and meet other fami ly responsibi l ities-'

5. the defendant shall work regularly at a lawfu l occupation. unless excused by the probation oft-icer 1-01. schooling- train ing. or othcr

acceptablc reasons.

the defendant shall notify the probation officer at least ten days prior to any change in residence 01- employmcnt:

the defendant shall refrain frem excessive use of alcohol and shal l not purchase, possess, use. distribute. 01- adm inister any control led

substance or any paraphernalia related to any controlled substances. except as prescribed by a physician:

the defendant shall not freqtlent places where control led substances are illegal ly seld, used. distributed. or administered-'

the defkndant shall not associate with any persons engaged in criminal activity and shall not associate with any person convi cted o f a

felony. un less grantecl permission to do so by thc probation o ffqcer'.

the defendant shal l permit a rrohati on oftscer to v isit h im or her at an) ti me at home or cl scw hertt and shal 1 gcrm i t con Ii scation o t' any

contraband ohscrvetl in plain view of the probation ofl-iccr'.

the defendant shal l noti là' the probati ()n of-f-icer withi n seventy-two hours o f' bci ng arrested or question ed b) a l 81:: en rorcement o f-f-iccr:

the delkndant shall aot enter into any agrccment to act as an informer or a special agent ot- a law en Ibrcement agency w ithout the

permission of the coul4-' and

as directed by the probation ofticcr. the defendant shal l notify third partics of risks that may be occasioned by the defendant's crim inal

record or personal history or characteristics and shall permit the probation oftscer to make such notilications and to contirm the defendant's

compliance with such notitication requirement.

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A() 2458 (Rev. TXN l 0/ 1 2) Judgment in a Criminal Case

DEFEN DAN T:

CASE NUM BER:

Iudgment -- laage 4 of ! 0

BENN Y LEE DOE, JR

4:14-CR-00136-MAC-DDB(7)

SPECIAL CO ND ITIO NS O F SUPER V ISIO N

The defendant shall provide probation officer w ith access to any requested financial

inform ation for purposes of m onitoring fine/restitution paym ents and em ploym ent.

The defendant shall not incur new credit charges or open additional Iines of credit

w ithout the approval of the probation officer unless paym ent of any financial obligation

ordered by the Court has been paid in full.

The defendant shall not participate in any form of gam bling unless paym ent of any

financial obligation ordered by the Court has been paid in full.

The defendant shall participate in a program of testing and treatm ent for drug abuse,

under the juidance and direction of the U.S. Probation Office, until such time as the

defendant Is released from the program by the probation officer. The defendant shall pay

any cost associated w ith treatm ent and testing.

The defendant shall acquire a General Educational Development (GED) Certificate.

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-1 udgnAent -- Page 5 of l 0

DEFEN DAN T:

CASE NUM BER:

BENNY LEE DOE, JR

4:14-CR-00136-MAC-DDB(7)

CR IM INAL M O NETAR Y PENA LTIES

The defendant must a the total criminal monetar enalties under the schedule of a ments on Sheet 6,

Assessm ent Fine Restitution

TOTALS $200.00 $.00 $88 l ,335.99

The determination of restitution is deferred until An Amended Judgmenl in a Criminal ()>tzvc (A()24 .5C) will be entered

after such determ ination.

rk'l The defendant must make restitution (including community restitution) to the following payees in the amount listed below,

j 3664(1 ) If the defendant makes a partial payment. cach payee shall receive an approximately proportioncd pal'mttnt. I'lowever- rursuant to 1 8 LJ.S.C. . al l nonfederal victims must he paid before the United States is paid.

Restitution of $478,006. l 5 to:

American National Bank of Texas Attn: Susan Rowe

$30,020.02

BBVA Com pass Bank

$4.659.00

Capitol One

$27,426.00

Citizens N ational Bank

$7,200.00

Citizens State Bank

$7. 120.00

Credit Union of Texas

$2,800,00

Cypress Bank

$4,925.00

DATCU Credit Union

$4,800.00

EECU

$ l 0,000,00

Extraco Banks

$3,985.00

First National Bank Midcities

$ 14,837.00

First State Bank

$ 1 ,960.00

Frost

$8.5 10.00

I B C

$37,734.00

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AO 2)58 (Rcv. TXN 10/1 2) Judgment in u Criminal Case

DEFENDANT:

CASE NUM BER:

ludgment -- Page 6 ot- l ()

BENN Y LEE DO E, JR

4:14-CR-00136-MAC-DDB(7)

J. P. M organ Chase Bank

$97,589. l 9

Navy Army Credit Union

$ 1 ,896.00

N orthelm Trust

$24,630.00

Omni American Bank

$29,4 15,00

Partners Federal Credit Union

$9 85 .00

Pinnacle Bank

$ 1 2,950.00

Premier Bank

$ 1 ,792.00

Qualtrust Credit Union

$ l 0 , 7 5 2 . 00

RBFCU

$3,845.00

Regions Bank

$900.00

Shanna Cobbs

$2,588.00

State Farm Bank

$ 12,5 16.00

Texas Cred it U n ion

$44,6 1 0.94

Texas Trust Credit Union

$ 1 ,875.00

Tolleson Private Bank

$ 1 3,748.00

USAA

$ 1 5 , 7 l 7 .00

V iewpoint Bank/l-egacy Texas Bank

$23,400.00

W ells Fargo Bank

$ l 2,82 1 .00

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I ttcl glmen t -- Pagc 7 o t' I ()

DEFENDANT:

CASE NUM BER:

Restitution of $2, l 82.80, jointly and severally with co-defendant Christina Lynn Gallo (4: 1 4-cr-00 1 36-9), Christopher Henry Cosby

(4: 1 4-cr-00 l 36-2), Dianna Leigh Painton (4: 14-cr-001 36-3), Katherine Jones Reynolds (4: 14-cr-00 136-1 6), Mallori Lee Moss (4: 14-

cr-00 1 36-6), Moses George Freelove (4: 1 4-cr-00 1 36- l 3) and Robert Aaron Green (4: 14-cr-00 1 36- 1 ), to:

Bank of America Attn: Cindy Hunt

BENN Y LEE DO E, JR

4:l4-CR-001 36-M AC-DDB(7)

Restitution of $5,80 1 .zojjointly and severally with co-defendant Christina Lynn Gallo (4: l4-cr-00 1 36-9), Christopher Henry Cosby

(4: 14-cr-00 136-2), Dianna Leigh Painton (4: l 4-cr-001 36-3), Katherine Jones Reynolds (4: 14-cr-00 1 36- 1 6), Mallori Lee Moss (4: 1 4-

cr-oo 1 36-6), Moses George Freelove (4: 1 4-cr-00 l 36-1 3), Robert Aaron Green (4: I4-cr-00 1 36- l ) and Wendy Lee Wrenn (4: l 4-cr00 1 36- l 4), to:

Bank of America Attn: Cindy Hunt

Restitution of- $5,605.00, jointly and severally with co-defendant Christopher Henry Cosby (4: I 4-cr-00 1 36-2), Dianna Leigh Painton

(4: l 4-cr-00 1 36-3) and Robert Aaron Green (4: 14-cr-00 1 36- 1 ), to:

W ells Fargo Bank

Restitution of $ 1 7, l 2 1 ,45, jointly and severally with co-defendant Christina Lynn Gallo (4: l 4-cr-00 I .36-9). Christopher Henry Cosby

(4: l 4-cr-00 136-2), Katherine Jones Reynolds (4: 14-cr-00 1 36- 1 6), Mallori Lee Moss (4: l 4-cr-00 1 36-6) and Robert Aaron Green

(4: 1 4-cr-00 136- l ), to:

Bank of America Attn: Cindy Hunt

Restitution of $ l ,700,00, jointly and severally with co-defendant Christina Lynn Gallo (4: 14-cr-00 1 36-9), Christopher Henry Cosby

(4: l 4-cr-00 I ,36-2), David Lee Brown (4: 14-cr-00 1 36-1 0), Mallori Lee Moss (4: I4-cr-00 1 36-6), Robert Aaron Green (4: 14-cr-00 1 36-

1 ) and W endy Lee W renn (4: 14-cr-00 1 36-1 4), to:

J. P. M organ Chase Bank

Restitution of $6,029.05, jointly and severally with co-defendant Christina Lynn Gallo (4: 14-cr-00 I 36-9), Christopher Henry Cosby

(4: 14-cr-00 I 36-2), Katherine Jones Reynolds (4: 14-cr-00 1 36-1 6), Mallori Lee Moss (4: 14-cr-00 1 36-6), Moses George Freelove

(4: I 4-cr-00 1 36- 1 3) and Robert Aaron Green (4: 14-cr-00 l 36- 1 ), to:

Bank of Am erica Attn: Cindy Hunt

Restitution of $5.80 1 .zo.jointly and severally with co-defendant Christina Lynn Gallo (4: 14-cr-00 l 36-9), Christopher Henry Cosby

(4: l 4-cr-00 1 36-2), Mallori Lee Moss (4: 14-cr-00 136-6) and Robert Aaron Green (4: 1 4-cr-00 l 36- 1 ), to:

Bank of America Attn: Cindy Hunt

Restitution of $27.00. jointly and severally with co-defendant Christina Lynn Gallo (4: l 4-cr-00 I 36-9), Christopher l'lenry Cosby

(4: 14-cr-00 1 36-2), David Lee Brown (4: 1 4-cr-00 1 36- I 0) and Robert Aaron Green (4: 1 4-cr-00 l 36- l ), to:

J. P. Morgan Chase Bank

Restitution of $ 145, 1 57.27, jointly and severally with co-defendant Christina Lynn Gallo (4: 14-cr-00 l 36-9), Christopher Henry Cosby

(4: 1 4-cr-00 l 36-2) and Robert Aaron Green (4: 14-cr-00 1 36- 1 ), to:

Bank of Am erica Attn: Cindy Hunt

$122,764.30

Bank of Texas

$6,400.00

J. P. M organ Chase Bank

$1 5,992.97

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AO 24'58 (Rev. TXN 10/1 2) Judgment in a Criminat Case

DEFENDANT:

CASE NUM BER:

Judgment -- Page 8 of l 0

BENN Y LEE DO E, JR

4:14-CR-00136-MAC-DDB(7)

Bank of America Attn: Cindy Hunt

$3,094.50

J, P. M organ Chase Bank

$28,924.84

W ells Fargo Bank

$ l 0,645.00

Restitution of $987.00, jointly and severally with co-defendant Christopher Henry Cosby (4: 14-cr-00 l 36-2) and Katherine Jones

Reynolds (4: 14-cr-00 I 36- 16), to:

Viewpoint Bank/Legacy Texas Bank

Restitution of $ 1 7,850.00, jointly and Severally with co-defendant Christina Lynn Gallo (4: 14-cr-00 1 36-9) and Christopher Henry

Cosby (4: 14-cr-00 l 36-2). to:

Am erican N ational Bank of Texas Attn: Susan Rowe

$7,500.00

First State Bank

$3,750.00

Point Bank

$6,600.00

Restitution of $144.832.47, jointly and severally with co-defendant Christopher Henry Cosby (4: 14-cr-001 36-2), to:

American National Bank of Texas Attn: Susan Rowe

$7,330.00

Bank of America Attn: Cindy Hunt

$78,600,50

BBVA Compass Bank

$38,600.00

J. P. Morgan Chase Bank

S 1 4,858.97

Viewpoint Bank/l-egacy Texas Bank

$ 1 ,793.00

W ells Fargo Bank

$3,650.00

Restitution of $ 1 ,225.35, jointly and severally with co-defendant Christian Dom inque Scott (4: l 4-cr-00 l 36- 1 5), Katherine Jones

Reynolds (4 : 1 4-cr-00 1 36- 1 6) and M allori Lee M oss (4: 14-cr-00 1 36-6), to:

CitiBank

$.397.35

U SA A

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AO 24*58 (Rev. 'I-XN 1 0/ 1 2) Judgment in a Criminal Case

DEFENDANT:

CASE NUM BER:

$828 ,00

Restitution of $759.03, jointly and severally with co-defendant Christian Dominque Scott (4: l 4-cr-00 1 36- 1 5), Katherine Jones

Reynolds (4: 14-cr-00 1 36- 16), M allori Lee M oss (4: 14-cr-00 1 36-6) and W endy Lee Wrenn (4: 14-cr-00 1 36- 1 4), to:

CitiBank

.1 udgl-ne 17 t -- I7age 9 o f l 0

BENNY LEE DO E, JR

4:14-CR-00136-MAC-DDB(7)

Restitution of $223.06, jointly and severally with co-defendant Mallori Lee Moss (4: 1 4-cr-00 1 36-6) and Wendy Lee Wrenn (4: I 4-cr00 1 36- 14). to2

Texas Credit Union

Restitution of $393.62, jointly and severally with co-defendant Mallori Lee Moss (4: 14-cr-00 l 36-6), to:

CitiBank

Capitol One

Restitution amount ordered pursuant to plea agreement $

The defendant must pay interest on restitution and a fine of more than $2,500. unless the restitution or fine is paid in full before

the fifteenth day aker the date of the judgment, pursuant to 1 8 U.S.C. j 36 12(9. A1I of the payment options on Sheet 6 may be

subject to penalties for delinquency and default, pursuant to I 8 U.S.C. j 361 2(g).

Z The court determined that the defendant does not have the ability to pay interest and it is ordered that:

(? the interest requirement is waived for the (((qj fine (1 Restitution

((4lj the interest requirement for the (11 ((((j restitution is modified as fbllows:

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AO 2458 (Rev. 'I'XN l 0/ 1 2) Judgment in a Criminal Case

DEFENDANT:

CASE NUM BER:

SC H ED U L E O F PA Y M EN T S

Having assessed the defendant's ability to pay, payment of the total criminal monetary penalties is due as follows:

A (H Lump sum payments of $ 88 1,535.99 due immediately, balance due

not Iater than

= in accordance (? F below: or

B Payment to begin imlmediately (may be combined with El(q) F belowl; or

.1 udgment -- Page l 0 of- l 0

BENNY LEE DOE, JR

4:14-CR-00136-M AC-DDB(7)

Paym ent in equal .. . . .......................... (e.g., wtrtA/l', lnonthly, quarterly) installments of $ over a period of

(ag., months or years), to commence (e.g., 30 or 60 #qpA'? after the date of this judgment,.

or

D Payment in equal (e.g., weekly, monthly, quarlerly) installments of $ over a period of

(e.g., ?7J(?r??/?.5' or years), to commence (e.g. , 30 or 60 days) after reI ease from

ilmprisonment to a term of supervision', or

Payment during the term of supervised release will commence within (e.g. , 3() t)/- 60 daysl af-ter release

Som imprisollmellt. The cottrt Will set the payment plan based on an assessment ol iite defendant's ability to pay at that

t i rf'l e ,' o r

Z Special instructions regarding the payment of criminal monetary penalties:

It is ordered that the Defendant shall pay to the United States a special assessment of $200.00 for Counts 1 and 21

which shall be due im mediately. Said special assessment shall be paid to the Clerk, U.S. District Court. Any

restitution am ount that rem ains unpaid w hen the defendant's supervision com m ences is to be paid on a monthly

basis at a rate of at least 100,4 of the defendant's gross incom e, to be changed during supervision, if needed, based

on the defendant's changed circtlmstances, pursuant to 18 U.S.C. j 3572(d)(3). If the defendant receives an

inheritance, any settlements (including divorce settlement and personal injury settlement). gifts, ta: refunds,

bonuses, Iawsuit awards, and any other receipt of money (to include, but not be Iim ited to, gambling proceeds,

lottery w'innings, and money fonnd or discovered) the defendant m ust, within 5 days of receipt, apply 100M, of

the value of such resources to any restitution or fine still owed.

Unless the court has expressly ordered otherwise, if this judgment imposes imprisonment, payment of criminal monetary penalties is

due during imprisonment. A11 criminal monctary penalties, except those payments m ade tlzrough the Federal Bttreau of Prisons'

Inmate Financial Responsibility Program, are made to: U.S. District Court. Fine & Restitution, l 9 l 0 E SE Loop 323 No 287. Tyler. TX 7570 I

The defendant shall receive credit for a11 payments previously made toward any criminal monetary penalties imposed.

IK Joint and Several

See above for Defendant and Co-Defendant Names and Case Numbers (including Jf(/i,nJr?#?/ nltmbel'). Total Amount, Joint and

Several Amount, and corresponding payee, if appropriate.

IZI Defendant shall receive credit on his restitution obligation for recovery from other defendants who contributed to the same Ioss

that gave rise to defendant's restitution obligation.

EEI The defendant shall pay the cost of prosecution.

Z The defendant shall pay the following court costts):

Z The defendant shall forfeit the defendant's interest in the following property to the United States:

Payments shall be applied in the following order: ( 1 ) assessment, (2) restitution principals (3) restitution interest, (4) fine princ ipal. (5) fine interest, (6) community restitution, (7) penaities, and (8) costs, including cost of prosecution and cour't costs.

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Case 4:14-cr-0O136-RAS-DDB Docum ent 1 Filed 08/13/14 Page 1 of 27 PagelD #: 1

F, g j. F ; () ) xw

EASTERN Dl U-S, DISJFCI- Cojlq-t kt5 I RSGT Cft fùM tù

IN THE UNITED STATES DISTRICT COURT ALC 1 3 2â1?I

FOR THE EASTERN D ISTRICT OF TEM S

SHERM AN DIV ISION DAVID .J. MALAND, CLERK

By

DEPU7Y

UN ITED STATES OF AM ERICA

No. 4:14cRl3@

Judge % +

ROBERT AARON GREEN (1)

a k a $çLil Dave''

CHRISTOPHER HENRY COSBY (2)

a.k.a. ç$Lil Chris''

DIANNA LEIGH PAW TON (3)

SHELTON JVRROD GREEN (4)

a k a Sishank''

DEM ETRIS JEROM E

CUNNINGHAM (5)

a k a. d<M eM e''

MALLORI LEE MOSS (6)

a k a tsBulm y''

BENNY LEE DO ,E JR. (7)

a'kta. ESJ, Jay, and JR''

STEVEN TAURUS GREEN (8)

a k a. dsspud''

CHRISTINA LYNN GALLO (9)

DAVID LEE BROWN (10)

JOHNTHAVIAS KEON BROW N (11)

a k a- '%JT''

KAM ESHA NYCOLE BROW N (12)

MOSES GEORGE FREELOVE (13)

H NDY LEE WRENN (14)

CHRISTIAN DOM INQUE SCOU (15)

KATHERINE JONES REYNOLDS (16)

IN DICTM ENT

THE UNITED STATES GM ND JURY CHARGES:

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Count O ne

Violation: 18 U.S.C. j 1349

(Conspiracy to Commit Bnnk Fraud)

A. Introduction

1. Bank of America, JP M organ Chase ($fchase'') Bankzviewpoint Bank, CitiBnnk,

American National Barlk of Texas, American Bank of Texas, M etropolitan National Bank, W ells

Fargo Bnnk, BBVA Compass Bank, Northstar Bank, Liberty Bnnk, First State Bank, Regions

Bank, Point Bank, Pegasus Bnnk, Capital One Bank, Bnnk of Texas, Com m erce Bank, U S Bank,

First Fidelity Bank, USAA Federal Savings Bank, Bank of Commerce, Citizens National Bank,

Commtmity Trust Bank, StmTrust Bank, Landmark Bfmk, Kanza Bnnk, Arvest Bank, Sunflower

Bank, Barlk of the W est, Intrust Bank, Emprise Bank, First Convenience Bank, First National

Bank ofTexas, Credit One Bank, Omni Am erican Bank, and BancFirst were financial institutions

insured by the Federal Deposit lnsurance Corporation; an.d Equishare Credit Union, CFE Federal

Credit Union, eCo Credit Union, Texans Crqdit Union, Navy Federal Credit Union, Oklahoma

Central Credit Union, Chevron Federal Credit Union, Resource One Credit Union, Credit Union of

Texas, Nascoga Federal Credit Union, Texas Trust Credit Union, Pentagon Federal Credit Union,

and Your Commtmity Credit Union were credit unions insured by the National Credit Union Share

lnsurance Fund (collectively dtFinancial lnstitutions'').

M D I, M D2, M M I, M M 2, JA I, JA2, EM I, EM 2, RM I, RM 2, AA I, M l, LA I,

LA2, JGI, JG2, SK I, SK2, VSI, VS2, CW I, CW 2, AHI, AH2, DM I, DM 2, M R, CD, SF, ET,

CB, LO, SM , KG , KT, SP, SA , AB/LB, M W , EA, D B, D/PP, M S, AL, RW , SV, JH , M /M EB, GS,

. 

'

BE, PT, JL, K S, KJ, BJ, BD , JD , AD , DL, DP, BW , KH, S1, JB, A S, JK , A T, BM , IQN H, lH, M G ,

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D/DF KO LW M H AB SC TM SS LC JP and BP were individ > > > .$ ) > > > ; ; uals known to the Grand Jury;

each had their personal identifying inform ation stolen, and in some instances their bnnk checkq and

bank cards. SD and DS were indiyiduals known to the Grand Jury and had their vehicles

burglarized. None of the individuals listed herein authorized the defendants or other members of

the conspiracy to take their personal identifying information, bank checks or bank cards.

B. The C onspiracv

3. Beginnihg in or about Jmmary 2012, and continuing through on or about August 13,

2014, in the Emstern District of Texas and elsewhere, Robert Aaron Green (.tGrten''),

Christopher Henry Cosby (d$Cosby''), Dianna Leigh Painton (tspaintonn), Shelton Jerrod

Green (çshelton Green''), Demetris Jerome Cunningham (sdcunningham'), M allori Lee

M oss ($$M oss''), Benny Lee Doe, Jr. ($$D0e'') Steven Taurus Green (ttsteven Greenh'),

Christina Lynn Gallo (d$GaIIo''), David Lee Brown (ççDavid Brown'), Jonthavias Keon

Brown (dslohnthavias Browi1''), Kamesha Nyeole Brown (dtlfamesha Brown''), M oses George

Freelove (d$Frçelove''), W endy Lee W renn ('%W renn''), Christian Dominque Scott (t$Scott'')

and Katherine Jones Reynolds ((Reynolds''), defendants, intentionally, knowingly and willfully

conspired, confederated, and agreed with each other and with other individuals both known and

unknown to the Grand Jury to devise a scheme and artifice to defraud and obtain money and

property from the Financial lnstitutions by means of materially false and fraudulent pretenses and

representations, a violation of 18 U.S.C. 5 1344.

M anner and M eans of the Conspiracv

4. In the Eastern D isîict of Texas and elsewhere, Green, Cosby, Cunningham , D oe,

Steyen G reen, David Brow n, Johnthavias Brown, and others lcnown and unknown to the Grand

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Jttry stole bank checks, bank cards, and personal identitication cards at locations such as daycare

facilities, gyms, and public pm'ks. The theRs were typically from motor vehicles and were made

via forcible entry.

5. M oss, Scott, W renn, Reynolds, and others known and unknown to the Orand Jury,

typically used victim s' bank cards within minutes of the thei, often at gas stations, convenience

stores, or retail stores.

6. Green, Cosby, Shelton Green, Doe, Cunningham , David Brown, Johnthavias

Brown, and others known and 'lnknown to the Grand Jury, kept or turned over the vidims' checks

and drivers licenses lo other members of the conspiracy.

Painton, M oss, Gallo, Reynolds, and other members of the conspi<acy, disguised

as theft victim s often through the use of wigs, visittd finançial institutions, typically via the

drive-thru teller lanes, using rtnted vehicles. Other members of the conspiracy, including Green,

Cosby, Cunningham , Doe, and Frtelove were usually hidden in tht back seat of tht rtnted

vehicles and provided the co-conspirators, including Painton, M oss, Gallo, and Reynolds, with

the stolen checks. Painton, M oss, Gallo, Reynolds, and others ltnown and unknown to the

Grand Jury presented stolen checks, with the corresponding stolen drivers' licenses and bnnk

cards, made payable from one vidim to another. Bank tellers cashed the checks and the payee

victims' banks suffered the loss when the checks were retumed from the maker victims' banks as

stolen.

Throughout the execution of the scheme, Shtlton Green and other members of the

conspiracy provided surveillance for the rental vehicles used to present the stolen chepks to the

financial institutions, typically in other rented vehicles, The co-conspiratprs often used stolen

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license plates to conceal the tlue license plates of the rental vehicles used in the scheme. Steven

Green, Kam esha Brown, Reynolds, and other members of the conspiracy rented the vehicles

used in the scheme.

9. On or about the following dates, as l'epresentative of the m almer and means of the

conspiracy, Green, Cosby, Painton, Shelton Green, Cunningham , M oss, Doe, Steven Green,

Gallo, David Brown, Johnthavias Brown, Kamcsha Brown, Freelove, W renn, Scott,

Reynolds, and other co-conspirators kllown and unltllown to the Grand Jury, took the following

actions, nm ong others, w ith respect to the following transactions on the following dales in the

Eastem District of Texas and elsewhere:

a. On or about M arch 30, 2012, an unknown co-conspirator broke into M D1's

vehicle in Greenville, South Carolina, and stole M D1's bnnk cards, bank checks, and personal

identifying information.

On or about April 2, 2012, arl unknown co-conspirator broke into M R's

Vehicle in Little Rock, Arkansas, and stole M R's bank cards, bank checks, and personal

identifying information.

Between on or about April 2, 2012, and April 3, 20 12? Kam esha Brown

possessed M R's M etropolitan National Bank check number 6055 in the amount of $1,700 made

payable to M D1 that was presented to and cashed at Bnnk of America in Oklahom a City,

Oklahoma.

d. On or about August 30, 2012, an unlcnown co-conspirator broke into CD's

vehicle in Rockw all, Texas, and jtole CD 's bnnk cards, bank checks, and personal identifying

. '

infonuation.

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C.

SF's vehicle in Plano, Texas, in the Eastern District of Texas, and stole SF's bank cards, bank

checks, and personal identifying information.

On or about September 13, 2012, an unknow n co-conspirator broke into

f. On or about September 19, 2012, an unknown co-conspirator broke into

M M 1's vehicle and ET's vehicle, both in Plano, Texas, in the Eastern District of Texas, and stole

M M 1's and ET's bnnk cards, bnnk checks and personal identifying inform ation. Kamesha

Brown had rented the vehicle used in the btlrglaries.

g. On or about September 26, 2012, an unknown co-conspirator brokc into

CB's vehicle in Frisco, Texas, in the Eastern District of Texas, and stole CB's bank cards, bank

checks, and personal identifying information,

On or about August 14, 2012, an tmknown co-conspirator broke into a

vehicle in Terrell, Texas, and stole AB/LB'S personal identifying information and bank checks.

On or about October 2, 2012, an unknown co-conjpirator broke into a LG's

vehicle in Allen, Texas, in the Eastern District of Texas, and stole LG's bank cards, bank checks,

and personal identifying information.

On or about Octobtr 5, 2012, Painton, whilt wearing a disguise and with

Green and Cosby lying down in the back seat so as to be out of sight of bank persormel, drove a

rental vehicle into the drive-tlm z lane of four Bnnk of America bnnkg - two in Dallas, Texas, one in

(Jrartd Prairie, Texas, and one in Arlington, Texas - and presented a check at each bank in the

amount of $998 drawn from the accolmt of LG and m ade payable to CB.

k. On or about Octobez 6, 2012, an unknown co-conspirator broke imo DS's

vehicle in Corsicana, Texas, and stole JA1's bank checks, bnnk cards, and personal identifying

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intbrmation.

1. On or about October 6, 2012, all unknown co-conspirator broke into M M2's

vehicle in Corsicana, Texas, and stole M M 2fs bank checks, bank cards, and personal identifying

information.

m . On or about October 24, 2012, Gallo drove a rental vehicle into the

drive-thru lane of an American National Bnnk in Rockwall, Texas, and preseéted check number

1105 in the amount of $1,500 drawn from the account of EM 2 and made payable to CD .

n. On or about October 24, 2012, Gallo drove a rental vehicle into the

drive-thru lane of an Am erican National Bank in Rockwall, Texas, and presented check ntlm ber

1174 in the amount of $1,500 drawn from the account of EM 2 and made payable to CD.

On or about October 24, 2012, Gallo drove a rental vehicle into the

drive-thru lane of an Am erican National Bank in Rockwall, Texas, and presented check number

1175 in the amount of $1,500 drawn from the accotmt of EM 2 and made payable to CD .

p. On or about October 24, 20 12, Gallo drove a rental vehicle into the

drive-thru lane of an Am erican National Bank in Rockwall, Texas, and presented check number

1176 in the amount of $1,500 drawn from the accotmt of EM 2 and made payable to CD.

q. On or about October 24, 2012, Gallo drove a rental vehicle into the

drive-tlu'u lane of an American National Bank in Forney, Texas, and presented check number 1 177

in the amount of $1,500 drawn from the account of EM 2 and made payable to CD.

r. On or abom October 25, 2012, Gallo, with Doe lying down in the back seat

so as to be out of sight of bank personnel, drove a rental vehicle into the drive-thru lane of an

AmericanNational Bnnk of Texas in Sachse, Texas, and presented a check in the amount of $1,500

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drawn from the account of JA1 and made payable to CD.

Steven G reen.

The rental vehicle had bcen rented by

On or about November 14, 2012, D0e and Steven Green broke into EM 1's,

SM 's, KG's, KT's, and SP's vehicles in Forney, Texas, and stole their rcspective bnnk cards, bnnk

checks, and personal identifying information.

On or about December 10, 2012, an unknown co-conspirator broke into

SA's vehicle in Frisco, Texas, in the Eastern District of Texas, and stole SA's bnnk cards, bank

checks, and personal identifying intbrmation.

u.

rental ve/cle into the drive-thru lane of a First State Bank in M abnnk, Texas, and presented a

check in the amount of $1,250 drawn from the accotmt of AB/LB and made payable to M M 2.

On or about Decem ber 19, 2012, Gallo, 'while wearing a disguise, drove a

On or about December 19, 2012, GaII0, while weazing a disguise, drove a

rtntal vehicle into the drive-timz lmw of a First Statt Bank in Gtm Barrel City, Texas, in the

Eastern District of Texas, and presented a check in the amount of $1,250 dl'awn from the account

of AB/LB and made payable to M M2.

On or about December 19, 2012, Gallo, while wearing a disguise, drove a

rental vehicle into the drive-tlu'u lane of a First State Bank in Athens, Texas, in the Eastern District

of Texas, and presented a check in the amount of $1,250 drawn from the account of AB/LB and

m ade payable to M M 2.

X .

rental vehicle into the drive-thru lane of a First State Bank in M alakoff, Texas, in the Eastern

District of Texas, and presented a check in the nmount of $ 1,250 drawn from the accpunt of

On or about Dtcembtr 19, 2012, Galln, while wearipg a disguise, drove a

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ABJLB and m ade payable to M M 2.

On or about Janumy 1, 2013, an unknown co-conspirator broke into RM l's

vehicle in Coppell, Texas, and stole ltM l's brmk cards, bank chccks, and personal identifying

inform ation.

On or about January 22, 2013, an unknown co-conspirator broke into M W 's

vehicle in M cKinney, Texas, in the Eastern District of Texas, and stole M W 's bnnk cards, bank

checks, and personal identifying irlformation.

aa. On or about Jmw ary 24, 2013, an unknown co-conspkator broke into

A A.1 's and LA 1's vehicles in Southlake, Texas, and stolè AAl's and LA l's bank cards, bank

checks, and personal identifying information.

bb. On Qr about January 25, 2013, an unknown co-conspirator broke into EA's

and RM 2's vehicles in Southlake, Texas, and stole EA 's and RM 2's bank cards, bank checks, and

personal identifying information.

On or about January 29, 2013, an unknown co-conspirator broke into DB's

vehicle in Dallas, Texas, and stole DB's bnnk cards, bank checks, and personal identifying

inform ation.

dd. On or about February 3, 2013, an unknown co-conspirator broke into

D9 P'S vehicle in Dallas, Texas, and stole D/PP'S barlk cards, bank checks, mld personal

identifying information.

ee. On or about February 5, 2013, M oss, with Freelove lying down in the back

seat so as to be out of sight of bnnk personnel, drove a rental vehicle into the drive-thru lane of a

Bnnk of America in Coppell, Texas, and presented a check in the amount of $1,989.00 drawn from

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the accotmt of D/PP and m ade payable to DB. Freelove also possessed a piece of paper.that

contained the names of prior burglary victims including EA, RM 2, AA1, LA I, and M W .

On or about M arch 1, 2013, an unknown co-çonspirator broke ilto M S's

vehicle in M cKizmey, Texas, in the Eastern District of Texas, and stole M S's bank cards, bank

checks, and personal identifying information.

gg. On or about M arch 2, 2013, an unknown co-conspirator broke into LA2's

vehicle in Arlington, Texas, and stole LA2's banlt cards, bnnk checks, and personal identifying

infolnnation.

lzh. On or about M arch 7, 2013, Gallo, while wearing a wig and with Steven

Green lying down in the back seat so as to be out of sight of bank personnel

, drove a rental vehicle

into the drive-thru lane of a Bnnk of America in Cedar Hill

, Texas, and presented a check in the

amount of $980 drawn from the accotmt of M S mld made payable to RM 1.

On or about M arch 16, 2013, an unknown co-conspirator broke into AL's

place of business and stole AL's bnnk checks.

On or about M arch 20, 2013, an unknown co-conspirator broke into RW

vehicle in Dallas, Texas, and stole RW 's bank cardss bnnk checks, and personal identifying

inform ation.

l(k. On or about M arch 20, 2013, an unknown co-conspirator broke into SV's

vehicle in M esquite, Texas, mzd stole SV's bnnk cards,' bnnk checks, and personal identifying

inform ation.

l1. On or about M arch 20, 2013, an unknown co-conspirator broke into JH 's

vehicle in M esquite, Texas, and stole JH 's bank cards, bnnk checks, and personal identifying

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inform ation.

m m. 0n or about M arch 20, 2013, David Brown and Johnthavias Brown

possessed LA2's, RW 's, SV's, and JH's bank cards, checks and personal identifying inforrftation.

nn. On or about M arch 23, 2013, M oss drove into the drive-tlu.u lane of an

American Bank of Texas, in Sherman, Texas, in the Eastern District of Texas, and presented a

check in the amount of $3,000 drawn from the account of AL and made payable to SA.

On or about M arch 27, 2013, an unknown co-conspirator broke into

M /M EB'S vehicle in Dallas, Texas, and stole M /M EB'S bank cards, bank checks, and personal

identifying information.

pp. On or about M arch 27, 2013, David Brown possessed M /M E. B's bnnk

chècks and brmk cards.

Qq.

vehicle in Trophy Club, Texas, in the Eastern District of Texas, and stole JG1's personal

idcntifying information, bank cards, and bank checks.

n'. On or about April 19, 2013, an unknown co-conspirator broke into DM 1's

0n or abèut April 12, 2013, an lmknown co-conspirator broke into JG1's

vehicle, SK 1 's vehicle, OS's vehicle, BE's vehicle, and VS 1's véhicle, a11 in Plano, 'fexas, in the

Eastern District of Texasj and stole personal identifying information, bank checks and bank cards

related to the DM I, SKI, GS, BE, and VSI.

ss. Between on or about M ay 1, 2013 and June 14, 2013, Shelton Green

. 

'

oàserved fraudulent transactions, as described in paragraphs 7 and 8 above, from a surveillance

vehicle nearby financial institm ions, including W ells Fargo Banks and Chase Banks.

Cunningham participated in the fraudulent transactions that Shelton Green observed.

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t1. 0n or about M ay 3, 2013, an unknown co-conspirator broke into JA2's

vehicle in Plano, Texas, in the Eastern District of Texas, and stole JA2's bnnk cards, bazlk checks,

and personal identitking information.

uu. On or about M ay 13, 2013, an unknown co-conspirator broke into PT's

vehicle in Tyler, Texas, in the Emstern District of Texas, and stolc PT's bnnk cards, brmk checks,

and personal identifying information.

m . On or about M ay 13, 2013, an llnknown co-conspirator broke into Jlw's

vehicle in M ansfield, Texas, and stole JL's bank cards, bpnk checks, and personal identifying

information.

ww. On or about M ay 14, 2013, an llnknown co-conspirator broke into AA2's

vehicle in Dallas, Texas, mld stole AA2's bank cards, bnnk checks, and personal identifying

information.

u . On or about M ay 14, 2013, an unknown co-conspirator broke into KS's

vehicle in Flower M ound, Texas, in the Eastern District of Texas, and stole KS's oredit union cards

(

and personal identifying information.

yy. On or about M ay 15, 2013, M oss drove into the drive-thnl lane of a

Viewpoint Bnnk in Allen, Texas, in the Eastern District of Texas, :nd presented check number 836

in the mnount of $967 drawn from the account of JL and m ade payable to JA2.

zz. On or about M ay 15, 2013, M oss drove into the drive-thru lape of a

Viewpoint Bank in Garland, Texas, and presented check number 837 in the am otmt of $865 drawn

from the account of JL and made payablq to JA2.

aaa. 0n or about M ay 15, 2013, M oss drove into the drive-tlmz lane of a

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Vitwpoint Bank in Coppell, Texas, and presented a check in the amount of $990 drawn from the

account of AA2 and made payable to JA2.

bbb. On or about M ay 16, 2013, an unknown co-conspirator broke into KJ's

vehicle in Allen, Texas, in the Eastern Disttict of Texas

, and stole KJ's benk cards and KJ's and

BJ's personal idcntifying intbrmation.

ccc. On or about July 1, 2013, Shelton Grecn knowingly possessed the

following items at 3922 M yrtle Street, Dallas, Texas tstMyrtle Street Safehouse''): 82 stolen

credit cards, 16 stolen personal checks, 55 stolen drivers' licenses, 39 stolen social security cards,

6 stolen medicare cards, and 3 stolen United States passpods belonging to a total of 98 different

individuals. JAz's driver's license and bank cards, KJ's and BJ's Social Secmity Cards, KS's

driver's license and credit lmion card, JG1's driver's license, DM 1's United States Passpqrt

, and

SK1's driver's license were among the stolen items at the M yrtle Street Safehouse. Green

recruited Shelton Green and Cunningham to the conspiracy. Cunningham brought the stolen

credit cards, checks, and personal identifying inform ation of the victim s to the M yrtle Street

Safehouse. Cunningham also brought other co-conspirators

, including Steven G reen; to stay at

the property when thcy were in thc area.

ddd. On or about July 7, 2013, an unknown co-conspirator broke into SD's

vehicle in Plano, Texas, in the Eastern District of Texas, and stole BD's bank cmds, bank checks,

and personal identifying 'intbrmation.

eee. On or about July 7, 2013, an unknown co-conspirator broke into JD's

vehicle in Plano, Texas, in the Eastern District of Texas, and stole JD 's brmk cards, bnnk checks,

and personal identifying information.

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fff. On or about July 8, 2013, an unknown co-conspirator broke into AD's

vehicle in Lewisville, Texas, in the Eastern District of Texas, and stole AD's bank cards, bank

checks, and pcrsonal identifying infbrmation.

ggg. On or about July 8, 2013, an unknown co-copspirator broke into DL's

vehicle in Grand Prairie, Texas, and stole Dla's bank cards, bank checks, and personal identifying

inlbnuation.

hhh. On or about July 9, 2013, an lmknown co-conspgator broke into DP's

vehicle in Denton, Texas, in the Eastern District of Texas, and stole DP's, BW 's and CW 1's bnnk

cards, bank checks, and personal identifying inform ation.

iii. On or about July 9, 2013, an unknown co-conspirator broke into VS2's

vehicle in Denton, Texas, in the Eastern District of Texas, and stole VS2's bnnk cards, bank

checks, and personal identifying information,

jjj. On or about July 9, 2013, Johnthavia, Brown possessed DP's, BW 's,

CW 1's, SD 's, AD's, DL's, and VS2's brmk cards, bank cltecks and personal idontifying

inform ation.

kkk. On or about July 19, 2013, an unknown co-conspirator broke into M D2's

,

KH's, Sl's, and JB's vehicles, a11 in Plano, Texas, in the Eastern District of Texas, and stole

M D2's, KH 's, SI's, and JB's bank cards, bnnk checks and personal identifying information.

111. On or about September 16, 2013, Cunningham possessed a bnnk check

owned by SF and SF's personal identifying information. Cunningham also, while driving a

rental vehicle and in an attem pt to conceal the true license plate of the vehicle, had a Texas license

plate taped over the Florida license plate that was affixed to the rental vellicle.

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mmm . On or about Septembcr 27, 2013, atl unknown co-conspirator broke into

JG2's vehicle in Richardson, Texas, in the Eastern District of Texas, and stole JG2's bnnk cards,

brmk checks, and personal identifying information.

nnn. On or about September 30, 201j, an unknown co-conspirator broke'into

AS's vehicle in Rockwall, Texas, and stole AS's bank cards, bank checks, and personal identifying

inform ation.

ooo. On or about October 1, 2013, M oss and Scott used AS's bnnk card at a gas

station in Dallas, Texas.

ppp, 0n or about October 8, 2013, ml unknown co-conspirator brokt into M 'Il's

. 

'

vehicle in Dallas, Texas, and stole Al-ll's bank cards, bnnk checks, and personal identifying

information.

qqq. On or about October 14, 1013, an unknown co-conspirator broke into JK's

vehicle in North Richland Hills, Texas, and stole .1K'S bank cards, bnnk checks, and personal

identifying infermation.

nT. On or about October 16, 2013, Reynolds drove into the drive-thru lant of a

Viewpoint Bank in Garland, Texas, and presented a check in the amotmt of $987 drawn from the

account of JK and m ade payable to JG2,

sss. On or about October 19, 201 3, an unknown co-conspirator broke into AT's

vehicle in Hurst, Texas, and stole AT's bank cards, bnnk checks, and personal identifying

information.

ttt. On or about October 21, 2013, Rcynolds drove into the drive-thru lane of a

Viewpoint B ank in Oarland, Texas, and presented a check in the amount of $987 drawn from the

Page l 5 of 27

GREEN, ET AL - INDICTM ENT

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Case 4:14-cr-00136-RAS-DDB DocMm ent 1 Filed 08/13/14 Page 16 of 27 PagelD #: 16

account of AT and made payable to AHI.

uuu. On or about N ovem ber 1 1, 2013, an unknown co-conspirator broke into

JP's vehicle in the M iami, Florida area and stole JP's personal identifying information, bartk cards,

and bank checks.

vvv. On or about November 16, 2013, Steven Green possessed a sheet of paper

that contained practice signatures of PT, and PT's name, address and date pf birth, and JP's bank

chicks.

ww w. On or about N ovem ber 16, 2013, an Ilnknown co-conspirator broke into

SK7's vehicle in Coppell, Texas, and stole SK2's bank cards, bank checks and personal

idtntif/ng information.

xxx. On or about November 16, 2013, M oss, Scott and Reynolds used Sr 's

bnnk card at Narious stores.

yyy. On or about November 18, 2013, an unknown co-conspirator broke into

BM 's vehicle in M cKinney, Texas, in the Eastern District of Texas, and stole BM 's bank cards,

bnnk chccks and personal identifying information.

zzz. On or about November 18, 1013, Moss, Scott and Reynolds used BM 's

bank card at a retail store in Fairview, Texas, in the Eastern District of Texas.

aaaa. On or about December 10, 2013, Cunningham broke into K'Nl-l's vehicle

in Rowlett, Texas, and stole IkNH'S bank cards, bank checks, and perqonal identifying

inform ation.

bbbb. On or about D ecem ber 10, 2013, C unningham broke into IH 's vellicle in

Rowlett, Texas, and stole IH's bnnk cards, bank checks, and personal identifying inform ation.

Page 16 of 27

GREEN, ET AL - INDICTMENT

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Case 4:14-cr-0O136-RAS-DDB Document 1 Filed 08/13/14 Page 17 of 27 PagelD #: 17

Cunningham also, while driving a rental velaicle, possessed a Texas license plate under the front

passenger seat that had been reported stolen eazlier that day.

cccc. On or about December 17, 2013, Kamesha Brown, wllile driving a rental

vehicle, possessed 51 stolen item s, including 14 driverq' licenses, 1 Social Security Cazd, 10 bnnk

checks, and 26 bank cards. Among the stolen items Kamesha Brown possessed was M D2's

Texas driver's license and bank card.

dddd. On or about December 23, 2013, an unknown co-conspirator broke into

CW 2's vehicle in Richardson, Texas, and stole CW 2's bank cards, bank checks, and personal

identifying inform ation.

çeçe, On or about December 23, 2013, W renn and M oss used CW 2's bnnk card

at a retail store in Richardson, Texas.

ffff. On or about December 24, 2013, arl unknown co-conspirator broke into

M G's vehicle in Plano, Texas, in the Easterh District of Tèxas, and stole M G's bank cards, bnnk

checks, and personal identifying information.

gggg. On or about December 24, 2013, W renn and M oss used M G's bnnk card at

various retail stores in Plano, Texas, in the Eastern District of Texas.

hhhh. On or about December 29, 2013, an llnknown co-conspkator broke into

D/DF'S vehicle in Plano, Texas, in the Eastern District of Texas, and stole D/DF's bank cards,

bnnk checks, and personal identifying inform ation.

iiii. On or about December 24, 2013, W renn used D& F's bnnk card at various

gas stations in Plano, Texas, in the Eastern District of Texas.

In violation of 18 U.j.C. j 1349.

Page 17 of 27

GREEN, ET AL - JNDICTM ENT

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Case 4:14-cr-00136-RAS-DDB Docum ent 1 Filed 08/13/14 P

age 18 of 27 PagelD #: 18

Counts Tw o throuzh Seventv-six

Violation: 18 U.S.C. jj 1028A and 2

(Aggravated ldentity Theft)

On or about the following dates, in the Eastern District of Texas and elsewhere

, the

following deftndants, aided and abetled by others known and llnknown to the Grand Jury, did

knowingly possess, transfer, and use, without lawlkl autholity, the following m eans of

identifkation of another person's, during and in relation to a violation of 18 U.S.C. j 1349

(conspiracy to commit bnnk fraud), as alleged in Count One of this lndictment:

Count Defendant Date Name M eans 0#

Identification

Green and Cosby 3/22/12-3/27/12 KO Commerce Barlk

checks

Green, Cosby lww 3 ja-jwjyjz I.o Viewpoint Bank and Painton checks

4 Green and Cosby 4/3/12 LW First Fidelity Bnnk

checks

5 Green and Cosby A112 Oklahpma Central

4/3/12 Credit Union checks

Grecxf, Cosby ' Texa 6 d P an ainton 9/26/12 - 10/5/12 CB s driver's

license

Green, Cosby Tçxas driver's

7 mld Kam esha 9/19/12 M M 1 li B ccnse, bank cards,

row n ' G bnnk checks

reen, Cosby ' Texas driver's

8 and Kamesha 9/19/12 ET li B cense, bank cards,

rown bnnlc checks

9 Green 3/22/12 M I . 

- United States bank I

checks

10 G reen 4/3/12-4/4/12 A B sank of com m erce

Sh checks elton Green w j/la 1 1 Jaz Capital 0ne Bnnk and Cunningham card

Pagç 18 of 27

OREEN: BTAL . m DICTMENT

Case 0:20-tp-60008-WPD Document 1 Entered on FLSD Docket 03/23/2020 Page 29 of 38
Case 4:14-cr-00136-RAS-DDB Docum ent 1 Filed 08/13/14 Page 19 of 27 PagelD #: 19

Count Defendaht Daté Nam e M eans of

Identifieatinn

Possessed and Used

Shelton Green 12 7/1/13 jjxjj u s passport and Cunnin ham . .

13 7/ Shelton Green j/jg su l Texas driver's

and Cunhingltam license

Shelton Green )jf) 9 

,

14 7 J()1 Texas driver's

and Cunningham license

15 7/1/13 K Shelton Green

and Cunnin ham J Social Security Card

16 7/1/13 Shelton Green

and Cunningham BJ Sooial Security Card

Texas driver's

Shelton Green yjyja u 7 s license, Your

and Cunningham Community Credit

Union card

Texas driver's

18 Cunningham 9/13/13-9/16/13 SF license, Social

securkt card

Chmse Bank checks,

Capital One Barlk

, card, Citizens

19 Cunningham 12/10/13 KNH National Bnnk card

,

Navy Federal Credit

Union card, Chase

Bank card

Texas driver's

lictnse, Chase Bank

20 Cunningham 12/10/13 IH checks and card,

W ells Fargo checks

and card

Texas driver's

license, Social

21 Doe and Gallo 8/30/13-10/25/13 CD Security Card

,

Am erican National

B/nk of Texas card

Doe and Gallo 10/6/12- Firàt State Bank 10/25/12 JA 1

checks

Page 19 of 27 .

GREEN, ET M . . INDICTMENT

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Case 4:14-cr-00136-RAS-DDB Document 1 Filed 08/13/14 Page 20 of 27 PagelD #: 20

C ount D efendant D ate Nam e M eans of

Identlficatien

Possessed and Used

Texas driver's

Doe and Steven j j/j4ylz EM 1 license 23 , Citizens

Green National Bank card

24 D0e and Steven 1 j/l4yjz SM Texas identification

G reen card

Texas driver's

D0e and Steven KG license, Social

25 11/14/12 Security Cazd G reen ,

American National

. Bank oç Texas card

26 11/14/12 D0e and Steven KT Texas driver's

G reen license

Doe arzd Steven SP Texas driver's

27 11/14/12 license G recn , U SA A Bank

cards

Ttxas driver's

28 8/13/13 SC Doe and Steven license, Chase Bnnk

Green withdrawal slips,

Chase Bartk card

* Doe and Steven g/ja/l? 'j-u USAA Federal 29

Green Savings Bnnk check

Doe and Steven Texas driver's

30 8/13/13 SS license G reen , Chase Bank

card

31 8/13/13 LC Doe and Sttven Chevron Federal

G reen Credit Union Check

D 0e apd Steven Texas driver's

32 8/1/13-8/13/13 DM 2 license G reen . , W ells Fargo

Bank card

Steven G reen and Texas driver's

33 1/1/13-3/7/13 RM 1 license Gallo , Bank of

Am erica card

34 3/1/13 Steven Green and

G - 3/7/13 M S Chase Bank checks allo

35 Steven G reen 5/13/13-11/16/13 PT N nm e, date of birth

36 Steven G reen 11/11/13- JP SunTrust Bank 1 1/16/13 checks

Page 20 of 27

GREEN, ET AL - INDICTMENT

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Case 4:14-cr-0O136-RAS-DDB Docum ent 1 Filed 08/13/14 Page 21 of 27 PagelD #: 21

Count Defendant Date Name . M eans of

. 

Idejjtm cation

Possessed and Used

37 Gallo 8/14/12- sank checks 12/19/12 AB/LB .

38 Gallo 10/5/12-10/24/12 EM 2 Citibrmk checks

39 G allo 8/14/12- Texas driver's 12/19/12 M M 2

license

David Brown and 3/2/13 40 Johnth -3/20/13 Bnnk of Ameiica avias LA 2

Brpwn checks

sank oj- America

David Brown and checks, Texas

3/20/13 driver s licensc , 41 Johnthavias RW ,

Brown Social Security

Card, Resource One

Credit Union cards

D avid Brown and ' Texas driver's 3/20/13

42 Johnthavias SV license

, Social

Brown Security Card

David Brown and Texas driver's

43 Johnthavias 3/20/13 JH license, Citicredit

Brow n ' Union card,

44 David Brown 3/27/13 M /M EB Chase Bank checks

Brad Dean's nnme,

45 Johnthavias jjyfqs- yjojjj so Credit Unioh

Bror n account numbers,

address

46 7/8/13 Johnthavias Capital One Bank Br - 7/9/13 AD

own checks

Texas driver's

license, Diedra

' Lee's Perm anent

Jahnthavias Resident card 47 7/8/13-7/9/13 DL B ,

rown Chase Bnnk card,

Bpnk of America

card, Social Secuzity

Card

Page 21 of 27

UREEN. ET AL - INDICTMENT

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Case 4:14-cr-00136-RAS-DDB Document 1 Filed 08/13/14 Page 22 of 27 PagelD #: 22

Count D efendant D ate Nam e M eans of

Identification

Possessed and U sed

Nascoga Federal

Credit Union

Johnthavlas checks 48 ,ys/j? op , Texas

Brewn driver s, jjoyse,

Nascoga Federal

. Credit Union card

49 7/9/13 BP Jobnthavias

Brown Citi Bank card

50 Johnthavias yfojqj sw A merican Bank of

Brown . Texas card

' Texas driver's

license, Landmark

Johnthavias Bank card,

B 7/9/13 CW 1 American Bnnk of

row n

Texas card, date of

birth Social t

Secunt Card

M issouri driver's

Johnthavias licenqe, W ells Fargo

52 7/9/13 VS2 Brmk card Brow n , Chase

B ank card, Social

security Card

M etropolitan

Kamesha Brown 4/2/1à - 4/3/13 MR National Bank

checks

Texas driver's

Kamesha Brown 7/19/13-12/17/13 M D2 license, Bank of

' Am erica card

55 K am esha Brow n 4/3/12 M D1 Name, Bank of

America account

56 Freelove 1/22/13-2/5/13 Nnme M W

57 Freelove 1/24/13-2/5/13 Nmne AA1

58 Freelove 1/24/13-2/5/13 LA 1 Name

59 Freelove 1/25/13-2/5/13 EA N amc

60 Freelove 1/25/13-2/5/13 RM 2 N am c

Page 22 of 2)

GREEN, ET AL - m DICTMENT

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Case 4:14-cr-00136-RAS-DDB Document 1 Filed 08/13/14 Page 23 of 27 PagelD #: 23

Count Defendant Date Name M eans of

Identifitation

Possessed and Used

M oss and Texas driver's

61 1/29/13-2/5/13 DB license Bank of F

reeleve A ! g m erlca car .

62 2/3/13 M oss and

F -2/5/13 D/PP Chase Bank clwck retlove

63 M oss 3/16/13- Bank of America 3/23/13 AL

checks

Texas driver's

64 M pss 5/3/13-5/15/13 JA2 liccnse, Viewpoint

. ssnk card

65 M oss 5/14/13-5/15/13 AA2 Chase Bank checks

Texas driver's

66 M oss 12/10/12-3/23/13 SA license, American

Bank of Texas card

67 W renn ai)d M oss 12/23/13 Bank card CW

2

68 W renn and M oss 12/24/13 M G Bank çards

W yenn 12/29/13 Barlk of America

69 D/DF card, Chast Bank

card

70 Scott and M oss 10/1/13 First Convenience . AS B

snk card

Scott, M ess, and 11/16/13 CitiBank card

Reynolds SK 2 Am ,

erican Express

card

Scott, M ess, and 1 1/18/13 . Chase Bank card

Reynolds BM Chase withd ,

rawal

sli

Reynolds 9/27/13-10/16/13 . Texas driver's

73 JG2 license

, Social

Sectlri Card

74 Reynelds 10/8/13-10/21/13 Texas driver's AH 1

license

75 Reynnlds 10/14/13-10/16/13 Texas Trust Credit JK

. Union checks

76 Reynolds 10/19t13-10/21/13 Bank of America AT

checks

Page 23 of 27

GREEN, ETM - INDICTMENT

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case 4:14-cr-Q0136-RAS-DDB Docum ent 1 Filed 08/13/14 Page 24 of 27 PagelD #: 24

Each Count in violation of 18 U.S.C. jj 1028A and 2.

XOTICE OF INTENT TO SEEK CRIMINAL FORFEITURE

Pllrsuant to 18 U.S.C. j 982(a)(2)(A) and 28 U.S.C, i 2461

As the result of committing the offenses alleged in this Indictm ent, the defendants shall

forfeit to the U nited States pursuant to,'18 U.S.C, j 981(a)(2)(A) and 28 U.S.C. j 2461 a11 property,

real or personal, that constitutes or is derived from proceeds tracealle to the aforementioned

offense including but not limited to the following:

Cash Proceeds

Approkim ately $1,374,982.68 in United States cm-rency and al1 interest and proceeds

traceable thereto, in that such sub in aggregate is property constimting, or derived from, proceeds

obtained directly or indirectly, as the result of the foregoing offenses, alleged in this Indictment.

Substitute A:sets

If any of the property described above as being subject to forfeiture, as a result of any act or

om ission of thc defendants -

(a) cannot be located upon the esercise of due diligenct; 

(b) has been transferred or jold to, or deposited with a third person;,

(c) has been placed beyond the jurisdiotion of the cout't;

(d) has been substantially diminished in value; or

(e) has been commingled with other property which cnnnot be

subdivided without diffculty;

it is the intent of the United States, pursuant to 18 U.S.C. j 982(a)(4), to seek forfeiture of any

other property of the defendants up to the value of the above forfeitable property, including but not

lim ited to a1l property, both real mld personal owned by the defendants.

Pago 24 ûf 27

GREEN, ET AL . INDICTMENT

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Case 4:14-cr-0Q136-RAS-DDB Docum ent 1 Filed 08/13/14 Page 25 of 27 PagelD #: 25

By virtue of the commission of the offenses alleged in this Indictment, any and a1l interest

the defendards have in the above-described property is vested in and forfeited to the United States.

A TRUE BILL

bRAHD MIRY FoREpERsox

JOHN M . BALNS

IJNITED STATES ATTORNEY

CH Y STOPHER A . EA SO

A ssistant United States Attom ey

$ . ( 3 .-lN

Date

Page 25 of 27

GREEN, ET M - m DICTMENT

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case 4:14-cr-00136-RAS-DDB Docum ent 1 Filed 08/13/14 Page 26 of 27 PagelD #: 26

IN THE U NITED STATES DISTRICT COU RT

FOR THE EASTERN DISTRICT QF TEM S

SHERM AN DIVISION

UNITED STATES OF AM ERICA

NO. 4:14Ck

Judge

ROBERT AARON GREEN (1)

a k a. ç(Li1 D ave''

CHRISTOPHER HENRY COSBY (2)

a.k.a. t$Li1 Chris''

DIANNA LXIGH PAm TON (3)

SHELTON JERROD GREEN (4)

a k a ç'Shank''

DEMEYRIS JEROME

CUNNINGHAM (5)

a k a. $$M eM e''

MALLORI L:E M OSS (6)

a k a çsBllnny''

BENNY LEE DO ,E JR. (7)

a.k,a. T'J, Jay and JR''

swvsx 'réuRus ellssx (8)

a ka. <tspud''

CHRISTINA LYNN GALLO (9)

DAVID LEE BROW N (10)

JOHNTHAVIAS KEON BROW N (11)

a k a. ''JT''

KAMESHA NYCOLE BROW N (12)

MOSES GEORGE FREELOVE (13)

WENDY LEE W IIENN (14)

CHIUSTIAN DOM INQUE SCOTT (15)

KATHERINE JONES REYNOLDS (16)

NO TICE O F PEN ALTY

C ount One

s?iolation: 18 U.S.C. j 1349

(Conspiracy to Commit Bnnk Fraud)

A fine of not more than $1,000,000, imprisonment

for not m ore than 30 years, and a Tel'm of Supervised

Penaltv:

Pagc 26 of 27

GREEN, ET AL - NOTICE OF PENALTY

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Case 4:14-cr-00136-RAS-DDB Document 1 Filed 08/13/14 Page 27 of 27 PagelD #: 27

Release for not more than 5 years,

. Special

Assessm ent: $100.00

Counts Tw o throuqh SevenW -six

Violations.

Penalty:

18 U.S.C. j 1028A

For each count; two years imprisonment in addition to the punisbment

provided by the predicate felony; a fine not to exceed $250,000, or not more

than the greater of twice the gross gain to the defendant br twice the gross

loss to one other than the defendant, or both; supervised release of not m ore

than onç year.

For each count: $100.00

Special

A ssessm ent:

Page 27 of 27

OREEN, ET AL - NOTICE OF PENALTY

Case 0:20-tp-60008-WPD Document 1 Entered on FLSD Docket 03/23/2020 Page 38 of 38