AO 91 (Rev. 11/11) Criminal Complaint

UNITED STATES DISTRICT COURT

for the

__________ District of __________

United States of America )

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)

)

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v.

Case No.

Defendant(s)

CRIMINAL COMPLAINT

I, the complainant in this case, state that the following is true to the best of my knowledge and belief.

On or about the date(s) of in the county of in the

District of , the defendant(s) violated:

Code Section Offense Description

This criminal complaint is based on these facts: 

u Continued on the attached sheet.

Complainant’s signature

Printed name and title

$JHQWVZRUQDQGVLJQDWXUHFRQILUPHGYLDUHOLDEOHHOHFWURQLFPHDQVSXUVXDQWWR)HG5&ULP3

Date:

Judge’s signature

City and state:

Printed name and title

 Northern District of Texas

Patricia Maldonado 3:22-MJ-0047-BH

November 15, 2019 Dallas

Northern Texas

 18 U.S.C. 2113(a) Bank Robbery

See attached affidavit of FBI SA Randall K. White.

✔

SA Randall K. White, FBI

January 19, 2022

Dallas, Texas IRMA CARRILLO RAMIREZ, U.S. Magistrate Judge FILED

KAREN MITCHELL

CLERK, U.S. DISTRICT 

COURT January 19, 2022

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Affidavit in Support of Application for Criminal Complaint—Page 1 

AFFIDAVIT IN SUPPORT OF 

APPLICATION FOR CRIMINAL COMPLAINT

I, Randall K. White, a Special Agent with the Federal Bureau of Investigation 

(“FBI”), being first duly sworn, hereby depose and state as follows: 

INTRODUCTION

1. I am a Special Agent with the FBI and have been since January 2011. 

During my training and since that time, I have received formal training from the FBI as 

well as training through contact with experts from various law enforcement agencies 

regarding bank robbery investigations, Hobbs Act robberies, and other violent crime 

related offenses. As a result of my training and experience, I am familiar with violations 

of federal laws pertaining to bank robbery and those who aid and abet robbers of 

commercial institutions in their criminal activity. Through my training and experience, I 

am familiar with techniques used to investigate such crimes. As a Federal Agent, I am 

authorized to investigate violations of laws of the United States and to execute warrants 

issued under the authority of the United States. 

2. In preparation for this affidavit, I have discussed the facts of this case with 

other law enforcement agents and officers. The information contained in this affidavit is 

based on my personal knowledge, information I received from other law enforcement 

agents and officers assisting in this investigation, witnesses, and what I have learned from 

the other sources specifically discussed herein. Because this affidavit is being submitted 

for the limited purpose of securing a criminal complaint, I have not included every fact 

known to me concerning this investigation. 

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3. This affidavit sets forth facts establishing probable cause to believe that on 

or about November 15, 2019, in the Dallas Division of the Northern District of Texas, 

and elsewhere, Patricia Maldonado committed the offense of bank robbery, in violation 

of 18 U.S.C. § 2113(a).

PROBABLE CAUSE 

1. The FBI is investigating a series of bank robberies which took place 

between October 22, 2019 and November 15, 2019 in Dallas, Texas in the Northern 

District of Texas. 1 As further described below, based on a report from a citizen who saw 

a news release on the bank robberies, and similarities in the suspect’s appearance, 

clothing, and modus operandi, I believe that Maldonado has committed each of the 

described bank robberies. 

I. Description of Bank Robberies 

A. October 22, 2019 Robbery – Comerica Bank, Dallas, Texas 

2. The first robbery occurred on October 22, 2019 at Comerica Bank, located 

at 2727 Fort Worth Ave., Dallas, Texas, in the Northern District of Texas. On that date, 

at approximately 10:54 a.m., a Hispanic female wearing a blue baseball cap, a gray 

zippered hoodie, khaki pants, black shoes, and heavy makeup entered the bank carrying a 

blue bank bag and displayed a note to the victim teller demanding that all the money from 

the teller drawer, with no dye packs or trackers, or she would pull out a gun. The teller 

gave the suspect $815.60 in cash and the suspect fled the bank on foot. The suspect was 

1

 Each of the victim financial institutions described below were insured, at all times relevant, by the 

Federal Deposit Insurance Corporation.

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not apprehended.

 

B. November 5, 2019 Robbery – Chase Bank, Dallas, Texas 

4. On November 5, 2019, at approximately 2:00 p.m., at Chase Bank, located 

at 6310 E. Mockingbird Ln., Dallas, Texas, in the Northern District of Texas, a Hispanic 

female wearing a white TCU baseball cap, a green jacket, khaki pants, and black shoes 

entered the bank carrying a blue bank bag and displayed a note to the victim teller 

demanding money and that the suspect had a gun. The teller gave the suspect $1,782 in 

cash and the suspect fled the bank on foot. The suspect was not apprehended. 

 

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C. November 12, 2019 Robbery – Comerica Bank, Dallas, Texas 

6. On November 12, 2019, at approximately 10:30 a.m., at Comerica Bank, 

located at 11155 Garland Road, Dallas, Texas, in the Northern District of Texas, a 

Hispanic female wearing a light-colored baseball cap, black jacket, and light colored 

pants, carrying a blue bank bag, entered the bank. The suspect approached the victim 

teller at the counter and produced a note demanding money. The teller gave the suspect 

$390 in cash and the suspect fled the bank on foot. The suspect was not apprehended. 

D. November 15, 2019 Robbery – Chase Bank, Dallas, Texas 

8. On November 15, 2019, at approximately 3:00 a.m., at Chase Bank Bank 

located at 12900 Coit Rd., Dallas, Texas, in the Northern District of Texas, a Hispanic 

female wearing a black jacket with a large pink stripe, a khaki-colored baseball cap, and 

khaki pants, entered the bank. She approached the victim teller at the counter and 

produced a note demanding money and stating that the suspect had a gun. The teller gave 

the suspect $1,000 in cash and the suspect fled the bank on foot. Surveillance footage 

showed the suspect walk to an Exxon gas station located next to the bank and enter a 

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silver in color Jeep Patriot and flee the area. The suspect was not apprehended.

 

II. Similarities between Bank Robberies 

10. Based on similarities in the suspect’s appearance and clothing across 

multiple robberies, including the same apparent blue bank bag being used; similarities in 

the suspect’s modus operandi across multiple robberies, I believe that the same suspect 

has committed each of the above-described robberies and that Maldonado, as further 

detailed below, is that person. 

III. Identification of Patricia Maldonado 

11. The investigation to date has used social media accounts records, witness 

accounts, and law enforcement surveillance to link the suspect identified in the four (4) 

bank robberies offenses above. The investigation has developed evidence that the 

individual identified in the four (4) bank robberies is possibly Patricia Maldonado. 

12. On November 20, 2019, a citizen who had observed a news release 

regarding the robbery suspect flagged down Dallas Police Sgt. P. Ralson #8679. The 

citizen did not have direct knowledge of the offense but had observed the pictures of the 

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unmasked suspect that had been released. The citizen believed that the suspect was 

Patricia Maldonado, a Hispanic female that was approximately 30 years old, who lived 

at 2930 Ramsey Ave. Dallas, TX 75216. The citizen stated that Maldonado did not have 

a vehicle of her own but was known to use a close family member’s vehicle that he 

described as a silver Jeep. The citizen provided a Facebook picture (below left) of the 

person he knew as Patricia Maldonado (below left) that is located as a profile picture on 

the Facebook Account “Patricia Maldonado” 

(https://www.facebook.com/profile.php?id=100039131553171). 

13. Dallas Police Department Detective Stephen Prince was notified and began 

a check of the name Patricia Maldonado at the address 2930 Ramsey Avenue in the 

Dallas Police Department Record Management System “RMS.” That check revealed two 

females by that name had provided that address in previous contacts with Law 

Enforcement. One was 53 years old (at the time of the offense). The other person had a 

birthdate of July 3, 1987 (32 years old at the time of the offense). A Texas Driver License 

check of Patricia Maldonado, date of birth 7/03/1987, revealed that her Texas ID Card 

ID #: 22499433; (picture below second from left) returned to 2930 Ramsey Avenue and 

listed her as 5’3”, 149LBS, with brown hair and brown eyes. Investigators noticed 

immediate similarities in the appearance and physical description of Patricia Maldonado 

and the Robbery suspect (below second from right – ref: 10/22/19 Comerica Bank 

Robbery and below right – ref: 11/15/19 Chase Bank Robbery). 

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14. Investigative research into the Facebook Account revealed multiple related 

accounts. Investigators located a picture (below left) on the Facebook Account “Mayra 

Maldonado” (https://www.facebook.com/mayra.maldonado.9809) where it appears 

Patricia Maldonado is wearing the same sweatshirt as the suspect in the October 21, 2019 

Comerica Robbery (Below Right) 

15. Further investigation performed in Dallas PD RMS and the online 

investigative tool TLOxp regarding the address 2930 Ramsey Avenue Dallas, Texas 

revealed that Patricia’s sister Carolina Maldonado, (aka: Carolina Maldonado Espinosa; 

Date of Birth: 01/27/1984) had also been related to that address for multiple years. 

Further investigation revealed that Carolina Maldonado Espinosa owned a silver 2017 

Jeep Patriot (Texas License Plate: JWW2370; VIN: 1C4NJPBA8HD145888) at the time 

of the robberies. Investigators located two pictures from October 2017 (below) on the 

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Facebook Account “Carolina Maldonado” 

(https://www.facebook.com/carolina.maldonado.902/timeline?lst=100004886705311%3

A100000383741950%3A1574303695) of Patricia Maldonado standing with the same 

Jeep Patriot and inside of it.

16. License Plate Reader activity (below) along with the Facebook pictures

(above) revealed that the Jeep Patriot appeared to be similar in year, color, wheel design 

and model as the suspect vehicle (below right) 

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17. On November 21, 2019, members of the FBI Task Force and the Dallas

Police Department Fugitive Unit who were operating in a covert capacity located the Jeep

Patriot at its registered address: 657 Bow and Arrow Drive, Dallas, Texas 75224. Covert 

Elements observed the vehicle travel to 2930 Ramsey Road, Dallas, Texas. 

18. On January 19, 2022, FBI Task Force Officers with the Dallas Police

Department discovered that Patricia Maldonado had active warrants for her arrest and 

further investigation revealed that she was employed at GlassFloss Industries in Desoto, 

Texas. Officers went to that location and arrested Maldonado without incident.

19. On January 19, 2022, following her arrest on the warrants, FBI Agents

were notified and they went to DPD to question her about the bank robberies. After 

having been Mirandized, Maldonado was questioned and shown four photos from the 

four bank robberies she was believed to have been involved in and she positively 

identified herself as the individual who was identified as the perpetrator of the four 

robberies, including the robbery that occurred at the Chase Bank on November 15, 2019.

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CONCLUSION

4. Based on the facts set forth above, there is probable cause to believe that on

or about November 15, 2019, in the Dallas Division of the Northern District of Texas, 

Patricia Maldonado, knowingly and intentionally committed a violation of 18 U.S.C. 

§ 2113(a), that is, bank robbery, at Chase Bank located at 12900 Coit Road, Dallas,

Texas, a locating within the Northern District of Texas. 

_______________________________ 

Randall K. White 

Special Agent 

Federal Bureau of Investigations 

Agent sworn and signature confirmed via reliable electronic means on January 19, 2022, 

pursuant to Fed. R. Crim. P. 4.1. 

_______________________________________ 

HONORABLE IRMA CARRILLO RAMIREZ 

UNITED STATES MAGISTRATE JUDGE 

NORTHERN DISTRICT OF TEXAS 

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