AO 106 (Rev. 04110) Application for a Search Warrant 

UNITED STATES DISTRICT COURT 

for the 

Southern District of Ohio 

In the Matter of the Search of 

(Briefly describe the property to be searched or identify the person by name and address) 

2000 Chevrolet Silverado pickup truck 

VIN: 1GCEC14W3YZ117399 

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Case No. 

APPLICATION FOR A SEARCH WARRANT 

I, a federal law enforcement officer or an attorney for the government, request a search warrant and state under 

penalty of perjury that I have reason to believe that on the following person or property (identify the person or describe the 

property to be searched and give its location): 

See Attachment A 

located in the Southern District of ~~~~~~~~~~~-

Ohio , there is now. concealed (identify the 

person or describe the property to be seized): 

See Attachment B 

The basis for the search under Fed. R. Crim. P. 41 ( c) is (check one or more): 

~evidence of a crime; 

0 contraband, fruits of crime, or other items illegally possessed; 

0 property designed for use, intended for use, or used in committing a crime; 

0 a person to be arrested or a person who is unlawfully restrained. 

The search is related to a violation of: 

1 s u ~oee ~fig on B k R bb d I 'd t 1 Offense Description an o ery an nc1 en a ch'r'ries 

[and others in affidavit] [See Affidavit] 

The application is based on these facts: 

See attached Affidavit 

~ Continued on the attached sheet. 

0 Delayed notice of __ days (give exact ending date if more than 30 days: ) is requested - --- --,.<; 

under 18 U.S.C. § 3103a, the basis of which is set forth on the att ed sheet. 

Robert G. Moledor, Task Force Oficer 

Printed name and title 

Sworn to before me and signed in my presence. 

Date: ~(pl Jo /8 - City and state: CmUj{} ~_l-;; 14 -+) CJt+ __,_ Printed nam 

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AFFIDAVIT 

I, Robert G. Moledor, a Task Force Officer with the Federal Bureau oflnvestigation 

(FBI), Cincinnati Division, being duly sworn, depose and state as follows: 

1. I have been employed as a police officer of the Columbus Division of Police for 

28 years, and am currently assigned to the Cincinnati Division's Columbus Resident Agency. I 

have been assigned in an investigative capacity as a Detective and Task Force Officer (TFO) for 

20 years. In my current assignment I investigate gang activity, criminal enterprises, narcotics, 

fugitives, robberies and other violent crimes. I have worked as a law enforcement officer for a 

total of 33 years and as such I have attended the Central Texas Regional Police Academy, the 

United States Army Criminal Investigations course as well as the Columbus Police Academy and 

have been awarded certificates from the Texas Commission on Law Enforcement Officer 

Standards and Education (TCLEOSE) and Ohio Peace Officer Training Commission (OPOTC), 

as well as numerous hours of law enforcement training. While employed by the FBI, I have 

assisted in the investigation of federal criminal violations related to numerous violent incident 

crimes including bank robbery. I have gained experience through FBI in-service training and 

everyday work related to conducting these types of investigations. 

2. As a Task Force Officer with the FBI, I am authorized to investigate violations of 

laws of the United States and to execute warrants issued under the authority of the United States. 

3. I am investigating the activities of JABRAEL YN A. BUNN of 1120 Ninth Street 

NW, Canton, Ohio. As will be shown below, there is probable cause to believe that BUNN was 

involved in the robbery of PNC Bank, 438 Lake Avenue NE, Massillon, Ohio, in violation of 

Title 18, United States Code, Section 2113. I am submitting this affidavit in support of a search 

warrant authorizing a search of Bunn's 2000 Chevrolet Silverado truck, VIN 

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1GCEC14W3YZ117399, bearing Ohio license HDR4655 (the "Vehicle"). The vehicle is 

secured at the Columbus Police Impound Lot located at 2700 Impound Lot Road, Columbus, 

Ohio. The vehicle is more particularly described in Attachment A, for the items specified in 

Attachment B hereto, which items constitute instrumentalities, fruits, and evidence of the 

foregoing violation. I am requesting authority to search the entire vehicle for items specified in 

Attachment B, and to seize all items listed in Attachment B as instrumentalities, fruits, and 

evidence of the crime. 

4. The statements in this affidavit are based in part on information provided by 

victims as well as observations by Affiant and other law enforcement officers. Since this 

affidavit is being submitted for the limited purpose of securing a search warrant, I have not 

included each and every fact known to me concerning this investigation. I have set forth only the 

facts necessary to establish probable cause to believe that evidence, fruits, and instrumentalities 

of a violation of Title 18, United States Code, Section 2113, are presently located within the 

vehicle in the possession of the Columbus Police. 

STATUTORY AUTHORITY 

5. This investigation concerns alleged violations of Title 18, United States Code, 

Section 2113 relating to the robbery of PNC Bank, a federal insured institution. Title 18, United 

States Code, Section 2113c prohibits a person from receiving, possessing, concealing, storing, 

barters, selling, or disposing of any property or money or other thing of value which has been 

taken or stolen from a bank, credit union, or savings and loan association. 

BACKGROUND OF THE INVESTIGATION 

6. On 09/14/2017 at 11:10 am, a lone black male entered PNC Bank, 

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438 Lake Avenue NE, Massillon, Ohio, a federally insured institution, and approached the victim 

teller. The subject stated he wished to get some money at which time the teller requested his 

debit and identification card. The subject stated he had neither but did have a gun. Subject 

brandished a handgun and ordered all parties to put their hands in the air. He then threw his 

back pack to the teller and ordered her to fill it with money. He demanded that she not provide 

him bait money or marked bills. 

7. The subject moved on to a second teller and demanded the same. While she was 

filling the bag, the subject pointed his weapon at the Mortgage Officer who was in his office and 

on the phone. The subject ordered the employee off of the phone. He continued to waive his 

weapon around the bank while the second teller was filling the bag. After retrieving the bag 

from the second teller, the subject grabbed the bank's candy from the teller counter then exited 

the front door of the bank and walked northbound. 

8. The subject was last seen entering a getaway vehicle driven by a second unknown 

subject. Two witnesses observed the subject enter a white short bed pick-up truck which was 

parked on Gail Street NE at the rear of 1413 Amherst Avenue NE, Massillon, Ohio (March's 

grocery store). The two subjects drove off and were last seen westbound on Gail Street NE. 

9. On 09/17/2017, SA Andrew J. Hayden was contacted by the Columbus Police 

Officer Luke A. Velie advising they had found the bank robbery getaway truck abandoned near 

an apartment building on the north side of Columbus, Ohio. The located vehicle was a 2000 

Chevrolet Silverado pickup truck, white in color, VIN 1GCEC14W3YZ117399, bearing Ohio 

license HDR4655. The truck had a broken passenger door handle rendering the passenger door 

inoperable from the outside of the truck. The vehicle was registered to JABRAEL YN BUNN of 

1120 Ninth Street NW, Canton, Ohio. A subject meeting the description of the bank robber 

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appeared to have abandoned the truck after which he car jacked a Toyota Corolla from a nearby 

apartment resident. 

10. Later on 09/17/2017, four subjects were located by law enforcement driving the 

stolen Toyota in West Milford, WV. The vehicle refused to stop for the police after which one 

subject (later identified as BRIAN ZIRO)"fired rounds from that moving vehicle at responding 

law enforcement. The vehicle crashed into a ditch and all four subjects fled on foot. At one 

point, ZIRO separated himself from the crowd and was spotted later by law enforcement while 

he walked across a nearby bridge. ZIRO pulled his weapon on the officers at which time he was 

shot and killed by the police. 

11. The driver of the Toyota Corolla was identified as JABRAEL YN A. BUNN, 

DOB 09/24/1996, SSN 302-98-7763, home address 1120 9th Street NW, Canton, Ohio. 

12. The deceased (identified as the bank robber) was positively identified through 

DNA as BRIAN ZIRO, black male, 5'9" tall, 185 pounds, DOB 08/28/1996, SSN xxx-xx-5809, 

last known address 1074 Scott Street, Columbus, Ohio. 

13. The remaining two passenger were identified as JACOB M. HUNTER, white 

male, DOB 08/01/1999, SSN xxx-xx-9936, home address 1120 9th Street NW, Canton, Ohio, 

and JADA N. HILL TON, black female, DOB 11/18/1998, SSN xxx-xx-9068, last known address 

1120 9th Street NW, Canton, Ohio. 

14. JADA HILLTON was previously interviewed by the FBI in West Virginia 

following the aforementioned car chase and shooting. At that time, HILL TON indicated she and 

BUNN didn't wake up on 09/14/2017 (day of the bank robbery) until 1:00 pm. 

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15. On 12/05/2017, HILL TON was located in Canton, Ohio and interviewed by SA 

Hayden. HILL TON admitted to lying to the West Virginia authorities earlier in an effort to 

protect herself and BUNN. HILLTON stated she and BUNN actually woke up between 9:00 am 

and 10:00 am on 09/14/2017. BUNN left the house at that time with ZIRO but wouldn't tell 

HILL TON where he was going. BUNN returned home with ZIRO between 11 :30 am and 12:00 

pm on the same day. 

16. A local search warrant was executed on T-Mobile seeking cell site tower data and 

call records for the cellular phones utilized by BUNN and HILLTON. The FBI's Cellular 

Analysis Survey Team (CAST) reviewed the call records and cell site data provided by T-Mobile 

in response to the search warrant. The results indicated BUNN' s phone was in the near vicinity 

of the victim bank and utilizing nearby cellular towers during the commission of the robbery by 

ZIRO on 09/14/2017. 

17. Two witnesses reported a male meeting the description of ZIRO running from the 

area of the bank and approaching an older model white Chevrolet pickup truck parked in the rear 

of the Marc's grocery store. The male ran up to the passenger door (which had a broken handle) 

and pounded on the window to be let in. Someone in the truck let the male into the truck and 

both sped away. 

CONCLUSION 

18. Based on the aforementioned factual information, your affiant respectfully 

submits that there is probable cause to believe BUNN drove his white 2000 Chevrolet Silverado 

to transport ZIRO to and from the PNC Bank on 09/14/2017 for the purposes of a bank robbery 

in violation of Title 18 U.S.C. § 2113. Lastly, there is probable cause to believe that evidence of 

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the commission of criminal offenses, namely, violations of 18 U.S.C. §§ 2113, is located in the 

truck described above, and this evidence, listed in Attachment B of this affidavit, which is 

incorporated herein by reference, is contraband, the fruits of crime, or things otherwise 

criminally possessed, or property which is or has been used as the means of committing the 

foregoing offenses. 

28. Your affiant, therefore, respectfully requests that the attached warrant be issued 

authorizing the search and seizure of the items listed in Attachment B. 

Robert #<2~ G Moledor 

Task Force Officer 

Federal Bureau of Investigation 

Sworn and subscribed before me this 6th day of April, 2018. 

UNITED ST ATES MAGISTRATE JUDGE 

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ATTACHMENT A 

2000 Chevrolet Silverado pickup truck 

VIN: 1GCEC14W3YZ117399 

Captioned 2000 Chevrolet Silverado is white in color and may have a broken exterior 

passenger door handle. The truck was last bearing Ohio license# HDR4655. 

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ATTACHMENT B 

LIST OF ITEMS TO BE SEIZED 

1. Any and all notes, documents, records, or correspondence, in any format and 

medium -(including, but not limited to, envelopes, letters, papers, e-mail 

messages, chat logs and electronic messages, and handwritten notes) pertaining 

to any financial institution. 

2. Any and all documentation detailing maps or directions to or from any financial 

institution. 

3. Any and all documentation pertaining to BRIAN ZIRO, JABRAELYN BUNN, 

JADA HILL TON or JACOB HUNTER. 

4. Any and all documentation relating to the ownership of the Chevrolet Silverado 

being searched. 

5. Any pieces of candy or candy wrappers. 

B-1 

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