‘AO 91 (REV.5IB5) Ciminal Complaint AUSA Kartk K, Raman (312) 469-6026 UNITED STATES DISTRICT COURT «> NORTHERN DISTRICT OF ILLINOIS RECEIVED EASTERN DIVISION MAY 2 8 2010 UNITED STATES OF AMERICA ws s COMPLAINT (CHASE W. DORBINE CRIMINAL COMP! @LeR«. U8, DISTRICT COURT CASE NUMBER-G!STRATE JUDGE MASON 1OR o467 |, the undersigned complainant, being duly sworn on oath, state that the following is true and correct to the best of my knowledge and belief: On or about May 1, 2010, at Lincolnshire, in the Northern District of Ilinois, Eastem Division, MICHAEL ANGEL CASTILLO, defendant herein: v MICHAEL ANGEL CASTILLO by force and violence, and by intimidation, took from the person and presence of bank employees, money belonging to and in the care, custody, control, management, and possession of the Foster Bank, 255 Parkway Drive, Lincolnshire, Ilinois, the deposits of which were insured by the Federal Deposit Insurance Corporation; in violation of Title 18, United States Sections 2113(a). | further state that I am a Special Agent with the Federal Bureau of Investigation, and that this complaint is based on the facts contained in the Affidavit which is attached hereto and incorporated herein. Signature of Conplanant STEPHEN FARINA Special Agent, Federal Bureau of Investigation ‘Sworn to before me and subscribed in my presence, May 28, 2010 ‘at Chicago, illinois Date iy and State MICHAEL T. MASON, U.S. Magistrate Judge Lachacf Af ——_ Name & Tie of Judicial Offcer ‘Signature of Judidal OltosrUNITED STATES DISTRICT COURT ) NORTHERN DISTRICT OF ILLINOIS ) AFEIDAVIT I, Stephen Farina, being duly sworn depose and state as follows: Introduction 1. Tama Special Agent with the Federal Bureau of Investigation (“FBI”) and have been so employed since approximately 2007. Iam currently assigned to the FBI’s Violent Crimes Squad, and my responsibilities include the investigation of bank robberies. 2. This Affidavit is submitted in support of a criminal complaint alleging that MICHAEL ANGEL CASTILLO (“CASTILLO”) violated Title 18, United States Code, Section 2113(a), by engaging in the May 1, 2010, robbery of the Foster Bank branch located at 255 Parkway Drive, Lincolnshire, Illinois. The information herein is based on personal knowledge acquired through my participation in this investigation; reports I have read related to this investigation; conversations I have had with law enforcement officers and others who have knowledge of the events and circumstances described herein; and interviews of bank employees, witnesses, and other individuals. Because the limited purpose for this affidavit is to establish probable cause to believe ‘that CASTILLO committed the offenses alleged herein, I have not included all of the facts known to me or other law enforeement officers about this investigation. ‘The Robbery of the Foster Bank 3. On May 1, 2010, an unidentified white male (the “robber”) entered Foster Bank, 255 Parkway Drive, Lincolnshire, Ilinois (“Foster Bank”). The robber walked into the bank holding a cell phone to his ear. As he entered the bank, he remained on the cell phone and made eye contactwith a bank employee (“ ployee 1”) who was behind the teller counter. The robber then approached the teller counter and, while continuing to hold the cell phone to his ear, produced a bank robbery demand note for Employee 1 to read, The demand note, which the robber held in his hands, stated something to the effect of: “I’m a robber. Give me 100s, 50’s, 20’s, 10’s. Don’t scream. Don’tmake a scene.” Because Employee | could not read the demand note clearly, Employee 1 tried to take the demand note from the robber. Consequently, the robber said, “Don’t touch it”, and then further stated, “Just give me the money or will shoot you.” Employee 1 complied with the robber’s demands and gave him approximately $10,890 in United States Currency, consisting of $100, $50, $20, $10, and $5 denominations. Employee | also included a dye pack. The robber placed the money and the dye pack in his pocket and fled Foster Bank 4. Once the robber was outside Foster Bank, the dye pack the robber had in his pocket activated. ‘This engulfed the robber in a cloud of reddish smoke, Surveillance footage, which was later reviewed, captured a reddish smoke cloud near a lighter colored, four door sedan. 5. Employee i described the robber asa male, possibly white or Hispanic, with a light complexion, approximately 5°10” in height, weighing approximately 220 Ibs, with a heavy build, and having a moustache and a thin beard along his jaw-line. According to Employee 1, the robber was wearing a black hat with white letters, a black sweatshirt-style coat with a white T-shirt underneath, blue jeans, and white shoes. 6. The robber’s image was captured by video surveillance equipment at Foster Bank, and that video has been viewed. ‘The images on the video are consistent with Employee 1’s descriptions of the robber and the bank robbery.7. At the time of the robbery, two individuals (“Witness 1” & “Witness 2”), were outside the bank, seated together in a vehicle in the parking lot of Foster Bank. Witness 1 and Witness 2 observed a white male with a heavy build wearing a baseball hat. According to these witnesses, this individual was engulfed in a cloud of reddish smoke and was running from the direction of Foster Bank. Witness 1 and Witness 2 saw the individual enter a lighter colored Buick. Witness 1 recounted that the Buick had yellow Illinois temporary license plates that began with the numbers “609,” while Witness 2 recounted that the Buick had yellow Illinois temporary license plates that began with either the numbers “609 ” or “906.” 8. On May 27,2010, Employee 1 was shown a photo array containing photographs of six individuals, including MICHAEL ANGEL CASTILLO. Employee I selected the person in position 4 as the person responsible for the Foster Bank robbery on May 1, 2010. The photograph in position 4 was that of MICHAEL ANGEL CASTILLO. 9. A subsequent bank audit determined that Foster Bank sustained a loss of approximately $10,890 during the May 1, 2010, robbery. 10. At the time of the robbery, the deposits of Foster Bank were insured by the Federal Deposit Insurance Corporation. ‘The Robbery of the West Suburban Bank 11, OnApril20, 2010, white male (the “robber”) entered the West Suburban Bank, 40 St. Charles Road, Villa Park, Illinois (“West Suburban Bank”). The robber presented a bank robbery demand note to the teller (“Employee 2”) and said, “Read this.” Employee 2 attempted to take the demand note to read, but the robber pulled the demand note away and said, “Just give me the money,” “No sudden movements,” and “I'm armed.” Employee 2 complied and providedapproximately $1,540 in United States Currency, along with $500 in bait bills with recorded serial numbers. Employee 2 also included a dye pack with the currency. The robber fled the bank with the money and the dye pack. 12, Employee 2 described the robber as a Hispanic male, approximately 26 or 27 years old, approximately 5°6" tall with a heavy build, having a thin beard on his face. .Employee 2 recounted also that the robber was wearing blue jeans, a white T-shirt, a baseball hat with the letter “L” on the hat, and a black “hoodie” sweatshirt 13, The robber’s image was captured by video surveillance equipment at West Suburban Bank, and the video has been viewed. The images on the video are consistent with Employee 2's descriptions of the robber and the bank robbery. 14. Once the robber was outside West Suburban Bank, the dye pack activated, A witness (‘Witness 3”), who was walking to a car parked on the street, saw the robber outside the West ‘Suburban Bank and observed red smoke being emitted from the robber’s jacket. Witness 3 described the car as a late model, beige or cream in color, that was similar to a Chevrolet Cavalier. 15. On May 27, 2010, Employee 2 was shown a photo array containing photographs of six individuals, including MICHAEL ANGEL CASTILLO. Employee 2 selected the person in position 4 as the person responsible for the West Suburban Bank robbery on April 20, 2010. The photograph in position 4 was that of MICHAEL ANGEL CASTILLO, 16. A subsequent bank audit determined that West Suburban Bank sustained a loss of approximately $1,540 during the April 20, 2010, robbery. 17, Atthe time of the robbery, the deposits of West Suburban Bank were insured by the Federal Deposit Insurance Corporation.The Identification of MICHAEL ANGEL CASTILLO 18. MICHAEL ANGEL CASTILLO is a white male (Hispanic), approximately 5°11"" in height, approximately 245 Ibs. in weight, with a shaved head and brown eyes. He has a moustache and a thin beard along his jaw-line. 19. On May 27, 2010, Parole Officer Robert Drain, Senior Parole Agent, Area West Maywood Parole Office, was shown surveillance photographs from the robberies of West Suburban Bank and Foster Bank. Parole Officer Drain stated that the individual pictured in both the West. Suburban Bank robbery photographs and the Foster Bank robbery photographs resembled MICHAEL ANGEL CASTILLO, with whom Officer Drain recently had contact. The State Arrest of MICHAEL ANGEL CASTILLO. 20. After the April 20, 2010, West Suburban Bank robbery, the Villa Park Police Department recovered United States Currency with red dye stains from a Laundromat located in Franklin Park, Illinois. Upon discovery of the red dye-stained money, the Villa Park Police provided local police departments, including the Franklin Park Police Department, with a general description of the bank robber of the West Suburban Bank, a general description of the getaway vehicle, and a photograph of the bank robber. The Franklin Park Police were also aware of the bank robbery that ‘occurred in Lincolnshire. Moreover, the Franklin Park Police were aware the getaway vehicle was possibly a Buick with an Illinois temporary license plate starting with “609” or “906.” Moreover, the Franklin Park Police were aware that a dye pack had activated after the Villa Park bank robbery. 21. On the evening of May 26, 2010, at the same laundromat where the Villa Park Police had recovered the above-described, red dye-stained money, Franklin Park police officers saw aman, whom they later identified as MICHAEL ANGEL CASTILLO, drive a light colored Buick, with a‘emporary license plate, away from the Laundromat, The officers believed the driver of the Buick, CASTILLO, fit the physical description of the robber who committed the West Suburban Bank robbery. As Franklin Park Police followed his ear, CASTILLO pulled over, and was subsequently arrested for a traffic offense late in the evening on May 26 or early May 27, 2010. CASTILLO told Police that he had approximately $2,500 in United States Currency hidden in the center console of his car. This United States Currency was recovered. Some of the money was stained with red dye. ‘The Search of CASTILLO’s Buick 22. At the time of his arrest by the Franklin Park Police, CASTILLO voluntarily consented to a search of his 2001 Buick, which had yellow Ilinois temporary license plate number a suberanent 56 4/28/2010 6091358. During this search, red dye stains were observed on the interior of the Buick. Also, items ‘were recovered from the interior of the Buick that contained red dye stains. Conclusion 23 Based on the foregoing facts, there is probable cause to believe that MICHAEL ANGEL CASTILLO committed the erime charged in the foregoing criminal complaint. FURTHER AFFIANT SAYETH NOT. Stephen Farina Special Agent Federal Bureau of Investigation Subscribed and Swom to Before Me This 28th Day of May, 2010. MICHAEL T. MASON U.S. Magistrate Judge United States District Court ‘Northern District of Hinois