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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 July through October 2017 in the county of Deschutes in the
_ _ _ _ _ _ District of --~O_r~eg~o~n_ _ _ , the defendant(s) violated:
Date: 03/22/2018
City and state: Eugene, Oregon Jolie A. Russo, U.S. Magistrate Judge
Printed name and title
Case 6:18-mj-00067-MC Document 1 Filed 03/22/18 Page 2 of 10
I, Scott Helton being duly sworn, do hereby depose and state as follows:
1. I am a U.S. Postal Inspector employed by the U.S. Postal Inspection Service, and
have been so employed since March 2003. I am assigned to the Portland Oregon Domicile in the
Seattle Division of the Postal Inspection Service. My training and experience includes a
Bachelor of Science degree in Sociology and Criminology certificate from the University of
Utah, a Doctorate of Jurisprudence degree from Willamette University College of Law, and 12
weeks of basic Postal Inspector training. I am currently a member in good standing of the
Oregon State Bar. As a U.S. Postal Inspector, I am authorized to investigate crimes involving
offenses relating to the United States Postal Service (U.S.P.S.). During the course of my
investigations involving homicide, robbery, assault, burglary, mail theft, identity theft, credit
card fraud, bank fraud, wire fraud, mail fraud, the unlawful mailing of dangerous controlled
substances, the fraudulent use of stolen or forged Postal Money Orders, and the fraudulent use of
stolen credit card information to purchase merchandise, and the shipping of that merchandise
through the U.S. Mail. I have applied for and received search warrants in the investigation of
offenses relating to the U.S.P.S. I have participated in executing federal and state search
warrants.
- Theft or receipt of stolen mail matter generally, and (2) Title 18, United States Code, Section
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Case 6:18-mj-00067-MC Document 1 Filed 03/22/18 Page 3 of 10
1344- Bank Fraud, and (3) Title 18 United States Code, Section 1028A-Aggravated Identity
Theft.
3. The facts set forth in this affidavit are based on the following: my own personal
records related to this investigation; communications with others who have knowledge of the
events and circumstances described herein; and information gained through my training and
experience. Because this affidavit is submitted for the limited purpose of establishing probable
cause in support of a criminal complaint for Curtis Maynard Boyd and Amber Nicole Martin, it
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I does not set forth each and every fact that I or others have learned during the course of this
investigation.
Applicable Law
4. Title 18, United States Code, Section 1708 - Theft or Receipt of Stolen Mail
Matter Generally, provides that "Whoever steals, takes, or abstracts, or by fraud or deception
obtains, or attempts so to obtain, from or out of any mail, post office, or station thereof, letter
box, mail receptacle, or any mail route or other authorized depository for mail matter, or from a
letter or mail carrier, any letter, postal card, package, bag, or mail, or abstracts or removes from
any such letter, package, bag, or mail, any article or thing contained therein, or secretes,
II embezzles, or destroys any such letter, postal card, package, bag, or mail, or any article or thing
contained therein. . . shall be fined under this title or imprisoned not more than 5 years, or both."
..I~ 5. Title 18, United States Code, Section 1344 - Bank Fraud provides that "Whoever
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knowingly executes, or attempts to execute, a scheme or artifice to defraud a financial institution;
or to obtain any of the moneys, funds, credits, assets, securities, or other property owned by, or
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under the custody or control of, a financial institution, by means of false or fraudulent pretenses,
representations, or promises; shall be fined not more than $1,000,000 or imprisoned not more
6. Title 18 United States Code, Section 1028A - Aggravated Identity Theft provides
that "Whoever, during and in relation to any felony violation enumerated in subsection (c),
another person shall, in addition to the punishment provided for such felony, be sentenced to a
7. I know from my training and experience that perpetrators of mail theft and band
fraud, in order to obtain financial gain, thieve mail to obtain bank checks, bank issued credit
cards, bank account information including account and routing numbers. Mail thieves often alter
bank checks stolen from the U.S. mail and fraudulently negotiate the checks to obtain financial
gain. Mail thieves also frequently use bank information obtained from mail theft to fraudulently
make bank checks they then negotiate for financial gain. Mail thieves also use bank issued credit
cards fraudulently to obtain financial gain. I know that mail thieves often obtain personal
identification information from stolen U.S. mail, and then use that personal identification
information to make fraudulent identification documents to apply for credit to obtain financial
gam.
8. I know that mail thieves often work in concert with other mail thieves and trade
ll stolen mail, bank checks, bank issued credit cards, and personal identification information with
other mail and identity thieves for money or illegal drugs. I know that mail and identity thieves
purchase goods and services with money and credit obtained from the personal identification
9. I know that perpetrators of mail theft and identity theft often store evidence of
mail theft or the ill-gotten gains of their criminal activity at various locations including their
principal residences.
10. In the course of my assignment, I have investigated mail theft in Central Oregon,
including mail thefts in Bend, Madras, and Redmond Oregon. I learned from Deschutes County
Sheriffs Deputy J. Minton that on August 22, 2017, he took a report number 2017-00264153
from a Bend, Oregon resident, Victim 1. Victim 1 ordered a new box of bank checks from Selco
Community Credit Union that were mailed to his residence; however, Victim 1 did not receive
the checks. Victim 1 learned that his Selco checking account was overdrawn when he attempted
to negotiate a check and it was declined for insufficient funds. I learned that Victim 1 reported
to Deputy Minton that nine checks were drawn on his account between July 31, 2017 and August
18, 2017. Furthermore, Victim 1 also learned that on four of the checks, the name "Shelli Jo
Phillips" was printed above Victim 1's name, but Victim 1 had ordered the checks with only his
name printed on the checks. On two returned fraudulent check, the Washington State
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11. On one returned fraudulent check, the Washington State identification number
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Case 6:18-mj-00067-MC Document 1 Filed 03/22/18 Page 7 of 10
12. Deputy Minton learned and told me that there are no Washington State driver
license numbers or state issued identification cards corresponding to those numbers. A total of
$1,970 was fraudulently withdrawn from Victim l's Selco Credit Union account.
13. Deputy Minton told me that in September 2016, he obtained video images of an
attempted July 31, 2017 negotiation of one of Victim l's checks at the Bend, Oregon Walmart
store. The video images show a male and female person attempting the transaction; the female
presenting the check from her purse. The couple exited the store after the negotiation was
rejected and entered a dark colored SUV. Deputy Minton also visited the Redmond, Oregon
Walmart store and learned that on July 29, 2017 the same couple successfully negotiated a check
drawn on Victim 1's account for $210.68. Video images depicted the same couple with one
other female person who exited the store after the transaction and walked to a dark colored Jeep
Cherokee, with no front license plate, extra wide tires with alloy rims and front tum signals that
were unusually yellow in color. Deputy Minton took the still photos from the video surveillance
and disseminated the photos to law enforcement professionals in the Deschutes County Sheriffs
Office and the Bend, Oregon Police Department. Within an hour, several other deputies and
officers contacted Deputy Minton and told him they believed the photos from Walmart depicted
Amber Nicole Martin. Deputy Minton then compared Martin's most recent Deschutes County
Jail booking photo from June 2017, with the surveillance photos from Walmart and confirmed
the surveillance photos depicted Amber Nicole Martin. I have reviewed the still photos and
compared them to images of Amber Nicole Martin and I believe that Amber Nicole Martin is the
14. Deputy Minton consulted Facebook and learned that Amber Nicole Martin
appeared to be in a relationship with Curtis Boyd. Photos posted on Facebook depict Boyd and
were substantially similar to Boyd's most recent Deschutes County Jail booking photo from
August 2017. The Facebook photos also show Boyd with a Smokey the Bear tattoo surrounded
by two pine trees located on his left forearm. Deputy Minton noted that in the surveillance
photos from the Redmond, Oregon Walmart show the male person leaving the store and a
portion of a tattoo is visible on the male person's left forearm appears to show a tree; while the
entire tattoo is not visible on the surveillance photo, the description matched Curtis Boyd's
description. I have reviewed the still photos and compared them to the images of Curtis
Maynard Boyd and I believe the tattoo on Boyd's left forearm is in substantially the same
15. Deputy Minton told me that on October 5, 2017, he learned that a check from
Victim l's Selco Credit Union account was negotiated at Home Depot in Redmond on July 29,
16. Deputy Minton told me he learned that Boyd and Martin were associated with a
Jeep Cherokee bearing Washington license plate number BRC3476 and researched in law
enforcement databases where that vehicle had recently been stopped in Deschutes County, and
then drove those areas in an attempt to locate the Jeep Cherokee. Deputy Minton told me he
found the vehicle at 1453 NE Tucson Way, Bend, Oregon 97701, parked in front of the number
four unit. The building at that location is a four-plex multifamily unit, and Deputy Minton told
me he confirmed with neighbors that Boyd and Martin lived in unit number four.
17. Deputy Minton told me that based on the information he collected during his
investigation he applied for and was granted a Search Warrant from the State of Oregon Circuit
Court for Deschutes County on October 10, 2017. The warrant was signed by the Honorable
Bethany P. Flint, Judge. Deputies from the Deschutes County Sheriff's Office served the
warrant on October 10, 2017, and recovered stolen US mail, credit cards, and bank checks.
Many of the checks had been altered, with payee information erased physically and chemically.
18. I reviewed the mail recovered from the search of 1453 NE Tucson Way, Apt. 4,
Bend, Oregon 97701. A total of 1,015 US Postal Service customers' mail was recovered in the
residence. The total dollar amount on bank checks recovered from the residence is $178,007.80.
In addition, 39 different checks recovered were blank and 11 of those checks had been altered
with different payee names. 36 separate credit cards were recovered from the residence.
19. Included in the recovered checks were blank checks from Victim l's Selco
Community Credit Union account printed with his address and altered checks bearing the names
Shelli Jo Philips and Victim 1that are the same as those used fraudulently by Curtis Maynard
Conclusion
20. Based on the foregoing, I have probable cause to believe, Curtis Maynard Boyd
and Amber Nicole Martin violated Title 18, United States Code, Section 1708 - Theft or Receipt
of Stolen Mail Matter Generally, Title 18, United States Code, Section 1344 - Bank Fraud, and
21. Prior to being submitted to the Court, this affidavit, the accompanying
application, and the requested arrest warrant were all reviewed by Assistant United States
Attorney (AUSA) Gavin W. Bruce, and AUSA Bruce advised me that in his opinion the affidavit
and application are legally and factually sufficient to establish probable cause to support the