Professional Documents
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INFORMATION
COUNT ONE
On or about November 23, 2009, within the District of Columbia, the defendant, JEROME
THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from
the person or presence of another, money belonging to and in the care, custody, control,
management, and possession of Chevy Chase Bank, the deposits of which were insured by the
(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))
COUNT TWO
On or about January 6, 2010, within the District of Columbia, the defendant, JEROME
THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from
the person or presence of another, money belonging to and in the care, custody, control,
management, and possession of Chevy Chase Bank, the deposits of which were insured by the
(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))
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COUNT THREE
On or about March 8, 2010, within the District of Columbia, the defendant, JEROME
THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from
the person or presence of another, money belonging to and in the care, custody, control,
management, and possession of Chevy Chase Bank, the deposits of which were insured by the
(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))
COUNT FOUR
On or about March 12, 2010, within the District of Columbia, the defendant, JEROME
THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from
the person or presence of another, money belonging to and in the care, custody, control,
management, and possession of PNC Bank, the deposits of which were insured by the Federal
(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))
COUNT FIVE
On or about March 25, 2010, within the District of Columbia, the defendant, JEROME
THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from
the person or presence of another, money belonging to and in the care, custody, control,
management, and possession of Chevy Chase Bank, the deposits of which were insured by the
(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))
2
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COUNT SIX
On or about April 21, 2010, within the District of Columbia, the defendant, JEROME
THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from
the person or presence of another, money belonging to and in the care, custody, control,
management, and possession of Chevy Chase Bank, the deposits of which were insured by the
(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))
COUNT SEVEN
On or about April 26, 2010, within the District of Columbia, the defendant, JEROME
THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from
the person or presence of another, money belonging to and in the care, custody, control,
management, and possession of Chevy Chase Bank, the deposits of which were insured by the
(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))
COUNT EIGHT
On or about May 11, 2010, within the District of Columbia, the defendant, JEROME
THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from
the person or presence of another, money belonging to and in the care, custody, control,
management, and possession of PNC Bank, the deposits of which were insured by the Federal
(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))
3
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COUNT NINE
On or about May18, 2010, within the District of Columbia, the defendant, JEROME
THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, attempt
to take from the person or presence of another, money belonging to and in the care, custody,
control, management, and possession of PNC Bank, the deposits of which were insured by the
(Attempted Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))
COUNT TEN
On or about January 12, 2011, within the District of Columbia, the defendant, JEROME
THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from
the person or presence of another, money belonging to and in the care, custody, control,
management, and possession of Capital One Bank, the deposits of which were insured by the Federal
(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))
COUNT ELEVEN
On or about January 18, 2011, within the District of Columbia, the defendant, JEROME
THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from
the person or presence of another, money belonging to and in the care, custody, control,
management, and possession of PNC Bank, the deposits of which were insured by the Federal
(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))
4
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COUNT TWELVE
On or about March 16, 2011, within the District of Columbia, the defendant, JEROME
THOMAS, did willfully and unlawfully, and by force and violence, and by intimidation, take from
the person or presence of another, money belonging to and in the care, custody, control,
management, and possession of SunTrust Bank, the deposits of which were insured by the Federal
(Bank Robbery, in violation of Title 18, United States Code, Section 2113(a))
1. The allegations set forth in Counts One through Eight and Counts Ten through
Twelve of this Information are re-alleged as though set forth fully herein and incorporated by
reference for the purpose of alleging forfeiture to the United States of America pursuant to the
provisions of Title 18, United States Code, Section 981(a)(1)(C), and Title 28, United States Code,
Section 2461(c).
2. As a result of the offenses alleged in Counts One through Eight and Counts Ten
through Twelve of this Information, the defendant, JEROME THOMAS, shall forfeit to the United
States any and all property, real or personal, constituting, or derived from, proceeds obtained directly
or indirectly, as a result of the offenses alleged in Counts One through Eight and Counts Ten through
(i) at least $21,101, which represents a sum of money constituting, or derived from,
proceeds obtained, directly or indirectly, as a result of the offenses alleged in Counts
One through Eight and Counts Ten through Twelve of this Information, in violation
of Title 18, United States Code, Section 2113(a).
By virtue of the commission of the felony offenses charged in Counts One through Eight and Counts
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Ten through Twelve of this Information, any and all interest that JEROME THOMAS has in the
property constituting, or derived from, proceeds obtained directly or indirectly as the result of the
offenses alleged in Counts One through Eight and Counts Ten through Twelve of this Information,
is vested in the United States and hereby forfeited to the United States pursuant to Title 18, United
States Code, Section 981(a)(1)(C), and Title 28, United States Code, Section 2461(c).
3. If any of the property described above as being subject to forfeiture, as a result of any act or
e. has been commingled with other property that cannot be subdivided without
difficulty;
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it is the intention of the United States, pursuant to Title 18, United States Code, Section
981(a)(1)(C), and Title 28, United States Code, Section 2461(c), and incorporating by reference
Title 21, United States Code, Section 853(p), to seek forfeiture of any other property of said
defendant up to the value of said property listed above as being subject to forfeiture.
(Criminal Forfeiture, in violation of Title 18, United States Code, Section 981(a)(1)(C),
and Title 28, United States Code, Section 2461(c))
Respectfully Submitted,
By: __________/s/__________________
CATHERINE K. CONNELLY
Assistant United States Attorney
Massachusetts Bar No. 649430
Violent Crimes and Narcotics Trafficking Section
555 Fourth Street, NW, 4th Floor
Washington, D.C. 20530
(202) 252-7732
Catherine.Connelly2@usdoj.gov