Case: 1:16-cr-00548 Document #: 6 Filed: 08/26/16 Page 1 of 8 PageID #:18

AO 91 (Rw. I l/11) Criminal Complaint

AUSA Tobara

UNITED STATES DISTRICT COURT

NORTIIERN DISTRICT OF ILLINOIS
EASTERN DIYISION

S. Richardson

FILED
AU6262010

UNITED STATES OF AI\{ERICA

CASE NUMBER:

I]NDER SEAL

v.

c'EH-?USlo8,R[Yl8il*,

16cR 549

MARVIN McNEELEY

.RTMTNAL

"o*^f,t

J*DGE RoffiAND

I, the complainant in this case, state that the following is^.ETRATE

true to the best of my knowledge
and belief.

On or about July 18, 20L6, at Chicago, in the Northern District of Illinois, Eastern Division, the
defendant(s) violated:
Code Section

Offense Description

fitle

by intimidation, took from the person and

presence of a bank employee approximately
$Z,LZO in United States crurency belonging to
and in the care, custody control, management,

18, United States Code, Section

2tt3(a)

and possession of the Chase Bank located at 35

West Wacker Drive, Chicago, Illinois, the deposits
of which were then insured by the Federal
Deposit Insurance Corporation
This criminal complaint is based upon these facts:

Continued on the attached sheet.

R.

(FBI)
Sworn to before me and signed in my presence.
Date: Aueust 26.2016

City and state: Chicago.Illinois

Agent, Federal Bureau of Investigation

Case: 1:16-cr-00548 Document #: 6 Filed: 08/26/16 Page 2 of 8 PageID #:19

IINITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

AFFIDAVIT
I, JEREMY R. BAUER, being duly sworn, state as forows:

. 1'

I arn a Special Agent with the Federal Bureau of Investigation,

and

have been so employed since 20L5. My current responsibilities include the

investigation of violent crimes, including, among others, kidnaping, bank robbery,
and the apprehension of violent fugitives.

2'

This affidavit is submitted in support of a criminal complaint alleging

that MARVIN McNEELEY has violated Title 18, United States Code,
2L73(a) by engaging in the

Section

July 18, 2016 robbery of the Chase Bank branch located

at 35 West Wacker Drive, Chicago, Illinois.

Because

this affidavit is

submitted for the limited purpose of establishing probable cause

being

in support of a

criminal complaint charging McNEELEY \ rith bank robbery, I have not included
each and every fact known to me concerning this investigation.

I have set forth only

the facts that I believe are necessar5r to establish probable cause to believe that
the
defendant committed the offense alleged in the complaint.

3'

This affidavit is based on my personal knowledge, infor:nation

provided to me by other law enforcement agents, reports

investigation, conversations

I have read related to this

have had with others who have knowledge of the

events and circumstances described herein, interviews of bank employees and

other

Case: 1:16-cr-00548 Document #: 6 Filed: 08/26/16 Page 3 of 8 PageID #:20

witnesses, my review of surveillance images, and my experience and training as an

FBI Special Agent.

July

4.

18. 2016 Robbery

of Chase Bank

On July 18, 20L6, at approximately g:52 a.m., a lone male robber took

approximately $z,tZO from a bank teller at the Chase Bank branch located at
trVest Wacker

Bb

Drive, Chicago, Illinois (the "Bank"). According to four bank

employees who were working

at the time, and as can be seen on the

Bank,s

surveillance video, the robber was a tall, heavy-set black male wearing a t-shirt,

hat, and sunglasses.

5.

According to the Teller, at the time of the robbery, the Teller was

working behind the teller line when a male stepped up to the counter and stated,
"This is a robbery." The Teller was surprised and. stated something to the effect of,

'\Vhat?" The male then stated, "This is a robbery. I will shoot your friends. Give
me the money." As the Teller began to open the teller drawer, the robber made an

additional demand for 100's, 50's, 20's, and possibly 10,s. The Teller complied \,\rith

the robber's demand. After the robber left the counter, the Teller turned to the
Manager and stated that there was a robbery.

6.

The Teller described the robber as a black male, approximately Eb-60

years old, six feet

tall or taller, heavy build, with a dark complexion and a day or

two worth of facial hair growth. The Teller described the robber as wearing a dark

blue colored t-shirt, possibly with an undershirt beneath, dark colored sunglasses,
and carrying a blue wash cloth in his hand.

Case: 1:16-cr-00548 Document #: 6 Filed: 08/26/16 Page 4 of 8 PageID #:21

7.

According to the Manager, at the time of the robbery, the Manager

\Mas

working behind the teller line, assisting a new teller from another branch. The
Manager was told by the Teller that the bank had been robbed. The Manager then
looked up and saw a male exiting the bank.

8.

The Manager described the robber as a black male with a light

complexiorT, 6'4" to 6',6"

in height, heavy set, and. weighing approximately 300

lbs.

The Manager further d.escribed the male as wearing sunglasses, a green t-shirt with
a white shirt underneath, and a hat.

9.

The Banker was greeting customers in the Chase Bank lobby when the

robber entered the bank through the entrance off of Lake Street. The Banker
saw

the robber approach the teller counter and then depart the bank through the same
doors. The Banker acknowledged the robber as he entered and exited the bank.

It

was not until afber the male had exited that the Banker realized that the bank
had
been robbed.

10.

The Banker described the individual as a black male, 60 years o1d.,6,4"

in height, and heavy set, but not obese. The Banker further described the robber

as

wearing a bagry green shirt, a black hat, and sunglasses. The Banker stated that

the robber was not wearing gloves. The Banker further added that the robber
walked slowly as though he almost needed a cane to walk.

11.

The Greeter was working at the customer seryice desk at the time of

the robbery. The Greeter observed a male enter the bank from the south entrance.
The Greeter said, "good morning" to the man, but he did not respond. The Greeter

Case: 1:16-cr-00548 Document #: 6 Filed: 08/26/16 Page 5 of 8 PageID #:22

did not observe the man afber that, but was later notified that the bank had been
robbed by the man who had been in the bank.

72- The Greeter described the robber as a black male in his 80,s,
approximately 6'5" tall, with a heavy build, and weighing approximately BB0 lbs.
The Greeter further described the robber as wearing a blue t-shirt, dark pants, and
a black or dark colored baseball cap.

13. In the video surveillance

footage, the robber can be seen carr5ring an

object in his t-shirt pocket, which appears to be a cellular phone based on its
shape.

L4.

Chase Bank provided the FBI

with documentation showing that the

robber took approximately $2,lzo from the Teller during the

15.
July 18,

robbery.
r

Chase Bank provided the

FBI with documentation showing that

2OL6, Chase Bank's deposits \^rere insured

by the Federal

on

Deposit

Insurance Corporation.

16.

Following the bank robbery, local police forwarded several tips to the

FBI, from the same individual (,.Individual A"1) identi$ring the bank robber who
robbed the Bank on July LB,2oL6, as IVTARVIN M.NEELEY.

Based on the information provided by Individual

A in the tips, I

identified McNEELEY through law enforcement databases.

I then obtained

L7

MCNEELEYs Illinois state identification photo from the Illinois Secretary of State,

and
1

compared

that photo with the surveillance images from the July 1g, 2016

Individual A has prior misdemeanor and felony convictions, inclurling narcotics and
a weapon

offense.

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bank robbery. The robber depicted

in the surveillance

images appears to match

McNEELEYs physical appearance. The physical description of McNEELEY on his

Illinois state identification is also consistent with the descriptions of the robber
provided by the witnesses at the Bank.

18. I

spoke

with Individual A on July 21, 2016. Individual A identified

McNEELEY as the individual who robbed the Bank on July LB, ZO1G. Individual A
indicated that McNEELEY had been planning to rob a bank for approximately one

month- Individual A was shown surveillance pictures from the bank robbery and
identified McNEELEY as the offender. Individual A observed that the hat worn by
the robber was identical to a hat that McNEELEY possessed prior to and after the

July 18, 2016 robbery. Accord.ing to Individual A, McNEELEY stated. that he

received approximately $2,000 from the bank robbery. Individual A also provided

additional identifiers for McNEELEY to include his address and phone number
("Subject Phone 1"). The address provided by Individual A was the same
address on

McNEELEYs Illinois state identification. Moreover, according to a public source

euery, Subject Phone 1 is associated with McNEELEy.

19. I

also searched law enforcement databases for the name IVIARVIN

McNEELEY and the address for McNEELEY provided by Individual A. This search

identified a second phone number ("Subject Phone 2") for McNEELEy from January
20L6 to July 20L6- Pursuant to a court order,

I obtained historical cell site data for

Subject Phone 2. Those records for Subject Phone

Phone 2 being

2 are consistent with Subject

in the area of the Bank shortly before and shortly

afber the

July

Lg,

Case: 1:16-cr-00548 Document #: 6 Filed: 08/26/16 Page 7 of 8 PageID #:24

2OtG robbery. Additionally,

the records are consistent urith Subject pho-ne z

returning to the area of McNEELEys address following the robbery.

20'

On July 27, qg16, a sequential photographic zuray was created by the

FBI and shown to three of the Bank employees present at the time of the robbery.
The photographic array contained six sequentiat photographs of individuals,
one of
whom was McNEELEY. The six photographs were shown one by one to three
of the

bank employees separately. TWo of the three bank employees identified the
photograph of McNEELEY as the individual who robbed the Bank at
a confidence of
9AVo.

A third bank employee was unable to make an identification. The fourth

bank employee was on vacation on the date the other witnesses were shown the
photo array.

Case: 1:16-cr-00548 Document #: 6 Filed: 08/26/16 Page 8 of 8 PageID #:25

_qaNCLUsIpn

2L-

Based on the foregoing facts,

respectfully submit that there is

probable cause to believe that, on or about July 18, 2Oh6,I\{ARVIN McNEELEy,

bV

intimidation, did take United States crurency belonging to and in the care, custody,
control, management, and possession of the Chase Bank branch located. at Bb
West

Wacker Drive, Chicago, Illinois, the deposits of which were then insured by the
Federal Deposit fnsurance Corporation, in violation of Title 18, United States
Code,
Section 2113(a).

Dpeci.d Agent,

Federal Bureau of Investigation

RIBED AND SWO

United States Magistrate Judge

me on August 26,2016.