burns, verkisha latrice - fed. grand jury indictment 2009-12-16

8/9/2019 Burns, Verkisha Latrice - Fed. Grand Jury Indictment 2009-12-16

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RECEIVEDN THE UNITED STATES DISTRICT COURTFOR THE SOUTHERN DISTRICT OF IOWA DEC 16 2009

CLERI(U.S DSUiJlhcHN D i s ~ T C O U R TNITED STATES OF AMERICA, )) "1ltl , OF IOWAPlaintiff, ) Criminal No.3:09-cr-119

)v.VERKISHA LATRICE BURNS,KATELYN MARIE CURTIS

))))

INDICTMENTT. 18 U.S.C. 21 13(a), 21 13(d)T. 18 U.S.C. 924(c)a/k/a Katalyn Maria Curtis, ) T. 18 U.S.C. 2RAYLON DESHON JONES,

Defendants.

THE GRAND JURY CHARGES:

)))))

T. 18 U.S.C. 371

COUNT 1(Bank Robbery)

That on or about October 5, 2009, in and about Washington County in the SouthernDistrict ofIowa, the defendants, VERKISHA LATRICE BURNS, KATELYN MARIE CURTIS,a/k/a Katalyn Maria Curtis, and RA YLON DESHON JONES, by force and violence, and byintimidation, did take and attempt to take from the person and presence of another,approximately $3,760 in United States currency belonging to and in the care, custody, controland possession of West Chester Savings Bank, 1060 West Monroe Street, Washington, Iowa, thedeposits ofwhich were then insured by the Federal Deposit Insurance Corporation, and incommitting such offense, the defendants, VERKISHA LATRICE BURNS, KA TELYN MARIECURTIS, a/k/a Katalyn Maria Curtis, and RAYLON DESHON JONES, did assault and put injeopardy the life of another person by the use of a dangerous weapon.

This is a violation of Title 18, United States Code, Sections 21 13(a), 21 13(d), and 2.

Case 3:09-cr-00119-JAJ-TJS Document 2 Filed 12/16/09 Page 1 of 4


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THE GRAND JURY FURTHER CHARGES:COUNT 2

(Possession of Firearms in Furtherance of Violent Crime)

That on or about October 5, 2009, in and about Washington County in the SouthernDistrict of Iowa, and elsewhere, the defendants, VERKISHA LATRICE BURNS, KATELYNMARIE CURTIS, a/k/a Katalyn Maria Curtis, and RAYLON DESHON JONES, did knowinglypossess a firearm in furtherance of, and carry a firearm during and in relation to, a crime ofviolence, that is, a violation of Title 18, United States Code, Sections 2113(a) and 2113(d), as setforth in Count 1 ofthis Indictment, which is a felony prosecutable in a court of the United States,and did brandish said firearm in the course of that crime.

This is a violation of Title 18, United States Code, Sections 924(c) and 2.

THE GRAND JURY FURTHER CHARGES:COUNT 3

(Conspiracy to Commit Bank Robbery)That on or about October 5,2009, in and about Washington County in the Southern

District of Iowa, and elsewhere, the defendants, VERKISHA LATRICE BURNS, KATELYNMARIE CURTIS, a/k/a Katalyn Maria Curtis, and RAYLON DESHON JONES, did knowinglyand intentionally conspire with other persons to commit certain offenses against the UnitedStates, that is, bank robbery in violation of Title 18, United States Code, Sections 2113(a) and

2113(d).



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OVERT ACTS

In furtherance of the conspiracy, and to effect the objects thereof, the following overt acts,among others, were committed by the defendants, VERKISHA LATRICE BURNS, KATELYNMARIE CURTIS, a1k/a Katalyn Maria Curtis, and RAYLON DESHON JONES, as coconspirators, in the Southern District ofIowa and elsewhere:

1. During the period ofthe conspiracy, the defendants, VERKISHA LATRICEBURNS and KATEL YN MARIE CURTIS, alk/a Katalyn Maria Curtis, traveled to Washington,Iowa, with the intent to rob a bank, picking up RAYLON DESHON JONES in Washington,

Iowa, when they arrived.2. During the period of the conspiracy, the defendant, VERKISHA LATRICE

BURNS, stole a pair of gloves to use in the robbery.3. During the period ofthe conspiracy, the defendant, RAYLON DESHON JONES,

selected West Chester Savings Bank as the target because another bank was too busy.4. During the period of the conspiracy, the defendants, VERKISHA LATRICE

BURNS, KATEL YN MARIE CURTIS, a1k/aKatalyn Maria Curtis, and RAYLON DESHONJONES, circled West Chester Savings Bank in their car several times and parked offsite to helpeffectuate the robbery and their get-away.

5. During the period ofthe conspiracy, the defendant, KATELYN MARIE CURTIS,a1k/a Katalyn Maria Curtis, entered West Chester Savings Bank to case the bank and count thenumber of individuals in the bank.

6. During the period of the conspiracy, the defendant, VERKISHA LATRICEBURNS, entered West Chester Savings Bank and robbed the bank at gunpoint, taking $3,760 in

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United States currency belonging to and in the care, custody, control and possession of WestChester Savings Bank.

7. During the period of the conspiracy, the defendant, RAYLON DESHON JONES,advised his co-conspirators on the fastest way to leave town.

This is a violation ofTitle 18, United States Code, Section 371.

A TRUE BILL.

/ s /

FOREPERSON

Nicholas A. KlinefeldtUnited States Attorney

By: ,->:/s;:..../ _Joel W. BarrowsAssistant United States Attorney

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burns, verkisha latrice - fed. grand jury indictment 2009-12-16

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