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AO 91 (Rev. 11/11) Criminal Complaint AUSA Caitlin Walgamuth (312) 353-5311UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

v.CASE NUMBER:

UNITED STATES OF AMERICA

EDNER FLORES (also known as "Edner FloresJr.")

CRIMINAL COMPLAINT

I, the complainant in this case, state that the following is true to the best ofmy knowledge and belief.

On or about January 25, 2021, at Chicago, in the Northern District of Illinois, Eastern Division, thedefendant violated:

Code Section

Title 18, United States Code, Section2113(a)

Offense Description

attempted by force and violence, and by intimidationto take from the person or presence of a bankemployee money belonging to, and in the care,custody, control, management, and possession ofPNCBank located at 3337 W. North Avenue, Chicago,Illinois, the deposits ofwhich were then insured by theFederal Deposit Insurance Corporation.

This criminal complaint is based upon these facts:

___x__ Continued on the attached sheet.

Special Agent, Federal Bureau of Investigation(FBI)

Pursuant to Fed. R. Crim. P. 4.1, this Complaint is presented by reliable electronic means. The above-named agent provided a sworn statement attesting to the truth of the Complaint and Affidavit by telephone.

Date: January 26,2021Judge's signature

City and state: Chicago, Illinois HEATHER K. MCSHAIN, U.S. Magistrate JudgePrinted name and title

21CR55

FILED1/26/2021

THOMAS G. BRUTON

CLERK, U.S. DISTRICT COURT

Case: 1:21-cr-00055 Document #: 1 Filed: 01/26/21 of 9 PageID #:1

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

AFFIDAVIT

I, WARDYODER, being duly sworn, state as follows:

1. I am a Special Agent with the Federal Bureau of Investigation (FBI),

and have been so employed for eleven years. 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 Edner FLORES ("FLORES") has violated Title 18, United States Code, Section

2113(a). Because this affidavit is being submitted for the limited purpose of

establishing probable cause in support of a criminal complaint charging FLORES

with attempted 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

necessary 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, information provided

to me by other law enforcement agents who have knowledge of the events and

circumstances described herein, interviews of bank employees and witnesses, review

of documents provided by bank personnel and other witnesses, and review of the

bank's video surveillance images.


FACTS SUPPORTING PROBABLE CASE

4. As detailed below, on or about January 25,2021, at approximately 11:45

a.m., FLORES entered a PNC Bank located at 3337 W. North Avenue, Chicago,

Illinois (the "Bank"), approached a bank teller ("Teller 1"), handed Teller 1 a note that

stated he was "armed" and demanded money. Teller 1 hit the silent alarm and was

able to stall by requesting FLORES's identification, which he provided to Teller 1.

Responding law enforcement arrested FLORES as he stood in front of Teller l's teller

station inside the Bank. After his arrest, FLORES waived his Miranda rights and

admitted he attempted to rob the Bank.

5. The FBI has confirmed that the deposits of PNC Bank were insured by

the Federal Deposit Insurance Corporation ("FDIC") at the time of the attempted

bank robbery.

January 25, 2021Attempted Bank Robbery

6. As part of the investigation, law enforcement interviewed Teller 1.

According to a law enforcement interview with Teller 1, on or about January 25,2021,

Teller 1 was employed by the Bank and was working at a teller station at the Bank.

At approximately 11:45 a.m., a Hispanic male (the "Robber") arrived at the Bank.

According to Teller 1, the Robber appeared to be in his late-20s to early-30s,

approximately 5'5" tall, approximately 160 pounds, wearing a dark hooded jacket

with the hood up over his head, a blue and white disposable surgical mask, and off-

white colored work gloves with grey dots.

2


7. According to Teller 1, when the Robber entered the Bank, he waited in

line to see a Bank teller. When Teller 1 finished with his/her customer, he/she called

for the next customer, the Robber. According to Teller 1, the Robber approached

Teller 1 and handed Teller 1 a white PNC Bank deposit ticket that had a message

written on it that said: "$10,000" "No die Packs" "Armed." According to Teller 1,

he/she realized he/she was being robbed. Teller 1 activated the silent alarm at his/her

teller station. In an effort to stall until law enforcement arrived, Teller 1 then asked

the Robber, in effect, if he wanted to make a deposit or withdrawal and, according to

Teller 1, the Robber replied that he wanted a withdrawal. In response, Teller 1

handed the Robber a blue withdrawal slip and observed the Robber write "$10,000"

on the withdrawal ticket before handing it back to Teller 1. According to Teller 1,

Teller 1 then asked the Robber for his ATM Card and a form of identification. In

response, the Robber handed Teller 1 an identification card. According to Teller 1,

the Robber was still standing at Teller 1's teller window when law enforcement

arrived at the Bank.

8. Based on my reVIew of law enforcement reports and the body-worn

camera footage of the responding Chicago Police Department ("CPD")officers, CPD

officers entered the Bank and a bank employee pointed out the Robber, who was still

standing at a teller station in front of a bank teller, later identified as Teller 1. The

CPD officers approached the Robber and took him into custody at approximately

11:57 a.m., without incident. According to a CPD report, a knife was recovered from

the Robber's jacket pocket at the time of his arrest.

3


9. Based on my review of Bank surveillance stills, the Robber wore a dark-

colored hooded jacket with the hood up, a light-colored face mask, gray-colored gloves,

and a black cap under the hooded jacket. A still image taken from Bank surveillance

footage depicting the Robber is below.

4


10. The white and blue PNC slips the Robber wrote on were recovered by

law enforcement from Teller l's teller station. The photograph below depicts the two

deposit slips.

DEPOSIT TICKET

0.PNCBANK (ZOCASH •

11. After the Robber's arrest, law enforcement also recovered the

.x-----::NAL 10 ~L rEC

~I ~

identification the Robber provided Teller 1 from Teller l's teller station. A photograph

ACCOUNT NUMBER

Dll CHECKORTOTAL FROM·o HERSIDE

of the identification card is below. As shown, the identification card is a temporary

~ FOR CREOIT TO THE AC~OUN_T NA"lED HEREON

~ DATE \ . LS' 7._D--z._ \::;; ~IX:

~ NAME _

SUB TOTAL •

LESS CASHREceiVED ••

o CHECKING 0 SAVINGS

o CONSUMER 0 BUSINESS

fORM162269

NET DEPOSIT $ 10 .•00TlI'S D~SJr IS ACCEJOT£O 5U8J(Cl TO V(IIIiI'JCATION .VID TO THE RUlU '''.1) I='rGln.••.1fO·~s Of Hi S 15.:.,,1(

or,.OSITS •••••• '."Of B£ AVAILABLE fOR r •• tMro •.••.'£ ",HHOJIAWAL

~PNCBANl<ACCOUNT NUMBER

11..3~Sk1B~r

NON-NEGOTIABLE

Checking/Savings Withdrawal TicketREGIONAL 10 Date I. Z s: - 2. /

I )$ /0, 000 •

FORM162753

5


Illinois Secretary of State Identification Card issued on or about January 22,2021 to

EDNER FLORES JR.1

Jesse White • Illinois Secretary of StateOlIVer':, Llcensellden fiC<ltlon Card Number'

Name EDNER FLORES JR

Dato I:;;;u£:d' 01/2212021 322DV0376

KEEP THIS RECEIPT UNTIL YOUR PERMANENT CARD ARRIVES IN THE MAIL.You ShOU~d receive your Driver's license I CLP lID Card within 15 business days

from the date ISsued I above) unl h '\ ess you ave received correspondence stating otherwise.

YOU WILL NOT RECEIVE YOUR NEWDOCUMENT THE U S pos CARD IF YOU DO NOT LIVE AT THE ADDRESS LISTED BELOW ON THIS

ILLINOIS LA.W RE~UIRE~ y'OU T~ OFFICE CANNOT FORWARD DRIVER'S LICENSE, CLP OR 10 CARDS,NOTIFY THE SECRETARY OF STATE'S OFFICE OF AN ADDRESS CHANGE,

i it To ch.ck the delivery atatus of your card,v a 'WWVw.CYberdriveiliinoia.com or call (217) 782-7044,

'III \ 1lI1111 1IIII11 \11 \11111111111-'lrlllllll1J 1111Iff n111111" 111113520062016405657

oSEPARAlf YOUR TEMPORARY CREOE'IiTJAt ArpE'RFORAnoIoiS ('

lLLINOIS

FOR IDENTIFICATION PURPOSES ONLY.- -MOT A LICENSE TO ORNE

':"'(

Identification of EDNER FLORES as the Robber

12, Shortly after CPD officers took custody of the Robber in the Bank, law

enfOl'cement at the scene compared the Robber's physical description with the

1 FLORES's date of birth, m'iver's license number, and adm'ess have been redacted from thephotograph.

6


photograph of FLORES on the identification card the Robber handed Teller 1 and

observed the photograph accurately depicted the Robber.

13. Law enforcement databases subsequently confirmed that the

identification card the Robber provided Teller 1 matched FLORES's Illinois Secretary

of State Identification Card records.

14. According to law enforcement reports, the Robber was photographed

and fingerprinted by CPD following his arrest. Law enforcement databases confirmed

the Robber's fingerprints matched existing criminal arrest records for EDNER

FLORES with a date of birth that matches the Illinois Secretary of State records for

FLORES.2

15. In response to law enforcement questions, the Robber identified himself

as EDNER FLORES with a date of birth in 1986, which matched the date of birth of

FLORES in Illinois Secretary of State records.

16. Based on the information above, law enforcement identified the Robber

as FLORES.

Post-Arrest Interview

17. On or about the afternoon of January 25, 2021, an FBI agent and task

force officer interviewed FLORES at the CPD 19th District. The interview was audio

and video recorded. In summary, after providing a written Miranda waiver,

2 FLORES'scriminal arrest records also contain a seconddate ofbirth with the same birthmonth and birth year (but a different date) as the date ofbirth listed in FLORES'sIllinoisSecretaryofState records.

7


FLORES confessed that he attempted to rob the Bank. FLORES was shown a still

image of the Robber from the Bank's video surveillance system and identified the

Robber in the photograph as himself.

CONCLUSION

18. Based on the foregoing facts, I respectfully submit that there is probable

cause to believe that, on or about January 25, 2021, EDNER FLORES (aka "Edner

Flores Jr."), attempted by force and violence, and intimidation, to take from the

person and presence of a bank employee money belonging to, and in the care, custody,

control, management, and possession ofPNC Bank, located at 3337 W. North Avenue,

Chicago, Illinois, the deposits of which were then insured by the FDIC, in violation of

Title 18, United States Code, Section 2113(a).

FURTHER AFFIANT SAYETH NOT.

w~~Special Agent,Investigation

Federal Bureau of

SWORN TO AND AFFIRMED by telephone January 26, 2021.

Honorable HEATHER K. MCSHAINUnited States Magistrate Judge

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