Case 2:13-cr-00548-KM Document 1 Filed 07/29/12 Page 1 of 5 PageID: 1 UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY CRIMINAL COMPLAINT UNITED STATES OF AMERICA v. Mag. No. 12- 407S" CLAUDE WILLIAMS I, Michael A. Scimeca, being duly sworn, state the following is true and correct to the best of my knowledge and belief: SEE ATTACHMENT A I further state that I am a Special Agent with the Federal Bureau of Investigation, and that this complaint is based on the following facts: . SEE ATTACHMENT B Continued on the attached page and made a part hereof. Sworn to before me and subscribed in my presence, July 29,2012 in Morris County, New Jersey HONORABLE MICHAEL A. HAMMER UNITED STATES MAGISTRATE JUDGE Case 2:13-cr-00548-KM Document 1 Filed 07/29/12 Page 2 of 5 PageID: 2 ATTACHMENT A Count One - Bank Robbery On or about September 26,2011, in Somerset County, in the District of New Jersey and elsewhere, defendant, CLAUDE WILLIAMS, by force, violence, and intimidation did take from the person and presence of another, approximately $20,339.00 in money belonging to, and in the care, custody, control, management, and possession of the Financial Resources Federal Credit Union, the deposits of which were then insured by the Federal Deposit Insurance Corporation, and in committing such offense, defendant, CLAUDE WILLIAMS, did assault and put in jeopardy the life of another person by the use of a dangerous weapon, that is a firearm. In violation of Title 18, United States Code, Sections 21 13(a), 2113(d), and 2. Count Two - Use of a Firearm in Furtherance of a Crime of Violence On or about September 26,2011, in Somerset County, in the District of New Jersey and elsewhere, defendant, CLAUDE WILLIAMS, during and in relation to a crime of violence for which defendant, CLAUDE WILLIAMS, may be prosecuted in a court of the United States, specifically the bank robbery set forth in Count One, did knowingly and willfully use, carry, and, in furtherance of such crime, possess a firearm, which was brandished. In violation of Title 18, United States Code, Sections 924(c)(I)(A)(ii) and 2. Count Three - Bank Robbery On or about November 21, 2011, in Somerset County, in the District of New Jersey and elsewhere, defendant, CLAUDE WILLIAMS, by force, violence, and intimidation did take from the person and presence of another, approximately $14,691.00 in money belonging to, and in the care, custody, control, management, and possession of Somerset Savings Bank, the deposits of which were then insured by the Federal Deposit Insurance Corporation, and in committing such offense, defendant, CLAUDE WILLIAMS, did assault and put in jeopardy the life of another person by the use of a dangerous weapon, that is a firearm. In violation of Title 18, United States Code, Sections 2113(a), 21 13(d), and 2. Count Four - Bank Robbery On or about July 12,2012, in Middlesex County, in the District of New Jersey and elsewhere, defendant, CLAUDE WILLIAMS, by force, violence, and intimidation did take from the person and presence of another, approximately $9,192.00 in money belonging to, and in the care, custody, control, management, and possession of Unity Bank, the deposits of which were then insured by the Federal Deposit Insurance Corporation, and in committing such offense, defendant, CLAUDE WILLIAMS, did assault and put in jeopardy the life of another person by the use of a dangerous weapon, that is a firearm. Case 2:13-cr-00548-KM Document 1 Filed 07/29/12 Page 3 of 5 PageID: 3 In violation of Title 18, United States Code, Sections 2113(a), 2113(d), and 2. Count Five - Use of a Firearm in Furtherance of a Crime of Violence On or about July 12,2012, in Somerset County, in the District of New Jersey and elsewhere, defendant, CLAUDE WILLIAMS, during and in relation to a crime of violence for which defendant, CLAUDE WILLIAMS, may be prosecuted in a court of the United States, specifically the bank robbery set forth in Count One, did knowingly and willfully use, carry, and, in furtherance of such crime, possess a firearm, which was brandished. In violation of Title 18, United States Code, Sections 924(c)( 1)(A)(ii) and 2. Case 2:13-cr-00548-KM Document 1 Filed 07/29/12 Page 4 of 5 PageID: 4 ATTACHMENT B I, Michael A. Scimeca, am a Special Agent with the Federal Bureau of Investigation ("FBI"). I am fully familiar with the facts set forth herein based on my own investigation, my conversations with other law enforcement officers, and my review of reports, documents, and items of evidence. Where statements of others are related herein, they are related in substance and part. Because this complaint is being submitted for a limited purpose, I have not set forth each and every fact that I know concerning this investigation. Where I assert that an event took place on a particular date, I am asserting that it took place on or about the date alleged. 1. On or about September 26,2011, at approximately 9:46 a.m., Financial Resources Federal Credit Union (the "Credit Union")-a bank in Franklin Township, New Jersey, the deposits of which were then insured by the Federal Deposit Insurance Corporation ("FDIC")­ was robbed. Bank employees later provided statements to law enforcement. According to bank employees, an older black male entered the bank. He was armed with a handgun and wearing a bandana, a hooded sweat shirt or jacket, and white gloves. The male vaulted the counter and, while waiving his gun, demanded that bank employees give him their money. The loss sustained was approximately $20,339.00. 2. On or about November 21,2011, at approximately 9:49 a.m., Somerset Savings Bank, an FDIC-insured bank in Somerville, New Jersey, was robbed. After the robbery, bank employees provided statements to law enforcement. Bank employees stated that an older black male entered the bank. The male was armed with a handgun and wearing a bandana, a hooded sweat shirt, and white gloves. He vaulted the counter and, while waving his gun, demanded that bank employees give him their money. After he left the bank, the male removed his bandana and hood, and a bank employee observed that he was bald and had facial hair. The loss sustained was approximately $14,691.00. 3. On July 12,2012, at approximately 11 :55 a.m., Unity Bank, an FDIC-insured bank located in Middlesex, New Jersey, was robbed. Surveillance video from the day of the robbery shows that a black male-armed with a handgun and wearing a bandana, a hooded sweat shirt or jacket, and gloves-entered the bank. He left the bank with approximately $9,192. 4. Prior to July 12,2012 robbery, an unarmed off-duty police officer (the "Officer") was parked across from the Unity Bank. The Officer observed a black male, wearing a face covering and a hooded sweat shirt or jacket, enter the Unity Bank. Thereafter, the Officer observed the suspect exit the Unity Bank and get into the rear of a green Ford Taurus bearing New Jersey license plate X91BVR (the "Ford Taurus"). After getting into the Ford Taurus, which was being driven by a female, the suspect crouched down so as not to be visible to observers. 5. The Officer then followed the Ford Taurus, which, after a period oftime, attempted to elude her. After the unsuccessful attempt to elude the Officer, the Ford Taurus stopped. The male-whom the Officer later described as an older black male with a shaved head and facial hair-exited the rear of the car and pointed his gun at the Officer. Case 2:13-cr-00548-KM Document 1 Filed 07/29/12 Page 5 of 5 PageID: 5 6. CLAUDE WILLIAMS owns and regularly uses the Ford Taurus. Several days after the July 12 Robbery, the Ford Taurus was seen parked outside CLAUDE WILLIAMS's residence in Elizabeth, New Jersey, and he was later observed driving it. Nevertheless, CLAUDE WILLIAMS had the Ford Taurus falsely registered in the name of another individual. 7. CLAUDE WILLIAMS's age and appearance are consistent with the Officer's description of the individual whom she observed point a gun at her and with descriptions of the bank robber given by witnesses to of the bank robberies. 8. Within minutes of the September 26,2011 bank robbery, CLAUDE WILLIAMS's cell phone connected to a phone tower in the vicinity of the Credit Union. Approximately thirty minutes after the robbery, CLAUDE WILLIAMS's cell phone connected to a phone tower between the Credit Union and his residence. 9. Approximately thirty minutes before the November 21,2011 robbery, CLAUDE WILLIAMS's cell phone connected to the phone tower closest to the Somerset Savings Bank. Approximately thirty minutes after the robbery, CLAUDE WILLIAMS's cell phone connected to a phone tower between the Somerset Savings Bank and his residence. 10. Approximately six minutes before the July 12,2012 robbery, CLAUDE WILLIAMS's cell phone connected to a phone tower in the vicinity of the Unity Bank.