1. At times material to this indictment:

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1 Case: 1:18-cr Document #: 14 Filed: 06/14/18 Page 1 of 5 PageID #:33 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION COT]NIT ONE.ilil-iU6:,8,fi[?13il*, The SPECIAL DECEMBER 20L7 GRAM JURY charges: 1. At times material to this indictment: Old Second National Bank was a bank with a branch located at 323 East Norris Drive, Ottawa, Illinois (hereinafter "OId Second National Bank"), the deposits of which were then insured by the Fed.eral Deposit Insurance Corporation. b. Norstates Bank was a bank \{rith a branch located at 5384 Grand Avenue, Gurnee, Illinois (hereinafter "Norstates Bank"), the deposits of which were then insured by the Federal Deposit Insurance Corporation. c. Aurora Bank & Trust was a bank with a branch located at 2287 West Galena Boulevard, Aurora, Illinois (hereinafter "Aurora Bank & Trust"), the deposits of which were then insured by the Federal Deposit Insurance Corporation. 2. From on or about March 2018 and continuing through on or about May 31-, 2018, in the Northern District of Illinois, Eastern Division, and elsewhere, JAMES D. WILLIAMS and ALEXIS T. HANDELMAN, \l

2 Case: 1:18-cr Document #: 14 Filed: 06/14/18 Page 2 of 5 PageID #:34 defendants herein, did conspire with each other and others known and unknown to the Grand Jury, to commit an offense against the United States, namely, bank robbery, in violation of Title 18, United States Code, Section 2113(a). 3. It was pari of the conspiracy that defendant JAMES D. WILLIAMS and defendant ALEXIS T. IIANDELMAN agreed" that they would rob the Old Second National Bank, Norstates Bank, and Aurora Bank & Ttust. Overt Acts 4. In furtherance of and to effect the object of the conspiracy, defendants committed and. caused to be committed the following overt acts, among others, in the Northern District of Illinois: a. In or around March hois,williams stole an AK-47 firearn. b. In or around May 2018, WILLIAMS obtained an additional firearm. c. On or about May 11, 2018, WILLIAMS purchased latex gloves. d. On or about May L1-, 2018, WILLIAMS and HANDELMAN robbed the Old Second National Bank of approximately $g,ge5. e. On or about May 1-5, 20t8, WILLIAMS rented a blue Nissan Rogue from a rental car company. f. On or about May 21,2018, WILLIAMS caused two license plates to be stolen. g. Onorabout May2L,h}L},WILLIAMS causedthenissanrogue's Iicense plates to be replaced" with the stolen license plates.

3 Case: 1:18-cr Document #: 14 Filed: 06/14/18 Page 3 of 5 PageID #:35 h. On or about May 2L, 20L8, WILLIAMS and IIANDELMAN caused the Norstates Bank to be robbed of approximately $5,tSg. i. On or about May 22,2018, WILLIAMS returned the Nissan Rogue to the rental car company. j. On or about May 22,20L8,WILLIAMS rented a black Ford Fusion from a rental car company. k. On or about May 23, 20L8, WILLIAMS and IIANDELMAN traveled to a cellular phone store in Schaumburg, Illinois. 1. On or about May 23, 20L8, WILLIAMS purchased a cellular phone using robbery proceeds. m. One or about May 31, 2018, WILLIAMS and IIANDELMAN caused" the Aurora Bank & Trust to be robbed of approximately $t}l,5+1. n. On or about May 31, 2018, WILLIAMS returned the Ford Fusion to the rental car company. In violation of Title 18, United States Code, Section

4 Case: 1:18-cr Document #: 14 Filed: 06/14/18 Page 4 of 5 PageID #:36 Division, COI]IYT TWO The SPECIAL DECEMBER 2Ot7 GRAND JURY charges: 1. On or about May 11, 2018, in the Northern District of lllinois, Eastern JAMES D. WILLIAMS and ALEXIS T. IIANDELMAN, defendants herein, by force and violence, and by intimidation, did take from the person and presence of a bank employee approximately $9,305 in United States currency belonging to and in the care, custody, control, management, and" possession of Old Second National Bank, located at 323 East Norris Drive, Ottawa, Illinois, the deposits of which were then insured by the Federal Deposit Insurance Corporation; In violation of Title 18, United States Code, Section 2113(a) and2.

5 Case: 1:18-cr Document #: 14 Filed: 06/14/18 Page 5 of 5 PageID #:37 Forfeiture Allegation The SPECIAL DECEMBER 20L7 GRAND JURY turther alleges: 1. Upon conviction of an offense inviolation oftitle 1-8, United States Code, Section 2113(a), as set forth in this Indictment, WILLIAMS shall forfeit to the United States of America any property which constitutes and is derived from proceeds traceable to the offense, as provided. in Titte 18, United States Code, Section 981(aX1XC) and Tit1e 28, United States Code, Section 246L(c). 2. The property to be forfeited includes, but is not limited to: a. approximately $8,gOO seized by law enforcement on May 31, 2018 from WILLIAMS'person. 3. If any of the property described above, as a result of any act or omission by a defendant: cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with, a third party; has been placed beyond, the jurisdiction of the Court; has been substantially diminished in value; or has been commingled with other property which cannot be divided without difficulty, the United States of America shall be entitled to forfeiture of substitute property, as provided in Title 21, United States Code Section S53(p). A TRUE BILL: FOREPERSON UNITED STATES ATTORNEY