Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 1 of 20 PageID# 1 IN THE UNITED STATES DISTRICT COURT FOR THE

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1 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 1 of 20 PageID# 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA 'r WMM^MWr UNITED STATES OF AMERICA Alexandria Division Criminal No. l:15-cr-87" m ^SBMiSPBr ' UNDER SEAL THOMAS ANTHONY GEORGE, Defendant. Count 1: 18 U.S.C. 1951(a) Conspiracy to Commit Hobbs Act Robbery Counts 2-7: 18 U.S.C. 2 & 2113(a) & (d) Bank Robbery Counts 8-13: 18 U.S.C. 2 & 924(c)(1)(A) Brandishing and Using a Firearm During and in Relation to a Crime ofviolence Forfeiture: 18 U.S.C. 981(a)(1)(c) & 28 U.S.C. 2461(c) INDICTMENT March 2015 Term - at Alexandria Count One (Conspiracy to Commit Hobbs Act Robbery) THE GRAND JURY CHARGES THAT: From inand around January 2015, and continuing through on or about March 13,2015, in Fairfax County within the Eastern District ofvirginia and elsewhere, the defendant, THOMAS ANTHONY GEORGE did knowingly combine, conspire, confederate and agree with Dawitt Ralph Hall and others, known and unknown to the grand jury, to commit an offense

2 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 2 of 20 PageID# 2 against the United States ofamerica: namely, to obstruct, delay and affect commerce by robbery, in violation oftitle 18, United States Code, Section MANNER AND MEANS OF THE CONSPIRACY The purpose of the conspiracy was to obtain money from federally-insured financial institutions in the Eastern District ofvirginia and elsewhere by way ofarmed robbery. The manner and means by which the conspirators conducted the conspiracy included the following: 1. It was part of the conspiracy that members of the conspiracy traveled in interstate commerce to commit armed robberies ofbanks. 2. It was further part ofthe conspiracy that the defendant and coconspirators entered banks, armed with firearms, and wearing masks, disguises, and/or other face coverings to obscure part of their faces. 3. Itwas further part ofthe conspiracy that the defendant and coconspirators stole money from bank employees while brandishing firearms. 4. It was further part of the conspiracy that a member of the conspiracy served as a "getaway" driver from the scene ofarmed bank robberies. OVERT ACTS In furtherance of the conspiracy and to effect the object thereof, the defendant and his coconspirators performed the following overt acts in the Eastern District of Virginia and elsewhere: 1. On or about January 2,2015, THOMAS ANTHONY GEORGE entered the Bank of America branch located at 1369 Chain Bridge Road, McLean, Virginia, wearing a black coat, black gloves, dark sunglasses, a black, wide-brimmed hat, and a dark beard disguise.

3 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 3 of 20 PageID# 3 2. On or about January 2,2015, THOMAS ANTHONY GEORGE brandished a firearm at employees of Bank of America, and ordered them to the floor. 3. On or about January 2,2015, THOMAS ANTHONY GEORGE robbed Bank of America of approximately $28, in United States currency. 4. On or about January 16, 2015, THOMAS ANTHONY GEORGE and a coconspirator entered the BB&T Bank branch located at 8416 Arlington Boulevard, Fairfax, Virginia, wearing black hats, black masks, and dark gloves. 5. On or about January 16, 2015, THOMAS ANTHONY GEORGE brandished a firearm at customers and employees of BB&T Bank. 6. On or about January 16,2015, THOMAS ANTHONY GEORGE and the coconspirator robbed BB&T Bank ofapproximately $5, inunited States currency. 7. On or about January 20, 2015, THOMAS ANTHONY GEORGE and a coconspirator entered the Bank of America branch located at 235 Maple Avenue, Vienna, Virginia, wearing black hats, dark gloves, and face coverings. 8. On or about January 20, 2015, THOMAS ANTHONY GEORGE and the coconspirator brandished firearms at customers and employees of Bank of America, and ordered them to the floor. 9. On or about January 20, 2015, THOMAS ANTHONY GEORGE and the coconspirator robbed Bank of America ofapproximately $47, in United States currency. 10. On or about January 30, 2015, THOMAS ANTHONY GEORGE and a coconspirator entered the Essex Bank branch located at 1460 Ritchie Highway, Arnold, Maryland, wearing dark face and head coverings, darkjackets, and dark gloves.

4 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 4 of 20 PageID# On or about January 30,2015, THOMAS ANTHONY GEORGE and the coconspirator brandished firearms at employees of Essex Bank, and ordered customers to the floor. 12. On or about January 30,2015, THOMAS ANTHONY GEORGE and the coconspirator robbed Essex Bank ofapproximately $6, in United States currency. 13. On or about February 5, 2015, THOMAS ANTHONY GEORGE entered the SunTrust Bank branch located at3070 Leonardtown Road, Waldorf, Maryland, wearing a black coat, gloves, dark sunglasses, a black, wide-brimmed hat, and a dark beard disguise. 14. On or about February 5, 2015, THOMAS ANTHONY GEORGE brandished a firearm at employees of SunTrust Bank. 15. On or about February 5, 2015, THOMAS ANTHONY GEORGE robbed SunTrust Bank of approximately $19, in United States currency. 16. On or about February 18, 2015, THOMAS ANTHONY GEORGE and a coconspirator entered the BB&T Bank branch located at 440 Maple Avenue East, Vienna, Virginia, wearing black stocking caps, black face coverings, black coats, and black gloves. 17. On or about February 18, 2015, THOMAS ANTHONY GEORGE and the coconspirator brandished firearms at customers and employees of BB&T Bank, and ordered them to the floor. 18. On or about February 18,2015, THOMAS ANTHONY GEORGE and the coconspirator robbed BB&T Bank ofapproximately $2, in United States currency. 19. On or about February 18, 2015, THOMAS ANTHONY GEORGE and a coconspirator entered the Wells Fargo Bank branch located at47040 Community Plaza, Sterling, Virginia, wearing dark coats, dark gloves, and dark face coverings.

5 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 5 of 20 PageID# On or about February 18, 2015, THOMAS ANTHONY GEORGE and the coconspirator brandished firearms at customers and employees of Wells Fargo Bank. 21. On or about February 18,2015, THOMAS ANTHONY GEORGE and the coconspirator robbed Wells Fargo Bank of approximately $27, in United States currency. 22. On or about March 2,2015, THOMAS ANTHONY GEORGE and a coconspirator entered the Wells Fargo Bank branch located at 1000 West Broad Street, Falls Church, Virginia, wearing black hats, black face coverings, and black gloves. 23. On or about March 2,2015, THOMAS ANTHONY GEORGE and the coconspirator brandished firearms at customers and employees of Wells Fargo Bank, and ordered them to the floor. 24. On or about March 2,2015, THOMAS ANTHONY GEORGE and the coconspirator robbed Wells Fargo Bank of approximately $35, in United States currency. 25. On or about March 13,2015, THOMAS ANTHONY GEORGE entered the Wells Fargo Bank branch locatedat 4302 Connecticut Avenue NW, Washington, D.C., wearing a blue jacket, sunglasses, gloves, and a mask. 26. On or about March 13,2015, THOMAS ANTHONY GEORGE brandished a firearm at employees ofwells Fargo Bank. 27. On or about March 13,2015, THOMAS ANTHONY GEORGE robbed Wells Fargo Bank ofapproximately $9, in United States currency.

6 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 6 of 20 PageID# On or about March 13,2015, THOMAS ANTHONY GEORGE, after robbing the Wells Fargo Bank, entered the passenger side ofa black Chevrolet Suburban driven by Dawitt Ralph Hall, who drove the vehicle from the scene ofthe robbery. (All in violation oftitle 18, United States Code, Section 1951(a).)

7 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 7 of 20 PageID# 7 Count Two (Bank Robbery) On or about January 2, 2015, in Fairfax County, Virginia, in the Eastern District of Virginia, the defendant, THOMAS ANTHONY GEORGE, by force and violence, and by intimidation, did take from the person and presence ofanother, namely employees of the Bank of America branch located at 1369 Chain Bridge Road, McLean, Virginia, approximately $28, in United States currency, money belonging to and in the care, custody, control, management, and possession of the Bank of America, the deposits of which were then insured by the Federal Deposit Insurance Corporation, and did assault and put in jeopardy the life ofanother person, namely Bank ofamerica employees, by the use ofa dangerous weapon, namely a firearm. (In violation oftitle 18, United States Code, Sections 2113(a) and (d), and 2.)

8 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 8 of 20 PageID# 8 Count Three (Bank Robbery) Onor about January 16,2015, in Fairfax County, Virginia, in the Eastern District of Virginia, the defendant, THOMAS ANTHONY GEORGE, by force and violence, and by intimidation, did take from the person and presence ofanother, namely employees ofthe BB&T Bank branch located at 8416 Arlington Boulevard, Fairfax, Virginia, approximately $5, in United States currency, money belonging to and in the care, custody, control, management, and possession ofbb&t Bank, the deposits ofwhich were then insured by the Federal Deposit Insurance Corporation, and did assault and put in jeopardy the life ofanother person, namely BB&T Bank employees and customers, by the use ofa dangerous weapon, namely a firearm. (In violation of Title 18, United States Code, Sections 2113(a) and (d), and 2.)

9 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 9 of 20 PageID# 9 Count Four (Bank Robbery) On or about January 20,2015, in Fairfax County, Virginia, in the Eastern District of Virginia, the defendant, THOMAS ANTHONY GEORGE, by force and violence, and by intimidation, did take from the person and presence of another, namely employees ofthe Bank of America branch located at 235 Maple Avenue, Vienna, Virginia, approximately $47, in United States currency, money belonging to and in the care, custody, control, management, and possession of the Bank of America, the deposits of which were then insured by the Federal Deposit Insurance Corporation, and did assault and put in jeopardy the life of anotherperson, namely Bank of America employees and customers, by the use of a dangerous weapon, namely a firearm. (In violation oftitle 18, United States Code, Sections 2113(a) and (d), and 2.)

10 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 10 of 20 PageID# 10 Count Five (Bank Robbery) On orabout February 18, 2015, in Fairfax County, Virginia, in the Eastern District of Virginia, the defendant, THOMAS ANTHONY GEORGE, by force and violence, and by intimidation, did take from the person and presence ofanother, namely employees ofthe BB&T Bank branch located at 440 Maple Avenue East, Vienna, Virginia, approximately $2, in United States currency, money belonging to and in the care, custody, control, management, and possession ofbb&t Bank, the deposits ofwhich were then insured by the Federal Deposit Insurance Corporation, and did assault and put in jeopardy the life ofanother person, namely BB&T Bank employees and customers, by the use ofadangerous weapon, namely a firearm. (In violation oftitle 18, United States Code, Sections 2113(a) and (d), and 2.)

11 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 11 of 20 PageID# 11 Count Six (Bank Robbery) On or about February 18, 2015, in Loudoun County, Virginia, in the Eastern District of Virginia, thedefendant, THOMAS ANTHONY GEORGE, by force and violence, and by intimidation, did take from the person and presence of another, namely employees ofthe Wells Fargo Bank branch located at Community Plaza, Sterling, Virginia, approximately $27, in United States currency, money belonging to and in the care, custody, control, management, andpossession of Wells Fargo Bank, the deposits of which were then insured by the Federal Deposit Insurance Corporation, and did assault and put injeopardy the lifeof another person, namely Wells Fargo Bank employees and customers, by the use of a dangerous weapon, namely a firearm. (In violation of Title 18, United States Code, Sections 2113(a) and (d), and 2.) 11

12 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 12 of 20 PageID# 12 Count Seven (Bank Robbery) On or about March 2,2015, in City of Falls Church, Virginia, in the Eastern District of Virginia, the defendant, THOMAS ANTHONY GEORGE, by force and violence, and by intimidation, did take from the person and presence ofanother, namely employees ofthe Wells Fargo Bank branch located at 1000 West Broad Street, Falls Church, Virginia, approximately $35, in United States currency, money belonging to and in the care, custody, control, management, and possession ofwells Fargo Bank, the deposits ofwhich were then insured by the Federal Deposit Insurance Corporation, and did assault and put in jeopardy the life ofanother person, namely Wells Fargo Bank employees and customers, by the use ofa dangerous weapon, namely a firearm. (In violation of Title 18, United States Code, Sections 2113(a) and (d), and 2.) 12

13 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 13 of 20 PageID# 13 Count Eight (Brandishing and Using a Firearm During a Crime of Violence) On or about January 2, 2015, in Fairfax County, Virginia, in the Eastern District of Virginia, the defendant, THOMAS ANTHONY GEORGE, did knowingly and unlawfully use, carry, and brandish a firearm during and in relation to a crime of violence for which he may be prosecuted in a courtof the United States, that is, the January 2,2015 armed robbery of Bank of America, as set forth and charged in Count Two ofthis Indictment. (In violation of Title 18, United States Code, Sections 924(c)(l)(A)(ii), and 2.) 13

14 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 14 of 20 PageID# 14 Count Nine (Brandishing and Using a Firearm During a Crime of Violence) Onor about January 16, 2015, in Fairfax County, Virginia, in the Eastern District of Virginia, the defendant, THOMAS ANTHONY GEORGE, did knowingly and unlawfully use, carry, and brandish a firearm during and in relation to a crime ofviolence for which he may be prosecuted in a court of the United States, that is, the January 16,2015 armed robbery of BB&T Bank, as set forth and charged in Count Three ofthis Indictment. (In violation of Title 18, United States Code, Sections 924(c)(l)(A)(ii), and 2.) 14

15 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 15 of 20 PageID# 15 Count Ten (Brandishing and Using a Firearm During a Crime ofviolence) On or about January 20, 2015, in Fairfax County, Virginia, in the Eastern District of Virginia, the defendant, THOMAS ANTHONY GEORGE, did knowingly and unlawfully use, carry, and brandish a firearm during and in relation to a crime ofviolence for which he may be prosecuted in a court ofthe United States,that is, the January 20, 2015 armed robberyofbankof America, as set forth and charged in Count Four ofthis Indictment. (In violation oftitle 18, United States Code, Sections 924(c)(l)(A)(ii), and 2.)

16 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 16 of 20 PageID# 16 Count Eleven (Brandishing and Usinga Firearm During a Crime of Violence) On or about February 18, 2015, in Fairfax County, Virginia, in the Eastern Districtof Virginia, the defendant, THOMAS ANTHONY GEORGE, did knowingly and unlawfully use, carry, and brandish a firearm during and in relation to a crime of violence for which he may be prosecuted in a court of the United States, that is, the February 18,2015 armed robbery of BB&T Bank, as set forth and charged in Count Five ofthis Indictment. (In violation of Title 18, United States Code, Sections 924(c)(l)(A)(ii), and 2.) 16

17 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 17 of 20 PageID# 17 Count Twelve (Brandishing and Using a Firearm During a Crime of Violence) Onor about February 18,2015, in Loudoun County, Virginia, in the Eastern District of Virginia, the defendant, THOMAS ANTHONY GEORGE, did knowingly and unlawfully use, carry, and brandish a firearm during and in relation to a crime of violence for which he may be prosecuted in a court of theunited States, that is, the February 18,2015 armed robbery of Wells Fargo Bank, as set forth and charged in Count Six of this Indictment. (In violation of Title 18, United States Code, Sections 924(c)(l)(A)(ii), and 2.) 17

18 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 18 of 20 PageID# 18 Count Thirteen (Brandishing and Using a Firearm During a Crime ofviolence) On or about March 2,2015, in City offalls Church, Virginia, in the Eastern District of Virginia, the defendant, THOMAS ANTHONY GEORGE, did knowingly and unlawfully use, carry, and brandish a firearm during and in relation to a crime ofviolence for which he may be prosecuted in a court ofthe United States, that is, the March 2, 2015 armed robbery ofwells Fargo Bank, as set forth and charged in Count Seven ofthis Indictment. (In violation oftitle 18, United States Code, Sections 924(c)(l)(A)(ii), and 2.) 18

19 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 19 of 20 PageID# 19 FORFEITURE NOTICE The defendant, THOMAS ANTHONY GEORGE, ifconvicted ofcounts Two through Eight of this Indictment, shall forfeit to the United States, pursuant to Title 18, United States Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c), any property, real or personal, which constitutes or is derived from proceeds ofthe offenses charged in those counts. This property includes, but is not limited to: (a) approximately $28, in United States currency taken from Bank of America on January 2, 2015; (b) approximately $5, inunited States currency taken from BB&T Bank on January 16,2015; (c) approximately $ in United States currency taken from Bank of America on January 20,2015; (d) approximately $6, in United States currency taken from Essex Bank on January 30, (e) approximately $19, in United States currency taken from SunTrust Bank on February 5, 2015; (f) approximately $2, in United States cunency taken from BB&T Bank on February 18, 2015; (g) approximately $27, in United States currency taken from Wells Fargo Bank on February 18, 2015; (h) approximately $35, inunited States currency taken from Wells Fargo Bank on March 2,2015; 19

20 Case 1:15-cr JCC Document 1 Filed 03/19/15 Page 20 of 20 PageID# 20 Pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title 28, United States Code, Section 2461(c), the defendants shall forfeit substitute property, up tothe value ofthe amount described above, ifby any act or omission ofthe defendants, the property described above, or any portion thereof, cannot be located upon the exercise ofdue diligence; has been transferred, sold, orsubstantially diminished in value; orhas been commingled with other property that cannotbe divided without difficulty. Furthermore, pursuant to Title 18, United States Code, Section 924(d)(1), any firearms that were used by the defendant, during and in relation to the armed robberies charged in this Indictment, in violation of Title 18, United States Code, Section 924(c), shall be forfeited tothe United States. (Pursuant totitle 18, United States Code, Sections 924(d)(1) and 981(a)(1)(C); and Title 28, United States Code, Section 2461(c); and Rule 32.2(a), Federal Rules ofcriminal Procedure.) ATRUE'^S^^theE-GovcnmjentAcC* W orfgihal ofthis page has been filed materseal indiectoik's Office, - Dana J. Boente United States Attorney Foreperson ofthe Grand Jury By: Tobias/D. Tobler Assistant United States Attorney Jonathan L. Fahey Assistant United States Attorney 20