Free Complaint (Sealed) - District Court of Delaware - Delaware

Case 1:06-cr-00005-SLR
A 0 91 (Rev. 12/93) Criminal Complaint

Document 2

Filed 01/05/2006

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United States District Court
DISTRICT OF
UNITED STATES OF AMERICA

DELAWARE

v.

~diminal Complaint
DOLENA GRAYSON,
(Nameand Address of Defendant)

I, the undersigned complainant,being duly sworn, state the following is true and c rrect to the best of my knowledge and belief.
On or about January 5.2006,
Language of OtTenss)

in New Castle

County, in the District of

t

(TrackStatutory

did, with intent to defraud, pass, utter, and possess counterfeited securities, e.g., counterfeit che ks, in violation of Title 18 United States Code, Section(s) 5 13

.

f

I further state that I am a(n) S~ecial Agent, U.S. Secret Service
Offic~al T~tle

and that this comp1,iintis based

on the following facts:

SEE ATTACHED AFFIDAVIT Continued on the attached sheet and made a part hereof: YES

Andrew Balceniuk, Special Ag snt U.S. Secret Service

Sworn to before me and subscribed in my presence, January 5,2006
Date

at

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, ,

Honorable Mary Pat Thynge United States Magistrate Judge
Name & Title of Judicial Off~cer

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UNITED STATES DISTRICT COURT DISTRICT OF DELAWARE
AFFIDAVIT OF SPECIAL AGENT ANDREW BAL

I, Andrew Balceniuk, being duly sworn, depose and say:
1. Your affiant is a Special Agent with the U.S. Secret Servic employed since October 2002. Your affiant is currently as Wilmington, Delaware, Resident Office. Your affiant's d investigation of counterfeit checks and the use of these training given to U.S. Secret Service Special Agents in months of field and classroom training in all aspects o counterfeit checks, the process in which these checks obtained, and how computers are used to create count affiant's employment with the U.S. Secret Service, an Inspector by the Bureau of Alcohol, Tobacco an 2. On 2/15/05, your affiant was contacted by a fi-aud Savings Fund Society (WSFS) regarding a investigation involving Dolena Grayson. for Wilmington

3. The investigator stated that, on 1/25/05, William Burton open d a business checking account at the Glen Eagle WSFS branch and, on 11 6/05, deposited into that account two counterfeit commercial checks, #952 114 an #952124, totaling $50,630.99 and made payable to Burton Contracting and Con truction. On 1/28/05, Burton returned to the Glen Eagle branch and receiv d three $10,000 cashier's checks, one each made payable to Eugene Adams, t Dolena Grayson Catering, and to F.C. Kerbeck.

..

On February 25,2005, your affiant and another special ag at the Howard R. Young Correctional Institution in Wilm Burton stated that in early January 2005, he was approac with the proposition of making money. Burton stated th Burton with a check in the amount of $1,717.08 which cashing business in Wilmington, Delaware. In return Burton received $40.00 and Grayson received the r the following day Grayson introduced Burton to E Adams was "the master-mind behind the checks". his name and address and was told that Adams following day Grayson picked up Burton and then Dollar Tree store in Wilmington, Delaware. Ad approximately ten checks made payable to Burton which Burt then cashed at various check cashing businesses January, Burton stated that he opened a busines

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Construction at the WSFS Branch in Glen Mills, Pennsylv he opened an account with approximately $53,000.00 in Grayson and Adams. With a portion of the money he stated he acquired three $10,000.00 cashier's checks; Eugene Adams, Dolena Grayson Catering and F.C. cashier's checks to Grayson and Adams. Burton cashed her check at a WSFS Branch on Dupont Adams cashed his. Burton was shown a security camera and identified the 5. In July 2005, your affiant met with a cooperating witness case. While discussing that case, the CW stated that she passing counterfeit checks. She stated that Dolena as a man using the name " G . The CW stated that contacts within Wilmington Trust Company and headquartered in Wilmington, Delaware, and recruiting people to cash the checks.

. Burton stated that

on an unrelated a group that was as well

6. On July 7,2005, the CW contacted your affi Resident Office via telephone and stated way connection. The CW stated that she h person interested in making some extra money and w scheme worked. At that point, Grayson was connect explained to your affiant that your affiant would be identification, probably a driver's license. Grayson to create a fake driver's license with your affiant's Your affiant was to use the fake identification to each of which your affiant would deposit a $5,00 The next day your affiant was to withdraw the fi $5,000.00 in the form of a check provide follow this procedure three days in a row, an additional $5,000.00. The money your affi Grayson, the CW and your affiant.
7. On 7/12/05, the CW agreed to make a consensually monitore telephone call to Grayson. Grayson, believing she was

that we would use to open business accounts. We provided by "people she knew", and then
8. On 12/2/05, the CW made a second consensually monitored telephone call to Grayson. The CW asked Grayson if she her with a financial problem by providing her with checks. In exchange for the checks, the CW would account and give $20,000.00 to Grayson. Grayson

Case 1:06-cr-00005-SLR

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to provide the checks and would set up a time with the or Tuesday to conduct the transaction.

following Monday

9. On 1/5/06, the CW telephoned Grayson in order to set up a m eting place for

delivery of several checks. Your affiant listened to the conve sation in which Grayson told the CW that she was in personal possession o f t e checks this morning, and would not need to pick them up fi-om anyone el e. 10. On 1/5/06, Grayson met with the CW in the parking lot in Diamonds, 4451 Concord Pike, Wilmington, Delaware, -r this Service including your affiant, as well as several x" State Police, observed Grayson hand over a white turned the envelope over to another agent who it contained four counterfeit commercial
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Based on my investigation, your affiant submits that there believe that Dolena Grayson has violated 18 USC 513, making, p counterfeited securities. WHEREFORE, your affiant p Dolena Grayson.

probable cause to or uttering

Special Agent United States Secret Se ice

I