Jerry Banks is accused of kidnapping GD on January 6, 2018 in Danville, Vermont. GD's wife MD reported that a man claiming to be a US Marshal arrested GD for racketeering and took him away in a white vehicle. GD's body was later found shot in Barnet, Vermont. The FBI investigation identified two prepaid phones, a 911 phone and 201 phone, purchased by the same individual around the times of the kidnapping and murder. Surveillance footage showed a bearded white man matching Banks' description purchasing one of the phones. Cell site data placed both phones near the crime scenes around the relevant times. Banks is charged with kidnapping resulting in death.

1. ^uery Reports Utilities Help What's New Log Out
D!5"iiliwT cr-jni .
U.S.District Court DiSTPj:f OF «■; JiF.-U.
District ofVermont (Rutland) pm 1: I|2
CRIMINAL DOCKET FOR CASE #: 5:22-mi-00037-gwc-l
mj-uuu:>/-gwc-
Case title: USA v. SEALED
B' )TK!MS,CLlRH
Date Filed: 03/30/2022
Assigned to: Chief Judge Geoffrey W.
Crawford
Defendant (IJ
Jerry Banks
Pending Counts
None
Disposition
Highest Offense Level fOpeningJ
None
Terminated Counts
None
Disposition
Highest Offense Level CTerminatedJ
None
Complaints
18:1201(a)(l).F - KIDNAPPING
Disposition
Plaintiff
USA represented by Jonathan Ophardt, AUSA
United States Attorney's Office
District of Vermont
P.O. Box 570
Burlington, VT 05402-0570
(802) 951-6725
Email: Jon.Ophardt@usdoj.gov
ATTORNEY TO BE NOTICED
Designation: Assistant USAttorney
Paul J. Van de Graaf, AUSA
United States Attomey's Office
District of Vermont
Case 0:22-mj-00022-KHR Document 1 Filed 04/06/22 Page 1 of 16

2. P.O. Box 570
Burlington,VT 05402-0570
802-951-6725
Fax:802-951-6540
Email:paul.van.de.graaf@usdoj.gov
ATTORNEY TO BE NOTICED
Designation:Assistant USAttorney
Date Filed # Docket Text
03/30/2022 i COMPLAINT as to Jerry Banks(1).Signed by ChiefJudge Geoffrey W.Crawford on
3/30/2022.(Attachments:#iAffidavit ofPatrick Hanna)(esm)(Entered:03/30/2022)
03/30/2022 2 MOTION to Seal1Complaint and Arrest Warrant by USA as to Jerry Banks,(esm)
(Entered:03/30/2022)
03/30/2022 3 ORDER granting 2 Motion to Seal1Complaint and Arrest Warrant as to Jerry Banks(1).
Sealed until the arrest ofthe defendant.Signed by ChiefJudge Geoffrey W.Crawford on
3/30/2022.(esm)(Entered:03/30/2022)
Case 0:22-mj-00022-KHR Document 1 Filed 04/06/22 Page 2 of 16

3. Case 5:22-m]-00037-gwc Document1 Filed 03/30/22 Page 1 of1
AO91(Rev.11/l1) Criminal Complaint
U.o. DIOTniOT COURT
United StatesDistrictCourt districto^f^wrmont
for the
2022MAR 30 PHZjSI
District ofVermont
United States ofAmerica
V.
Jerry Banks
CaseNo.^
CLERK
8Y, ^
Defendanl(s)
CRIMINAL COMPLAINT
I,the complainantin this case,state thatthe following is true to the bestofmy knowledge and belief.
On or aboutthe date(s)of January 6,2018
District of Vermont
in the county of
,the defendant(s)violated:
Caledonia in the
CodeSection
18 U.S.C.§ 1201(a)(1)
Offense Description
The unlawful seizure,confinement,Inveigling, decoying,kidnapping,
abduction,and carrying away,for reward and otherwise,GD,and In
committing and In furtherance ofthe commission ofthe offense,travelling In
Interstate commerce and using a facility and Instrumentality ofinterstate
commerce.
This criminal complaintis based on these facts:
See attached Affidavit.
ffif Continued onthe attached sheet.
Sworn to before meand signed in my presence.
Date: 03/30/2022
City and state: Rutland,Vermont
/C
Compiainant'ssignature
Patrick Hanna,Special Agent,FBI
Printed name and title
Judge'ssignature
Hon.Geoffrey W.Crawford,Chief US District Judge
Printed name and title
Case 0:22-mj-00022-KHR Document 1 Filed 04/06/22 Page 3 of 16

4. Case 5:22-mj-00037-gwc Document1-1 Filed 03/30/22 Page 1 of 12
AFFIDAVIT
I,Patrick Hanna,being duly swom,depose and say:
Introduction
1. I am a Special Agentwith the Federal Bureau ofInvestigation(FBI)and cun*ently
assigned to the Burlington Resident Agency in Vermont.I have been an FBI Special Agentfor
19 years. My duties as an FBI Special Agentincludeinvestigating violations ofTitle 18 ofthe
United States Code asthey pertainto corporate fraud,complex financial crimes,embezzlement,
public corruption,money laundering and related white-collar crimes,as well as violent crimes
and criminal enterprises.I have participated in investigations ofcriminal violations ofvarious
federal laws.I have executed search and arrest wan-ants,interviewed and interrogated subjects,
witnesses,and victims,and conducted sui-veillance.In the course oftheseinvestigations,I have
gained an understanding ofcurrenttechnology,to include computers and online accounts,
cellular telephones and associated records and data,and have conducted analyses ofthe data
related to such accounts and devices,forthe puipose ofsolving and proving crimes.
2. I am submitting this Affidavitin supportofacomplaintalleging that Jeriy Banks
kidnapped GD(the victim)on January 6,2018,in violation of18 U.S.C.§ 1201(a)(1).
3. This case is being investigated by the FBI and the VermontState Police(VSP).
Since this affidavitis being submitted forthe limited puipose ofsupporting a complaint,I have
notincluded details ofeveiy aspectofthe investigation.Exceptas otherwise noted,the
information contained in this Affidavitis based upon my personal knowledge and obsei-vations,
mytraining and experience,conversations with otherlaw enforcement officers and witnesses,
and myreview ofdocuments and records.
Probable Cause
A. The Kidnapping and Shooting
4. On January 7,2018,VSP responded to a homicide in Bainet,VT.The victim,
identified as GD,wasfound partially covered by snow nearthe base ofasnowbank on a pull off
area near the west side ofPeacham Road.The victim wasfound handcuffed and had been shot
multiple timesin tlie head and torso.GD resided at884 Hawkins Road,Danville,VT atthe time.
The victim's body was discovered approximately 15 miles fiom hisresidence. Evidence
gathered from the crime scene included.22caliber caitridge casings.
5. VSP Detectives responded to GD's home and interviewed his wife,MD,and their
12-year-old son(minor child #1).Both wereinterviewed again later. MD told VSP Detectives
that at approximately 9:00 p.m.on Januai-y 6,2018,she and her husband were in a first-floor
bedroom in their Danville home.They heard someoneIcnock on the door.GD wentto the door to
see who wasthere.GD came back to the bedroom and told MD that a man claiming to be a U.S.
Marshal came to the victim's home to arresthim.GD got his clothes on and left with the man.
MD saw tlie man and described him as having handcuffs,a rifle,and wearing ajacket and mask
with an eye opening,both ofwliich had a U.S.Maishals emblem.MD also reported thatthe man
Case 0:22-mj-00022-KHR Document 1 Filed 04/06/22 Page 4 of 16

5. Case 5:22-mj-00037-gwc Document1-1 Filed 03/30/22 Page 2of12
said he had an airest warrantfor GDfor racketeering and was bringing him to Virginia.Minor
child #1,who observed the man and his carfrom asecond-floor window,told police thatthe man
drove a whitefour-doorcar with red and blue emergency lights activated onthe dash.GD leftin
the man'scar.The man was wearing black clothes and had a gun and a beltwith variouslaw
enforcementtools on it. MD did notcontactpolice.
6. On January 10,2018,AgentJennie Emmonsconfirmed with Supervisory Deputy
U.S.Marshal Carl Staley ofthe Burlington Vermontoffice ofthe U.S. Marshals Service that GD
was not arrested by their agency.Further,Deputy Mar'shal Staley said thatthere had been no
active federal warrants for GD.
B. The 911 Phone
7. Ilistened to a911 call madearound thetime ofthe victim's kidnapping.The call
took place approximately 15 minutes prior to the kidnapping and originated within a mile ofthe
victim'sresidence. The VT 911 call centerreceived acallfrom(802)473-0535(the911 Phone)
at8:42p.m.on January 6,2018. The 911 call center'stechnology identified the call ascoming
from alocation on North Danville Road,Danville,VT,only a short distancefrom the victim's
residence.I believethatBanks used the 911 Phoneto facilitate the victim's kidnapping and
murder.
a. During the call,a man stated thathe shothis wife and was going to shoothimself.
The caller gave an address of"71772 Cross Road"(with notown information),after which the
caller hung up.The call information wasrelayed to VSP in St.Johnsbury,Vermont.VSP
attempted to locate a Cross Road in the St.Johnsbury area withoutsuccess.
b. VSP thereafterrequested that AT&T provide location informationforthe phone
in question dueto the exigentchcumstance.AT&T confirmed thatthe 911 call camefrom the
North Danville Road location. AT&T also reported thatthe phone was a prepaid phone with no
subscriber information available. After VSP checked the North Danville location and several
possible"Cross Roads"outside the town ofSt. Johnsbury,the matter wasclosed.Atthattime,
the victim's body had not been discovered.
c. I later obtained search warrantsfor various accounts used by Banks,including his
Facebook account,where Banks listed his user nameas GrizzSands. Among the data inthe
Facebook accountwere video recordings,including avideo in which Banks nar'rated atour ofhis
residence in Fort Garland,CO.Banks'voice soundssimilar'tothe voice ofthe 911 caller.
8. AT&Tresponded to a search warrantforinformation associated with the911
Phone.The AT&T search warrantdata confirmed the location ofthe 911 call on January 6,2018,
near the time and location ofvictim's kidnapping.
9. The data provided by AT&T wasreviewed by Special AgentJames Winesofthe
FBI's Cellular Analysis Survey Team.After this review,and consultation with AT&T security
personnel.AgentWinesadvised thattlie911 Phone wasa prepaid phone purchased ata Walmart
on January 5,2018.The recordsshowed only two calls made by the phone,afour-second call to
a Pizza Hutin St.Johnsbury,VT at4:14 p.m.on January6and the911 call at8:42p.m.on
Case 0:22-mj-00022-KHR Document 1 Filed 04/06/22 Page 5 of 16

6. Case 5:22-mj-00037-gwc Document1-1 Filed 03/30/22 Page 3of12
Januaiy 6. The phone used only two sectors ofthe same cell tower,located in St.Johnsbury,
VT,for all cell site activity.Agent Wines also advised thatthis phone was activated,meaning
thatitcould operate on the AT&T network,shortly before4:00 p.m.on January 6,within
minutesofthe Pizza Hutcall.I have notbeen able to establish howthe phone was activated.
10. Agent Wines advised me that helearned from contacts at Walmaitsecurity that
the prepaid phone was purchased with $100cash on January 5,2018,at4:14 p.m.atthe Walmart
located at 100 Supercenter Drive,Clearfleld,PA.Agent Winesforwarded me numerous security
camera images ofthe individual purchasing the phone,which were obtained from Walmart
security.Theimagesshow a bearded,adult,white man purchasing the phone.The man arrived
and departed in a white Ford Explorer.Thecamerafootage indicatesthe vehicle parked inthe
Walmartpai'king lot around 3:55 p.m.and leftthe lotaround 4:17 p.m.The Explorer doesnot
appear"to have afrontlicense plate.The rear plate waslightin color and appeared to be white.
Numbersand/orletters were notrecognizable on the rear plate.TheExploreris generally
consistent with minor child#rs description ofthe kidnapper's car*.
11. FBI personnel in Pennsylvania canvassed gasstations and otherlocationsin the
vicinity ofthe Walmartat 100 Supercenter Drive,Clearfield,PA,to determine ifadditional
security camerafootage ofthe bearded,white male and/orthe whiteFord Explorercould be
located.Additional videofootage ofthe suspectand vehicle were located ata BP gas station at
14624 Clearfleld Shawville Highway,Cleai'field,PA 16830.
12. I reviewed stills ofthisfootage,which included images ofthe beai'ded,white man
and the white Ford Explorer,andthey appearto bethesame person and vehicle shown in the
Walmartsecurity video.Thesuspectpurchased gasatthe BP station.I saw whatappearsto be a
smaitphone in the suspect's hand.A time stamp on this video putthe stop atthe gas station at
4:27p.m.on January 5,2018.My review ofthe reportsofthe agents who ti'avelled to Cleai'field,
Pennsylvaniashowsthatthe display timesfi'om the gasstation securityfootage appeal*to be plus
six or seven minutes relative to the actual time.
13. 1 have reviewed Colorado driver's license information about Banlcs. On
December 18,2017,a Colorado driver's license wasissued to Jerry Dean RobertBanks.Banks
gave his mailing address as 1179Pfotenhauer Road,Fort Gailand,CO. Based on the driver's
license photo ofBanks(taken only thiee weeksbefore the kidnapping),Banksresemblesthe man
depicted in the Walmartsui'veillanceimages asthe purchaser ofthe 911 Phone.Below isthe
license photo(onthe right)and an edited image oftheface ofthe 911 Phone purchaser (onthe
left)for compai'ison.
Case 0:22-mj-00022-KHR Document 1 Filed 04/06/22 Page 6 of 16

7. Case 5:22-mj-00037-gwc Document 1-1 Filed 03/30/22 Page 4of12
C. The 201 Phone
14. Agent Wines also reviewed AT&Ttower data obtained as a result ofsearch
warrants issued by this court. Agent Wines received a list ofcellular devices connecting to a
tower covering the ai*ea ofClearfield,Pennsylvania,wherethe 911 Phone was purchased.The
data included a list ofdevices connecting to the tower at or about the timethe 911 Phone was
purchased.Agent Wines compared this data to data he received listing cellular devices
connecting to atower covering the area ofDanville,Vermont,where the abduction took place.
The data included devices connecting to the tower ator aboutthe time ofGD's abduction. Only
one cellular phone wascommon to both sets ofdata,and it was a device with phone number
(201)208-7436(the 201 Phone).Based on the information below,I believe thatBanks used the
201 Phone to facilitate the victim's kidnapping and murder.
15. Further investigation by Agent Wines determined that 201 Phone is an Android
cell phone purchased at a Walmartlocated at201 Southeast Salem Street,Oak Grove,Missouri
on November 13,2017,at approximately 9:58 a.m.(CST),and additional service(minutes/data)
for that phone were purchased at a Walmartlocated at 2025 W.Business Highway 60,Dexter,
Missouri on Januaiy 4,2018 at approximately 9:20 a.m.(CST).Agent Wines obtained receipts
for these purchases,which show these purchases,like the 911 Phone purchase in Pennsylvania
on Januaiy 6,2018,were each made with $100 cash. The details on the receipts suggest tliat the
customer paid with a $100 billfor all thi'ee purchases:the 201 Phone,the extra minutesfor the
201 Phone,and the 911 Phone.
16. I obtained a search warrant for historical cell site and location information for the
201 Phone. The 201 Phone did not make or receive any phone calls or texts during the relevant
period.Its only interactions with tlie AT&T network involved data transmissions.The records do
notreveal the kind ofdata transmitted. Agent Wines and I have reviewed the information
obtained from this warrant. Analysis ofthe data shows tlie 201 Phone assigned number was
registered with the AT&T network on November 14,2017. Itfirst interacted with the network
thi'ough cell towers in the area of Monte Vista,Colorado for a brieftime on December 29,2017.
Case 0:22-mj-00022-KHR Document 1 Filed 04/06/22 Page 7 of 16

8. Case 5:22-mj-00037-gwc Document1-1 Filed 03/30/22 Page 5 of12
The phone nextinteracted with a celltowerin the area ofDexter,Missouri on Januaiy 3,2018,
and January 4,2018,again for shortperiods.Thereafter,tire phone interacted with cell towers
nearroadsfollowing a path in anorthern and eastern direction thi'ough Illinois,Indiana,and
Ohio.Analysisofthe data showsthe phone interacted with celltowers in the Columbus,Ohio,
area for atime period between 7:30 p.m.January 4,2018to 11:20 a.m.January 5,2018. The
phonethereafter continued to interact with celltowers near roadsthi'ough Pennsylvania,New
York,and Connecticut.Analysis ofthe data showsthe phone interacted for a period oftime with
cell towers inthe ai'ea Southington,Connecticut,fi
*om 12:00 a.m.to 10:00 a.m.on January 6,
2018.The datashowsthe phonethen continued thi-ough Massachusetts and arrived in Vermont
on January 6,2018,at approximately 11:37 a.m.The phone then tr'aveled north,consistent with
travel on Interstate 91,and arrived inthe area ofSt. Johnsbury,Vermont,atabout 1:30 p.m.
Thi'oughoutthe afternoon and into the evening ofJanuary 6,2018,tlie data showsthe phone was
in the areas ofSt. Johnsbury and Danville,Vermont.The phone remained in the general ar-eain
whichthe victim's kidnapping took place(atapproximately 9:00p.m.)and where his body was
recovered the nextday. After approximately 9:24 p.m.,the phone appearsto have traveled south
outofthe Danville/St.Jolinsbiuy area,consistent with tr*avel on Interstate 91. The lastreported
cell site orlocation data was at 10:01 p.m.,after which the phone had no more interaction with
the AT&T network.Based on this information,there is probable cause to believe thatthe 201
Phone was used for the purpose ofthe victim's Iddnapping and murder.
17. Further analysis ofthe data showsthat during the travel to Vermont,the 201
Phone passed thi'ough the area ofCleai'field,Pennsylvania atthetime the911 Phone was
purchased atthe Walmartin Clearfield,Pennsylvania.
18. I have attempted to obtain informationfrom Google aboutthe use ofthis phone
by subpoena.The only information Googlecould provideshowed that the201 Phone connected
to Google seiTersfor the firsttime on November 14,2017,and for the lasttime on January 6,
2018.
19. I have reviewed recordsfrom Verizon Wirelessthatidentify Jeriy Banlcs as the
subscriber ofthe phone with number(719)480-3879(the719Phone)during the relevant
timeframe.Banlcs wasthe effective subscriberfrom 10/20/2017through 11/8/2018.Banlcs listed
(661)433-5327(the 661 Phone)as his home phone number and work phone number.
20. I have also reviewed Verizon Wireless Billing Statements,whichshow the
approximate location ofthe719Phone when calls were made.I have confu'med with Verizon
Wireless personalthatthis location information is associated with the celltowers and switch
connecting to the phone atthe time ofcalls.I also learned that Verizon Wireless maintained
more precise location information for this phonefor only approximately one year.That data was
gone by the time I obtained the seai'ch warrant.Ifound the following locationsofnotefor this
phone in the Billing Statements:
a. On 10/26/2017,a callfrom this phone originated in Denver,CO.
b. On 12/13/2017,a call from this phone originated in Dexter,MO.
c. On 12/28/2017 a call fi
'om this phone originated in Alamosa,CO.
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9. Case 5:22-mj-00037-gwc Document 1-1 Filed 03/30/22 Page6 of 12
d. On 12/29/2017,another callfrom this phone originated in Alamosa,CO,which is
close to Monte Vista,CO. As noted above,the 201 Phone firstinteracted with cell towers in the
area ofMonte Vista,CO on 12/29/2017.
a. On 1/2/2018 and 1/3/2018,callsfrom this phone originated in Dexter,MO.As
noted above,the 201 Phone interacted with celltowers in Dexter,MO on 1/3/2018.
f. No calls are made between 12:59 p.m.on 1/3/2018 and 1/7/2018,when the 201
Phone was actively being used.
g. On 1/7/2018,at approximately 9:24p.m.,a callfrom this phone originated in
O'Fallon,MO,which is along 1-70 in Missouri.The time between the lastuse ofthe201 Phone
and this call on the 719Phone is approximately 25 hours. Google Mapsshowsthat driving time
from Barnet,VTto O'Fallon,MO is approximately 19hours.
h. On 1/8/2018,a call fi
'om this phone originated in Alma,KS. This call takes place
approximately 15 minutes afterthe Kansas Highway Patrol car stop ofBanlcs in Alma,KS,
described below.The call connects with(573)421-4798 for approximately 20 minutes.
i. On 1/9/2018,multiple calls are madefrom this phone,all originating in Colorado
(Alamosa,Sanford and Colorado Springs).
21. Banks'use ofthe 719Phone connected to his Google account,described below,is
consistent with him buying and using the201 Phone.
22. I have reviewed Google recordsfor the email address banksavs@gmail.com.
Jeriy Banksisthe subscriberofthe email account. He uses bankspes@gmail.com for his
recovery email. The account was created on 6/5/2009.SMS(texts)are connected to the 719
Phone.The subscriber services listed ai*e Android,Gmail,Google Calendar,Google Chi'ome
Sync,Google Cloud Print,Google Drive,Google Hangouts,Google Keep,Google My Maps,
Google Payments,Google Photos,Google Play,GooglePlay Music,Google Services,Google
Voice,Has Madison Account,Location History,Web & App Activity,YouTube,and iGoogle.
23. I obtained a seai*ch warrantfor informationfrom the banksavs@gmail.com
account.I and other investigators working with me have reviewed the information. We have
identified a number ofpieces ofinformation in the Google data thatfurther supportthe
conclusion thatBanlcs wasresponsiblefor GD'skidnapping and murder,including the
following:
a. Within the Google maps datathere are a number ofpieces ofinformation
including searchesfor Vermonton October 10,2017,December 12,2017,and January 4,2018.
b. Within the Google search history data are a number ofpieces ofinformation
including searchesfor:Explorer Police Interceptorsfor sale on October26,2017;Ford Explorer
Police Interceptorrims as well as steel wheels and a police spotlight on October29,2017;ARC-
22.22LR Conversion Kitson December 17,2017;and body armor on December 26,2017. As
noted above,.22 caliber ammunition was used to kill GD.
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c. Withinthe Google location information are thousandsofGPS coordinates
including coordinates connecting the Google userto tlie 201 Phone.As noted above,the201
Phone was purchased in Oak Grove,MO at9:58 a.m.(GST)on November 13,2017.On
November 13,2017at 11:09 a.m.,when the location information wasturned on,it showsthe
user 50 miles eastofOalc Grove,MO on Interstate 70,travelling east.Interstate 70 also travels
through Oak Grove,MO.This information suggests to me thatthe Google user wasin Oak
Grove atthetime the 201 Phone waspurchased.The locationinformation also shows thatthe
Google accountuser ti-avelled from Fort Gaiiand,CO to Dexter,MO on Januaiy 2,2018,and
stayed there until January 4,2018.1 have reviewed recordsfrom the DexterInn,which show that
Banks wasstaying atthe motel on the nights ofJanuaiy 2and 3,2018.Fuifher,the location
information showsthatthe Google user wasinsidethe Dexter,MO Walmaitat9:20 a.m.on
Januaiy 4,2018,thesame time the exti-a minutes were purchased forthe 201 Phone.
d. Though there are hundreds ofpieces oflocation information on mostdays,there
is no location information for certain relevant periods oftuneincluding: 1)between 9:51 a.m.
(CST)on Januaiy 4,2018,and 9:22p.m.(CST)on Januaiy 7,2018;2)between 3:53 p.m.(CST)
on November 11,2017and 11:09 a.m.(CST)on November 13,2017;and 3)2:31 p.m.(CST)on
November 13,2017 and 9:17 p.m.(CST)on November20,2017.When the location information
wasturned on after 9:22p.m.(CST)on January 7,2018,the Google user was travelling west on
Route 70in eastern Missouri.The location information showsthatthe Google user spentthe
night ofJanuary 7near a Route70exitin Missouri,before travelling towai'ds Fort Garland on
Januaiy 8.This data showsthatexceptfor afew hours on November 13,2017,Banks was not
using his719Phone while ti'avelling to Vermont both in November2017for areconnaissance
trip and in Januaiy 2018forthe kidnapping/murder trip.
24. The Google data also confirmsthat Banlcs used the Grizz Sands Facebook
account.
D. The Ford Explorer
25. I consulted with Matthew Fyie,Manager,Design Analysis Engineering,atFord
Motor Company,to determine the model and year range ofthe Ford Explorer observed in
photographs and video obtained from Clearfield,Pennsylvania.Fyie told methatthe Clearfield
Explorer wasa 2013 to 2015 PoliceInterceptor model.He noted thatthe Clearfield Explorer was
pictured with Ford Explorer XLT wheels,which were notan option for the 2013to 2015 Police
Interceptor models.Fyie provided photographs ofthe thi*ee wheel styles offered forthosePolice
Interceptors,each ofwhich is differentfrom the XLT wheel.Fyie suggested the XLT wheels
were installed on the vehicle at a later time or as an after-marketchange.Ford later provided
information,including YIN numbers,forthe 17,291 White Explorer Police Inceptorsfor model
years 2013 to 2015 manufactured and sold by Ford.
26. The VermontIntelligence Center(VIC)conducted searches to identify and find
vehicles ofinterest based on certain parameters/criteria(vehicles registered in states ofinterest.
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11. Case 5:22-mj-00037-gwc Document 1-1 Filed 03/30/22 Page 8 of12
inthis case Colorado,vehicles sold at auction with high mileage,and vehicles with sales or
service recordsthatoccured around the time ofthe kidnapping and homicide.)
27. Leads were generated to locatethe vehicles ofinterest and identify the owners at
the time ofthe kidnapping/homicide. One lead wassentto Colorado Bureau ofInvestigation
(CBI)AgentJoseph Cahill,who wasthen assigned to an FBITask Force.Thisparticular lead,
based on the additional research and identifiers provided by the VermontIntelligence Center
(VIC),wasspecificto a2013 Ford Explorer with VIN 1FM5K8AR6DGC73609.CARFAX
records indicated thaton October6,2017,a 2013 white Ford Explorer fi
'om Highline
Automotive Inc.,VIN 1FM5K8AR6DGC73609,wasoffered for sale.Mileage onthe Explorer at
thetime was 117,138.On December22,2017,the Ford Explorer wassei*viced atDowney Car
Center,Downey,California per CARFAX records. Mileage on the Ford Explorer atthetime was
130,404.CARFAX records indicate the mileage on the vehicle was 137,168 on March 16,2018,
the nexttime the vehicle was offered for sale by Maximum Auto Search.
28. Agent Cahill and CBI AgentKevin Koback conducted interviews in connection
with the Ford Explorer and the dealership,Highline Automotive,which waslocated in Denver,
Colorado.(Highline has since gone out ofbusiness.)AgentCahill provided me verbal and
wiitten reports ofthe interviews.Those reportsshow thatBanlcs was using the Explorer atthe
time ofthe kidnapping.Steve Iskhakov,who ran Highline,provided CBI Agents with
documents,including the Highline Automotive salesjacketfor the Explorer,which show that
Banl^s had possession ofthe Explorer atthetime ofthe kidnapping. Iskhalcov said he never had
anyone drive so many miles on a carin the short period oftime Banl<s had the Explorer.
29. Agent Cahill and I interviewed Carmine Gulli,the salesman and finance manager
who dealtinitially with Banks,on separate occasions. Gulli told methatBankspicked up the
Exploreron October 26,2017,with an agreementto purchase it with financing.Banks made a
down paymentof$3,000in cash.Gulli was notableto obtain financingfor Banksfrom the first
finance company that hetried. Gullithen tried to financethe Explorer thi'ough asecond finance
company in mid-November.He did not meetwith Banksin person atthatpoint but dealt with
him by phone and email. Gulli was not ableto getfinancing arranged thi-ough the second
finance company either. He then had to aiTangefor Banksto return the vehicle.Bankstold Gulli
thathe"lived offthe grid"neai-the New Mexico border. Accordingto Gulli,Bankshad no real
creditscore.Gulli described Banl<s as"a ghost." Gulli looked atthe Walmartsecurity camera
photographs and stated he felt it appeared to depictthesame person asthe Explorer buyer but
with more facial hair.
30. Mark Wilcox was also intei-viewed by AgentCahill. Wilcox isthe Chiefof
Mountain States Emergency Medical Services in Denver,Colorado. He is the currentowner of
the Ford Explorer. Wilcox purchased iton April 17,2018,fi
*om Maximum Auto Search in
Englewood,Colorado. Wilcox recalled the person he dealt witliat Maximum told him thatthe
Explorer was being sold on consignmentfor Higliline Automotive dueto a pending bankruptcy.
The XLT wheels can be seen in a photograph taken during the time oftlie intei*view.
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31. I also spoke with Wilcox. Wilcox confirmed thatthe same XLT wheels were on
the Explorer when he purchased itfrom Maximum Auto Seaich. Wilcox also told methe
Explorer did nothave a spotlight attached on the driver's side when he boughtit. The Clearfield
photos,while notcleai*,do appearto show a spotlighton the driver's side.Thislight,as
described below,appearsto have been attached while Banks had the Explorer and removed
before Banksreturned itto Highline Automotive.
32. 1 have reviewed the Highline Auto sales information.Ifound thefollowing
information regarding the sale/purchase ofthe Explorer:
a. purchaser:Jeny Banks,including his date ofbirth and social security number;
b. address: 1179Pfotenhauer Road,Fort Garland,CO 81133;
c. phone number:(719)480-3879;
d. email addi'ess: banksavs@gmail.com;
e. additional phone number:(718)298-2328;
f. registrationinformation:plateB094536for the 2013 white Ford Explorer;
g. Progressive Insurance,policy number917738127,effective 10/26/2017 to
4/26/2018,forthe Ford Explorer;
h. purchase date: 11/16/2017 with mileage reading of117,138;
i. surrender date: 1/24/2018,documentsindicate"milesand use paid for"and"loan
is being written off,no harm to borrower." A receiptfor the additional"miles and
use"indicates Banlcs paid $1,500 in cash when he surrendered the vehicle;
j. Banks"suiTendered"the Ford Explorerto Highline Automotive Inc.
33. I also reviewed records provided by Progressive Insui'anceinvolving Banks'
puichase ofthe 2013 Ford Explorer. Theinsured is listed as Jerry Banks with phone numbers
(661)433-5327 and(719)480-3879and an email address ofbanksavs@gmail.com. The primary
use ofthe vehicle is designated"Pleasure." This vehicle wasadded to the policy on 10/26/2017.
This vehicle wasremoved from the policy on 1/25/2018.
34. I have also reviewed Colorado vehicle registration information aboutthe
Highline Explorer.Those recordsshow thatBanks gotatemporaiy registrationforthe Explorer
first on 10/26/17,consistent with theProgressiveInsurance Records.The Colorado registration
recordsfurther show thatBanks gota second temporaiy registration forthe Explorer on
11/16/17,the purchase datein the Highline Auto records.The temporary tag issued on 11/16/17
was B094536. AgentCahill,who isfamiliar with Colorado temporaiy registi'ation tags,told me
thatthose tags are whitein color and made ofpaper. Colorado only issues atemporary tag for
the real'ofcar nota second for thefront.Thiskind oftemporaiy tag is consistent with the images
from tlie Clearfield Explorer,which had a lightcolored rear tag and no fronttag.
E. The 661 Phone
35. I reviewed Verizon Wirelessrecords obtained for the phone using number(661)
433-5327(the661 Phone)duringthe relevant period. Thesubscriber is All Valley Solai*(AVS).
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The mailing addressfor the billing statement is All Valley Solar(AVS),12623 Sheiman Way
Ste. A,N.Hollywood,CA 91605. As noted above,Progressive records show that Banks
provided this phone number as his work phone number,and Verizon Wirelessrecordsforthe
719Phoneshow Banlcs provided this number as his home and work phone. The investigation
hasrevealed informationthatBanks worked for All Valley Solar before 2017.
36. The 661 Phone records also show approximate location information forthe calls.
On the morning of11/18/2017,thiee calls were madefrom this phone all originating from
Bai'net,Vermont.As noted above,the 719Phone recordsshow no phone activity between
11/10/17and 11/20/17,while Banks appearsto have travelled to Vermontfor areconnaissance
trip.
F. Kansas Hiehwav Patrol Stop
37. Based on reviews oflaw enforcementcontact with Banks,I discovered that on
1/8/2018 at approximately 1:48 p.m.GST,a traffic stop wasconducted by Kansas Highway
Patrol Technical Trooper Clark in the vicinity ofmile post337on 1-70 Westbound in Alma,KS.
I have reviewed reports aboutthe stop.Jerry Banks was operating the white Ford Explorer.
Banks wasstopped for alane violation.I spoke with Technical Trooper Clark and reviewed a
DVD recording ofthe traffic stop he provided.Trooper Clai'k described Banks as extremely
nervous.The vehicle contained multiplelaw enforcementitems including a gun,tactical vest and
law enforcement equipment.Trooper Clai'k noted the back seatofthe Ford Explorer wasfolded
down and a matti'ess wasobserved inthe middleto back area ofthe Explorer.
38. On 3/3/2020,1 reviewed aDVD copy ofthetraffic stop conducted by Technical
Trooper Clark on 1/8/2018.Jerry Banlcsfalsely said that he wastravelingfrom Dexter,MO.
During the traffic stop,a phone can be heard ringing insidethe Ford Explorer.The phone
ringtone is consistent witli a Samsung Galaxy phone standard ringtone.
39. I compared the video ofBanksfrom the cai'stop to the photos/video from the
Clearfield,PA Walmartpurchasing the911 Phone and BP gas station,described above. Banks
looks similar to tlie person in the Cleaidield images.The Google location information showstliat
Banks drovefrom Foil Garland,CO to Dexter,MO on Januaiy 2driving a routefurther south
than Route70thi*ough Kansas.Ifhe had been driving dhectly homefrom Dexteron January 8 he
would likely have used that more southerly route ratherthan Route 70,which isthe mostdirect
route to CO from the Northeast.
G. Banks'Finances
40. We have attempted tofigure outBanlcs'financial situation to help provethathe
received money in connection with the murder,because I havefound no evidence ofany
personal connection between Banks and tlie victim. The Highline Auto recordsshow thatBanks
worked for the Costilla County Sheriffduring the fall of2017.1 have learned from search
warrant materials thatBanks was attending Community Collegefulltime during the fh'st several
10
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14. Case 5:22-mj-00037-gwc Document1-1 Filed 03/30/22 Page 11 of12
months of2018.The Highline recordsinclude acopy ofa pay stubfrom Costilla County
provided in connection with his attempted financing ofthe Explorer.Banks waseai'ning$640 a
week gross and less than $500 a week net.I have reviewed recordsfrom Green Dot,a business
that allows users to deposit money onto a debitcard.In addition tothe$4,500in cash paid for
the Explorer,Banks put$2,600in cash on his Green Dotcard in November and December2017,
and $12,500 in cash on his Green Dotcard duringthe first halfof2018.
41. Banlcs'Facebook accountincludes statements Banks made on Facebook
Messenger.He has several conversations with Stephanie Giambra.with whom Banks appearsto
be close.Banks apparently worked with Giambra at All Valley Solar,used an AYS creditcard in
the past,and owed her money.In October2017,he wi'ote herthathe had a sidejob and a"bunch
ofmoney for her."On December 8,he asked Giambra whathe owed her and reported doing well
financially and wanting to take cai'e ofher while he could.I believe thatBanks,who had not
personal connection with Banks,waspaid to kidnap and murder GD.
H. Banlcs'Purchases
42. Within the Google email data are emails with information related to purchases
including thefollowing: 1)On November3,2017,an order confirmation emailto Jeriy Banlcs
describing the purchasefrom Amazon ofa publicsafety scanner;2)on November 8,2017a
shipping confirmation email to Jerry Banlcsfor a blue/red flashing modes;and 3)on December
20,2017,an email containing aPaypal purchase confirmationto"JemiBanlcs"for pui"chases of
an Antique Gold Mai'shal Badge,a US Marshal ShoulderPatch and a US Marshalembroidery
patch.
43. I have reviewed records fi'om Amazon that reflect Banks has been a customer
since July 31,2013 and has used the email address banksavs@gmail.com. I have reviewed the
order histoiy which showsthefollowing purchases.On November4,2017,he purchased a
handheld scanner and police-style car antenna.On December4,2017,he purchased aPolice
Interceptor nameplateforthe Ford Explorer. On December 10,2017,he purchased a police
spotlightthatcould be attached to the Explorer.On December26,2017,he purchased two sets of
handcuffs and a setofautomotive parts thatcan be used to assemble a silencer. On December27,
2017,he purchased dashboai'd red and blue emergency lights.
44. I have reviewed PayPalrecords for JeiTu Banksthatreflectthatthe account was
opened on December20,2017,and the email address provided was banksavs@gmail.com. The
recordsshow purchases on December 20,2017,ofa Marshal's badge and various Mai'shal's
patches.
45. I have reviewed records provided by Spartan Armor Systems which reflectJerry
Banks purchasing two body armorjackets on December 20,2017.
11
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15. Case 5:22-mj-00037-gwc Document 1-1 Filed 03/30/22 Page 12 of 12
Conclusion
46. For the reasons described above,there exists probable causeto believe thatJerry
Banks unlawfully seized,confined,inveigled,decoyed,kidnapped,abducted,and carried away
for reward and otherwise GD,when Bankstravelled in interstate commerce and used a facility or
instrumentality ofinterstate commerce in committing and infurtherance ofthe commission of
tlie offense,in violation of18 U.S.C.§ 1201(a)(1).
Dated atRutland,in the Distiict ofVermont,this day ofMarch,2022.
Patrick Hanna
Special Agent-FBI
I'D
Sworn to and subscribed before methis ^ day ofMarch,2022.
Honorable Geoffrey W.Crawford
ChiefUnited States District Judge
12
Case 0:22-mj-00022-KHR Document 1 Filed 04/06/22 Page 15 of 16

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