1 AFFIDAVIT I, MICHAEL EASTER, being duly sworn, do hereby ...

AFFIDAVITI, MICHAEL EASTER, being duly sworn, do hereby depose andstate:I. INTRODUCTION1. I am a Special Agent with the Federal Bureau ofInvestigation (FBI), and have been so employed since June of2004. I am currently assigned to the Los Angeles Division,Ventura Resident Agency, where I investigate violations offederal law relating to bank robberies, among other things. Ihave received formal training at the FBI Academy and haveparticipated in approximately 35 investigations of violationsfederal law relating to bank robberies.II. PURPOSE OF AFFIDAVIT2. This affidavit is made in support of a complaint andarrest warrant against JESSE JAMES SALINAS, SR. ("SALINAS") forthe armed bank robbery of the Bank of America, located at 510 NewLos Angeles Avenue, Moorpark, California, on January 22, 2008, inviolation of Title 18, United States Code, Section 2113(a),(d).The facts set forth in this affidavit are based upon my personalobservations, my training and experience, and informationobtained from other law enforcement officers and witnesses. Thisaffidavit is intended to show that there is probable cause forthe requested complaint and arrest warrant and does not purportto set forth all of my knowledge of or investigation into thismatter.1

obber had on fake sideburns and a fake mustache.10. Ashley stated that the robber walked to an open telleron the east side of the bank, where he saw the robber remove whatappeared to be a black handgun from his waistband and point it atthe teller. Ashley grabbed his daughter and left the bank. Onceoutside, he began to warn bystanders that a man with a gun wasinside. While outside the bank, Ashley observed the robber exitthe bank, walk past him and continue southwest.11. Ashley followed the robber and observed him get into awhite Toyota 4Runner that was parked behind a nearby Chevron GasStation. The robber drove the 4Runner toward Spring Road andthen made a right turn onto northbound Spring Road. Ashleyprovided descriptions of the robber and the 4Runner to DeputyRompal, who was the first deputy to arrive at the bank afterSheriff’s dispatch advised patrol units of the bank robbery.Deputy Rompal passed on the descriptions to be broadcast to otherlaw enforcement officers in the area.12. As detailed below in paragraph 21, Ashley lateridentified both SALINAS and the 4Runner in a field show-up.B. Pursuit of SALINAS13. At approximately 3:46 p.m. on January 22, 2008, almostimmediately after the robbery, VCSD Deputies Hawthorne and Heaveyreceived a radio broadcast relaying that an armed bank robberyhad occurred at Bank of America. The dispatch operator advisedthat the robber, described as a Hispanic male wearing an orangehat and a brown jacket, may have fled the scene in a mid-to-late‘90's white Toyota 4Runner. Deputies Hawthorne and Heavey set up4

a surveillance position to watch for the robber by parking theirpatrol vehicle against the right shoulder of the southbound 23Freeway on-ramp at Olsen Road. The position gave them anunobstructed view of all traffic traveling southbound on the 23Freeway.14. At approximately 3:52 p.m., two other VCSD Deputiesresponding to the broadcast, Deputies Jones and Duffield, advisedDeputies Hawthorne and Heavey that they were traveling northboundon the 23 Freeway approaching Tierra Rejada Road, and that theyobserved the possible suspect vehicle traveling southbound on the23 Freeway approaching Olsen Road.15. At approximately 3:53 p.m., Deputies Hawthorne andHeavey observed a white older-model Toyota 4Runner, bearingCalifornia license plate No. 5KQG110, traveling southbound on the123 Freeway passing Olsen Road. They began to follow the vehicleand continued southbound towards Janss Road.16. The 4Runner exited the 23 Freeway at Janss Road andturned eastbound onto Janss Road from the freeway. DeputiesHawthorne and Heavey activated their car’s lights and sirens.The driver of the 4Runner did not pull over, but insteadreentered the 23 Freeway, now going northbound, via the on-rampat Janss Road.17. The 4Runner accelerated to approximately 60 to 65 milesper hour as it entered the northbound 23 Freeway. Deputies1I know from personal experience and familiarity with thearea that this location is approximately 4.5 miles south of thebank that was robbed.5

Hawthorne and Heavey continued to pursue the 4Runner northboundas it passed Avenida De Los Arboles at approximately 70 miles perhour. Shortly after passing Arboles, the 4Runner drove from thefar-left traffic lane over a raised plastic pylon and into aconstruction zone, where it was able to speed past traffic. The4Runner continued northbound on the 23 Freeway, traveling atapproximately 80 miles per hour as it passed Olsen Road. As the4Runner approached Tierra Rejada Road, it was traveling atapproximately 90 to 95 miles per hour. As the 4Runner mergedonto SR 118, it entered the center divide of the roadway andalmost caused a collision with another vehicle. The 4Runnercontinued eastbound on SR 118, traveling at approximately 70miles per hour as it passed Collins Drive and Madera Road. Asthe 4Runner passed Madera Road, at approximately 4:05 p.m., CHPunits arrived in order to take over the pursuit and deputiesHawthorne and Heavey dropped back. CHP officers eventuallymanaged to stop the vehicle in the area of SR 118 and PorterRanch Drive.18. Soon after CHP officers stopped the 4Runner, VCSDSenior Deputy Jeffrey Hill arrived at scene of the stop. Heobserved that the 4Runner was in the middle of Porter Ranch Road,facing westbound. The front of a CHP patrol car, facingsouthbound, was in contact with the front passenger door of the4Runner. A suspect, later identified as SALINAS, was inhandcuffs and in the back seat of a CHP unit.19. CHP Officer Dockus advised VCSD Deputy Dean Cook thatduring the pursuit of the 4Runner, CHP officers observed the6

driver of the 4Runner discarding items out of the 4Runner'swindow onto the highway. CHP Officers later recovered thefollowing items, which Officer Dockus gave to Deputy Cook: oneorange hat, which Officer Dockus described as being found in thethird-from-left lane of the eastbound SR 118 east of DeSotoAvenue; and one black sweatshirt, which Officer Dockus describedas being found in the third-from-left lane of the eastbound SR118 east of Rocky Peak.C. Field Identifications20. VCSD Deputies Ives and Saleh transported the victimteller, Rafael Torres III, to the location of the vehicle stop.Upon arrival, Deputy Ives gave Torres the VCSD’s standardadmonitions for field identifications. The Deputies positionedtheir patrol vehicle approximately 20 yards from the suspect andturned on the headlights and spotlights of their patrol vehicle.Torres made a positive identification of SALINAS as the robberand said, "Yeah, that's him."21. VCSD Deputy Michael Rompal transported John Ashley tothe location of the vehicle stop at approximately 4:45 p.m. Uponarrival, Deputy Rompal gave Ashley the VCSD’s standardadmonitions for field identifications. As they approached,Ashley positively identified the 4Runner as the car he had seenat the scene of the robbery, and identified SALINAS as therobber. Ashley said, "That's definitely the car. That's the hat.That's definitely him."22. VCSD Deputy Rick Cochrane placed SALINAS under arrest.SALINAS provided his name as JESSE JAMES SALINAS, SR. Deputy7

Cochrane’s report describes SALINAS as a Hispanic male, 5' 7"tall, weighing approximately 185 lbs, with brown eyes, brownhair, a mustache and facial hair below his lower lip.D. Search of SALINAS’ Vehicle23. After the 4Runner was stopped, CHP Officer Greenobserved a black plastic bag on the front passenger's sidefloorboard of the 4Runner. When VCSD deputies arrived at thescene, Officer Green pointed out the bag, which was later foundto contain $3,619.00 in various denominations of U.S. Currency.24. VCSD Senior Deputy Jeffrey Hill conducted a furthersearch of the Toyota 4Runner incident to SALINAS' arrest. DeputyHill located a white "Denny's" plastic bag inside the rearpassenger compartment of the 4Runner. Among the items inside theplastic bag were the following: false hair; four latex gloves,with one glove containing black false hair and double-sided tapeinside; a roll of double-sided tape; a pair of rubber handcuffs;a pair of hair scissors in a black case; a pack of men's groomingtape; one "Crosman" CO2 box, containing four CO2 cartridges; a1500-count bottle of "Copperhead" BB's; a pair of blacksunglasses; a black knit cap; a ten-inch knife with a red woodhandle in a black leather sheath; a white plastic bag containing54 new syringes in packages, a spoon, foil, and a ball of cotton;and 24 used syringes in a black plastic bag.E. Digital Surveillance Video25. On January 23, 2008, I reviewed the digitalsurveillance video provided by the branch of Bank of America at510 New Los Angeles Avenue, Moorpark, California. I observed8

that at aproximately 3:45 p.m. on January 22, 2008, thesurveillance video covering the main entry and exit doorscaptured the robber entering the bank wearing a baseball stylehat, a dark colored hooded sweatshirt, latex gloves, and longpants. Upon entering the bank, the robber walked past thecustomer line and directly to a teller station, where a tellerwas assisting a customer. I observed the robber grab theshoulder of the customer and move her slightly away from theteller station.26. I observed the robber then place a black plastic bag onthe teller counter. The robber then raised his sweater with hisleft hand, reaching under it with his right hand to grasp a darkobject, which he proceeded to pull slightly out of his waistbandand then replace. The robber then grabbed the black plastic baghe had placed on the teller counter and opened the bag. Therobber held out his hand across the counter to the teller, whoreached in his drawer, took out a stack of bills, and placed themin the robber’s hand. The robber thumbed through the money andthen discarded a portion of money back onto the teller counter.The robber placed the remaining money into the black plastic bag,then grabbed the forearm of the customer and pulled her back infront of the teller station. The robber then turned away fromthe teller station and left through the same doors he used toenter the bank.F. Other Investigation27. I have checked the license plate number of the suspectvehicle, 5KQG110, as noted in VCSD Deputy Hawthorne’s report,9

against the Department of Motor Vehicles database. The platecame back to a 1991 Toyota utility vehicle registered to twoowners, one of whom was JESSE JAMES SALINAS, SR. at 632 EastChapel Street, Apt. B, Santa Maria, California. The other ownerwas Sandra Denise Taechens (relationship unknown).28. On January 28, 2008, I consulted the websitewww2.fdic.gov and determined that the Bank of America at 510 NewLos Angeles Ave., Moorpark, California was insured by the FederalDeposit Insurance Corporation under FDIC certificate number 3510.IV. CONCLUSION28. Based on the foregoing, I believe there is probablecause to believe that JESSE JAMES SALINAS, SR. committed armedbank robbery, in violation of Title 18, United States Code,Section 2113(a),(d)._______________________Michael EasterSpecial AgentFederal Bureau of InvestigationVentura, CaliforniaSubscribed and sworn to before methis_____day of January, 2008.______________________________U.S. Magistrate10