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$: UNITED STATES OF AMERICA - TownNewsbloximages.chicago2.vip.townnews.com/wmicentral... · UNITED STATES OF AMERICA ,b . V. CRIMINAL COMPLAINT . t(. ,\''''' ~ ~~ Ronald Michael Capito$
UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

UNITED STATES OF AMERICA

,b V. CRIMINAL COMPLAINT t(. ,\''''' ~ ~~Ronald Michael Capito

and Joel Jay Glore CASENUMBER:/cJ -3)CJ5117

I, the undersigned complainant being duly sworn state the following is true and correct to the best of my

knowledge and belief.

See attached Counts 1 through 8

I further state that I am a Special Agent, Federal Bureau of Investigation and that this complaint is based on the

following facts:

See attached Statement of Probable Cause

Continued on the attached sheet and made a part hereof: I8J Yes DNo

AUTHORIZED BY: AUSA Alison S. Bachuj0i5

Lance Leising, Special Agent, FBI Name of Complainant . nature omplainan ~ Sworn to before me and subscribed in my presence,

March 12,2010 Date

Lawrence O. Anderson, U.S. Magistrate Judge Name & Title of Judicial Officer

Case 3:10-mj-03105-LOA Document 1 Filed 03/12/10 Page 1 of 35

Count 1

On or about September 8, 2009, in the District of Arizona, defendants RONALD MICHAEL CAPITO and JOEL JAY GLORE did knowingly take by force, violence, or intimidation from the persons of Pamela Sniff, Elizabeth Murphy, and Jessica Crawford, money in the care, custody, control, management, and possession ofBank of the West, 1945 Highway 260, Heber, Arizona, and in the commission of the offense the defendants did assault and put in jeopardy the lives of Pamela Sniff, Elizabeth Murphy, and Jessica Crawford by the use ofa dangerous weapon or device, that is, a gun, in violation ofTitle 18 U.S.c. §§ 2113(a) and (d) and 2.

Count 2

On or about October 14, 2009, in the District of Arizona, defendants RONALD MICHAEL CAPITO and JOEL JAY GLORE did knowingly take by force, violence, or intimidation from the persons ofBrian Hjalmarson, Scott Krohn, and Brittany Fierros, money in the care, custody, control, management, and possession of the Arizona Central Credit Union, 1948 South Woodlands Village Boulevard, Flagstaff, Arizona, and in the commission ofthe offense the defendants did assault and put in jeopardy the lives of Brian Hjalmarson, Scott Krohn, and Brittany Fierros by the use ofa dangerous weapon or device, that is, a gun, in violation of Title 18 U.S.C. §§ 21 13(a) and (d) and 2.

Count 3

On or about October 30, 2009, in the District of Arizona, defendants RONALD MICHAEL CAPITO and JOEL JAY GLORE did knowingly take by force, violence, or intimidation from the persons of Anita Martinez and Brenda Gomez, money in the care, custody, control, management, and possession ofCountry Bank, 3044 North Glassford Hill Road, Prescott Valley, Arizona, and in the commission of the offense the defendants did assault and put in jeopardy the lives of Anita Martinez and Brenda Gomez by the use of a dangerous weapon or device, that is, a gun, in violation ofTitle 18 U.S.c. §§ 2113(a) and (d) and 2.

Count 4

On or about November 25, 2009, in the District of Arizona, defendants RONALD MICHAEL CAPITO and JOEL JAY GLORE did knowingly take by force, violence, or intimidation from the person of Jessica Sainato, money in the care, custody, control, management, and possession of Compass Bank, 613 South Beeline Highway, Payson, Arizona, and in the commission of the offense the defendants did assault and put injeopardy the life of Jessica Sainato by the use of a dangerous weapon or device, that is, a gun, in violation of Title 18 U.S.c. §§ 21 13(a) and (d) and 2.


Count 5

On or about December 3, 2009, in the District of Arizona, defendants RONALD NnCHAEL CAPITO and JOEL JAY GLORE did knowingly take by foree, violence, or intimidation from the person of Dawn Steyer, money in the care, custody, control, management, and possession ofChase Bank, 5305 South Superstition Mountain Drive, Gold Canyon, Arizona, and in the commission of the offense the defendants did assault and put in jeopardy the life of Dawn Steyer by the use of a dangerous weapon or device, that is, a gun, in violation of Title 18 U.S.C. §§ 2113(a) and (d) and 2.

Count 6

On or about December 4, 2009, in the District of Arizona, defendants RONALD MICHAEL CAPITO and JOEL JAY GLORE did knowingly take by force, violence, or intimidation from the person ofAmy Lackey and Cade Phillips, money in the care, custody, control, management, and possession of Compass Bank, 781 East White Mountain Boulevard, Pinetop, Arizona, and in the commission ofthe offense the defendants did assault and put in jeopardy the lives of Amy Lackey and Cade Phillips by the use of a dangerous weapon or device, that is, a gun, in violation of Title 18 U.S.C. §§ 2113(a) and (d) and 2.

Count 7

On or about January 25, 2010, in the District of Arizona, defendants RONALD MICHAEL CAPITO and JOEL JAY GLORE did knowingly take by force, violence, or intimidation from the persons ofRenata Macy, Regina Wilson, and Laneya Wilson, money in the care, custody, control, management, and possession of Sunwest Bank, 822 North Humphreys, Flagstaff, Arizona, and in the commission of the offense the defendants did assault and put in jeopardy the lives ofRenata Macy, Regina Wilson, and Laneya Wilson by the use ofa dangerous weapon or device, that is, a gun, in violation of Title 18 U.S.C. §§ 2113(a) and (d) and 2.

Count 8

On or about February 24, 2010, in the District of Arizona, defendants RONALD rvncHAEL CAPITO and JOEL JAY GLORE did knowingly take by force, violence, or intimidation from the persons of Renata Macy and Laneya Wilson, money in the care, custody, control, management, and possession of Sunwest Bank, 822 North lIumphreys, Flagstaff, Arizona, and in the commission of the offense the defendants did assault and put in jeopardy the lives of Renata Macy and Laneya Wilson by the use of a dangerous weapon or device, that is, a gun, in violation of Title 18 U.S.C. §§ 21 13(a) and (d) and 2.


1 AFFIDAVIT OF PROBABLE CAUSE

2 Your affiant, SA Lance Leising, being duly sworn, deposes and says to wit:

3 I am a Special Agent (SA) with the Federal Bureau of Investigation (FBI) and am

4 currently assigned to the FBI Phoenix Division's Violent Crime Squad. I have been

5 employed as an FBI SA for approximately 12 years and have investigated hundreds of bank

6 robberies. During dozens of these bank robbery investigations, I have used evidence

7 obtained from the suspects' mobile telephones, specifically cell site tower locations ofthese

8 telephones, in order to develop probable cause. I am familiar with the facts surrounding the

9 investigation of a series of sixteen bank robberies throughout Arizona, Colorado, Utah, and

10 New Mexico from September 8, 2009 through February 24, 2010 committed by the "High

11 Country Bandits." These robberies are connected based on the witness and video evidence

12 of the suspects' descriptions, the style of robberies, the language used by the robber during

13 the robberies, and the method in which the suspects fled from the scenes. The following is

14 a list of the dates and locations of each robbery:

15 Bank Robbery Events:

16 8 September 2009 Bank of the West, 1945 Highway 260, Heber, AZ

17 22 September 2009 First Nat. Bank ofDurango, 351 Bayfield Center Drive, Bayfield, CO

18 14 October 2009

19 30 October 2009

20 10 November 2009

21 25 November 2009

AZ Central Credit Union, 1948 S. Woodlands Village, Flagstaff, AZ

Country Bank, 3044 N. Glassford Hill Rd, Prescott Valley, AZ

First Community Bank, 19390 Highway 314, Belen, NM

Compass Bank, 613 S. Beeline Highway, Payson, AZ

1


1 3 December 2009

2 4 December 2009

3 15 December 2009

4 22' December 2009

5 25 January 2010

6 29 January 2010

7 30 January 2010

8 5 February 2010

9 16 February 2010

10 24 February 2010

Chase Bank, 5305 S. Superstition Mtn Dr, Gold Canyon, AZ

Compass Bank, 781 E. White Mountain Blvd, Pinetop, AZ

The Village Bank, 1224 S. River Road, St. George, UT

Bank ofthe San Juans, 1710 Main St., Durango, CO

Sunwest Bank, 822 N. Humphreys Street, Flagstaff, AZ

Land of Enchantment FCU, 1101 Don Diego, Santa Fe, NM

Bank of America, 3101 Southern Boulevard, Rio Rancho, NM

Community Banks of Colorado, 1438 E. Main St., Cortez, CO

US Bank, 1514 Park Avenue, Park City, UT

Sunwest Bank, 822 N. Humphreys Street, Flagstaff, AZ

11 Ofthe above sixteen financial institutions, seven ofthe banks and one credit union are

12 located in the District ofArizona. The other seven banks and one credit union are located

13 in Colorado, Utah, and New Mexico. All United States currency stolen during these

14 robberies was federally insured by the Federal Deposit Insurance Corporation ("FDIC") or

15 the National Credit Union Administration ("NCUA").

16 I learned the facts contained in this affidavit from my own investigation or from the

1 7 investigation of other law enforcement officers who are working the case with me. A

18 summary of the facts of each robbery are detailed below.

19 BANK ROBBERIES

20 On Tuesday September 8, 2009, at approximately 1600 hours, a male (unknown race),

21 5'7", medium build, wearing a dark ski mask, jacket, and gloves entered the Bank of the

2


1 West, located at 1945 Highway 260, Heber, Arizona. The Suspect brandished a dark, semi

2 automatic handgun and announced a bank robbery. The Suspect handed a drawstring bag to

3 the tellers, and demanded them to fill the bag with money. After the last teller had put money

4 into the bag, the Suspect took the bag and fled the bank. The subject fled the bank with

5 $7,205 of federally insured US Currency. Witnesses observed the Suspect flee through an

6 open lot south ofthe bank. Another witness described seeing two males on a "hunting style"

7 four-wheeler enter the open lot. One ofthe males would walk down near the bank and then

8 return to the four-wheeler. She said she saw these males do this on at least two occasions

9 prior to the robbery.

10 On Tuesday, September 22,2009, at approximately 1400 hours, a white or Hispanic

11 male, 5'6", 130-140 pounds, wearing a dark ski mask, sunglasses, jacket, baseball hat and

12 gloves entered the First National Bank of Durango, 351 Bayfield Center Drive, Bayfield,

13 Colorado. The Suspect brandished a dark, semi-automatic handgun and announced that this

14 was a "holdup." The Suspect demanded money from two tellers' drawers, specifically

15 demanding both top and bottom drawers, and placed the money in a camouflage bag. After

16 the last teller had put money into the bag, the Suspect ordered everyone on the ground and

17 fled the bank. The subject fled the bank with $9961 of federally insured US currency.

18 Witnesses observed Suspect 1 run from the bank and get on the back of a red all-terrain

19 vehicle ("ATV") driven by Suspect 2. Suspect 2 was described as a white or Hispanic male

2 a in his 40s. The suspects drove the A TV to a wooded area where witnesses lost them.

21 Officers later recovered a stolen, red ATV near where the Suspects were last seen. A canvass

3


1 of the area developed witnesses who observed two males, described as White or Hispanic,

2 riding a similar ATV in the area. They were also associated with a grey, full size, 4-door,

3 newer model Dodge or Ford pick-up truck.

4 On Wednesday, October 14, 2009, at approximately 1551 hours, a white male, 5'2"

5 5'5",160-170 pounds, wearing a dark ski mask, sunglasses,jacket, baseball hat, and gloves

6 entered the Arizona Central Credit Union, 1948 South Woodlands Village Boulevard,

7 Flagstaff, Arizona. The Suspect brandished a dark, semi-automatic handgun and announced

8 "Get your hands up!" The Suspect demanded money from the top and bottom drawers of

9 multiple tellers and placed the money in a bag he had brought into the bank. After the last

10 teller put the money into the bag, the Suspect ordered everyone on the ground and fled the

11 bank. The Suspect fled the bank with $17,262 of federally insured US currency. Witnesses

12 did not observe how the Suspect left the area.

13 On Friday, October 30,2009, at approximately 1456 hours, a white male, 5'5", l30

14 135 pounds, wearing a dark ski mask, sunglasses,jacket, baseball hat, and gloves entered the

15 Country Bank, 3044 North Glassford Hill Road, Prescott Valley, Arizona. The Suspect

16 brandished a dark, semi-automatic handgun and demanded money from the top and bottom

1 7 drawers ofmUltiple tellers. He ordered the tellers to place the money in a bag he had brought

18 in the bank. After the last teller put the money into the bag, the Suspect ordered everyone

19 on the ground and fled the bank. The Suspect fled the bank with $14,297 offederally insured

20 US Currency. Witnesses outside the bank reported seeing a man matching the description

21 of the robber run to the parking lot ofa Fry's grocery store near the bank. This Suspect ran

4


1 to an A TV where a second Suspect was waiting for him. The first Suspect jumped on the

2 back ofthe ATV and the second Suspect quickly drove away, jumping a curb in the process.

3 On Tuesday, November 10,2009, at approximately 1453 hours, a white male, 35-45

4 years old, 5'6 II-5'8", thin build, wearing a dark ski mask, sunglasses, jacket, baseball hat, and

5 gloves entered the First Community Bank, 19390 Highway 314, Belen, New Mexico. The

6 Suspect brandished a dark, semi-automatic handgun and demanded large bills from the

7 bottom drawers of multiple tellers. He ordered the tellers to place the money in a bag he

8 brought in the bank. After the last teller put the money into the bag, the Suspect ordered

9 everyone on the ground and fled the banle The Suspect· fled the bank with $14,915 of

10 federally insured US Currency. Witnesses outside the bank reported seeing a man matching

11 the description of the robber nee on an ATV.

12 On Wednesday, November 25, 2009, at approximately 1552 hours, a white male, 30

13 50 years old, 5'7"-5'8", thin to medium build, wearing a dark ski mask, sunglasses, jacket,

14 baseball hat, and gloves entered the Compass Bank, located at 613 South Beeline Highway,

15 Payson, Arizona. The Suspect approached the victim tellers, brandished a black semi

16 automatic handgun and demanded the money in the top and bottom drawers of multiple

1 7 victim tellers. He ordered the tellers to place the money in a bag he had brought in the bank.

18 After the last teller put the money into the bag, the Suspect ordered everyone on the ground

19 and ned the bank. The Suspect ned the bank with $10,167 offederally insured US Currency.

20 Witnesses observed the Suspect run from the bank and get into the passenger side of a

21 waiting grey van. The van then drove south on the Beeline Highway.

5


1 A subject matching the description as this Suspect, to include similar clothing, was

2 observed by a witness near the bank two to three hours prior to the robbery. This witness

3 indicated that the Suspect was acting suspicious and was talking on a cellular telephone

4 during the time he was in the area of the bank.

5 On Thursday, December 3,2009, at approximately 1552 hours, a white male, 40s-50s,

6 shorter, medium build, wearing a dark ski mask, glasses, baseball hat, and a glove on his left

7 hand, entered the Chase Bank, 5305 South Superstition Mountain Drive, Gold Canyon,

8 Arizona. The Suspect pointed a handgun at the teller and demanded all the money in the

9 drawer. The victim teller informed the Suspect that she did not have a cash drawer, only an

10 automatic cash dispenser. The teller entered a code into the dispenser, which automatically

11 dispensed $1000. The Suspect took the money and fled the bank. The suspect was observed

12 getting onto the back of an ATV driven by another subject and fleeing the area. Witnesses

13 reported seeing the Suspect run towards a nearby business and get on the back of an ATV,

14 where a second Suspect was waiting for him. The two suspects fled into the desert on the

15 ATV.

16 On Friday, December 4, 2009, at approximately 1555 hours, a white male, 30s-50s,

17 5'5"-5'8", 130-170 pounds, wearing a dark ski mask, glasses, baseball hat and gloves, entered

18 the Compass Bank located at 781 East White Mountain Blvd, Pinetop, Arizona. The Suspect

19 approached the victim tellers, brandished a black semi-automatic handgun, and demanded

20 the money in the top and bottom drawers ofmultiple victim tellers. He ordered them to place

21 the money in a bag he had brought in the bank. After the last teller put the money into the

6


1 bag, the Suspect ordered everyone on the ground and fled the banle The Suspect fled the

2 bank with $3827 offederally insured US Currency. Witnesses observed the Suspect running

3 into a residential area and looking around as if he were lost. Witnesses soon saw an

4 individual matching the Suspect's description speeding out ofthe residential area on the back

5 ofan A TV driven by a second Suspect. Officers later followed this escape route and found

6 ATV tracks leading off the road and going through what appeared to be a fresh cut hole in

7 a barbed wire fence separating the Indian Reservation from the town. The next day, officers

8 followed these tracks for approximately 17 miles northwest until they were lost near Show

9 Low and Linden.

10 On Tuesday December 15,2009, at approximately 1445 hours, a white male, 5'7"-5'8",

11 slender build, 30-40 years old, wearing a wearing a dark ski mask, sunglasses, jacket,

12 baseball hat and gloves, entered The Village Bank, 1224 South River Road, St. George, Utah.

13 The Suspect approached the victim tellers, brandished a black semi-automatic handgun and

14 demanded "all ofthe money" from multiple victim tellers. He ordered the tellers to place the

15 money in a bag he had brought in the bank. After the last teller put the money into the bag,

16 the Suspect ordered everyone on the ground and fled the bank. The Suspect fled the bank

17 with $17,200 of federally insured US currency. Witnesses did not observe how the Suspect

18 left the area.

19 On Tuesday, December 22,2009, at approximately 1115 hours, a white male, 5'6", 160

20 pounds, 30-40 years old, wearing a wearing a dark ski mask, sunglasses, jacket, hat and

21 gloves, entered the Bank of the San Juans, 1710 Main Street, Durango, Colorado. The

7


1 Suspect approached the victim tellers, brandished a black semi-automatic handgun and

2 demanded money from the mUltiple tellers, specifically asking for the top and bottom

3 drawers. The Suspect ordered the tellers to place the money in a bag he had brought in the

4 bank. After the last teller put the money into the bag, the Suspect ordered everyone on the

5 ground and fled the bank. The Suspect fled the bank with $11,000 of federally insured US

6 Currency. Officers followed what they believed to be the Suspect's footprints in the snow

7 as they led away from the bank. The footprints ended abruptly approximately one and a half

8 blocks from the bank in the middle of the roadway, as if the Suspect was picked up by

9 someone in a vehicle.

10 On Monday, January 25,2010, at approximately 1445 hours, a white male, 5'5"-5'8",

11 medium build, mid-40s, wearing a wearing a dark ski mask, sunglasses,jacket, baseball hat,

12 and gloves, entered the Sunwest Bank, 822 North Humphreys Street, Flagstaff, Arizona. The

13 Suspect approached the victim tellers, brandished a black semi-automatic handgun, and

14 demanded money from the multiple tellers, specifically asking for the top and bottom

15 drawers. The Suspect ordered the tellers to place the money in a bag he had brought in the

16 bank. After the last teller put the money into the bag, the Suspect ordered everyone on the

17 ground and fled the bank. The Suspect fled the bank with $17,142 of federally insured US

18 Currency. It is unknown how the Suspect fled the area.

19 On Friday, January 29, 2010, at approximately 1530 hours, a white or Hispanic male,

20 5'6"-5'7", medium build, 150 pounds, mid-30s, wearing a wearing a dark ski mask, dark

21 jacket, and baseball hat, entered the Land of Enchantment Federal Credit Union,1101 Don

8


1 Diego, Santa Fe, New Mexico. The Suspect approached the victim teller, brandished a black

2 semi-automatic handgun, and demanded money from her. The Suspect ordered the teller to

3 place the money in a bag he had brought in the bank. After the teller put the money into the

4 bag, the Suspect ordered everyone on the ground and fled the bank. The Suspect fled the

5 bank with $2872 offederally insured US Currency. It is unknown how the Suspect fled the

6 area.

7 On Saturday, January 30,2010, at approximately 1315 hours, a white or Hispanic male,

8 5'6"-5'8", thin to medium build, late 20s to early 30s, wearing a dark hat, dark scarf, and

9 baseball hat, entered the Bank of America, 3101 Southern Boulevard, Rio Rancho, New

10 Mexico. The Suspect approached the victim tellers, brandished a black semi-automatic

11 handgun, and demanded money from the multiple tellers, specifically asking for all the

12 money. The Suspect put the money in a bag he had brought in the bank. After the last teller

13 put the money into the bag, the Suspect ordered everyone on the ground and fled the bank.

14 The Suspect fled the bank with $2349 of federally insured US Currency. The Suspect fled

15 on foot and may have fled in a dark passenger vehicle.

16 On Friday, February 5,2010, at approximately 1510 hours, a white or Hispanic male,

1 7 5'7" -5' 1 0", 30's-40's, slender build, distinct hazel eyes, wearing a dark ski mask, sunglasses,

18 jacket, grey hooded sweatshirt, and gloves, entered the Community Bank ofColorado, 1438

19 East Main Street, Cortez, Colorado. The Suspect approached the victim tellers, brandished

2 a a black semi-automatic handgun, and demanded money from the multiple tellers, specifically

21 asking for the top and bottom drawers. After the Suspect obtained the money, he ordered

9


1 everyone on the ground and fled the banle The Suspect fled the bank with $6485 of federally

2 insured US currency. It is unknown how the Suspect fled the area.

3 On Thursday, February 16, 2010, at approximately 1617 hours, a white male, 5'5"-5'8",

4 35-40 years ofage, medium build, wearing a black hooded sweatshirt, dark beanie cap, dark

5 sunglasses, gloves, ski mask over the lower halfofhis face, and gloves, entered the US Bank,

6 1514 Park Avenue, Park City, Utah. The Suspect approached the victim tellers, brandished

7 a black semi-automatic handgun described as a Glock or Springfield XD, and demanded

8 money from the multiple tellers, specifically asking for all the money in both drawers. The

9 Suspect presumably could not see through the sunglasses and lowered the sunglasses,

10 exposing his face between his eyebrows and his nose to the bank employees. The Suspect

11 ordered the tellers to place the money in a bag he had brought in the bank. After the last

12 teller put the money into the bag, the Suspect ordered everyone on the ground and fled the

13 bank. The Suspect fled the bank with $12,058 of federally insured US currency. Witnesses

14 did not see how the Suspect fled the area.

15 On Thursday, February 24,2010, at approximately 1230 hours, a white male, 5'5"-5'8",

16 medium build, mid-40s, wearing a wearing a dark ski mask, sunglasses, jacket, baseball hat,

1 7 and gloves, entered the Sunwest Bank, 822 North Humphreys Street, Flagstaff, Arizona, the

18 same bank that was robbed on January 25,20 IO. The Suspect approached the victim tellers,

19 brandished a black semi-automatic handgun, and demanded money from the multiple tellers,

20 specifically asking for the top and bottom drawers. The Suspect ordered the tellers to place

21 the money in a bag he had brought in the bank. After the last teller put the money into the

10


1 bag, the Suspect ordered everyone on the ground and fled the banle The Suspect fled the

2 bank with $3349 of federally insured US currency. It is unknown how the Suspect left the

3 area.

4 INITIAL INVESTIGATION

5 After reviewing the witness statements and bank surveillance photographs, investigators

6 immediately identified several consistencies in these robberies that indicate they were

7 committed by the same individuals. First, the physical description of the main suspect in the

8 bank remains consistent, a white male, short, slender build, 30-50 years old, wearing

9 sunglasses, a dark ski mask often described as "neoprene", and a baseball hat. The Suspect

10 also consistently carries a dark, semi-automatic handgun and always wears gloves, sometimes

lIon only one hand. In addition, based on your affiant's training and experience, a review of

12 the bank surveillance video shows that the Suspect has the same mannerisms and method of

13 operation during the robberies. Investigators' initial impression is that the same person

14 conducted each ofthese robberies. While the face coverings and clothing worn by the robber

15 make it impossible for investigators to definitively say it is the same person, based on your

16 affiant's training and experience, it is likely that it is indeed the same person or at least two

1 7 individuals working in concert.

18 Second, the robberies are consistently conducted in the same manner. The financial

19 institutions are located in small, rural jurisdictions where bank robberies rarely occur. As

20 Suspect 1 enters the bank, he always announces to everyone in the lobby area that he is

21 robbing the bank. He may vary his word slightly, but he always demands everyone's

11


1 attention, demands money from multiple tellers~ and specifically demands money from the

2 top and bottom drawers. Further, Suspect 1 almost always orders everyone to the floor as he

3 leaves the bank.

4 Finally, in the robberies where a witness has observed Suspect 1 's getaway, Suspect 1

5 always flees with the assistance of Suspect 2. With the exception of a couple of the above

6 described robberies in which witnesses have observed the Suspects' flight, Suspect 1 and 2

7 flee on an ATV through a remote area and at times to a waiting passenger vehicle. Further,

8 a witness from the Payson robbery described seeing a person matching the description ofthe

9 Suspect talking on a cell phone in a nearby parking lot prior to the bank robbery. Based on

10 your affiant's training and experience, bank robbers who work as a team often conduct

11 surveillance ofthe victim bank prior to the robbery in order to detennine the best bank to rob

12 and the best escape routes to use.

13 Based upon your affiant's training and experience, when the robbery involves a

14 conspiracy, robbers and co-conspirators tend to" use cellular telephones to communicate

15 regarding their plans. Further, when a robbery involves a conspiracy, it is common for

16 robbers and co-conspirators to conduct meetings to discuss their plans and tactics

17 immediately prior to committing a robbery, and also to conduct meetings to discuss their

18 success and divide proceeds following a successful robbery. It is also common for robbers

19 to travel to the location ofa planned robbery just prior to the robbery. With this in mind,

20 investigators obtained a court order, signed by U.S. Magistrate Judge David K. Duncan, for

21 records ofall mobile telephones that registered with cell phone towers closest to four of the

12


1 more remote robbery locations on the dates of the robberies, known colloquially as "cell

2 phone tower dump" records. Investigators used the four most rural locations in order to

3 minimize the amount of extraneous telephone data that would likely be obtained through

4 such a court order. Investigators obtained the court order for the following robbery dates and

5 locations:

6 8 September 2009

7 25 November 2009

8 3 December 2009

9 4 December 2009

Bank of the West, 1945 Highway 260, Heber, AZ

Compass Bank, 613 S. Beeline Highway, Payson, AZ

Chase Bank, 5305 S. Superstition Mtn Dr, Gold Canyon, AZ

Compass Bank, 781 E. White Mountain Blvd, Pinetop, AZ

10 Cell phone tower dump records provide a listing of any cell phones that have utilized

11 the cell phone tower for a particular date and time. They do not pinpoint the exact location

12 of a cell phone; rather, they indicate the general location of the phone based upon the

13 incoming and outgoing signals from the phone registering at a cell phone tower location.

14 The signals are not continuous and are only captured when the phone places or receives a call

15 or text message. Further, the signals are not continuously captured throughout the entirety

16 of the call, but rather are a snapshot in time, usually the beginning or the end ofa phone call

1 7 or text message. The cell phone tower locations therefore indicate the general location ofthe

18 cell phone and only provide an area accurate to within a few miles. Hundreds of cell

19 telephones register with these towers each minute. The above-referenced court order resulted

20 in the FBI receiving in excess of 150,000 telephone numbers registering with these towers.

21 However, due to the vast difference in distance and time between the cell towers and the

13


1 dates of the robberies, investigators believed that it would be extremely unusual for a cell

2 phone number to appear on two or more of the cell phone towers servicing the area of the

3 bank on the exact robbery dates.

4 An analysis of these records was conducted utilizing Microsoft Access by creating a

5 table for each ofthe phone companies responding to the court orders for each ofthe dates of

6 the robberies. These tables were then queried for any cell phone numbers that were common

7 between the different robbery dates and cell tower locations. Some telephone providers, such

8 as Verizon Wireless, did not have cell towers in all four of the locations. Verizon Wireless

9 does not have cell towers covering Gold Canyon, Arizona, so Verizon could only provided

10 records for the other three rural locations. This analysis produced only one telephone number

11 out of the thousands collected that utilized a cell phone tower servicing the area of the bank

12 during the exact date of three robberies: Verizon Wireless phone number 928-205-_

13 This number utilized a cell phone tower that covers the area of each respective bank on the

14 date ofeach ofthe following robberies: the September 8,2009 Heber, Arizona robbery, the

15

16

November 25,2009 Payson, Arizona robbery and the December 4,2009 Pinetop, Arizona

robbery. On November 25, 2009 and December 4,2009,928-205 I. '.vas in contact with

17 Verizon Wireless phone number 928-358-~ust prior to the robbery. A more in depth

18 analysis of 928-358-" revealed that it also utilized a cell phone tower that covers the area

19 ofthe respective bank on November 25, 2009 in Payson, Arizona, and on December 4, 2009

2 a in Pinetop, Arizona.

14


1 In summary, the Verizon mobile telephone assigned 928-205-~ was in the area of

2 all three of the above mentioned banks on the same day that the banks were robbed. On

3 November 25, 2009 and December 4,2009, the Verizon mobile telephone assigned 928-358-

4 .,. was also in the area of the banks and was in contact with 928-205-". Based on your

5 affiant's training and experience, it is likely that whoever was using these two cellular phone

6 numbers, 928-205~ and 928-358-.... were involved in the above described robberies.

7 DEVELOPMENT OF SUSPECTS

8 On 3/3/2010, your affiant obtained a court order signed by U.S. Magistrate Judge David

9 Duncan for subscriber information, historical call detail records, and cell site location

g 10 information for 928-205-~ and 928-358 2 . On 3/4/2010, Verizon Wireless provided

11 the requested records and advised that 928-205-~was subscribed to by RON CAPITO,

12 with an address ........ Show Low, Arizona, and that 928-358-"

13 was a pre-paid telephone serviced by Verizon Wireless, but sold by Tracfone. Since

14 Tracfone is a pre-paid wireless re-seller, any subscriber information is provided at the sole

15 discretion of the subscriber. On 3/5/2010, Tracfone advised that the subscriber to 928-358-

16 .. provided the name of JOEL GLORE and the date of birth as 3 : : £ d. The subscriber

17 did not provide a home address.

18 An analysis of the historical call detail records and cell site information corroborated

19 the earlier theory that the users of these telephones were involved in the above described

20 robberies. While the cell site records do not pinpoint the exact location of the mobile

21 telephone, it does provide a general location, usually within a three mile area of where the

15


1 mobile telephone is located. Investigators reviewed the cell site records and analyzed the

2 general location ofthe mobile telephones assigned 928-205- $ 6and 928-358 __-. These

3 Verizon records show that 928-205'" and 928-358-111 were either in very close

4 proximity to each ofthe above captioned sixteen bank robberies on the date and near the time

5 of each robbery or the telephones can be documented traveling between the general area of

6 Show Low, Arizona to or from the general area of each bank during the respective time

7 frame ofeach robbery. Further, these telephones often appear to be traveling with each other

8 on the dates of each of the robberies. The following are two examples of the cell site

9 analysis described above. Similar examples can be shown for all sixteen bank robberies.

lOOn 10/28/2009 at approximately 6:00AM, CAPITO's and GLORE's mobile telephones

11 were being used in the area ofa cell tower located in Show Low, Arizona. That same day,

12 both mobile telephones appear to travel west near Interstate 40, with GLORE's telephone

13 using towers near Williams, Arizona and CAPITO's telephone using towers near Williams,

14 Arizona and Ash Fork, Arizona. By 11 :OOAM on 10/2812009, both telephones were being

15 used on the same cell towers in Prescott, Arizona. Both telephones remain in the general

16 area of Prescott, Arizona through 10/30/2009. GLORE's telephone exclusively uses cell

17 towers in Prescott and Prescott Valley, Arizona through 10/30/2009. CAPITO's telephone

18 remains mainly on towers in Prescott and Prescott Valley, but occasionally uses towers in

19 Chino Valley and on Mingus Mountain near Jerome, Arizona, both within 20 miles of

20 Prescott Valley, Arizona.

16


1 On 10/30/2009 at approximately 2:56PM~ the High Country Bandits robbed the Country

2 Bank at 3044 N. Glassford Hill Road in Prescott Valley, Arizona. On 10/3012009, both

3 telephones begin the day on cell tower 202 in Prescott, Arizona. GLORE's telephone appears

4 to be off and does not depict any cell tower traffic from 6:46AM until 3 :39PM, when it uses

5 a cell tower along Interstate 17 northeast of Prescott Valley near Sedona and McGuireville,

6 Arizona. GLORE's phone continues to use cell towers between Sedona and Jerome, Arizona

7 until approximately 1: 17AM on 10/3112009 when it is back in the Show Low, Arizona area.

8 CAPITO's telephone uses towers in Prescott, Arizona until 12:02PM. The next tower

9 appearing on CAPITO's cell is located on top of Mingus Mountain at 2:40PM. While this

10 tower is approximately 20 miles from Prescott Valley, Arizona, it is located on a large

11 mountain that overlooks the Prescott Valley, Arizona area and likely covers a large service

12 area that includes parts ofPrescott Valley. CAPITO's telephone remains on this tower until

13 6: 12PM when it uses the same tower as GLORE's phone near Sedona, Arizona and, just as

14 with GLORE's telephone, it is next used at approximately 1 :22AM on 10/3112009 when it

15 is back in the Show Low, Arizona area.

16 In summary, both GLORE and CAPITO's mobile telephones show travel from Show

17 Low, Arizona to Prescott, Arizona on 10/28/2009. Their phones remain in the general

18 Prescott Valley, Arizona area until 10/30/2009 and within hours after the bank robbery in

19 Prescott Valley, they travel north and ultimately return to Show Low on or before 1 :20AM

20 that evening, 10/3112009.

17


1 On 11125/2009, both CAPITO's and GLORE's mobile telephones begin the day at

2 6:31AM on the same cell tower in Show Low, Arizona, when CAPITO calls GLORE's

3 mobile telephone. Both mobile telephones remain in Show Low until CAPITO's telephone

4 uses a cell tower near Punkin Center, approximately 30 miles south ofPayson, Arizona. By

5 approximately 11 :OOAM, both CAPITO's and GLORE's phones are using the same cell tower

6 in Star Valley, Arizona, approximately 5 miles east of Payson, Arizona and likely covering

7 areas of Payson, Arizona. By 1 1:50AM, both CAPITO's and GLORE's mobile telephones

8 are using towers in Payson, Arizona that are almost certainly within the coverage area of the

9 Compass Bank located at 613 S. Beeline Highway, Payson, Arizona. GLORE's telephone

10 remains on these Payson cell towers and last uses a Payson cell tower located only 1 mile

11 from the Compass Bank at 3:27 PM when he receives a call from CAPITO's cell telephone.

12 CAPITO's telephone continues to use the Star Valley and Payson towers through the 3 :27PM

13 call, when CAPITO's telephone is using a cell tower located only 1.7 miles from the

14 Compass Bank. At approximately 3:29PM, the High Country Bandits rob the Compass

15 Bank, 613 S. Beeline Highway, Payson, Arizona. The next call on either GLORE or

16 CAPITO's mobile telephones is at approximately 4:40PM when they are contacting each

17 other and both are using the cell tower near Punkin Center, approximately 30 miles south of

18 Payson, Arizona. Both mobile telephones remain using that cell tower throughout the night

19 and return to Show Low, Arizona by 11 :OOAM the next day.

20 In summary, both GLORE'S and CAPITO's mobile telephones show travel from Show

21 Low, Arizona to Payson, Arizona on 11125/2009. Their phones are in routine contact

18


1 throughout the day and use cell towers less than two miles from the bank until two minutes

2 prior to the Compass Bank robbery in Payson, Arizona. Their telephones make no calls until

3 an hour and a half after the robbery when they are 30 miles away from the bank. Both

4 telephones remain in this remote location and return to Show Low on or before 11 :OOAi\1 the

5 next day. These facts corroborate the facts obtained from the witnesses to the Compass Bank

6 robbery, including a witness who saw a suspicious individual matching the description ofthe

7 robber talking on a cell phone near the bank prior to the robbery.

8 While these above two examples show some ofthe best cell tower infonnation from the

9 Arizona robberies, investigators analyzing this infonnation can show a pattern oftravel and

10 cooperation between GLORE and CAPITO placing at least one ofthem at almost all sixteen

11 robbery locations. CAPITO uses his cellular telephone more than GLORE and, therefore,

12 there are more cell tower locations showing the general location of CAPITO's telephone.

13 The cell tower history shows that CAPITO's mobile telephone was either in the immediate

14 area of each of the above sixteen banks on the day of the robbery or, if no cell tower

15 infonnation is available that day, that the cell towers used by CAPITO's mobile telephone

16 indicates travel to and from the general areas of the robberies on or near the robbery date.

17 GLORE's cell tower history shows that he was either in the immediate area of eleven of the

18 above sixteen banks on the day of the robbery. For GLORE's phone, cell tower activity is

19 sometimes rare. For the 10114/2009, 1213/2009, 12115/2009, 12/22/2009 and 112512010

20 robberies, GLORE's phone does not record any cell tower activity near the dates and times

21 ofthe robberies. This does not show that GLORE's phone was located somewhere other than

19


1 the robbery; rather, it only shows that his phone was not used around the time of the

2 robberies. Considering the vast distance between robbery locations and the sheer number of

3 robberies, the fact that CAPITO and GLORE's mobile telephones are in the area of, or

4 traveling between, most robbery locations not merely a coincidence. Rather, it creates a

5 likely pattern by GLORE and CAPITO oftravel to the robberies, communication during the

6 robberies, and flight from the robberies.

7 INVESTIGATION OF GLORE AND CAPITO

8 A Google internet search for phone number 928-205--' returned an Arizona

9 Registrar ofContractors webpage that showed this was the phone number for Wapiti Ridge

10 Construction Inc,.......... , Show Low, Arizona, and listed a Corporate

11 Officer as RONALD MICHAEL CAPITO. A ChoicePoint Clear database check of

12 RONALD CAPITO returned the same address, Show Low,

13 Arizona, and provided a date ofbirth of bl, and social security account number of

14 . An internet property records check shows that the property a[ j I I r

15 .-, Show Low, Arizona is owned by RALPH and VERA CAPITO, who purchased it

16 from RONALD and JACKIE CAPITO on 12/13/2007. Ralph and Vera Capito,".

1 7 • respectively, are likely RONALD CAPITO's parents. An Arizona Motor Vehicles

18 Division ("MVD") records check was conducted on Capito, and his residence and identifying

19 infonnation were verified by virtue ofhis Arizona driver's license infonnation.

20 Arizona MVD records also show that Capito has three vehicles registered in his name,

21 including a metallic grey, 2006 Dodge one-ton pick-up truck, Arizona license plate •••

20


1 On 3/412010, 3/5/2010,31712010 and 3/8/2010, law enforcement conducting surveillance in

2 this case observed the truck parked outside ....... ShowLow,

3 Arizona. The make, model, color and tires match the general description of the truck seen

4 by witnesses associated with a red A TV prior to the September 22,2009 robbery in Bayfield,

5 Colorado. In addition, on 3/8/2010, two ATVs were observed under the carport on

6 CAPITO's property. One of the ATVs was yellow and the other had a cover over it

7 concealing the A TV down to the wheels.

8 A Choice Point Clear database check ofphone number 928-35 8 ....retumed the name

9 JOEL GLORE with a current addresses Show Low, Arizona. On

10 2/27/2010, Navajo County Animal Control Officers responded to a dog bite call at~

11 , Show Low, Arizona and interviewed the resident, JOEL JAY GLORE, age

12 51. Glore advised officers that this was his current residence. A check of Arizona Motor

13 Vehicle Division records indicated that Arizona driver's license number.

14 to JOEL JAY GLORE, Show Low, Arizona, date of birth __

15 issued 7 and listed GLORE as 57", 165 pounds, with hazel eyes. This physical

16 description is an almost exact match to the physical description of Suspect 1 who is almost

1 7 always inside the bank during the robberies, including the hazel eyes that the victim teller

18 from the February 5, 2010 robbery specifically mentioned. Based on the physical

19 descriptions alone, investigators believe that GLORE is likely the bank robber (Suspect 1)

20 and he is relying on CAPITO (Suspect 2) to drive the getaway car and/or ATV.

21


1 Surveillance was initiated on GLORE and CAPITO's residences on 3/4/2010 and

2 continued intennittently through 3/9/2010. On 3/5/2010 and 3/8/2010, CAPITO was

3 observed coming and going from ••••• Show Low, Arizona. On

4 3/5/2010, he was observed driving the above described grey Dodge pick-up from the

5 residence. On 3/812010, CAPITO was observed driving an ATV to and from his residence.

6 INVESTIGATION CORROBORATING CELL TOWER ANALYSIS

7 A. Arizona

8 Investigators mapped the Show Low, Arizona addresses for CAPITO and GLORE and

9 discovered that they were in the same residential neighborhood and were in close proximity

10 to Highway 260. The first bank robbery believed to be part of this series of robberies was

11 the September 8, 2009, bank robbery at Bank of the West, 1945 Highway 260, Heber.

12 Arizona. This bank is approximately 31 miles from their residences and the closest of the

13 sixteen banks to their residences. The Suspect fled the robbery through an open lot near the

14 bank. A witness reported seeing two suspicious males on a "hunting style" ATV in the open

15 lot some time prior to the robbery.

16 A review of the Arizona Supreme Court database revealed that RONALD CAPITO

1 7 received a traffic ticket for improper riding on a motorcycle/all-terrain vehicle from the

18 Snowflake Justice Court on September. 2009. Investigators contacted the Arizona Game and

19 Fish Officer who wrote the ticket. The officer advised that on September 4, 2009, just four

20 days prior to the bank robbery in Heber, he observed an individual driving a camouflaged

21 ATV east along State Highway 260 near the west end of Heber, Arizona. This ATV was a

22


lone-person ATV and the driver was carrying a passenger on the back of the ATV. The

2 Officer stopped the ATV for Riding Double on an ATV Against Manufacturer's

3 Specifications (ARS 28-892) and identified the driver as RONALD M. CAPITO, age 52, and

4 the passenger as JOEL J. GLORE, age 51. CAPITO admitted that he had no license plate

5 and the ATV was not registered. This incident shows that CAPITO and GLORE have

6 knowledge ofand access to ATV s and is further evidence ofthe likelihood that CAPITO acts

7 as GORE'S get-away driver. Additionally, this incident took place within two miles of the

8 first bank robbery in this series and just four days prior to the robbery. Finally, the

9 camouflaged color ofthe A TV matches the witnesses' descriptions ofa suspicious "hunting

10 style" ATV ridden by two men in the area ofthe bank prior to the Heber robbery. Based on

11 your affiant's training and experience, GLORE and CAPITO likel:y chose the Heber bank for

12 their first robbery based on their familiarity with the area and associated escape routes.

13 Two photographic lineups were created, each containing pictures ofsix individuals with

14 similar physical characteristics. One of the lineups contained a driver's license photograph

15 of CAPITO and the other contained a driver's license photograph of GLORE. These were

16 distributed to investigators in Arizona, Utah, New Mexico and Colorado. Considering that

1 7 the Suspect in the bank always wore a ski mask, sunglasses and hat, very few witnesses were

18 able to obtain a good view of the Suspect's face. Investigators identified any witness who

19 thought they may be able to identifY the Suspect and showed these lineups to those witnesses.

20 A bank customer from the 10/30/2009 Prescott Valley robbery reviewed the CAPITO lineup,

21 pointed to CAPITO and said, "I think it is him." When asked how positive she was in a

23


1 percentage fonn, she said twenty percent. When asked what she remembered about the

2 robber, she said his pointy shaped nose and eyes. The witness stated that she saw the robber

3 from the side most of the time. No other witness in Arizona was able to identify GLORE or

4 CAPITO from the lineups.

5 B. Utah

6 On 3/5/2010, investigators showed the GLORE lineups to three witnesses from the

7 2/16/2010 robbery of the US Bank in Park City, Utah. During this robbery, the Suspect

8 presumably could not see through the sunglasses and lowered the sunglasses, exposing his

9 face between his eyebrows and his nose to the bank employees. When reviewing the

10 GLORE lineup, all three witnesses identified GLORE as the individual who robbed the US

11 Bank. Therefore, not only are GLORE and CAPITO's mobile telephones in the area of the

12 US Bank in Park City, but witnesses identified GLORE as the robber. In addition, as will

13 be detailed in the "Colorado" section immediately below, Colorado law enforcement had

14 contact with GLORE and CAPITO after the Park City, Utah robbery.

15 C. Colorado

16 Investigators in Colorado cross referenced GLORE's name and numbers to the evidence

17 obtained in and around the time of the Colorado robberies. Investigators have linked

18 GLORE and CAPITO in the Bayfield, Colorado area near the time ofthe 9/22/2009 robbery

19 ofthe First National Bank ofDurango. A review ofcasino records in the area shows that on

20 9/17/2009, CAPITO and GLORE applied for players cards at the Sky Ute Casino in Ignacio,

21 Colorado, approximately 11 miles from the First National Bank of Durango in Bayfield,

24


1 Colorado. Both GLORE and CAPITO provided their Arizona driver's license when applying

2 for these player's cards. On the day of the robbery at 1 :37PM, GLORE and CAPITO's

3 phones called each other and used cell towers in Bayfield, Colorado, less than two miles from

4 the bank and less than 30 minutes prior to the robbery. Therefore, not only cell tower

5 records, but also casino records place GLORE and CAPITO in the area of the Bayfield,

6 Colorado robbery on the days prior to and day of the robbery.

7 After the robbery of the Bank of the San Juans in Durango, Colorado on 12/22/2009,

8 investigators collected hotel registrations throughout Durango on the day of the robbery.

9 Investigators reviewed these records and found that the Econolodge, located at 2002 Main

1 0 Ave, Durango, Colorado, provided the following hotel registration infonnation for JOEL J.

11 GLORE: GLORE checked into the Econolodge Hotel on 12/2112009 and checked out on

12 12/22/2009, the exact day the Bank ofthe San Juans was robbed. He provided a Visa credit

13 card number in his name in case ofdamages, but paid for the room in cash. Hotel employees

14 made a notation that the hotel room was for two adults. GLORE also provided an address

15 o~ Show Low, AZ and telephone number 928-358~ the same

16 number identified as being in close proximity to the High Country Bandit robberies. The

17 hotel's policy is to verifY the owner of the credit card against a photo identification. The

18 Econolodge is located approximately three blocks north ofthe Bank ofthe San Juans. Video

19 obtained from a nearby gas station showed Suspect 1 approaching the bank from the north.

20 Further, CAPITO's mobile telephone shows that he was traveling in the area ofthe Colorado

21 and New Mexico border approximately 2 hours after the 12/2212009 Durango, Colorado

25


1 robbery. Therefore, cell tower records and hotel records show that GLORE and CAPITO

2 were likely in the area ofDurango, Colorado on the day ofthe robbery, with GLORE in the

3 immediate area of the bank.

4 Investigators also learned that GLORE and CAPITO were contacted by San Miguel

5 County Sheriffs Office (SMCSO) on 2119/2010 near Telluride, Colorado, just three days

6 after the 2/16/2010 US Bank robbery in Park City, Utah. Officers responding to a 911 call

7 regarding a missing person in a rural location found CAPITO next to his silver, 2005 Toyota

8 Avalon, Arizona license plate~. This vehicle is registered to RONALD CAPITO,

9 Show Low, Arizona. CAPITO produced a Glock handgun from

10 somewhere on his person and complied with the officer's commands to drop it. This Glock

11 handgun closely matches the description of the gun used in the Park City, Utah robbery on

12 2116/2010. CAPITO then consented to the search ofhis Toyota. Officers found a revolver

13 in the trunk and blood on the front seat and snow around the vehicle indicating a struggle.

14 Officers also found $4029 in United States currency in several large wads on CAPITO's

15 person. CAPITO claimed he and GLORE obtained the money from casino winnings the day

16 prior and he had the gun to protect himself from mountain lions.

1 7 When interviewed, CAPITO advised that he got into an argument with JOEL GLORE

18 and that he had punched GLORE in the face. GLORE had run offinto the woods hours prior

19 and CAPITO was concerned for GLORE's safety. Officers located GLORE, who was

20 hypothennic and bloody. CAPITO was arrested for assault, carrying a concealed weapon,

26


1 and disorderly conduct. Officers released the money to GLORE, who used it to pay the bond

2 for CAPITO's release.

3 Therefore, not only does this incident demonstrate CAPITO's and GLORE's violent

4 relationship, but it also shows that they traveled together with weapons and a significant

5 amount ofUS currency just three days after the Park City, Utah robbery. Further, the Glock

6 handgun matches the description of the handgun used in the Park City robbery. Finally,

7 CAPITO's booking photo shows that he has changed his appearance by dying his hair black.

8 D. New Mexico

9 Investigators have not yet shown photographic lineups to the witnesses in the New

10 Mexico robberies.

11 WARRANTS

12 On 3/9/2010, based on the above listed evidence, the United States District in Salt

13 Lake City issued an arrest warrant for JOEL GLORE for one count of armed bank robbery

14 of the US Bank in Park City, Utah on 211612010.

15 INTERVIEWS

16 On 3/1112010, your affiant interviewed JOEL GLORE at the Summit Healthcare

1 7 Regional Medical Center in Show Low, Arizona. The audio ofthis interview was recorded.

18 GLORE was advised ofhis Miranda rights and agreed to speak with investigators. GLORE

19 had been hospitalized since Monday, 3/812010, due to a ruptured appendix. GLORE was

2 a receiving antibiotics and had not received any other medication for at least four hours prior

21 to the interview. Nurses treating GLORE advised that he had been receiving visitors and that

27


1 he was coherent and lucid. GLORE also advised investigators that he was feeling fine prior

2 to the interview. GLORE provided the following infonnation:

3 GLORE admitted that he and RON CAPITO robbed all of the above listed 16

4 financial institutions, including all eight Arizona financial institutions, and split the robbery

5 proceeds in half. He admitted that while he and CAPITO planned all of the robberies,

6 GLORE's job was to do the robbery inside the banks and CAPITO'S job was to be the get

7 away driver. GLORE provided specific details regarding each ofthe Arizona robberies that

8 were not disseminated to the public. He identified himself as the robber in the bank

9 surveillance photographs of each Arizona robbery, except the Heber robbery where your

10 Affiant did not have a surveillance photograph to show. 'Wilen asked how the robberies

11 began, GLORE advised that sometime prior to the 9/8/2009 Heber, Arizona bank robbery,

12 RON CAPITO approached him with the idea of robbing banks. GLORE said he initially

13 thought CAPITO was joking, but GLORE and CAPITO were desperate for money and began

14 planning their first bank robbery. GLORE stated that their first bank robbery was conducted

15 at a bank in Heber, Arizona. He said that when he and CAPITO were stopped by the Arizona

16 Game and Fish Officer in Heber, Arizona on 9/412009, they were looking at the area near the

17 bank: and planning their robbery. GLORE said that in the Heber robbery, they fled on

18 CAPITO's camouflaged A TV, but they used CAPITO's black ATV in subsequent robberies.

19 GLORE said they did not always flee on an ATV, but at times used CAPITO's Dodge pick

20 up, CAPITO's white Jeep Cherokee, CAPITO's grey Toyota Avalon, or GLORE's green Jeep

21 Cherokee.

28


1 GLORE described two occasions when CAPITO "got physical" with him after

2 GLORE was hesitant to do a robbery. GLORE described one incident in New Mexico when

3 he felt that CAPITO was intimidating him into committing the robberies. In that instance,

4 CAPITO had called his wife to tell her that he won a lot of money at a casino. When

5 GLORE was hesitant to commit a bank robbery, CAPITO became angry. GLORE also

6 described the 2119/2010 incident with SMCSO near Telluride, Colorado. GLORE said he

7 ran from CAPITO because CAPITO threatened to kill him after GLORE did not follow

8 CAPITO's instructions as they were preparing for a bank robbery in Colorado earlier that day.

9 GLORE said that CAPITO always traveled with a gun and would carry a gun with him in the

10 car during their bank robberies.

11 GLORE stated that his cell phone number is 928-358-~and CAPITO's cell phone

12 number is 928-205-". He said that they initially used the cell phone to communicate

13 while planning and conducting the robberies, but used them less as they became more

14 familiar with their routine. GLORE does not let anyone else carry his cell phone and he has

15 not known anyone else to carry CAPITO's cell phone.

16 On 3111/2010, CAPITO was brought in for questioning. After investigators read

17 CAPITO his Miranda rights, he invoked his rights and requested an attorney.

18 SEARCH WARRANTS

19 On 311012010, United States Magistrate Judge Lawrence O. Anderson issued search

20 warrants for GLORE and CAPITO's residences and two of CAPITO's vehicles. On

21 3111/2010, FBI Agents executed these seareh and obtained evidence oftheir involvement in

29


1 the series of 16 bank robberies. In GLORE's residence, investigators located a SigSauer

2 Airsoft pellet gun and the remnants ofan exploded bank dye pack that was still covered with

3 red dye. Investigators also found old newspaper articles regarding law enforcement's search

4 forthe "High Country Bandits," as well as a Cortez, Colorado newspaper dated 2/6/20 10, one

5 day after the robbery of the Community Banks of Colorado in Cortez, Colorado.

6 Investigators found a handwritten log of cities that closely match the cities where the banks

7 were robbed. The list included Heber, Bayfield, Flagstaff, Prescott, Belen, Payson, Gold

8 Canyon, and Pinetop - all the Arizona cities in which banks were robbed by the High

9 Country Bandits. Finally, investigators found a light blue long sleeve shirt matching the

10 description of the shirt the robber wore in the 1213/2009 Chase Bank robbery in Gold

11 Canyon, Arizona and a Denver Broncos T-shirt that closely matches the description of the

12 shirt the robber wore in the 12/22/2009 robbery of the Bank of the San Juans in Durango,

13 Colorado.

14 Investigators then searched CAPITO's property, which contained a residential

15 building, one large bam-style garage and several vehicles. Investigators found a stolen, black

16 Polaris A TV in CAPITO's garage. Investigation revealed that the A TV had been stolen from

17 a residence in Overgaard, Arizona on October 2, 2009. A witness to this theft reported

18 seeing two men dressed in black stealing the ATV. Investigators then searched a white Jeep

19 Cherokee, Arizona license plate -., that was located next to the stolen A TV in

20 CAPITO's garage. Inside the Cherokee, investigators found a loaded Ruger P345 handgun

21 that resembles the weapon used in many of the 16 bank robberies, to include the 12/312009

30


1 robbery of the Chase Bank in Gold Canyon, Arizona. Investigators also found a neoprene

2 style ski mask that closely resembles the description of the ski mask worn by the robber in

3 several of the above robberies, to include the 11125/2009 Compass Bank robbery in Payson,

4 Arizona. Also inside the Cherokee was a camouflage jacket that closely resembles the jacket

5 that the robber wore in the 2/24/2010 Sunwest Bank robbery in Flagstaff, Arizona, as well

6 as a GPS unit. While investigators did not locate large sums ofmoney, they did find several

7 cash straps, similar to bank or casino straps used to secure large amounts ofcurrency, as well

8 as gambling receipts.

9 CAPITO's wife, Jackie Capito, was interviewed and she confirmed that 928-205 ....

lois RONALD CAPITO's cell phone and he is the only one that uses and maintains possession

11 ofthat mobile telephone. She also advised that she and CAPITO are behind on several debts

12 and that CAPITO regularly goes to the casinos. She also said that CAPITO has been out of

13 work since the fall of 2009.

14 II

15 II

16 II

17 II

18 II

19 II

20 /I

21 /I

31


1 CONCLUSION

2 Based on the above listed facts, your Affiant believes there is probable cause to charge

3 RONALD MICHAEL CAPITO and JOEL JAY GLORE with eight counts ofAnned Bank

4 Robbery and Aid and Abet in the District of Arizona, in violation of Title 18 U.S.C. §§

5 21 13(a) and (d) and 2.

Dated this 12th day of March , 2010.

Subscribed and sworn to and before me this 12th day of March, 2010.

LAWRENCE o.!2~~ United States Magistrate Judge

32


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