8AO 91 (REV.5/85) Criminal Complaint AUSA Tiffany J.

Tracy (312) 353-1412

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION

UNITED STATES OF AMERICA

v.
CRIMINAL COMPLAINT
WILLIAM F. WOHLERS
CASE NUMBER:

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

knowledge and belief.

On or about August 11, 2009 in Cook County, in the Northern District of Illinois, defendant did,

by force and violence, and intimidation, take from the person and presence of bank employees at
of MB Financial Bank, 2251 Plum Grove Road, Rolling Meadows, Illinois, approximately $14,112
in United States Currency belonging to and in the care, custody, management, and possession of MB
Financial Bank, the deposits of which were insured by the Federal Deposit Insurance Corporation,

in violation of Title 18 United States Code, Section(s) 2113(a).

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

is based on the following facts:

See attached Affidavit.

Continued on the attached sheet and made a part hereof: X Yes No

___________________________________
Craig Heidenreich, Special Agent, FBI
Signature of Complainant
Sworn to before me and subscribed in my presence,

August 12, 2009 at Chicago, Illinois

Date City and State

MICHAEL T. MASON, U.S. Magistrate Judge

___________________________________
Name & Title of Judicial Officer Signature of Judicial Officer
 COMPLAINT AFFIDAVIT

I, Craig J. Heidenreich, being duly sworn, do hereby state and depose as follows:

1. I am a Special Agent with the Federal Bureau of Investigation (“FBI”) and have

been so employed for approximately three years. I am currently assigned to the violent crimes squad

of the FBI’s North Resident Agency office located in Rolling Meadows, Illinois. My duties include

the investigation of bank robberies and other violent crimes.

2. I make this affidavit based upon my personal knowledge, my participation in this

investigation, reports I have read, and conversations I have had with others who have personal

knowledge of the events and circumstances described herein. The information below is provided

for the limited purpose of establishing probable cause and does not contain all details or all facts of

which I am aware relating to this investigation.

3. On August 11, 2009, at approximately 9:40 a.m., the MB Financial Bank, located

at 2251 Plum Grove Road, Rolling Meadows, Illinois (“the Bank”) was robbed. An employee of

the bank noticed a white male (“the Robber”) outside of the front entrance of the Bank. According

to the same bank employee, the Robber left a black mountain bike outside of the Bank and entered

the bank. According to eyewitnesses and video surveillance, the Robber approached the teller

counter, pulled a black handgun from an orange-colored bag, and brandished the weapon during the

robbery. Eyewitnesses advised that the Robber then demanded money from bank employees.

4. According to eyewitnesses, the teller withdrew money from the drawer and gave

it to the Robber. After receiving money from the teller, the Robber demanded money from the

“safe.” The Robber entered the vault area of the Bank along with two Bank employees. The Bank

employees opened the vault, retrieved money and placed it into a bag that the Robber had brought

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with him. According to eyewitnesses, after the Robber received the money from the bank, he exited

the Bank and fled on the black mountain bike.

5. According to bank employees, they provided approximately $14,112 in United

States Currency (“USC”) to the Robber. Included in the USC were several bills that had pre-

recorded serial numbers.

6. Bank employees described the Robber as a white male, approximately 20 to 30-

years’ old, approximately 6'1" in height, who was slimly built. According to bank employees and

bank surveillance images, the robber wore a gray, long-sleeved shirt, a dark-colored baseball hat,

sunglasses, shorts, white socks, gym shoes, gloves, a white handkerchief around his neck, and

carried an orange-colored bag that was slung around his shoulder.

7. Law enforcement personnel from Rolling Meadows Police Department,

Arlington Heights Police Department, and the FBI responded to the Bank robbery. At

approximately 9:55 a.m., law enforcement personnel noticed a black bicycle in the back of a red

Ford F-250 pickup truck. The truck was parked in front of a gas pump at a gas station located at the

intersection of Arlington Heights Road and Palatine Road in Rolling Meadows, Illinois. The

driver’s side window was unrolled and the pump was still in the tank of the truck. The gas station

at the intersection of Arlington Heights Road and Palatine Road in Rolling Meadows, Illinois is

approximately 1.5 miles from the Bank.

8. When law enforcement personnel arrived at the gas station, they had a general

physical description of the Robber and knew that he had arrived and left the Bank on a black

mountain bike.

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 9. Officers looked at the cab of the red truck with the black bike in the back and

observed a bag and a large amount of loose cash in the front passenger side of the cab.

10. One or more officers approached and entered the gas station. Upon entry, a man

who was inside of the gas station, and later identified as WILLIAM F. WOHLERS (“WOHLERS”),

looked in the direction of the officers and fled out of the back door of the gas station.

11. Officers apprehended WOHLERS behind the gas station. When the officers

apprehended WOHLERS he said, “You got me.” WOHLERS was then taken into custody.

12. WOHLERS is a white male, approximately 6'0", has a slim build, and is 30-

years’ old.

13. Law enforcement personnel returned to the red Ford F-250 pickup truck and

observed through the unrolled window a black semi-automatic handgun in the space between the

driver’s seat and the center seat. Law enforcement personnel observed in the front passenger side

of the truck, a gray, long sleeved sweatshirt, gloves, a white bandana, a black baseball hat, loose

currency, and a bag. Further investigation revealed that the black semi-automatic handgun was

loaded. Further investigation revealed that the red Ford F-250 pickup truck was registered to

WOHLERS.

14. A subsequent inventory of USC found inside of the vehicle revealed that it

contained $14,112 in USC, the same amount that bank employees reported was taken from the Bank

during the robbery. Also included in the USC found inside of the vehicle were bills with

pre-recorded serial numbers that matched the serial numbers provided from the Bank.

15. Law enforcement personnel, after informing WOHLERS of his Miranda rights,

which he waived, interviewed WOHLERS regarding the robbery. WOHLERS stated, among other

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things, that he robbed the Bank. WOHLERS also provided details of the Robbery that matched

witness accounts and bank video images.

16. The deposits of the Bank were then and are now insured by the Federal Deposit

Insurance Corporation.

CONCLUSION

17. Based on the foregoing, your affiant respectfully submits that there is probable

cause to believe that, on or about August 11, 2009, defendant WILLIAM F. WOHLERS did, by

force, violence, and intimidation, take from the person and the presence of others, money belonging

to and in the care, custody, control, management, and possession of MB Financial Bank located at

2251 Plum Grove Road, Rolling Meadows, the deposits of which were then insured by the Federal

Deposit Corporation (FDIC), in violation of Title 18, United States Code, Section 2113(a).

FURTHER AFFIANT SAYETH NOT.

______________________________
Craig Heidenreich
Special Agent, Federal Bureau of Investigation

Subscribed to and sworn before

me this 12th day of August, 2009

_______________________________________
United States Magistrate Judge Michael T. Mason