Free Complaint - District Court of Delaware - Delaware

Case 1 :07-cr-00029—GIV|S Document 1 Filed 02/12/2007 Page 1 of 3
United States District Court
DISTRICT OF DELAWARE
UNITED STATES OF AMERICA
v.
KELIN BRADLEY
Criminal Complaint
CASE NUNIBER: 07- QBM
(Name and Address of Defendant)
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 February l0, 2007, in the State and District of Delaware, Defendant Kelin Bradley, with intent to defraud, did pass falsely made,
forged and counterfeited obligations of the United States, that is, Unitcd States Currency, which he then knew to be falsely made, forged and
counterfeited, in violation of Title 18, United States Code, Section 472.
I further state that I am a(n) Special Agent, United States Secret Service, Department of Homeland Securip; and that this complaint is based
Ofticial Title
on the following facts:
See attached Affidavit.
Continued on the attached sheet and made a part hereof: Yes X
/‘ % .
- A Signature of Complainant
Andrew Balceniuk
Special Agent, United States Secret Service
Sworn to before me and subscribed in my presence,
Februagg I2, 2007 at Wilmington, DE
Date n..-••...· `·
Honorable Mary Pat Thynge l .
United States Magistrate Judge . {.....
Name & Title eriudieai oram an ora`? I

Case 1 :07-cr-00029—GIV|S Document 1 Filed 02/12/2007 Page 2 of 3
AFFIDAVIT OF SPECIAL AGENT ANDREW BALCENIUK
I, Andrew Balceniuk, being duly sworn, depose and say:
1. Your affiant is a Special Agent with the U.S. Secret Service and has been so employed
since October 2002. Your affiant is currently assigned to the Wilmington, Delaware Resident
Office. Your affiant’s duties include the identification and investigation of counterfeit U.S.
currency production. Your affiant has received, approximately six months of field and classroom
training in the identification and investigationof various counterfeit U.S. currency schemes
perpetrated to pass counterfeit U.S. currency for fraudulent gains.
2. This afhdavit is submitted in support of a criminal complaint and warrant charging Kelin
Bradley with Passing and Possessing Counterfeit U.S. Currency in violation of 18 U.S.C.
§ 472. The allegations set forth in this affidavit are based upon my personal knowledge, as well
as upon information obtained from law enforcement officers, investigators, witnesses and other
parties and sources.
3. On February 10, 2007, Kelin Bradley was detained by Sears loss prevention officers at
Sears store #1853 located on Concord Pike in Wilmington, Delaware for attempting to purchase
a television using $200.00 in counterfeit U.S. currency.
4. Continuing on this date, Sears loss prevention contacted a trooper from the Delaware
State Police who took Bradley into custody for violations of state law pertaining to the passing of
the counterfeit U.S. currency. After questioning by the trooper, it was determined that Bradley
had made purchases at several stores in the Concord Mall and adjacent retail outlets. The trooper
went to these stores and recovered an additional $500.00 in counterfeit U.S. currency bearing
either the same serial numbers as the $200.00 already recovered, or manufactured in a similar
fashion as the currency already recovered. Alsearch subsequent to arrest also revealed several
hundred dollars in genuine U.S. currency on Bradley’s person. This money was folded into
separate stacks of just under $100.00, an indication your affiant knows from previous experience
that Bradley was purchasing smaller value items in order to exchange the counterfeit currency for
genuine currency.
5. Continuing on this date, Iwas contacted by the trooper and responded to the Sears store.
I verified that the currency recovered by the trooper was in fact counterfeit, specifically
"bleached" $5.00 bills. This is a technique utilized by counterfeit currency manufacturers in
which a genuine $5.00 bill has its ink chemically removed and a larger denomination is printed
on the genuine paper in an attempt to retain the anti-counterfeiting properties inherent to the
paper. After advising Bradley of his Miranda rights, Bradley stated that he had spent $1000.00
he received from the sale of a personally owned computer at various stores located in the
Concord Mall and along Concord Pike in Wilmington, Delaware. Bradley also stated that he
was, "70% sure that the money was not real", and that he never contacted law enforcement or a
bank for verification because he, "knew it would be taken and then he would be out the money."
After receiving written consent from Bradley, a search of his vehicle revealed several other bags
of merchandise purchased from local retailers.

Case 1 :07-cr-OOO29—GlV|S Docurrient 1 Filed O2/12/2007 Page 3 of 3
6. Continuing on this date, I responded to several stores in the Brandywine Town Center
visited by Bradley and recovered an additionali$300.00 in counterfeit U.S. currency bearing
either the same serial numbers as the $200.00 already recovered, or manufactured in a similar
fashion as the currency already recovered.
VVI-IEREFORE, based on my training and experience and the foregoing facts, your affiant
submits that there is probable cause to believe that Kelin Bradley did knowingly possess or pass
$1000.00 in counterfeit U.S. currency in violation of 18 U.S.C. § 472.
. Andrew Bialceniuk
n Special Agent, U.S. Secret Service
SWORN AND SUBSCRIBED TO .1.
th` - P z: · a ebruary, 2007. "
- ,+_ A an, p
Mary Pat ge
United States Magistrate Judge