Free Complaint - District Court of Delaware - Delaware

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United States District Court
DISTRICT OF DELAWARE
UNITED STATES OF AMERICA
v.
Criminal Complaint 08- gal M
JERRY LEE HOLMAN
1, the undersigned complainant, being duly sworn, state the following is true and correct to the best of my
knowledge and belief
On or about May 9, 2008, in New Castle County, in the District of Delaware, defendant, Jerry Lee Holman
did buy, sell, exchange, transfer, receive and deliver false, forged, and counterfeited obligations ofthe United States,
to wit five (5) one hundred-dollar ($100.00) Federal Reserve Notes, Series 1996, Serial Number AB75569'772K, and
twenty (20) fifty-dollar ($50.00) Federal Reserve Notes, Series 2001, Serial Number CFl6998361A, with the intent
that the same be passed, published, or used as true and genuine, in violation of Title 18, United States Code, Section
473 and 2.
I further state that I am a(n) Special Agent, with the United States Secret Service, and that this complaint is
based on the following facts: SEE ATTACHED AF FIDAVIT up _
Continued on the attached sheet and made a part hereof: YES l
Signature of Complainant
Andrew Balcenuik
Special Agent
Sworn to before me and subscribed in my presence,
May 9, 2008 at Wilmington, DE
Date City and State
Honorable Mary Pat Thynge {
United States Mag istrate Judge __ · ,¤,
Name & Title of Judicial Officer ure ofJudicia1 |ᤥ{

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AFFIDAVIT OF SPECIAL AGENT ANDREW BALCENIUK
I, Andrew Balceniuk, being duly sworn, depose and say:
l. 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 investigation of various counterfeit U.S. currency schemes
perpetrated to pass counterfeit U.S. currency for fraudulent gain.
2. This affidavit is submitted in support of a criminal complaints charging Jerry Holman and
Steven Taylor with Dealing in Counterfeit Obligations or Securities, in violation of 18 U.S.C. §
473. 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. Your affiant has not included every fact of which I am aware concerning this
investigation, but only those facts necessary to support probable cause to believe that the alleged
counterfeit violations occurred.
3. On April 24, 2008, New Castle City, Delaware Police Department (°‘NCPD") arrested a
man for selling crack cocaine (hereinafter “the C1"). A search incident to arrest revealed that the
CI was in possession of a counterfeit $100.00 Federal Reserve Note (PRN). Your affiant
responded to NCPD and interviewed the CI, the CI having been reminded of his Mircmdcz rights
by your aftiant after previously waiving those rights before NCPD detectives. During the
interview the CI admitted that he had bought the $100 counterfeit FRN from "Ted," later
identified as Ted Swan. The CI stated that he was at Swan’s house in New Castle, Delaware a
few days prior to his arrest, when Swan brought up the subject of counterfeit currency. When the
CI expressed interested in purchasing counterfeit currency, Swan telephoned his neighbor from
across the street. The Cl witnessed the neighbor walk across the street to Swan’s residence at
which time the neighbor presented the C1 with $170.00 in counterfeit FRNs. After discussing the
quality of the counterfeit FRNs, a deal was struck to purchase an additional $200.00 in
counterfeit FRNs for $30.00 in genuine currency between the C1 and the neighbor. The CI
observed Swan and his neighbor walk over to the neighbor’s house, and he observed Swan retum
with the additional $200.00 in what he was told were counterfeit FRNs. After admitting his own
criminal conduct, the CI agreed to cooperate with NCPD, and the CI further agreed to contact
Swan in an attempt to purchase more counterfeit FRNs.
4. On May l , 2008, your affiant observed a meeting in which the C1 and a New Castle City
Detective, acting in an undercover capacity, met with Swan at the Happy Harry’s Pharmacy
located on Route 13 South in New Castle, Delaware. During this meeting, the undercover New
Castle City Detective gave Swan $40.00 in genuine FRNs in return for $250.00 in counterfeit
FRNS.
5. On May 5, 2008, your affiant and the same New Castle City Detective met with Swan at
the New Castle City Police Department, after Swan was transported there by your affiant and the

Case 1 :08-mj-00092-UNA Document 1 Filed 05/O9/2008 Page 3 of 4
New Castle City Detective. After Swan was informed of his rights and signed a Miranda waiver,
he admitted to selling counterfeit FRNs on two occasions. The first occasion was prior to the
NCPD Cl’s April 24, 2008, arrest. Swan said he sold the NCPD Cl approximately $200.00 in
counterfeit FRNs for approximately $30.00 in genuine F RN s. The second occasion was during
the meeting with the New Castle City Detective on May 1, 2008. Swan stated that on both
occasions he received the counterfeit FRNS from "Jerry" (LNU), a neighbor who lives across the
street from Swan. Swan also stated that he gave all the money he received from the purchases to
"Jeny" and, in return, received, "a little bit of crack."
6. On May 9, 2008, Swan arranged a meeting between the undercover New Castle City
Detective working on the case, Jerry (subsequently identified as Jerry Holman) and the
manufacturer of the counterfeit (subsequently identified as Steven Taylor). ln telephone
conversations your affiant directed Swan to make, a deal was struck between Holman and Swan
for Holman and the counterfeit manufacturer Taylor to exchange $2,000.00 in counterfeit FRNS
for $500.00 in genuine currency provided by the New Castle City Detective acting in his
undercover capacity.
7. On May 9, 2008, your affiant observed Swan, Holman and Taylor meet with the
undercover detective at the Four Seasons Shopping Center on Route 896 in Newark, Delaware.
Swan introduced Holman to the undercover, and the undercover detective gave Holman $500.00
in genuine currency. This currency was provided to the undercover detective by your affiant
prior to the meeting. Holman then gave the undercover detective $1,400.00 in counterfeit FRNs
and stated that he couldn’t get the full $2000.00. Holman explained that he would have Swan
contact the undercover detective in order to set up a meeting to receive the remainder of the
$2000.00 counterfeit FRNS. When the undercover began to count the counterfeit FRNs, your
aftiant, other detectives from the NCPD, agents from the U.S. Postal Service, and agents from
the U.S. Secret Service arrested Holman and Taylor. During a search incident to arrest, agents on
the arrest team recovered the $500.00 genuine currency and two tom up counterfeit $50.00 FRNs
from Holman. The serial numbers on the tom up counterfeit FRNs match the serial numbers on
the bills provided to the undercover detective. Specifically, the counterfeit FRNs that were
seized during Holman and Taylor’s arrest were eighteen (18) counterfeit $50.00 FRNs, 2001
Series serial number CFl699836lA, two (2) torn $50.00 FRNs bearing the same serial number,
and five (5) counterfeit $100.00 FRNs, 1996 Series serial number AB75569772K, for a total of
twenty-five counterfeit FRNs with a total face value of $1 500.00.

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Based on my training and experience and the foregoing facts, your affiant submits that the
above facts establish that there is probable cause to believe that on or about May 9, 2008, in the
District of Delaware, J erry Holman and Steven Taylor knowingly bought, sold, exchanged,
transferred, and delivered false, forged, and counterfeited obligations of the United States as
described in paragraph 7 above, with the intent that the same be passed, published, or used as
true and genuine, all in violation of 18 U.S.C. § 473 and 2.
./' , ‘
An rew Balceniuk
Special Agent, U.S. Secret Service
SWORN AND SUBSCRIBED T0
this Q day o u ay, 2008.
_ A idk
.@. Mary Pat T .~-
Unite States Magistr e Judge

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