AO 91 (Rev. 12/93) Criminal Complaint E
UNITED STATES DISTRICT COURT
DISTRICT OF DELAWARE
UNITED STATES OF AMERICA
CRIMINAL C·OMPLAINT
V0 °-i` ‘-\ "'·. "-' —· .
l Tl l ` r' - \
¢E’)i[g®/itil i,iTiTi
J0DY CHUBBS lid “ fm.; l _ _,.
CASE NUMBER: 07-/W5 M (7*7*00
I, the undersigned complainant, being duly sworn, state the following is true and correct to the best of my
knowledge and belief. From on or about April 18, 2007 to on or about May 31, 2007, in New Castle and Kent Counties,
in the District of Delaware, defendant Jody CHUBBS, knowingly executed and attempted to execute a scheme and
artifice to defraud and to obtain moneys, funds, and assets owned by and under the custody and control of Sun National
Bank, a financial institution the deposits of which are and were then insured by the Federal Deposit Insurance Corporation,
in violation of Title 18 United States Code, Section(s) 1344.
I further state that I am a(n) Special Agent, U.S. Secret Service and that this complaint is based on the following facts
Official Title
See attached Affidavit
Continued on the attached sheet and made a part hereof: Yes
Michael S. Ann trong
Special Agent, U.S.S.S.
Sworn to before me and subscribed in my presence,
Augist 7, 2007 at Wilmington, DE
Date City and State
The Honorable Mary Pat Thynge
United States Ma istrate Jud e qi/L,,,,,_
Name & Title of Judicial Officer ignatu e o Judicial Of if e I
V !\"""‘""`* ·-j·—~·---. -,._ _
{ F I L E D
us. uistsict COURT
Case 1:07-mj-00145-UNA Document 8 Filed 08/10/2007 Page 2 of 4
AFFIDAVIT
I, Michael S. Armstrong, being duly sworn, depose and say:
1. I am a Special Agent with the United States Secret Service and have been so
employed since February 2003. I am currently assigned to the Wilmington,
Delaware, Resident Office. My duties include the investigation of federal crimes
including access device fraud, credit card fraud and computer fraud. The training
given to U.S. Secret Service Special Agents includes approximately six months of
field and classroom training in all aspects of access device fraud, including the
detection of such crimes. Prior to my employment with the U.S. Secret Service, I
graduated from the Delaware State Police Academy and was employed as a Police
Officer with the Rehoboth Beach and Bethany Beach Police Departments for five
years.
2. This investigation is based on information provided to me by a Detective with the
Delaware State Police ("DSP") Financial Crimes Unit resident at Troop #2. In turn,
the Detective received information from representatives of the victim banks and
institutions.
3. This investigation concerns the activities of Jody Chubbs ("Chubbs"), a female
resident of Middletown, Delaware. The investigation has determined that Chubbs
and her husband, Keith Chubbs, own and operate several businesses from their
Middletown, Delaware residence, including, but not limited to, Chubbs Towing, aka
Chubbs Towing LLC, First State Filter and Fabrication, AAA Towing, and J &K
Enterprises.
4. In or about May, 2007, the DSP Financial Crimes Unit was contacted by a fraud
investigator employed by Citizens Bank. The fraud investigator indicated that on or
about March 28, 2007, Chubbs opened account number xxxxxxl 584 at the
Middletown, Delaware branch of Citizens Bank in the name of "Chubbs Towing,"
and listed Chubbs’ home address in Middletown as the account address.
5. On or about April 11, 2007, Chubbs deposited into Citizen Bank account number
xxxxxx1584 three Bank One checks (check numbers 1013 for $3,900.00; 1015 for
$4,200.00; and 1016 for $6,400.00 — for a total of$14,500.00) drawn on Bank One
credit line account xxxxxx5 844 in the name of Jody and Keith Chubbs. Each of these
three Bank One checks was signed by Chubbs. The Citizens Bank investigator
provided surveillance photographs of Chubbs making bank transactions on account
xxxxxx1584 on April 11, 2007.
6. Between April 11 and April 18, 2007, Chubbs made several ATM withdraws and
point of sale purchases throughout Delaware using funds from the Citizen Bank
account xxxxxx1584. On April 18, 2007, all the aforementioned Bank One checks
Case 1:07-mj-00145-UNA Document 8 Filed 08/10/2007 Page 3 of 4
(#s 1013, 1015, and 1016) were retumed for insufficient funds. As a result of
Chubbs’ actions, Citizens Bank sustained a financial loss of $5,393.71.
7. On or about June l, 2007, the DSP Financial Crimes Unit was contacted by an
investigator employed by Sun National Bank, regarding a financial loss sustained by
Sun National Bank as a result of Chubbs’ actions.
8. Specifically, on April 18, 2007 and April 26, 2007, Chubbs opened two business
accounts, account numbers xxxxxx55 36 and xxxxxx5 549, respectively, at the Sun
National Bank branch office in Bear, Delaware. Both of these commercial accounts
were opened in the name of "Chubbs Towing LLC."
9. On or about April 26, 2007, Chubbs deposited into Sun National Bank account
#xxxxxx5536 Bank One check # 1018 in the amount of $7,540.00, drawn on Bank
One credit line account xxxxxx5 844 in the name of Jody and Keith Chubbs. Chubbs
was photographed depositing the $7,540.00 check. This check subsequently was
returned for insufficient funds.
10. On or about May 23, 2007, Chubbs deposited three additional checks into Sun
National Bank account #xxxxxx5536. Bank One check #1020, in the amount of
$4,200.00, was drawn on Bank One credit line account xxxxxx5 844 in the name of
Jody and Keith Chubbs and was returned for insufficient funds. Citizen Bank check
#1029, in the amount of $6,990.00, was retumed as being drawn on a closed account.
Chubbs was photographed depositing these two checks. The third check was drawn
on an Artisans Bank account opened on May 22, 2007 by Chubbs and was a starter
check in amount of $9,420.00. An Artisans Bank investigator had restricted activity
on this account shortly after it was opened, because the account was applied for by
Chubbs using a social security number that was not assigned to her.
ll. Beginning soon after the accounts were opened and through May 2007, Chubbs made
numerous purchases and withdrawals throughout Delaware from the Sun National
Bank accounts, including but not limited to multiple purchases/withdrawals at Dover
Downs, located at 1131 N. DuPont Highway, Dover, Delaware. While each of the
above four checks was deposited into account #xxxxxx5 536, a portion of those funds
were moved into account xxxxxx5 549 and withdrawn by Chubbs from that account.
As a result of Chubbs’ actions Sun National Bank sustained a loss of $21,745.00.
12. Chubbs did not respond to "10 Day Demand" letters received from Citizens Bank and
Sun National Bank and further rehised to speak with the Sun National Bank
personnel investigating the delinquent accounts.
1
moneys, funds, and assets owned by and under the custody and control of Sun National
Bank, a financial institution the deposits of which are and were then insured by the
Fede l Depos` s nce Corporation, in violation of 18 United States Code, Section
1344
-,
Michael S. Armstrong
Special Agent
U.S. Secret Service
Subscribed and swom to before me this g day of · .
A
_ MQ J
he Ho or • e Mar ;~
Unite i tates Magis te Judge
United States Free Forms
Canada Free Forms
United Kingdom Free Forms
Australia Free Forms