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Criminal Complaint — United States v. Ryan L. Terry, 2:25-cr-00546 (D.N.J., Document 1)

Summary

Document 1, filed 04/30/25, in Case 2:25-cr-00546-ES, is a criminal complaint against Ryan L. Terry in the District of New Jersey, sworn by Alexis Howell, a Special Agent with the Federal Bureau of Investigation. Count 1 charges conspiracy to commit bank fraud from in or about June 2023 through in or about December 2023, and Count 2 charges bank fraud on or about July 21, 2023. The affidavit states that checks stolen from the U.S. mail were deposited into accounts at Bank-1 in the name of a co-conspirator, including a check in the amount of $50,336.08. It states that Terry texted the co-conspirator to delete messages and asked the co-conspirator to recruit others. It states that dollar amounts and other figures are approximations.

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Cite this document

“Criminal Complaint — United States v. Ryan L. Terry, 2:25-cr-00546 (D.N.J., Document 1).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-united-states-v-terry-dkt-1-d-n-j-3305cfc0fc/, SHA-256 0597d6a6ceea2cfd0ab5a8e214acca72a7bd553aef48482ebcc57bdcb488efec.

Full text

  Case 2:25-cr-00546-ES    Document 1    Filed 04/30/25   Page 1 of 11 PageID: 1




                     UNITED STATES DISTRICT COURT
                        DISTRICT OF NEW JERSEY


UNITED STATES OF AMERICA             :     Hon. Michael A. Hammer

           v.                        :     Magistrate. No. 25-10127 (MAH)

RYAN L. TERRY                        :     CRIMINAL COMPLAINT

                                     :     Filed Under Seal


       I, Alexis Howell, being duly sworn, state the following is true and correct
to the best of my knowledge and belief:

                             SEE ATTACHMENT 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 ATTACHMENT B

continued on the attached pages and made a part hereof.


                                            _______________________________
                                            Alexis Howell, Special Agent
                                            Federal Bureau of Investigation


Special Agent Howell attested
to this Affidavit by telephone
pursuant to FRCP 4.1(b)(2)(A)
on April 30, 2025


_______________________________
Honorable Michael A. Hammer
United States Magistrate Judge
  Case 2:25-cr-00546-ES    Document 1    Filed 04/30/25   Page 2 of 11 PageID: 2




                               ATTACHMENT A

                                    Count 1
                      (Conspiracy to Commit Bank Fraud)

      From in or about June 2023 through in or about December 2023, in
Essex, Bergen and Hudson Counties, in the District of New Jersey, and
elsewhere, defendant

                               RYAN L. TERRY


knowingly and intentionally conspired with others to execute a scheme and
artifice to defraud a financial institution as defined in Title 18, United States
Code, Section 20, whose deposits were insured by the Federal Deposit Insurance
Corporation, and to obtain monies, funds, assets, and other property owned by
and under the custody and control of such financial institution, by means of
materially false and fraudulent pretenses, representations, and promises,
contrary to Title 18, United States Code, Section 1344.

      In violation of Title 18, United States Code, Section 1349.
  Case 2:25-cr-00546-ES   Document 1     Filed 04/30/25   Page 3 of 11 PageID: 3




                                   Count 2
                                 (Bank Fraud)

      On or about July 21, 2023, in Hudson County, in the District of New
Jersey, and elsewhere, defendant

                               RYAN L. TERRY

knowingly and intentionally executed, or attempted to execute, a scheme or
artifice to defraud a financial institution as defined in Title 18, United States
Code, Section 20, whose deposits were insured by the Federal Deposit Insurance
Corporation, and to obtain any of the monies, funds, assets, and other property
owned by and under the custody and control of such financial institution, by
means of materially false and fraudulent pretenses, representations, and
promises.

      In violation of Title 18, United States Code, Section 1344 and Section 2.




                                       -2-
  Case 2:25-cr-00546-ES    Document 1     Filed 04/30/25   Page 4 of 11 PageID: 4




                                ATTACHMENT B

       I, Alexis Howell, a Special Agent of the Federal Bureau of Investigation
(“FBI”), have knowledge of the following facts based upon my personal knowledge
and discussions with other law enforcement officers, as well as information
obtained from other sources, including: (a) statements made or reported by
various witnesses with knowledge of relevant facts; (b) my review of publicly
available information; and (c) my review of evidence, including photographs,
videos, business records, bank records, and other documents. Because this
Criminal Complaint is being submitted for a limited purpose, I have not set forth
every fact that I know concerning this investigation; rather, I have only set forth
those facts that I believe are sufficient to show that probable cause exists to
believe that the defendant has committed the offense set forth in Attachment A.
The contents of documents and the statements and conversations of individuals
referenced below are provided in substance and in part, unless otherwise
indicated. Where I assert that an event took place on a particular date and time,
I am asserting that it took place on or about the date and time alleged. Dollar
amounts, and other figures cited herein are approximations.

                                  Background

      1.    At all times relevant to this Criminal Complaint:

             a.   Defendant RYAN TERRY (“TERRY”) was a resident of
Piscataway, New Jersey. TERRY was a police officer with the Orange Police
Department and is currently employed as a police officer with the Essex County
Sheriff’s Department.

           b.     Co-Conspirator 1 (“CC-1”) deposited stolen checks into bank
accounts controlled by TERRY and/or other members of the conspiracy.

              c.   The bank accounts of Co-Conspirator 2 (“CC-2”) were used to
facilitate the scheme to defraud.

              d.   Co-Conspirator 3 (“CC-3”) provided transportation to other
members of the conspiracy to various financial and government institutions to
facilitate the scheme to defraud.

            e.    Co-Conspirator 4 (“CC-4”) was employed at Bank-1 and
provided insider access to the bank accounts CC-2 maintained at Bank-1.

            f.   The United States Postal Service (“USPS”) provided mail
processing and delivery services to individuals and businesses in the United
States.




                                        -3-
  Case 2:25-cr-00546-ES    Document 1    Filed 04/30/25   Page 5 of 11 PageID: 5




            g.    Bank-1, Bank-2 and Bank-3 (i) were “financial institution(s)”
as that term is defined in Title 18, United States Code, Section 20, offering,
among other things, checking and savings accounts to customers, (ii) had
deposits insured by the Federal Deposit Insurance Corporation and/or accounts
insured by the National Credit Union Insurance Fund, and (iii) had branches in
New Jersey.

                          Overview of the Conspiracy

      2.    An investigation by law enforcement revealed that from in or about
June 2023 through in or about December 2023, TERRY and Co-Conspirators
1-4 participated in a scheme to fraudulently obtain funds from Bank-1 using
checks stolen from the U.S. mail.

      3.    It was the goal of the conspiracy for TERRY and Co-Conspirators 1-
4 to enrich themselves by arranging for the deposit of stolen checks to
fraudulently obtain money from Bank-1.

    Theft of Checks and Scheme to Obtain Funds from Stolen Checks

      4.     TERRY and CC-1 deposited or caused to be deposited checks stolen
from the U.S. mail into accounts at Bank-1 maintained in the name of a CC-2
who, prior to the deposits, provided his/her banking information to TERRY.

      5.    To fraudulently obtain funds from Bank-1, TERRY, Co-Conspirators
1-4, and others then withdrew or caused others to withdraw money from CC-2’s
accounts through either cash withdrawals, the purchase of money orders at the
USPS, or transfers to other bank accounts.

      6.     Communications involving TERRY and Co-Conspirators 1-2 were
obtained by and reviewed by law enforcement.           These communications
chronicled the steps the co-conspirators took to execute the scheme, including
the acquisition of the CC-2’s banking information, the deposit of stolen checks,
and the coordination of cash withdrawals.

      7.     Communications from TERRY also revealed TERRY’s efforts or
attempts to insulate himself from any criminal exposure by directing CC-2 to
delete text messages after those messages were transmitted and read.

                             The First Stolen Check

       8.    On or about July 28, 2023, Individual-1 reported to the New Jersey
State Police on behalf of Company-1 that a check in the amount of $50,336.08
(the “First Stolen Check”) was not received or deposited by the intended payee.
Instead, records from Bank-1 showed that on or about July 12, 2023, the First
Stolen Check had been deposited into the checking account of an unknown


                                        -4-
  Case 2:25-cr-00546-ES    Document 1    Filed 04/30/25   Page 6 of 11 PageID: 6




individual, who was later identified as CC-2. According to Individual-1, the First
Stolen Check was written and sent through the U.S. mail on or about June 29,
2023.

      9.    Based on law enforcement’s review of video footage from Bank-1,
CC-1 deposited the First Stolen Check on July 12, 2023, into the account of
CC-2 at an Automated Teller Machine (“ATM”) located in Rutherford, New
Jersey.

       10. On or about July 21, 2023, Co-Conspirators 1-4, conducted the
following transactions to nearly deplete in full the amount of the First Stolen
Check from CC-2’s account:

         a. CC-2 made an in-person withdrawal at a bank branch in Jersey
            City in the amount of $25,000 facilitated by CC-4;

         b. CC-2 made an in-person withdrawal at an ATM in the amount of
            $8,900;

         c. CC-1 and CC-3 made an in-person withdrawal at an ATM in the
            amount of $3,000;

         d. CC-1 and CC-3 made an in-person withdrawal at an ATM in the
            amount of $1,000;

         e. CC-1 made an in-person purchase of a money order at a post office
            in the amount of $2,507.80;

         f. CC-3 made an in-person purchase of a money order at a post office
            in the amount of $2,407.80;

         g. CC-2 electronically transferred $5,000 to TERRY’s account at
            Bank-2 through Zelle 1 by directing payment to TERRY’s cell phone
            number in which TERRY is identified as the listed subscriber; and

         h. CC-2 electronically transferred $2,000 from another one of his/her
            accounts at a different bank to CC-1 through Zelle by directing
            payment to CC-1’s email address.



1 Zelle is a United States–based digital payments network that allows

customers to send money directly between almost any United States bank
accounts, typically within minutes, with just an email address or U.S. mobile
phone number.



                                        -5-
  Case 2:25-cr-00546-ES    Document 1     Filed 04/30/25   Page 7 of 11 PageID: 7




                   Text Messages about the First Stolen Check

      11. One day after the First Stolen Check was mailed, TERRY texted CC-
2 on or about June 30, 2023, and asked for CC-2’s banking information,
including the address on the account, pin number, username, password,
security question answers, and date of birth. CC-2 responded to TERRY and
provided the requested information.

      12. On or about July 19, 2023, TERRY texted CC-2, asking CC-2 to
“send a screen shot” of a mobile deposit that was made into CC-2’s account.
TERRY also instructed CC-2 to “delete these messages” after CC-2 sent the
screenshot.

     13.    On or about July 20, 2023―i.e., the night before the withdrawals,
purchases, and transfers described above―TERRY texted CC-2 the following
messages:

         Approximate           Message
         Date and Time
         July 20 – 8:43 p.m.   I need you to be free tomorrow baby
         July 20 – 8:43 p.m.   I’ll call you tonight to give you the run down
         July 20 – 8:43 p.m.   Cause tomorrow is the day
         July 20 – 8:56 p.m.   Feel me this test then focus on this money
         July 20 – 9:51 p.m.   Ok ima call you in a min

       14. In the early morning hours on or about July 21, 2023―i.e., the day
of the withdrawals, purchases, and transfers described above―CC-1 texted CC-
2 at 12:39 a.m.: “Hey will be to u around 820 am can u send the address &
screen shot of the mobile when it clear.” At nearly the same time, at 12:39 a.m.,
TERRY texted CC-2 twice, saying “My cousin texted you” and “Respond.”

      15. At approximately 5:56 a.m. on the morning of July 21, 2023, CC-1
texted CC-2: “Log in go to mobile deposit it s [sic] going [sic] say choose a [sic]
account just send a screenshot.” In response, CC-2 sent CC-1 the following
screenshot showing an account balance of $50,406.44:




                                        -6-
  Case 2:25-cr-00546-ES   Document 1    Filed 04/30/25   Page 8 of 11 PageID: 8




      16.   Later that same morning, CC-1 texted CC-2 the plan for that day:

        Approximate Date and Time        Message
        July 21 – 6:03 a.m.              We going to the plug
        July 21 – 6:03 a.m.              So please be up round early 8ish
        July 21 – 7:23 a.m.              Dress like you going to a [sic]
                                         interview
        July 21 – 7:45 a.m.              Send address

Based on my training and experience, CC-1’s reference to “plug” meant a location
where they would commit the fraud. After CC-2 provided his/her address to CC-
1 by text, CC-1 texted CC-2 at 8:45 a.m. to “Come out.”

     17. At approximately 1:25 p.m. that same day, CC-1 and CC-2
exchanged the following text messages:

      Sender                     Message
      CC-1                       Update?
      CC- 2                      [unreadable image]
      CC- 1                      Okay
      CC- 1                      Went over limit
      CC- 2                      You going to be around later



                                       -7-
  Case 2:25-cr-00546-ES     Document 1    Filed 04/30/25   Page 9 of 11 PageID: 9




      CC- 1                        Loved “you going to be around later”
      CC- 1                        Yeah
      CC- 2                        I can get it from my other and give you it
      CC- 1                        U transfer it to there
      CC- 1                        ?
      CC- 2                        Or I can send it to him to give to you
      CC- 1                        Send it there
      CC- 1                        I’ll come grab from u
      CC- 1                        Or zelle
      CC- 1                        Xxxxxxxxxxx##@yahoo.com
      CC- 1                        That’s my zelle
      CC- 2                        Ok
      CC- 2                        Done

As described above, CC-2 sent $2,000 from an account at Bank-3 to CC-1
through Zelle by directing payment to Xxxxxxxxxxx##@yahoo.com, which is the
email address CC-1 provided to CC-2.

     18. Later in the afternoon of July 21, 2023, TERRY and CC-1
exchanged a series of telephone calls as depicted in the chart below:

Call          Call        Call         Call            Duration
Initiated     Received    Initiation   Termination
By            By          Time         Time
CC-1          TERRY       14:54:09     14:54:09        0:00
CC-1          TERRY       15:24:12     15:25:18        1:06
TERRY         CC-1        15:44:20     15:45:53        1:33
TERRY         CC-1        16:21:13     16:21:18        0:05
TERRY         CC-1        16:32:52     16:34:10        1:18
CC-1          TERRY       18:00:32     18:00:32        0:00


                             The Second Stolen Check

      19. Later in July 2023, Company-1 mailed a second check in the
amount of $20,336.08 (the “Second Stolen Check”) that was not received or
deposited by the intended payee. Instead, records from Bank-1 showed that on
or about July 24, 2023, the Second Stolen Check had been deposited into
another account in the name of CC-2. This transaction was ultimately reversed
by Bank-1 before funds could be withdrawn from the account.

      20. On or about July 24, 2023―i.e., the date the Second Stolen Check
was deposited―TERRY texted CC-2 at approximately 8:30 p.m., asking CC-2 to
send TERRY “a screen shot of your ac.” Based on my training and experience,



                                         -8-
 Case 2:25-cr-00546-ES     Document 1    Filed 04/30/25   Page 10 of 11 PageID: 10




the reference to “ac” meant “account.” At the same time, TERRY also instructed
CC-2 to “delete this message.”

     21. At approximately 9:08 p.m. that same night, TERRY texted CC-2:
“Send me a pic of chck [sic] images that were dropped then delete this message.”
TERRY then sent the following instructions:

       Approximate           Message
       Date and Time
       July 24 – 9:30 p.m.   Log in
       July 24 – 9:31 p.m.   Click the account and scroll down
       July 24 – 9:31 p.m.   And hit view check of the old one my bad
       July 24 – 9:31 p.m.   Send the images of the old check my bad
       July 24 – 9:32 p.m.   Only the front
       July 24 – 9:33 p.m.   Delete it all out the thread when you done

                                    Recruitment

      22. On multiple occasions, TERRY requested that CC-2 recruit other
individuals to engage in similar fraudulent activity, as shown by the following
text messages on the approximate dates listed:

                                    8/8/2023
      Sender             Message
      TERRY              But look I need to make another play
      TERRY              Might wanna ask that girl if she wanna do it
      TERRY              I need another 5k

                                    8/15/23
      Sender          Message
      TERRY           But I need one more play fr
      TERRY           Big play
      CC-2            You never said what you wanted to do with that
                      other card
      TERRY           Can’t make that move no more need another joint
      CC-2            Okay
      TERRY           What about your nail tech
      CC-2            I don’t see her until 8/31. I don’t have her number.
                      imma ask my other girlfriend today if she know
                      someone that’s interested
      TERRY           Bet

      23.    On or about August 16, 2023, the day after he inquired about the
nail tech, TERRY texted CC-2 a request seeking the banking information of



                                        -9-
 Case 2:25-cr-00546-ES   Document 1     Filed 04/30/25   Page 11 of 11 PageID: 11




Female-1, including her name, address on the account, pin, online username,
password, security questions and answers, and social security number.

      24. On or about August 17, 2023, CC-2 texted TERRY the banking
information for Female-1.

      25. On or about November 30, 2023, TERRY texted CC-2 at
approximately 7:56 a.m.: “I’ma [sic] give my cousin your number he’s gonna
contact you to get in contact with her have her just cooperate please I’m about
to Ko.” Later that morning at approximately 11:53 a.m., TERRY texted CC-2,
stating “That’s him calling” and “Pick up for him.” According to cellular phone
records, CC-1’s cellular phone called CC-2 at approximately 11:51 a.m.

      26. Later that afternoon, on or about November 30, 2023, at
approximately 1:28 p.m., CC-1 texted CC-2, “Rose land,” “156 eagle rock road,”
and “Be there 230.” Bank-3 operates a branch at 156 Eagle Rock Avenue in
Roseland, New Jersey.

      27. On or about November 30, 2023, at approximately 1:29 p.m., CC-2
then texted Female-1 “156 eagle rock road, Roseland”.

      28. According to the information provided by or Bank-1, the fraudulent
transactions made with the aforementioned stolen checks by TERRY and his
co-conspirators resulted in financial losses to the banks.




                                      - 10 -


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