COMPLAINT. The Complainant, being duly sworn, makes complaint to the above-named Court and states that

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1 STATE OF MINNESOTA COUNTY OF DAKOTA DISTRICT COURT FIRST JUDICIAL DISTRICT COURT FILE NO. 19HA-CR COUNTY ATTORNEY FILE NO. CA CONTROLLING AGENCY: MN CONTROL NUMBER: State of Minnesota, Plaintiff, v. SADE ALEXIS ROBINSON 3908 VALLEY VIEW DR APT 306 EAGAN, MN (DOB: 12/3/93) [ ] SUMMONS [ ] WARRANT [X] ORDER OF DETENTION [ ] AMENDED Defendant. COMPLAINT The Complainant, being duly sworn, makes complaint to the above-named Court and states that there is probable cause to believe that the Defendant committed the following offense(s): COUNT 1: IDENTITY THEFT (OVER $35,000 OR MORE THAN 8 DIRECT VICTIMS) (AGGREGATING) Minnesota Statutes , Subd. 2; , Subd. 3(5); , Subd. 3(1); ; PENALTY: 0-20 Years and/or $30, $100, MOC: U1731 GOC: N [X]Felony [ ] Gross Misdemeanor [ ] Misdemeanor [ ] Petty Misdemeanor On or about February 27, 2015, in the County of Dakota, Minnesota, SADE ALEXIS ROBINSON, did while intentionally aiding, advising, or conspiring with another or others, transfer, possess, or use an identity that is not the person's own, with the intent to commit, aid, or abet any unlawful activity, and the offense involves eight or more direct victims; or the aggregate total, combined loss to the direct and indirect victims is more than $35,000; or if the offense is related to possession or distribution of pornographic work in violation of Minn. Stat. section or Sade Alexis Robinson Page 1 CA

2 STATEMENT OF PROBABLE CAUSE Your Complainant is a licensed peace officer in the State of Minnesota. Acting in that capacity, I have reviewed the police reports and state that the following facts are true and establish probable cause. On March 25, 2015, an investigator with the Eagan Police Department received a call from a Savage Police Investigator indicating he was working on a case where an unknown black male had come into the Target in the City of Eagan, Dakota County, Minnesota, on February 27, 2015, and used a Savage victim s credit card number to purchase a gift card. The Savage victim still had their credit card in their possession. The investigator further advised that the same unknown male has been observed by Target loss prevention in their stores repeatedly. The Eagan investigator contacted Target loss prevention and learned that the same individual had been to the Eagan store on the following dates: 2/27/2015, 3/17/2015, 3/19/2015, 3/21/2015, and 3/23/2015, where he made a total of 21 fraudulent transactions. He uses what appear to be cloned credit cards to purchase $100 Vanilla and Green dot gift cards. With a $6 transaction fee per gift card, his total fraud on these dates came to $2,231.35, with an additional nine transactions totaling $ being declined. On 3/21/2015, the male arrived in what appeared to be a green 2002 or 2003 Kia Spectra 4 door sedan. On 3/21/2015, he was observed in a black 2000 to 2005 Mercedes S Class 4 door sedan. The officer also learned from Target that there is a black female associated with the male that had been to the Eagan Target on the following dates: 2/28/2015, 3/1/2015, and 3/19/2015, where she made 11 transactions using what is believed to be cloned credit cards to purchase $100 Vanilla and Green dot gift cards. With a $6 transaction fee per girt card, her total fraud totaled $1,166, with an additional four transactions totaling $424 being declined. On 3/19/2015, she arrives in what appears to be a green 2002 or 2003 Kia Spectra 4 door sedan. Using the unique manufacture identification number associated with the gift cards purchased, Sade Alexis Robinson Page 2 CA

3 Target was able to determine where the cards were redeemed. At this point, most of the cards had been redeemed in the greater Chicago area. Several of the cards were used to purchase Illinois state toll passes. On March 27, 2015, the investigator learned from Target loss prevention that the Bloomington Target had captured a license plate number of 706ATL on the suspect green Kia Spectra. The plate was registered to a female who was contacted by the investigator. She indicated that she sold the vehicle in August to an individual named Sade Austin, who resides in the City of Eagan. Further investigation determined that Sade Austin is actually Sade Alexis Robinson, date of birth: 12/3/1993. In comparing Robinson s driver s license photograph to surveillance, it appears as though Robinson is the female on surveillance. On April 29, 2015, an investigator installed an electronic tracking device onto Robinson s Kia Spectra pursuant to a court order. Since this date, the vehicle was tracked at multiple Target and Walmart stores in Eagan, Burnsville, Richfield, Bloomington, Savage, Inver Grove Heights, Saint Paul, West Saint Paul, Oakdale, Stillwater, Shakopee, Minneapolis, Apple Valley, Woodbury, and Oak Park Heights. Specifically, it was tracked to Target stores on 39 occasions and Walmart stores on 9 separate occasions. The investigator had Target and Walmart compile a list of the transactions and determined the credit card numbers used to make the purchases. The investigator determined that there were 25 different credit card numbers used, and they all appeared to have been issued by Wells Fargo. Wells Fargo was able to determine that all 25 card numbers were compromised in the Home Depot data breach. In combining these victims with the prior victims, there are 40 separate credit cards used by the two suspects between April 29, 2015, through May of In monitoring the tracking data on the vehicle, the investigator determined that the vehicle was at the Minneapolis Saint Paul Airport on May 24, 2015, for approximately one minute, and then it returned to Robinson s residence. The investigator sent a photograph of the suspect male to the Airport Police Department and indicated that he was likely flying to Chicago. In reviewing surveillance video, the Airport Police Department was able to observe the suspect male go to the Spirit Airlines area and Sade Alexis Robinson Page 3 CA

4 board a flight for Chicago. The airline provided several possible names to the detective, who as able to review Facebook pages of the various names given to him. The detective located Emile Anthony Rey, date of birth 8/6/1979, on Facebook and determined that he was the same individual dropped off at the airport from Robinson s green Kia. On June 10, 2015, the investigator tracked the vehicle to the Eagan Target. The investigator called Target and had them monitor surveillance for Robinson or Rey. Target reported that Rey attempted to purchase a gift card, but the credit card was declined. Rey then made an additional attempted to purchase a gift card, and was again unsuccessful. The investigator arrived on scene as Rey was leaving the store. Once he got into the passenger side of the vehicle, the investigator approached the vehicle and told the female driver, who was identified as Robinson, to turn the vehicle off. Rey and Robinson were placed under arrest. When Rey was searched, the investigator located 8 various credit cards in his pocket and wallet. Several were later determined to be cloned credit cards. In addition to the cloned credit cards, Rey had several gift cards on his person that also appeared to be fraudulent. Officers searched Robinson s purse and located 6 additional credit and gift cards. They were transported to the Dakota County Jail and read their Miranda rights. Robinson spoke to the investigator and admitted that she and Rey were using cloned credit cards to purchase gift cards. She gave an estimate of $10,000 worth of gift cards that she alone had purchased. According to Robinson, the cards that she purchases she typically spends on food and clothing. Rey keeps the cards he buys. Robinson said the cloned credit cards are typically grey in color with some writing on them. The investigator showed Robinson several grey cards that had been collected from her and Rey, and she confirmed that they were similar. Robinson identified herself and Rey in surveillance photos from Target of 14 different times when cloned credit cards were used. A search warrant was executed at Robinson s residence on June 10, Officers located a total of 66 cloned credit cards, and a multitude of Vanilla, Visa, and American Express gift cards. The investigator has made personal contact with at least 13 of the victims of identity theft and Sade Alexis Robinson Page 4 CA

5 confirmed that they did not give permission for their credit card information to be used by Robinson and Rey. Sade Alexis Robinson Page 5 CA

6 NOTICE: You must appear for every court hearing on this charge. A failure to appear for court on this charge is a criminal offense and may be punished as provided in Minn. Stat Complaint requests that Defendant, Sade Alexis Robinson, subject to bail or conditions of release, be: (1) arrested or that other lawful steps be taken to obtain Defendant s appearance in court; or (2) detained, if already in custody, pending further proceedings; and that said Defendant otherwise be dealt with according to law. COMPLAINANT S NAME: COMPLAINANT S SIGNATURE: Subscribed and sworn to before the undersigned this day of, NOTARY STAMP: SIGNATURE: Notary Public Being authorized to prosecute the offenses charged, I approve this complaint. Date: PROSECUTING ATTORNEY'S SIGNATURE: (jjh) Name: Tricia A. Loehr Assistant Dakota County Attorney Dakota County Judicial Center 1560 Highway 55 Hastings, MN (651) Attorney Registration No.: Sade Alexis Robinson Page 6 CA

7 FINDING OF PROBABLE CAUSE From the above sworn facts, and any supporting affidavits or supplemental sworn testimony, I, the Issuing Officer, have determined that probable cause exists to support, subject to bail or conditions of release where applicable, Defendant s arrest or other lawful steps be taken to obtain Defendant s appearance in court, or Defendant s detention, if already in custody, pending further proceedings. Defendant is therefore charged with the above-stated offense. [ ] SUMMONS THEREFORE YOU, THE ABOVE-NAMED DEFENDANT, ARE HEREBY SUMMONED to appear on, at before the above-named court at the Dakota County Judicial Center 1560 Highway 55, Hastings, MN to answer this complaint. IF YOU FAIL TO APPEAR in response to this SUMMONS, a WARRANT FOR YOUR ARREST shall be issued. [ ] WARRANT To the Sheriff of the above-named county; or other person authorized to execute this warrant: I hereby order, in the name of the State of Minnesota, that the above-named Defendant be apprehended and arrested without delay and brought promptly before the above-named court (if in session), and if not, before a Judge or Judicial Officer of such court without unnecessary delay, and in any event not later than 36 hours after the arrest or as soon as such Judge or Judicial Officer is available to be dealt with according to law. [ ] Execute in MN Only [ ] Execute Nationwide [ ] Execute in Border States [X] ORDER OF DETENTION Since the above-named Defendant is already in custody, I hereby order, subject to bail or conditions of release, that the above-named Defendant continue to be detained pending further proceedings. Bail: Conditions of Release: This complaint, duly subscribed and sworn to, is issued by the undersigned Judicial Officer this _12 day of June, JUDICIAL OFFICER: SIGNATURE: NAME: TITLE: Judge of District Court /s/ Judge Sworn testimony has been given before the Judicial Officer by the following witnesses: STATE OF MINNESOTA vs. SADE ALEXIS ROBINSON COUNTY OF DAKOTA STATE OF MINNESOTA Plaintiff, Defendant. Clerk s Signature or File Stamp: RETURN OF SERVICE I hereby Certify and Return that I have served a copy of this COMPLAINT upon the Defendant herein named. Signature of Authorized Service Agent: Sade Alexis Robinson Page 7 CA