Case 1:13-cr-00318-CMH Document 34 Filed 08/20/13 Page 1 of 5 PageID# 111

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division UNITED STATES OF AMERICA v. JENARO BLALOCK, et al., Defendants. ) ) ) ) ) ) )

Crim No. 1:13-CR-318 Hon. Claude M. Hilton

OPPOSITION TO DEFENDANTS MOTION FOR BOND On August 13, 2013, Magistrate Judge Buchanan held a hearing pursuant to 18 U.S.C. 3142(f) to determine whether defendant JENARO BLALOCK should be detained pending trial. BLALOCK is charged with leading an identity theft ring that compromised personal information of more than 600 individual victims in the Washington, D.C. area. BLALOCK and his co-conspirators use victims personally identifiable information to obtain fraudulent identity documents, open fraudulent lines of credit, and obtain cash and merchandise in victims names. The United States argued for detention based primarily on BLALOCKs status on pre-trial release from Prince Georges County, his lack of legitimate employment or a stable residence, and the fact that, during this investigation, agents recovered 19 fraudulent drivers licenses bearing BLALOCKs photograph and victims PII. The United States also noted that the employer BLALOCK disclosed to pretrial, New Life Management, was often listed by members of the conspiracy as their employer on fraudulent credit applications. After argument by both parties, Magistrate Judge Buchanan found that detention was proper under the factors enumerated in 18 U.S.C. 3142(g).

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Because the Defendants present request for this court to review Magistrate Judge Buchanans detention ruling is not based on any change in the Section 3142(g) factors, this Court should deny BLALOCKs motion. ARGUMENT BLALOCKs motion raises no new issues. Rather, BLALOCK restates his original arguments that (1) he has no prior felony convictions, and (2) the charged conduct does not involve physical violence. Neither factor warrants reversal of Magistrate Judge Buchanans detention ruling. Pursuant to 18 U.S.C. 3142(g), a court determining whether pre-trial detention is appropriate must weigh the following factors: (1) the nature and circumstances of the offense charged. . .; (2) the weight of the evidence against the person; (3) the history and characteristics of the person, including (A) the persons character, physical and mental condition, family ties, employment, financial resources, length of residence in the community, community ties, past conduct, history relating to drug or alcohol abuse, criminal history, and record concerning appearance at court proceedings; and (B) whether, at the time of the current offense or arrest, the person was on probation, on parole, or on other release pending trial, sentencing, appeal, or completion of sentence for an offense under Federal, State, or local law; and (4) the nature and seriousness of the danger to any person or the community that would be posed by the persons release . . . . 18 U.S.C. 3142(g). These factors favor detention today, just as they did on August 13. First, BLALOCK is charged with leading a ring that has victimized over 600 individuals, 2

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including many Department of State, Department of Defense, and U.S. AID employees stationed overseas. Second, the evidence against BLALOCK is strong. Two co-conspirators were recruited into the conspiracy by BLALOCK, and one specifically admitted turning over victims PII to BLALOCK. Some of this PII was later recovered through a search warrant executed at another co-conspirators residence, and much of this PII was used by yet other co-conspirators to obtain cash and merchandise from victim retailers and banks. Third, BLALOCK is currently on pre-trial release from Prince Georges County, charged with the theft of vehicles that appear to have been originally rented using victims PII. Fourth, BLALOCK has no legitimate employment, and no fixed address; instead, he appears to stay intermittently with various lady friends, and the government believes that BLALOCK supports himself through proceeds of the identity theft ring. Moreover, in contrast to his August 13 statement to pre-trial that he was employed by New Life Management (which, as noted above, appears on fraudulent credit applications as an employer), BLALOCK now claims to be employed as a subcontractor for Real Properties. And fifth, of particular concern to the government, in the course of this investigation the government recovered 19 fraudulent drivers licenses bearing BLALOCKs photograph and victims PII confirming that BLALOCK has both the intention and ability to operate under false identities, which presents both a risk of flight and a danger to the community.

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As such, the United States respectfully requests that the Court deny BLALOCKs Motion for Bond. Pursuant to Local Criminal Rule 47(J), the United States submits that this Motion is appropriate for disposition without an oral hearing.

Dated: August 20, 2013

Respectfully submitted, Neil H. MacBride United States Attorney

By:

/s/ Lindsay A. Kelly Lindsay A. Kelly Assistant United States Attorney Peter V. Roman Special Assistant United States Attorney (LT)

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CERTIFICATE OF SERVICE I hereby certify that on the 20th day of August 2013, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system, which will send a notification of filing (NEF) to: Bruce Johnson, Esq. Law Offices of Bruce A. Johnson, Jr., LLC 4301 Northview Drive Bowie, Maryland 20716 (301) 860-1505 (Telephone) (301) 860-1508 (Facsimile) bajjlaw@aol.com Counsel for Jenaro Blalock

/s/ Lindsay A. Kelly Lindsay A. Kelly Assistant United States Attorney Office of the United States Attorney 2100 Jamieson Avenue Alexandria, Virginia 22314 Tele: 703-299-3700 Fax: 703-299-3981 lindsay.a.kelly@usdoj.gov