Case 2:24-mj-06503-DUTY Document 1 Filed 10/24/24 Page 1 of 11 Page ID #:1

AO 91 (Rev. 11/11) Criminal Complaint (Rev. by USAO on 3/12/20) ‫ ܆‬Original ‫ ܆‬Duplicate Original

UNITED STATES DISTRICT COURT FILED

CLERK, U.S. DISTRICT COURT

for the
10/24/2024
Central District of California
CENTRAL DISTRICT OF CALIFORNIA
ts
BY: ___________________ DEPUTY
United States of America

v.

DURK BANKS,
Case No. 2:24-MJ-06503-DUTY
aka “Lil Durk,”
aka “Mustafa Abdul Malak,”

Defendant

CRIMINAL COMPLAINT BY TELEPHONE

OR OTHER RELIABLE ELECTRONIC MEANS
I, the complainant in this case, state that the following is true to the best of my knowledge and belief.

Beginning on an unknown date, but no later than on or about August 18, 2022, and continuing until at least

August 19, 2022, in the county of Los Angeles in the Central District of California, the defendant violated:

Code Section Offense Description

18 U.S.C. § 1958(a) Conspiracy to Use Interstate Facilities to
Commit Murder-For-Hire Resulting in
Death

This criminal complaint is based on these facts:

Please see attached affidavit.

_ Continued on the attached sheet.

/s/ Sarah Corcoran

Complainant’s signature

Sarah Corcoran, Special Agent, FBI

Printed name and title
Attested to by the applicant in accordance with the requirements
ts of Fed. R.. Cr
C
Crim.
im. P. 4.1 by telep
telephone.

Date: October 24, 2024

Judge’s signature

City and state: Los Angeles, California Hon. Stephanie S. Christensen, U.S. Magistrate Judge
Printed name and title
AUSA: Ian V. Yanniello/Daniel H. Weiner
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AFFIDAVIT

I, Sarah Corcoran, being duly sworn, declare and state as

follows:

I. PURPOSE OF AFFIDAVIT
1. This affidavit is made in support of a criminal complaint

and arrest warrant against DURK BANKS also known as (“aka”) “Lil

Durk,” aka “Mustafa Abdul Malak,” (“BANKS”) for a violation of 18

U.S.C. § 1958(a): Conspiracy to Use Interstate Facilities to Commit

Murder-For-Hire Resulting in Death.

2. The facts set forth in this affidavit are based upon my

personal observations, my training and experience, and information

obtained from various law enforcement personnel and witnesses. This

affidavit is intended to show merely that there is sufficient

probable cause for the requested complaint and warrant and does not

purport to set forth all of my knowledge of or investigation into

this matter. Unless specifically indicated otherwise, all

conversations and statements described in this affidavit are related

in substance and in part only.

II. BACKGROUND OF AFFIANT

3. I am a Special Agent with the FBI and have been so

employed since April 2010. I am assigned to the Violent Crimes

Squad in the Los Angeles Field Office and work a variety of crimes,

including murder for hire, kidnappings, hostage taking, robberies,

extortions, aggravated threats, assaults on federal officers,

firearms violations, and felonies at federal facilities. Upon

joining the FBI, I attended and graduated from the FBI Basic Special
Agent Training Course in Quantico, Virginia where I received

training in a variety of investigative and legal matters, including

Case 2:24-mj-06503-DUTY Document 1 Filed 10/24/24 Page 3 of 11 Page ID #:3

the topics of Fourth Amendment searches, the drafting of search

warrant affidavits, and probable cause. In my current role, I am

assigned to a violent crime criminal squad where I have experience

conducting and assisting with multiple violent crime investigations

as described above. I have formal training in case management,

interviewing and interrogation, crisis management, crime scene

analysis, cellular telephone analysis, evidence collection, social

media exploitation, and handling confidential sources.

III. SUMMARY OF PROBABLE CAUSE

4. BANKS is the leader of the Chicago-based rap collective

known as Only the Family, or “OTF.” In addition to OTF’s status as

a rap collective, I know based on the investigation that OTF also

acts as an association-in-fact of individuals who engage in

violence, including murder and assault, at the direction of BANKS

and to maintain their status in OTF. For example, based on evidence

collected during the investigation, including the interview of

witnesses,1 I know that BANKS put a monetary bounty out for an

individual with whom BANKS was feuding named T.B.

5. As detailed below, on August 19, 2022, multiple OTF

members and associates used two vehicles and worked in tandem to

track, stalk, and attempt to murder T.B. at a gas station located in

Los Angeles, California. The co-conspirators fired at least 18

1Due to serious safety concerns, this affidavit does not

provide the identity of these witnesses. Based on the FBI’s
investigation, I know that witnesses and/or their family members
have already received threats and/or have been contacted in what
appear to be attempts to influence their participation in this
investigation.
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rounds at T.B.’s vehicle, striking and killing S.R. --- T.B.’s

family member who was traveling with T.B.

6. On October 17, 2024, a Grand Jury sitting in the Central

District of California returned an indictment charging five

co-conspirators --- Kavon London GRANT, Deandre Dontrell WILSON,

Keith JONES, David Brian LINDSEY, and Asa HOUSTON --- with crimes

arising from the murder, including Murder-for-Hire and Conspiracy to

Commit Murder-for-Hire Resulting in Death, in violation of 18 U.S.C.

§ 1958(a). See United States v. Kavon London Grant, et al., Case

No. 2:24-621-MRA. BANKS is identified as Co-Conspirator 1 in the

indictment, which is incorporated herein by reference.

7. Based on the investigation, and as described below,

evidence shows that BANKS ordered T.B.’s murder and that the hitmen

used BANKS and OTF-related finances to carry out the murder. For

example, bank and flight records show that an OTF member and close

associate of BANKS (“Co-Conspirator 3”) coordinated and paid for

JONES, LINDSEY, WILSON, HOUSTON, and another OTF member

(“Co-Conspirator 2”) to travel from Chicago to California on the day

before the murder (August 18, 2022). Co-Conspirator 3 paid for the

flights using a credit card linked to BANKS and OTF. Around the

time that Co-Conspirator 3 purchased the co-conspirators’ flights to

California, iCloud records show that a phone number associated with

BANKS texted Co-Conspirator 3: “Don’t book no flights under no names

involved wit [sic] me.”

8. Additionally, on the same day that the hitmen traveled to

California from Chicago, BANKS also traveled to California with

another charged co-conspirator (GRANT) on a private jet. Later that

day, GRANT purchased ski masks for the shooters to use to commit the
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murder, and paid for the other co-conspirators’ hotel room using a

credit card in BANKS’ name.

9. Earlier this morning (October 24, 2024), federal and local

law enforcement executed multiple search warrants at locations

associated with OTF members in and around the Chicago area, and

arrested GRANT, WILSON, JONES, LINDSEY, and HOUSTON. After

executing the warrants, the FBI learned that BANKS had been booked

on at least three international flights scheduled to leave the

United States today. When BANKS arrived near one of the departing

airports, he was arrested by law enforcement personnel.

IV. STATEMENT OF PROBABLE CAUSE

10. Based on my training and experience, my personal

involvement in this investigation, conversations with other law

enforcement officers, witness statements, and review of reports and

other documents prepared by law enforcement officers, I am aware of

the following:

A. Chicago-Based Hitmen Travel to Los Angeles to Murder a

Rival of BANKS
11. On October 17, 2024, a Grand Jury returned an indictment
charging GRANT, WILSON, JONES, LINDSEY, and HOUSTON with

Murder-for-Hire and Conspiracy to Commit Murder-for-Hire Resulting

in the Death of S.R., in violation of 18 U.S.C. § 1958(a); and

Discharge of Firearms and Machinegun in Furtherance of a Crime of

Violence Resulting in Death in violation of 18 U.S.C.

§§ 924(c)(1)(A)(iii), (c)(1)(B)(ii), (j)(1). The Grand Jury also

charged JONES with possession of a machinegun in violation of 18

U.S.C. § 922(o).

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12. As alleged in the indictment, on August 19, 2022, S.R. and

others, including S.R.’s family member, T.B. --- a rap artist known

as “Q.R.” --- were near their vehicle at a gas station across from

the Beverly Center in Los Angeles when three gunmen opened fire on

the vehicle, killing S.R. Law enforcement personnel subsequently

recovered 18 shell casings from the murder scene.

13. At the time of the murder, T.B. had a public feud with

BANKS, aka “Lil Durk.” BANKS is a Chicago-based gang member and

leader of the rap collective known as Only the Family, or “OTF”.2

The feud stemmed from a November 6, 2020 murder, where an associate

of T.B. shot and killed an OTF rapper named Dayvon Bennett aka “King

Von.” Bennett was a member of OTF and BANKS’ close friend.

14. According to open-source reporting and witnesses, BANKS

placed a monetary bounty on T.B.’s life.3

15. Based on the investigation to date, including open-source

research, my training and experience investigating gangs and violent

crime, and witness statements, OTF is a hybrid organization that

functions as a BANKS-led music collective and a gang. Based on the

2 Based on open-source research, I know that BANKS has attempted

to publicly distance himself from suspected gang and/or criminal
activity. See, e.g., “Lil Durk Launches the Durk Banks Scholarship
Fund at Howard University with Amazon Music”, available at
https://www.billboard.com/music/rb-hip-hop/lil-durk-banks-endowment-
fund-howard-university-1235302817/ (Apr. 14, 2023); “Rapper Lil Durk
Turned to Therapy to Cope With Tragedies”, available at
https://www.latimes.com/entertainment-arts/music/story/2023-05-
29/lil-durk-therapy-almost-healed-all-my-life-morgan-wallen-j-cole
(May 29, 2023); “Lil Durk Says He ‘Ain’t a Felon Anymore’ After
Criminal Record is Cleared: ‘Everyone Should Get Second Chances’”,
available at https://www.complex.com/music/a/tracewilliamcowen/lil-
durk-criminal-record-cleared (Sept. 23, 2024).
3 As described above in footnote 1, due to significant concerns
about witness safety, this affidavit does not provide the identity
of these witnesses.
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investigation to date, including conversations with other law

enforcement agents and witness statements, HOUSTON and WILSON are

associated with OTF, and LINDSEY and JONES are associated with other

gangs in Chicago.
B. The Hitmen Travel Using Funds Linked to BANKS
16. I know the following based on my review of LAPD police

reports, surveillance footage, bank and flight records, witness

statements, and homicide detectives from the LAPD and federal

investigators involved in this case:

a. On August 18, 2022 --- the day before S.R.’s murder -

-- OTF members learned of the location of T.B. from a long-time OTF

affiliate, Co-Conspirator 4. After OTF members learned this, the

following men took a one-way flight from Chicago to San Diego:

JONES, LINDSEY, WILSON, HOUSTON, and Co-Conspirator 2.

b. The one-way tickets to San Diego were purchased using

an American Express credit card ending in -2039 and in the name of

Co-Conspirator 3, who is also associated with OTF and BANKS. Based

on records from Apple, I know that on that same day, a number ending

in -9595 believed to be associated with BANKS4 sent a text message to

Co-Conspirator 3, stating: “Don’t book no flights under no names

involved wit [sic] me.”

c. Based on my review of hotel records, I know that

GRANT rented and paid for a room at the Sheraton Universal Hotel in

4Facts associating this number with BANKS include

Co-Conspirator 3 and GRANT saving this number with contact names
associated with BANKS, and BANKS self-identifying using this number
in a February 2022 text message to an individual in Florida
unrelated to this investigation.
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Universal City, California on August 18, 2022 using an American

Express card in BANKS’ name ending in -1015. JONES, LINDSEY,

WILSON, HOUSTON, and Co-Conspirator 2 stayed at the hotel the night

before the co-conspirators tracked, stalked, and attempted to kill

T.B.

d. Based on my review of bank records, I know the -2039

and -1015 credit cards were issued under an account belonging to

O.A. and “Astronaut Soundz LLC.” Based on public information, I

know that O.A. was BANKS’ manager in or around 2022. Georgia

Secretary of State online corporation records show that Astronaut

Soundz LLC was initially registered by O.A. in 2017. A request of

amendment was filed in 2021 and a new manager, BANKS, was added to

the business. The bank records also showed that the Astronaut

Soundz’s American Express account had four credit cards issued to

four individuals: BANKS, Co-Conspirator 3, BANKS’ father D.B., and

O.A.

e. Based on my review of records from a private airplane

company, I know that BANKS and GRANT flew on the same airplane from

Los Angeles to Miami on August 16, 2022, and back to Los Angeles on

August 18, 2022 --- the day before S.R.’s murder. Records from a

rental property show that BANKS’ manager, O.A., rented a house in

Encino, California from July 1, 2022 to October 1, 2022. Based on

investigators review of photographs of the interior of the Encino

rental, I know that video footage from an August 18, 2022 podcast

shows the host of the podcast with BANKS, wherein BANKS appears to

be inside the Encino house.

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f. On the day of the murder (August 19, 2022),

surveillance video shows T.B., S.R., and others leave their hotel in

Los Angeles and enter a black Cadillac Escalade (the “ESCALADE”).

Surveillance video taken from numerous locations throughout Los

Angeles, including T.B.’s hotel and the gas station where the murder

occurred, show that two vehicles followed the ESCALADE for hours

leading up to the shooting.

g. One vehicle was a white BMW (“Murder Vehicle 1”)5, and

the other was a white Infiniti (“Murder Vehicle 2”). Among other

things, surveillance video from the murder scene shows Murder

Vehicle 2 park in an alley behind the gas station, where three

shooters wearing black masks exit the vehicle (later identified as

JONES, LINDSEY, and Co-Conspirator 2), walk to the gas station, and

then open fire on the ESCALADE. The shooters then ran back to the

Murder Vehicle 2 and drove away. Murder Vehicle 1 drove away from

the area just minutes before the shooting.

h. Approximately 50 minutes after the shooting,

surveillance video from an In-N-Out restaurant in Los Angeles shows

GRANT, JONES, and WILSON arrive in Murder Vehicle 1. The video also

shows LINDSEY and Co-Conspirator 2 arrive at the In-N-Out in a black

SUV. Based on a comparison of surveillance video showing the murder

to video from the In-N-Out restaurant, law enforcement identified

Based on the investigation, GRANT was the primary driver of

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Murder Vehicle 1. As discussed above, in addition to driving the
vehicle, GRANT took steps to help facilitate the murder, including
booking the hotel room for the hitmen. Additionally, GPS data
associated with Murder Vehicle 1 shows that the vehicle was parked
outside of a sporting goods store at the approximate time that four
black ski masks matching the appearance of those used by the
shooters were purchased.
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that LINDSEY, JONES, and Co-Conspirator 2 were the individuals who

opened fire and killed S.R.

i. A few hours after the shooting, JONES, LINDSEY,

WILSON, HOUSTON, and Co-Conspirator 2 boarded a flight from San

Diego to Chicago. Once again, the credit card in the name of

Co-Conspirator 3 was used to pay for the one-way tickets.

C. BANKS Books Multiple International Flights After Law

Enforcement Arrested Multiple Co-Conspirators and Executed
Search Warrants at Locations Associated with OTF Members
17. I know the following based on my conversations with other

law enforcement agents involved in the investigation and my personal

involvement in the investigation:

a. In the early hours of October 24, 2024, law

enforcement arrested GRANT, JONES, LINDSEY, WILSON, and HOUSTON, and

executed multiple search warrants in the Chicago area, including a

warrant to search the home of Co-Conspirator 3.

b. Shortly after making these arrests and executing the

search warrants on October 24, the FBI received notifications from

U.S. Customs and Border Protection (“CBP”) showing that BANKS had

been booked as a passenger on two international flights: (i) a

one-way flight from Miami to Dubai, United Arab Emirates (“UAE”),6

connecting through Doha, Qatar, scheduled to depart the evening of

October 24; and (ii) a one-way flight from Fort Lauderdale to

Switzerland, connecting via New Jersey, also scheduled to depart the

evening of October 24. BANKS did not board either flight.7 At

6 Based on open-source research, I believe that the UAE does not

have a bilateral extradition treaty with the United States.
7 “Extradition To and From the United States: Overview of the
Law and Contemporary Treaties”, Congressional Research Service,
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approximately 6:40 p.m. ET, the FBI received an additional CBP

notification that BANKS had been booked as a passenger on a private

plane departing Miami and destined for Italy, scheduled to depart at

approximately 9:00 p.m. ET.

c. At approximately 8:00 p.m. ET, BANKS was arrested by

law enforcement in the vicinity of the departing airport.

V. CONCLUSION
18. For all of the reasons described above, there is probable

cause to believe that BANKS violated 18 U.S.C. § 1958(a): Conspiracy

to Use Interstate Facilities to Commit Murder-For-Hire Resulting in

Death.

Attested to by the applicant in

accordance with the requirements
of Fed. R. Crim. P. 4.1 by
telephone
ne on this 24th day of
October, 2024.

HON. STEPHANIE
EPHANIE S.
S CHRISTENSEN
UNITED STATES MAGISTRATE JUDGE

available at https://www.everycrsreport.com/files/20161004_98-
958_53c6c09c590214876fb5959c6fdb0d78942b5cc6.pdf.
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