UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

DEL RIO DIVISION

UNITED STATES OF AMERICA,

Petitioner,

V. CIVIL NO. DR-20-CV-36-

$1,531,924.54 IN UNITED STATES

CURRENCY SEIZED FROM

JPMORGAN CHASE BANK ACCOUNT

405685541 IN THE NAME OF

D L INVESTMENTS,

Respondent.

VERIFIED COMPLAINT FOR FORFEITURE

Comes now Petitioner United States of America, by and through the United States Attorney 

for the Western District of Texas and the undersigned Assistant United States Attorney, pursuant 

to Rule G, Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions, 

Fed. R. Civ. P., and respectfully states as follows:

I.

NATURE OF THIS ACTION

This action is brought by the United States of America seeking forfeiture to the United 

States of the following property:

$1,531,924.54 in United States Currency Seized from JPMorgan Chase Bank Account 

405685541 in the Name of D L Investments,

hereinafter the ARespondent Property.@

II.

JURISDICTION AND VENUE

Under Title 28 U.S.C. § 1345, this Court has jurisdiction over an action commenced by the 

United States, and under Title 28 U.S.C. § 1355(a), jurisdiction over an action for forfeiture. This 

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Case 2:20-cv-00036-AM Document 1 Filed 05/12/20 Page 1 of 4
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Court has in rem jurisdiction over the Respondent Property under Title 28 U.S.C. §§1355(b) and 

1395. Venue is proper in this district pursuant to Title 28 U.S.C. § 1355(b)(1) because the acts 

or omissions giving rise to the forfeiture occurred in this district, and pursuant to Title 28 U.S.C. 

§§ 1355(b)(1)(B) and 1395(b) because the Respondent Property is found in this district.

III.

STATURY BASIS FOR FORFEITURE

This is a civil forfeiture action in rem brought against the Respondent Property for violation

of Title 18 U.S.C. § 1343 and subject to forfeiture to the United States of America pursuant to 

Title 18 U.S.C. § 981(a)(1)(C), which states (with emphasis added):

§ 981. Civil forfeiture

(a)(1) The following property is subject to forfeiture to the United States:

***

(C) Any property, real or personal, which constitutes or is derived from 

proceeds traceable to . . . any offense constituting “specified unlawful activity” 

(as defined in section 1956(c)(7) of this title . . . .

↓

§ 1956. Laundering of monetary instruments

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(c) As used in this section―

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(7) the term “specified unlawful activity” means―

(A) any act or activity constituting an offense listed in section 1961(1) of this 

title . . . .

↓

§ 1961. Definitions

As used in this chapter―

(1) “racketeering activity” means . . . (B) any act which is indictable under any 

of the following provisions of title 18, United States Code: . . . section 1343 

(relating to wire fraud) . . . .

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IV.

FACTS IN SUPPORT OF VIOLATIONS 

See Appendix A for facts under seal.

V.

PRAYER

WHEREFORE, Petitioner, United States of America, prays that due process issue to 

enforce the forfeiture of the Respondent Property, that due notice pursuant to Rule G(4) be given 

to all interested parties to appear and show cause why forfeiture should not be decreed,1 and in 

accordance with Rule G of the Supplemental Rules for Admiralty or Maritime Claims and Asset 

Forfeiture Actions, Fed. R. Civ. P., that the Respondent Property be forfeited to the United States 

of America, that the Property be disposed of in accordance with the law and for any such further 

relief as this Honorable Court deems just and proper.

Respectfully submitted,

JOHN F. BASH

United States Attorney

By: 

Antonio Franco, Jr.

Assistant United States Attorney

Asset Forfeiture Section

601 NW Loop 410, suite 600

San Antonio, TX 78216

Tel: 210-384-7040 

Fax: 210-384-7045 

Email: antonio.franco@usdoj.gov

Texas Bar No. 00784077

 Attorneys for the United States of America

 

1 Appendix B, which is being filed along with this complaint, will be sent to those known to the 

United States to have an interest in the Respondent Property. 

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VERIFICATION

Special Agent Marc Epstein, declares and says that:

1. I am a Special Agent with the Federal Bureau of Investigation, assigned to the San

Antonio Division, Del Rio Resident Agency, and I am the investigator responsible for the accuracy

of the information provided in this litigation.

2. I have read the above Verified Complaint for Forfeiture and know: the contents

thereof; the information contained in the Verified Complaint for Forfeiture has been furnished by

official government sources; and the allegations contained in the Verified Complaint for Forfeiture

are true based on information and belief.

Pursuant to Title 28 U.S.C. 1746, I declare under penalty of perjury that the foregoing is

true and correct.

Executed on this the day of __ ....:...t1_~",1-'/--__ ,2020.

Marc Eps In, Special Agent

Federal Bureau of Investigation

San Antonio Division

Del Rio Resident Agency

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