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IN THE UNITED STATES DISTRICT COURT 

FOR THE NOTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

UNITED STATES OF AMERICA,

Plaintiff, 

vs. 

$34,200 in U.S. Currency, 

Defendant in Rem. 

No. 3:22-CVVERIFIED COMPLAINT FOR FORFEITURE IN REM 

Pursuant to Supplemental Rule G(2) of the Federal Rules of Civil Procedure, the 

United States of America alleges this in rem complaint for forfeiture against $34,200 in 

U.S. currency (“Defendant Property”): 

NATURE OF THE ACTION 

1. This is a forfeiture action under 21 U.S.C. § 881(a)(6) and 18 U.S.C. §

981(a)(1)(C). The United States seeks the forfeiture of the Defendant Property, because it 

is moneys furnished by any person in exchange for a controlled substance, proceeds 

traceable to such an exchange, and/or property intended to facilitate such an exchange in 

violation of 21 U.S.C. §§ 841(a) and/or 846. The Defendant Property is also subject to 

forfeiture under 18 U.S.C. § 981(a)(1)(C), because it was property which constitutes or is 

derived from proceeds traceable to a violation of 18 U.S.C. § 1952, a specified unlawful 

activity as defined in 18 U.S.C. §§ 1957(c)(7) and 1961(1). 

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JURISDICTION AND VENUE 

2. This Court has subject matter jurisdiction over this matter under 28 U.S.C. 

§§ 1345 and 1355(a), and in rem jurisdiction is proper under 28 U.S.C. § 1355(b). 

3. Venue in this Court is proper under 28 U.S.C. §§ 1355(b)(1)(A) and 1391(b), 

because acts or omissions giving rise to the forfeiture occurred in the Northern District of 

Texas and a substantial part of the events giving rise to the forfeiture occurred in the 

Northern District of Texas. 

PARTIES

4. The Plaintiff is the United States of America. 

5. The Defendant Property is $34,200 in U.S. currency. The Defendant 

Property was seized from Darrel Leon Rose at DFW Airport, Texas, on November 16, 

2021. On November 18, 2021, it was deposited into a Loomis bank account in Dallas, 

Texas. 

6. Darrel Leon Rose (“Rose”), a resident of Jacksonville, Florida, claimed the 

Defendant Property on January 2, 2022. 

FACTS 

7. The factual basis for the forfeiture in this case involves an investigation by 

the DEA Dallas Airport Interdiction Group (“DEA Task Force”) at DFW Airport 

(“DFW”). One of the DEA Task Force’s responsibilities at DFW is to investigate the use 

of the airport and the airlines that service the airport to perpetrate or facilitate the illegal 

transportation of proceeds obtained from criminal conduct including drug trafficking. 

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8. Those trafficking in illegal narcotics must often find a way to transport the 

proceeds of their criminal conduct without drawing the attention of law enforcement. Air 

travel is one mode used by the traffickers or couriers working for or with them to 

transport such proceeds. The use of air travel allows drug traffickers to keep their illgotten gains “off the books” and outside the banking system, which they know is 

regularly monitored by banking and governmental authorities.

9. Investigators with the DEA Task Force are specially trained and learn by 

experience how to identify those who are using the federal aviation system to facilitate 

narcotic trafficking.

10. On November 16, 2021, DEA Task Force members including Special 

Agents Sean Kassouf and Andrew Woeppel and Task Force Officers (“TFO”) Michael

McBride and Mark Adams received credible information regarding the suspicious travel 

of Darrel Leon Rose traveling on a one-way trip on American Airlines flight 2543 flying 

from DFW to Los Angeles, California. 

11. TFO McBride conducted a record check and discovered that Rose had two 

checked bags. TFO McBride located the checked bags prior to them being transferred 

onto the plane. He noted a strong odor of marijuana coming from both bags. 

12. SAs Kassouf and Woeppel approached Rose and verbally identified 

themselves with their names and badges. As Rose stood up from his seat, he said “Oh 

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shit.” Rose asked if he was under arrest and SA Woeppel said that he was not. SA 

Woeppel then asked if he could speak to Rose about his travels, and he agreed. 

13. During their conversation, SA Woeppel observed that Rose would not 

make eye contact, his speech was shaky, and he paced back and forth. In SA Woeppel’s

experience and based on his training, such unusual nervousness is potentially a sign that a 

person may be hiding something.

14. Rose confirmed he was flying from DFW to Lose Angeles on American 

Airlines flight 2543. SA Woeppel asked Rose where he was stayed while in Los Angeles 

and Rose stated he was planning on staying “a couple of days” at a hotel, but could not 

provide the name of the hotel. SA Woeppel asked what the purpose of his travel was, and 

Rose stated that he was “cheating on his wife” and that he’d be “visiting a girlfriend.” 

Rose stated he lives in Dallas and travels to Los Angeles every two weeks. 

15. SA Woeppel and SA Kassouf observed that Rose was traveling with a 

roller bag and brown purse. SA Woeppel asked Rose if the bags that Rose was carrying 

belonged to him and Rose stated that they did. Rose said he packed everything in the 

bags and everything in the bags. Rose also denied possessing weapons, drugs, or a large 

amount of U.S. or foreign currency. 

16. During his conversation with Rose, SA Woeppel did not obstruct the path 

of Rose and he was free at any time to walk away from the conversation.

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17. TFO McBride transported Rose’s checked bags to the terminal area. SA 

Woeppel asked Rose for consent to search his checked luggage and his carry-on bags and 

Rose said yes as witnessed by SA Kassouf. 

18. SA Kassouf, and TFOs McBride and Adams began searching Rose’s bags 

and found seven large rubber banded bundles of U.S. currency between Rose’s two 

checked bags. They found another eight rubber banded bundles of currency concealed 

among the contents of Rose’s carry-on bags. 

19. SA Woeppel asked Rose how much money he possessed and Rose stated he 

had “about twenty grand.” Rose stated all the currency belonged to him. 

20. SA Woeppel and SA Kassouf advised that they could smell the odor of 

marijuana coming from Rose’s bags and their contents. In his experience SA Kassouf is 

aware that individuals will often hide currency in different locations in order to avoid 

detection from TSA Screening equipment or law enforcement. 

21. SA Woeppel asked Rose why he was traveling with so much money and he 

replied he was “going to do some Christmas shopping” in Los Angeles. SA Woeppel 

asked Rose what kind of business he does, and Rose paused, then answered he is in the 

“hauling” business. Rose could not answer follow-up questions about the fleet size, cab 

models, or type of hauling units or trailers in his business. SA Woeppel asked Rose what 

financial institutions he banked with and if he had any records showing the withdrawal of 

a large amount of cash. Rose replied that he banks at Wells Fargo and Chase and that he 

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withdrew money “from time to time” but he could not provide SA Woeppel with any 

online records from his cell phone. 

22. SA Woeppel asked Rose to empty out the contents of his pockets and Rose 

complied. SA Kassouf observed that Rose removed an Apple iPhone from his pocket and 

placed it on the ground in front of SA Woeppel and SA Kassouf. SA Kassouf asked Rose 

if he had any photographs or text messages about the use, possession, sale or purchase of 

narcotics on his cellular phone. Rose did not answer. SA Kassouf asked for consent to 

search his phone, which Rose did not grant. 

23. SA Kassouf informed Rose that the currency and his cell phone would be 

seized. 

24. The money seized from Rose totaled $34,200. In SA Kassouf’s 

experience, possession of such a large amount of currency is not typical of legitimate 

airport travelers.

25. A criminal background check revealed that Rose has an extensive criminal 

history that includes narcotics violations. 

26. Additionally, officers looked for records supporting legitimate employment 

via the Texas Workforce Commission database and found no evidence of employment 

that would support Rose’s possession of such a large amount of currency at the time it 

was seized. 

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FIRST CAUSE OF ACTION 

21 U.S.C. § 881(a)(6) 

(forfeiture of property related to drug trafficking) 

1. The United States reasserts all allegations previously made. 

2. Under 21 U.S.C. § 881(a)(6), “moneys, negotiable instruments, securities, 

or other things of value furnished or intended to be furnished by any person in exchange 

for a controlled substance or listed chemical in violation of this subchapter, all proceeds 

traceable to such an exchange, and all moneys, negotiable instruments, and securities 

used or intended to be used to facilitate any violation of” 21 U.S.C. § 801 et seq. are 

subject to forfeiture. 

3. Under 21 U.S.C. § 841(a), it is “unlawful for any person knowingly or 

intentionally . . . to manufacture, distribute, or dispense, or possess with intent to 

manufacture, distribute, or dispense, a controlled substance.” An attempt or conspiracy 

to do the same is also prohibited by 21 U.S.C. § 846. 

4. As set forth above, the Defendant Property is moneys furnished by any 

person in exchange for a controlled substance, proceeds traceable to such an exchange, 

and/or property intended to facilitate such an exchange in violation of 21 U.S.C. §§ 

841(a) and/or 846. This property is therefore subject to forfeiture pursuant to 21 U.S.C. 

§ 881(a)(6). 

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SECOND CAUSE OF ACTION 

18 U.S.C. § 981(a)(1)(C) 

(forfeiture related to violation of the Travel Act) 

5. The United States reasserts all allegations previously made. 

6. Under 18 U.S.C. § 981(a)(l)(C), any property which constitutes or is 

derived from proceeds traceable to an offense constituting a “specified unlawful 

activity,” or a conspiracy to commit such offense, is subject to forfeiture to the United 

States. 

7. Under 18 U.S.C. §§ 1956(c)(7)(A) and 1961(1), interstate travel or 

transportation in aid of racketeering enterprises in violation of 18 U.S.C. § 1952 is a 

specified unlawful activity. 

8. 18 U.S.C. § 1952(a) prohibits, inter alia, any individual who uses “any 

facility in interstate or foreign commerce,”: 

with the intent to – 

 

(1) distribute the proceeds of any unlawful activity; or [ ] 

(3) otherwise promote, manage, establish, carry on, or facilitate the 

promotion, management, establishment, or carrying on, of any unlawful 

activity” 

 

from thereafter performing or attempting to perform the conduct described in 

subparagraphs (1) and (3) above. 

9. 18 U.S.C. § 1952(b) specifically includes within the definition of “unlawful 

activity” “any business enterprise involving . . . narcotics or controlled substances (as 

defined in section 102(6) of the Controlled Substances Act).” 

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10. As set forth above, the Defendant Property is property which constitutes or 

is derived from proceeds traceable to a violation of 18 U.S.C. § 1952. This property is 

therefore subject to forfeiture pursuant to 18 U.S.C. § 981(a)(l)(C). 

REQUEST FOR RELIEF 

WHEREFORE, the United States respectfully asserts that the Defendant Property 

is forfeitable to the United States under 21 U.S.C. § 881(a)(6) and 18 U.S.C. § 

981(a)(1)(C). 

 The United States further requests: 

A. That, pursuant to the Supplemental Rules for Admiralty or Maritime 

Claims and Asset Forfeiture Actions, Rule G(3)(b)(ii), the Clerk of the 

Court issue a Summons and Warrant of Arrest in Rem as to the 

Defendant Property.

B. That Notice of this action be given to all persons known or thought to 

have an interest in or right against the Defendant Property; 

C. That a Judgment of Forfeiture be decreed against the Defendant 

Property; 

D. That upon the issuance of a Judgment of Forfeiture, the United States 

Marshals Service or its delegate be able to dispose of the Defendant 

Property according to law; and 

E. That the United States receives its costs of court and all further relief to 

which it is entitled. 

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DATED this 3rd day of May, 2022. 

CHAD E. MEACHAM 

UNITED STATES ATTORNEY 

/s/ Elyse J. Lyons 

Elyse J. Lyons 

Assistant United States Attorney

Texas Bar No. 24092735 

1100 Commerce Street, Third Floor 

Dallas, Texas 75242-1699 

Telephone: 214-659-8774 

Facsimile: 214-659-8805 

Elyse.lyons@usdoj.gov 

ATTORNEY FOR PLAINTIFF

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