IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF OHIO

WESTERN DIVISION

UNITED STATES OF AMERICA, : Case No. 3:18-CV-024

:

Plaintiff, :

: JUDGE

v. :

:

TWENTY-ONE THOUSAND ONE : VERIFIED COMPLAINT FOR

HUNDRED DOLLARS IN UNITED : FORFEITURE IN REM

STATES CURRENCY ($21,100.00), :

:

Defendant. :

:

____________________________________

Plaintiff, United States of America, by its undersigned counsel, alleges the following for 

its action against the defendant in accordance with Supplemental Rule G(2) of the Federal Rules 

of Civil Procedure.

NATURE OF THE ACTION

1. This is a civil action in rem brought to enforce 21 U.S.C. § 881(a)(6), which 

provides for the forfeiture to the United States of:

All 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 this subchapter.

THE DEFENDANT IN REM

2. The defendant is Twenty-One Thousand One Hundred Dollars in United States 

Currency ($21,100.00) (“defendant currency”). On or about August 11, 2017, the Drug 

Enforcement Administration seized the defendant currency from a residence, located at 5588 

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Savina Avenue, Dayton, Ohio, during the execution of a federal search warrant. The United 

States subsequently deposited the funds into the Seized Asset Deposit Fund, where they will 

remain during the pendency of this action.

JURISDICTION AND VENUE

3. Plaintiff brings this action in rem in its own right to forfeit and condemn the 

defendant currency pursuant to 21 U.S.C. § 881(a)(6). This Court has jurisdiction over an action 

commenced by the United States under 28 U.S.C. § 1345 and over an action for forfeiture under 

28 U.S.C. § 1355(a).

4. This Court has in rem jurisdiction over the defendant currency pursuant to 28 

U.S.C. § 1355(b)(1)(A) because acts and omissions giving rise to the forfeiture occurred in the 

Southern District of Ohio.

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

and omissions giving rise to the forfeiture occurred in the Southern District of Ohio and pursuant 

to 28 U.S.C. § 1395 because the defendant currency was found in the Southern District of Ohio.

BASIS FOR FORFEITURE

6. The defendant currency is subject to forfeiture pursuant to 21 U.S.C. § 881(a)(6)

because the defendant currency represents property furnished or intended to be furnished by any 

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

or was used or intended to be used to facilitate any violation of 21 U.S.C. § 841 or a conspiracy to 

commit such offense in violation of 21 U.S.C. § 846.

FACTS

7. The Drug Enforcement Administration (“DEA”) and other law enforcement 

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agencies are investigating the fentanyl distribution activities of individuals in the Dayton, Ohio 

area and elsewhere. Federal agents identified Corey Gay (“Gay”) as a local drug trafficker who 

distributes kilogram quantities of fentanyl.

8. During late spring and early summer 2017, a confidential source (“CS#1”) agreed 

to provide information to law enforcement in an effort to gain early release from state parole. 

According to CS#1, Gay lived with Rashida Bennett (“Bennett”) in a house in Englewood, Ohio. 

Based on CS#1’s description, agents determined that CS#1 was referencing 5588 Savina Avenue, 

Dayton, Ohio. CS#1 further indicated that Gay had a residence at 665 Mia Avenue, Dayton, 

Ohio, but he did not reside there. CS#1 advised that Gay used drug proceeds to purchase multiple 

cars.

9. The investigation confirmed that Gay lived at 5588 Savina Avenue, Dayton, Ohio, 

with Bennett and that they previously were married. Bennett was charged and convicted in the 

same federal drug cases as Gay (Case Nos. 3:04-CR-031, 3:04-CR-129), and she was known to 

associate with another drug trafficker and profit from her association with that individual. 

10. DEA Special Agent Steven Lucas (“SA Lucas”) learned that Gay falsely told his 

federal probation officer that he resided at 665 Mia Avenue. 

11. During August 2017, SA Lucas interviewed a second confidential source (“CS#2”). 

CS#2 has provided information in the past, which law enforcement has independently 

corroborated, in exchange for monetary payments. CS#2 advised that he/she has known Gay and 

Bennett for several years. Based on conversations that CS#2 had with an associate of Gay, CS#2 

indicated that Gay was selling fentanyl and cocaine. CS#2 believed that Gay lived with Bennett 

at a house in Englewood, Ohio. 

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12. During August 2017, SA Lucas interviewed a third confidential source (“CS#3”). 

CS#3 has provided information in the past which law enforcement has independently corroborated. 

A federal grand jury has returned an indictment against CS#3; therefore, he/she has provided 

information to law enforcement in an effort to reduce CS#3’s sentence. CS#3 acknowledged 

knowing Gay and Bennett and advised that they lived together. Based on information of an 

associate of Gay, CS#3 believed that Gay was receiving kilogram quantities of fentanyl from 

relatives in Arizona.

13. On or about August 10, 2017, a fourth confidential source (“CS#4”) indicated that 

Gay was selling fentanyl, cocaine, and methamphetamine. CS#4 provided specific names of 

other individuals believed to work with Gay in distributing drugs. SA Lucas was familiar with 

the other individuals and knew them to be associated with Gay.

14. On or about August 10, 2017, CS#1 placed a monitored and recorded call to Gay. 

During this call, Gay indicated that he had methamphetamine and fentanyl for sale. CS#1 

indicated that he/she would pay Gay $199,000 owed from a prior drug debt and an additional 

$50,000 for a kilogram of fentanyl. During their discussions, CS#1 asked Gay if he had any 

problems with CS#1 heat sealing the money to avoid detection of a drug canine. Gay told CS#1 

that he always sealed his money and wore gloves when he processed bulk cash. Gay indicated 

that he would have everything ready shortly.

15. On or about August 11, 2017, CS#1 placed a monitored and recorded call to Gay. 

During this call, Gay indicated that he had one kilogram of fentanyl ready for CS#1. CS#1 

confirmed that he/she had the $249,000 ready as payment for past purchases of narcotics and for 

the kilogram of fentanyl. When asked about the quality of the current fentanyl, Gay responded 

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that it was “buck naked,” meaning that the fentanyl was uncut and of high potency. Gay indicated 

that he would text the location where CS#1 should meet him. A short time later, CS#1 received 

a text message from Gay stating that they should meet at “4293 wolf rd.”

16. Once at the meet location, Gay exited his car and approached CS#1’s car. CS#1 

then showed Gay a bag which purportedly contained thousands of dollars in United States 

currency. Gay took the bag as payment for the previous drug deals and for the additional 

kilogram of fentanyl. After Gay placed the bag in the backseat of his car, agents arrived at the 

scene and detained Gay. By accepting payment from CS#1, Gay confirmed that he previously 

had sold large amounts of fentanyl to CS#1.

17. On or about August 11, 2017, the DEA, with the assistance of other law 

enforcement officers, executed a federal search warrant at the Savina Avenue and Wolf Road 

residences.

18. During the execution of the search warrant at Savina Avenue, investigators 

recovered items associated with drug trafficking, such as $22,100.00 in United States currency, 

which was found in an armrest of a sectional sofa in the family room; a drug ledger, which was 

found in a shoe in the master bedroom; and two plastic jars labeled “Quinine,” which were found 

in a cabinet in the laundry room. Quinine is used by drug traffickers as a cutting agent.

19. The seized currency was separated into bundles and was held together with rubber 

bands, which is a typical method used by drug traffickers to store money. The defendant 

currency, which was claimed by Gay, is $1,000.00 less than the total seized currency. 

20. On August 13, 2017, a criminal complaint was filed against Gay (Case No. 3:17-

mj-369), charging him with knowing and intentional distribution of 400 grams or more of fentanyl, 

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a Schedule II controlled substance, in violation of 21 U.S.C. §§ 841(a)(1) and (b)(1)(A) and with 

attempting to knowingly and intentionally distribute 400 grams or more of fentanyl, a Schedule II 

controlled substance, in violation of 21 U.S.C. §§ 846 and 841(b)(1)(A).

21. Gay has a substantial criminal history including, among others, the following state 

convictions: disorderly conduct, obstructing official business, negligent assault, carrying 

concealed weapon, domestic violence, disorderly conduct/intoxication, and driving without a 

license. Further, Gay has the following federal convictions: conspiracy to distribute and 

possess with intent to distribute in excess of 5 kilograms of cocaine, 50 grams of cocaine base, and 

100 kilograms of marijuana and three counts of money laundering (Case No. 3:04-CR-031-4) and 

conspiracy to distribute and possess with intent to distribute in excess of 15 kilograms of cocaine 

(Case No. 3:04-CR-129-1). On his federal charges, Gay served a lengthy term of imprisonment 

and was released from the Bureau of Prisons (“BOP”) on October 24, 2014.

22. Less than three years after Gay was released from the BOP and while on supervised 

release, he returned to a life in drug trafficking.

CLAIM FOR RELIEF

WHEREFORE, the plaintiff respectfully requests that:

(a) the Court find there is probable cause to believe that the defendant currency has 

been forfeited to the United States pursuant to 21 U.S.C. § 881(a)(6);

(b) pursuant to Rule G(3)(b)(i), Supplemental Rules, the Court issue a warrant of arrest 

in rem, directing the United States to arrest and seize the defendant currency and to retain the same 

in its custody subject to further order of the Court;

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(c) the Court, pursuant to Rule G(4), Supplemental Rules, direct the United States to 

give notice to all persons and entities having an interest in the defendant currency to assert in 

conformity with the law a statement of any interest they may have, including notice by publication 

on the official government website, www.forfeiture.gov, for thirty consecutive days;

(d) the forfeiture of the defendant currency to the United States be confirmed, enforced, 

and ordered by the Court;

(e) the Court thereafter order the United States to dispose of the defendant currency as 

provided by law; and

(f) the Court award the United States all other relief to which it is entitled, including 

the costs of this action.

Respectfully submitted,

BENJAMIN C. GLASSMAN

United States Attorney

s/Deborah D. Grimes

DEBORAH D. GRIMES (0078698)

Assistant United States Attorney

Attorney for Plaintiff

221 East Fourth Street, Suite 400

Cincinnati, Ohio 45202

(513) 684-3711 / Fax: (513) 684-6385

Deborah.Grimes @usdoj.gov

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VERIFICATION

I, Steven M. Lucas, hereby verify and declare under the penalty of perjury that I am a 

Special Agent with the Drug Enforcement Administration, that I have read the foregoing Verified 

Complaint for Forfeiture In Rem and know the contents thereof, and that the matters contained in 

the complaint are true to my own knowledge, except that those matters not within my own personal 

knowledge are alleged on information and belief, and as to those matters, I believe them to be true.

The sources of my knowledge and information and the grounds of my belief are the official 

files and records of the United States, information supplied to me by other law enforcement 

officers, and my investigation of this case.

I hereby verify and declare under the penalty of perjury that the foregoing is true and 

correct.

01/19/18 s/Steven M. Lucas

Date STEVEN M. LUCAS, Special Agent

Drug Enforcement Administration

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AO 440 (5/85) Summons in a Civil Action

United States District Court

 SOUTHERN DISTRICT OF OHIO 

UNITED STATES OF AMERICA

V.

TWENTY-ONE THOUSAND ONE HUNDRED

DOLLARS IN UNITED STATES CURRENCY

($21,100.00)

 

SUMMONS IN A CIVIL ACTION

CASE NUMBER: 3:18CV024

TO: (Name and Address of Defendant) TWENTY-ONE THOUSAND ONE HUNDRED

DOLLARS IN UNITED STATES CURRENCY ($21,100.00)

c/o U.S. MARSHAL SERVICE

YOU ARE HEREBY SUMMONED and required to file with the Clerk of this Court and serve upon

PLAINTIFF'S ATTORNEY (name and address)

Deborah D. Grimes

Assistant U.S. Attorney

U.S. Attorney's Office

221 East Fourth Street, Suite 400

Cincinnati, Ohio 45202

a Claim pursuant to Rule G of the Supplemental Rules for Certain Admiralty or Maritime Claims and Asset Forfeiture Actions of

the Federal Rules of Civil Procedure within thirty (30) days after the service of this Summons upon you, exclusive of the day of 

service, and an Answer or Motion under Rule 12 to the Complaint which is herewith served upon you, within twenty (20) days 

after the filing of your Claim. If you fail to do so, judgment by default will be taken against you for the relief demanded in the 

Complaint.

Richard W. Nagel 

CLERK DATE

BY DEPUTY CLERK

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