UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF OHIO

WESTERN DI\TISION

UNITED STATES OF AMERICA, Case No. 1:18-CV-88

Plaintiff,

v, JUDGE

SEYENTEEN THOUSAND EIGHT

HUNDRED NINETY-THREE DOLLARS

IN UNITED STATES CURRENCY

($17,893.00),

VERIFIED COMPLAINT FOR

FORFEITURE IN REM

Defendant 1,

TWELVE THOUSAND NINE HUNDRED

DOLLARS IN UNITED STATES

CURRENCY ($12,900.00),

Defendant 2,

ONE 1970 CADILLAC FLEETWOOD,

vIN P0200185, WrrH ALL

ATTACHMENTS THEREON,

Defendant 3,

and

oNE 2017 GMC SIERRA PICKUP, \rIN

3GTU2NEC0HG2571 14, WITH ALL

ATTACHMENTS THEREON,

Defendant 4.

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

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

of Civil Procedure.

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NATURE OF THE ACTION

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

provides for the forfeiture to the United States of:

All conveyances, including aircraft, vehicles, or vessels, which are used, or

are intended for use, to transport, or in any manner to facilitate the

transportation, sale, receipt, possession, or concealment of property

described in paragraphs (1), (2), or (9);

and./or 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

fumished or intended to be fumished 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.

Paragraph (1) of 2l U.S.C. $ 881(a) states

All controlled substances which have been manufactured, distributed,

dispensed, or acquired in violation of this subchapter.

THE DEFENDANTS IN REM

2. Defendant 1 is Seventeen Thousand Eight HundredNinety-Three Dollars in United

States Currency ($17,893.00). On September l1 ,2017,law enforcement agents seized Defendant

1 from the residence of Jonathan lngram, located at 128 Beckett Street, Hamilton, Ohio, during

the execution of a state 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.

3. Defendant 2 is Twelve Thousand Nine Hundred Dollars in United States Currency

($12,900.00). On September 15, 2017, a third party voluntarily turned over Defendant 2, which

he had received from Jonathan Ingram, to a law enforcement agent. The United States

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

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during the pendency of this action.

4. Defendant 3 is a 1970 Cadillac Fleetwood, VN P0200185, with All Attachments

Thereon, which is registered to Jonathan Ingram. On September 11 , 2017, law enforcement

agents seized Defendant 3 from Southside's Detail and Wash, 811 Central Avenue, Hamilton,

Ohio, during the execution of a state search warrant. Defendant 3 is in the possession of the

United States Marshals Service, where it will remain during the pendency of this action.

5. Defendant 4 is a2017 GMC Sierra Pickup, VIN 3GTU2NEC0HG257ll4, with All

Attachments Thereon, which is registered to Jonathan Ingram. On September 11,2017,Law

enforcement agents seized Defendant 4 from Jonathan Ingram during a traffic stop. Defendant 4

is in the possession of the United States Marshals Service, where it will remain during the

pendency of this action.

JURISDICTION AND VENUE

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

defendants under 21 U.S.C. $ 881(aXa) and./or (aX6) 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. $ 13ss(a).

7. This Court has in rem juisdiction over the defendants under 28 U.S.C.

$ 1355(bX1)(A) because acts and omissions giving rise to the forfeiture occurred in the Southem

District of Ohio.

8. Venue is proper in this district pursuant to 28 U.S.C. $ 1355(b)(1XA) 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 defendants were found in the Southern District of Ohio.

J

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BASIS FOR FORFEITURE

9. The defendants are subject to forfeiture pursuant to 21 U.S.C. $ 881(a)(6) because

the defendants represent property fumished or intended to be furnished by any person in exchange

for a controlled substance, represent proceeds traceable to such an exchange, or were used or

intended to be used to facilitate any violation of 2l U.S.C. $ 841 or a conspiracy to commit such

offense in violation of 21 U.S.C. $ 846.

10. Defendant 4 also is subject to forfeiture pursuant to 21 U.S.C. $ 881(aXa) because

it was used or intended for use, to transport, or in any manner to facilitate the transportation, sale,

receipt, possession, or concealment of property described in 21 U.S.C. $ 881(a)(1).

FACTS

11. The Drug Enforcement Administration ("DEA") and other law enforcement

agencies are investigating the distribution of controlled substances by individuals in Butler County,

Ohio and elsewhere. The DEA has identified Jonathan Ingram ("Ingram") as a large-scale

narcotics trafficker for years in Hamilton, Ohio, and the surroundingarea.

12. On or about May 3 1 , 2017 , and July 28 , 20ll , 

law enforcement agents conducted

controlled purchases of methamphetamine, totaling approximately ninety-three grams, from

Ingram. During each transaction, agents observed lngram arrive in a white 2017 GMC Sierra

pickup truck (Defendant 4) at Southside's Detail and Wash, located at 811 Central Avenue,

Hamilton, Ohio.

13. Continuing on July 28,2017, agents observed Ingram engage in what appeared to

be a narcotics transaction, based on their training and experience, with an unknown male in the

parking lot of Southside's Detail and Wash. After the unknown male departed the are1 a deputy

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of the Butler County Sheriff s Office observed the individual commit three traffic violations and

conducted a stop on the vehicle. The deputy seized approximately twenty-five grams of cocaine

from the individual's vehicle.

14. On September 17,2017,Iaw enforcement agents observed Ingram, who was

operating Defendant 4, travel to Dayton, Ohio. Based on their experience, law enforcement

agents know that it is common for narcotics traffickers to replenish their drug supplies in Dayton,

Ohio. While in Dayton, agents observed Ingram spend a short period of time at a residence on

West Second Street before he headed toward Hamilton, Ohio. Law enforcement agents executed

a traffic stop on Ingram based on no front license plate and on the results of their ongoing

investigation.

15. During the traffic stop, a deputy of the Butler County Undercover Regional

Narcotics Task Force and a trained, drug-detection canine performed a free air sniff on Defendant

4, which resulted in positive alerts on the vehicle. While conducting a probable cause search of

Defendant 4, investigators discovered a brown plastic bag under the rear seat of the vehicle.

Inside the plastic bag was a hard, brick-shaped object which was wrapped in black electric tape.

DEA Task Force Agent ("TFA") Timothy Andrews found a white powdery substance after cutting

through several layers of packaging to include clear tape, rubber, plastic wrap, and grease. The

white powdery substance subsequently was lab tested and identified as approximately one

kilogram of cocaine, a Schedule II controlled substance.

16. Law enforcement agents arrested Ingram and transported him to the Butler County

Jail for an interview. TFA Andrews advised Ingram of his rights tnder Miranda. Ingram agreed

to speak with TFA Andrews and signed a written waiver form. When asked about the package

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that was located under the rear seat of Defendant 4,Ingram stated that it was cocaine or fentanyl.

Ingram also mentioned that it could be drywall. TFA Andrews advised Ingram that a field test

was conducted and that the substance tested positive for cocaine.

17. During the interview, Ingram advised that he had information about three kilograms

of fentanyl that were coming into the Butler County area. When TFA Andrews inquired about

the location of the fentanyl, Ingram indicated that he was to pick up the fentanyl later in the

afternoon on September I l, 2017, and that an unknown person would call him. According to

Ingram, once he received the call, he would drive to Dayton and pick up the fentanyl at a location

disclosed to him during the call. Ingram stated he then would return to the Hamilton area and

wait for a second call from an unknown subject who would pick up the fentanyl. During the

exchange, Ingram stated that he would receive $10,000.00 for holding the three kilograms of

fentanyl. Ingram further stated that he had completed this type of transaction-holding three

kilograms of fentanyl for $10,000.00-on three separate occasions. Ingram indicated that he had

spent nineteen years in prison and that he was going to do what he had been doing his whole life.

18. Ingram further admitted that he had picked up cocaine in Dayton on three separate

occasions as follows: (1) six kilograms, (2) four or five kilograms, and (3) one kilogram (the

latest transaction). Ingram stated that the kilograms were fronted to him and that he paid

$30,000.00 for the one kilogram but that he previously paid $39,000.00 per kilogram.

19. Agents seized Defendant 4 atthe scene of the traffic stop, following Ingram's arrest.

Ingram had purchased Defendant 4 on or about March 23,2017, for $56,429.10. Ingram made

two cash payments for the vehicle, each in the amount of $13,000, and he financed the remaining

balance.

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20. Continuing on September 11,2017, agents obtained a state search warrant for

Ingram's residence, located at 128 Beckett Street, Hamilton, Ohio. During the execution of the

search warrant, agents seized, among other things, four firearms, magazines, ammunition, baggies

containing a white powdery substance, loose green vegetation believed to be marijuana, and an

undetermined amount of United States currency from a gun safe in the master bedroom and from

a jar in the kitchen. The DEA later determined that the seized cuffency, which represents

Defendant 1, totaled $17,893.00. The white powdery substances in the baggies were lab tested

and identified as approximately 42.6 gtams total of cocaine, a Schedule II controlled substance.

21. On September 11, 2017, agents also obtained a state search warrant for Ingram's

business, Southside's Detail and Wash, located at 811 Central Avenue, Hamilton, Ohio. During

the execution of the search warrant, agents seized, among other things, two bags of suspected

marijuana from the office on a shelf, a clear baggie containing a white powdery substance from a

black tray in the bay area of the business, two clear plastic baggies containing a crystal substance

from the pocket of a shirt hanging in the office, and three kilogram-type wrappers from a dog food

bag on the floor in the office. Agents also seized a 1970 Cadillac Fleetwood, VIN P0200185

(Defendant 3), which Ingram purchased on or about May 23,2014, and claimed that it has a value

of approximately $25,000.00. The suspected narcotics were lab tested and identified as cocaine,

marijuana, and methamphetamine.

22. On September 15, 2017,law enforcement agents learned that on July 3, 2017,

Ingram paid an individual $13,000.00 in United States curency as a down payment for the

purchase of real estate. Ingram agreed to pay the seller an additional $ I 3,000.00 on August 1 1 

,

2017, to complete the transaction; however, the deal fell through prior to the final payment.

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Ingram subsequentlyrequested the return of the $13,000.00. Following Ingram's arrest, the seller

voluntarily tumed over the remaining curency ($12,900.00) in the form of a cashier's check,

which represents Defendant 2, to a law enforcement agent.

23. On September.20,2017, a federal grand jury retumed a two-count Indictment

against Ingram, charging him in Count 1 with distribution and possession with intent to distribute

a controlled substance, in violationof 2l U.S.C. $ 8a1(a)(l) and (b)(1)(B) and l8 U.S.C. $ 2 and

charging him in Count 2 with possession of a firearm by a prohibited person, in violation of 18

U.S.C. $ 922(9)(l) and 18 U.S.C. 5 92a@)Q) (Case No. 1:17-CR-107).

24. Although Ingram is licensed as a barber and has several businesses registered in

Ohio, records show that for the time period of 2005 through 2016,Ingram has not filed any

personal tax returns or any business tax retums for Southside Investments Group , LLC; Property

Solutions of Southwest Ohio, LLC; and Generate Investments Group, LLC with the City of

Hamilton. In addition, for the period of 2005 through 2016,Ingram has not filed any Ohio tax

returns for personal income, corporate income, sales, and withholding.

25. Ingram has an extensive criminal history, which includes but is not limited to

convictions for the following: aggravated robbery in 1982, carrying a concealed weapon in 1989,

weapons under disability in 1989, drug abuse in 1989, aggravated trafficking in 1992, aggravated

trafficking rn 1996, preparation of drugs for sale in 2001, trafficking in drugs in 2007, and

trafficking in marijuanain2007. Ingram has served a significant amount of time in prison.

CLAIM FOR RELIEF

By reason of the facts set forth herein, the defendants are properly condemned as forfeited

to the United States pursuant to 21 U.S.C. $ 881(a)(a) and/or (a)(6).

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WHEREFORE, the plaintiff respectfully requests that:

(a) pursuant to Rule G(3XbXi), Supplemental Rules, the Clerk issue a warrant of arrest

in rem, directing the United States to arrest and seize the defendants and to retain the same in its

custody subject to further order of the Court;

(b) 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 defendants to assert in conformity

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

official govemment website, www.forfeiture.gov, for 30 consecutive days;

(c) the forfeiture of the defendants to the United States be confirmed, enforced, and

ordered by the Court;

(d) the Court thereafter order the United States to dispose of the defendants as provided

by law; and

(e) 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 Attomey

s/Deborah D. Grimes

DEBORAH D. GRTMES (0078698)

Assistant United States Attorney

Attorney for Plaintiff

221East Fourth Street, Suite 400

Cincinnati, Ohio 45202

(sl3) 684-3111 lFax (s13) 684-6385

Deborah. Grimes@usdoj . gov

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- VERIFICATION

I, Timothy J. Andrews, hereby verify and declare under the penalty of perjury that I am a

Task Force 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 cornplaint are true to my own knowledge, except that those matters stated to be

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

fi1es 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.

Dated 2.a ,8Ct,Scvs,'trzs

J.

Drug Enforcement Admini stration

Force Agent

A

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