COMPLAINT in rem FOR FORFEITURE Page 1 of 4

S. AMANDA MARSHALL, OSB #95347

United States Attorney 

District of Oregon 

AMY E. POTTER 

amy.potter@usdoj.gov 

Assistant United States Attorney 

United States Attorney=s Office 

405 E. 8th Street, Suite 2400 

Eugene, Oregon 97401-2708 

Telephone: 541-465-6771 

Facsimile: 541-465-6917 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

EUGENE DIVISION 

UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

32683 Hidden Meadows Drive, Eugene, 

Lane County, State and District of Oregon, 

Real Property with Buildings, 

Appurtenances, and Improvements, in rem, 

 Defendant. 

 Case No: 6:15-CV-00143-MA 

COMPLAINT 

T

 Plaintiff, United States of America, by S. Amanda Marshall, United States Attorney for 

the District of Oregon, and Amy E. Potter, Assistant United States Attorney, for its complaint in 

rem for forfeiture, alleges: 

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COMPLAINT in rem FOR FORFEITURE Page 2 of 4

COUNT 1

I. 

 This Court has subject matter jurisdiction, in rem jurisdiction, and venue pursuant to 

21 U.S.C. § 881; 28 U.S.C. §§ 1345, 1355, 1356, and 1395; and 19 U.S.C. § 1610. 

II. 

 Defendant, in rem, 32683 Hidden Meadows Drive, Eugene, Lane County, State and 

District of Oregon, Real Property with Buildings, Appurtenances, and Improvements (herein 

after known as “32683 Hidden Meadows Drive”) and more particularly described as follows: 

Lot 27, HIDDEN MEADOWS, as platted and recorded December 18, 2003, Reception 

No. 2003 120977, Lane County Deeds and Records, in Lane County, Oregon 

is now and during the pendency of this action will be within the jurisdiction of this Court. 

III. 

 Defendant, in rem, 32683 Hidden Meadows Drive, represents proceeds traceable to an 

exchange for controlled substances or was used or intended to be used to facilitate such a 

transaction in violation of 21 U.S.C. § 801, et. seq., and is forfeitable to the United States 

pursuant to the provisions of 21 U.S.C. § 881(a)(7), as more particularly set forth in the 

declaration of Christopher M. Luh, Special Agent, Federal Bureau of Investigation, marked as 

Exhibit A, attached and fully incorporated herein by this reference. 

COUNT 2

IV. 

 This Court has subject matter jurisdiction, in rem jurisdiction, and venue pursuant to 

21 18 U.S.C. § 1956; 28 U.S.C. §§ 1345, 1355, 1356, and 1395; and 19 U.S.C. § 1610. 

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COMPLAINT in rem FOR FORFEITURE Page 3 of 4

V. 

Defendant, in rem, 32683 Hidden Meadows Drive, was seized in the District of Oregon, 

and is now and during the pendency of this action will be within the jurisdiction of this Court. 

VI. 

 Defendant, in rem, 32683 Hidden Meadows Drive, constitutes property, real or personal, 

involved in a money laundering transaction or attempted transaction or property traceable to 

money laundering offenses, in violation of 18 U.S.C. § 1956 and is therefore subject to forfeiture 

pursuant to 18 U.S.C. § 981(a)(1)(A) and 981(a)(1)(C), as more particularly set forth in the 

declaration of Christopher M. Luh, Special Agent, Federal Bureau of Investigation marked as 

Exhibit A, attached and fully incorporated herein by this reference 

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

enforce the forfeiture of defendant, in rem, 32683 Hidden Meadows Drive; that due notice be 

given to all interested persons to appear and show cause why forfeiture of this defendant, in rem, 

should not be decreed; that due proceedings be had thereon; that this defendant be forfeited to the 

United States; that the plaintiff United States of America be awarded its costs and disbursements 

incurred in this action. 

 Respectfully submitted this 27th day of January 2015. 

 S. AMANDA MARSHALL

 United States Attorney 

 s/ Amy E. Potter 

 AMY E. POTTER 

 Assistant United States Attorney 

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COMPLAINT in rem FOR FORFEITURE Page 4 of 4

VERIFICATION

 I, Christopher M. Luh, declare under penalty of perjury, pursuant to the provisions of 

28 U.S.C. Section 1746, that I am a Special Agent with the Federal Bureau of Investigation and 

that the foregoing Complaint in rem for Forfeiture is made on the basis of information officially 

furnished and upon the basis of such information the Complaint in rem for Forfeiture is true as I 

verily believe. 

 s/ Christopher M. Luh 

 CHRISTOPHER M. LUH

 Special Agent 

 Federal Bureau of Investigation 

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