Verified Complaint – Page 1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

BEAUMONT DIVISION 

UNITED STATES OF AMERICA § 

Plaintiff, § 

 § 

v. § Civil No. 1:23-cv-00207 

§ 

$101,020.00 IN UNITED STATES § 

CURRENCY, § 

Defendant. § 

 

VERIFIED COMPLAINT FOR FORFEITURE IN REM 

In accordance with Fed. R. Civ. P. Supplemental Rule G(2), the United States of 

America, Plaintiff, brings this complaint and alleges as follows: 

Nature of the Action 

1. This is an action to forfeit property to the United States pursuant to 21

U.S.C. § 881(a)(6). 

Defendant In Rem 

2. The property is $101,020.00 in United States Currency (Defendant 

Property). Deputies with the Jefferson County Sheriff’s Office seized the Defendant 

Property on December 14, 2022. The Defendant Property is currently in the custody of 

the United States Marshals Service. 

Jurisdiction and Venue 

3. The Court has subject matter jurisdiction over an action commenced by the 

United States pursuant to 28 U.S.C. § 1345, and over an action for forfeiture pursuant to 

Case 1:23-cv-00207 Document 1 Filed 05/25/23 Page 1 of 6 PageID #: 1
Verified Complaint – Page 2 

28 U.S.C. § 1355(a). 

4. The Court has in rem jurisdiction over the Defendant Property pursuant to 

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

in this district. 

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

because acts or omissions giving rise to the forfeiture occurred in this district. 

Basis for Forfeiture 

6. The Defendant Property is subject to forfeiture pursuant to 21 U.S.C. 

§ 881(a)(6) because it constitutes (i) money, negotiable instruments, securities and other 

things of value furnished and intended to be furnished in exchange for a controlled 

substance in violation of the Controlled Substances Act; (ii) proceeds traceable to such an 

exchange; or (iii) money, negotiable instruments, and securities used and intended to be 

used to facilitate a violation of the Controlled Substances Act. 

Facts

 7. On Wednesday December 14, 2022, Detectives with Jefferson County 

Sherriff’s Office (JCSO) conducted a traffic stop on a Dodge truck for a traffic violation 

on Interstate 10. The stop was conducted at the Stuckey’s gas station located at I-10 west 

bound at the FM 365 exit. 

 A Detective made contact with the driver who was identified as David Sanchez. 

The Detective asked Sanchez where he was coming from, and Sanchez stated the new 

Horseshoe Casino in Louisiana. Through a law enforcement database, the Detective was 

able to prove Sanchez was lying about his travels. The Detective discovered Sanchez had 

Case 1:23-cv-00207 Document 1 Filed 05/25/23 Page 2 of 6 PageID #: 2
Verified Complaint – Page 3

been in North Carolina and Virginia. The Detective asked Sanchez if he has anything 

illegal on him like drugs, weapons, or large amounts of currency to which Sanchez 

replied no to all. The Detective asked Sanchez for permission to search his vehicle and 

Sanchez denied consent. The Detective had JCSO K9 to conduct an open-air sniff to the 

vehicle and the K9 showed a positive alert for narcotics on the vehicle.

During the probable cause search of the vehicle, Detectives located a clear Ziplock 

baggie that contained numerous small black rubber bands. The Detectives also located a 

camouflage duffel bag on the back floorboard of the driver side and a red duffel bag lying 

on the back floorboard on the passenger side. The Detective opened the camouflage 

backpack and located a black Food Saver brand vacuum sealer and a roll of vacuum bags. 

The Detective also opened the red duffel bag and observed it full of clothes. After 

moving the clothing, he observed a large vacuum sealed bag containing bundles of U.S. 

currency held together with small black rubber bands like the small black rubber bands 

found inside the Ziplock baggie. The Detective also located opened air fresheners that 

had been wrapped in with the clothes. In total, there were five vacuum sealed bags that 

contained the currency. 

Due to the Detectives training and experience, small rubber bands are commonly 

used to bundle U.S. currency together. Vacuum sealers are commonly used to seal U.S. 

currency as a countermeasure to avoid being detected during a K9 sniff. Detectives

believe the currency was vacuum sealed and stored in the bag with the air fresheners in 

an attempt to conceal any narcotic odor that could be on them.

Case 1:23-cv-00207 Document 1 Filed 05/25/23 Page 3 of 6 PageID #: 3
Verified Complaint – Page 4 

Sanchez's vehicle was taken into a secure parking lot where it could be further 

searched. During the search, additional U.S. Currency was in the center console 

amounting to approximately $2800.00 and more in Sanchez's wallet that appeared to be 

just under $600.00. The Detectives know through training and experience, Drug 

Trafficking Organizations (DTOs) commonly use couriers to transport illegal narcotics 

and its proceeds and often receive a percentage of what is being smuggled as payment. 

This payment is typically found separated from what is being smuggled. The Detective 

also located several hotel room key cards and two hotel receipts that were dated for 

November 30, 2022 and were for two different hotel rooms at two different hotels in 

Suffolk Virginia both under Sanchez's name. 

Due to Sanchez's conflicting travel itinerary and how the currency was hidden and 

packaged, through the Detectives training and experience, the Detectives believed the 

currency was drug proceeds and seized the currency from Sanchez.

Potential Claimant

8. The only known potential claimant to the Defendant Property is: 

 David Sanchez 

 Represented by John J. Klevenhagen III 

 The Klevenhagne Law Firm, PLLC 

 952 Echo Lane, Suite 380 

 Houston, Texas 77024; and 

 Estefani Kimberly Cardenas 

 910 Centerwood Drive 

 Houston, Texas 77013-5747 

Case 1:23-cv-00207 Document 1 Filed 05/25/23 Page 4 of 6 PageID #: 4
Verified Complaint – Page 5 

Claim for Relief 

9. The United States respectfully requests that the Court forfeit the Defendant 

Property to the United States, award costs and disbursements in this action to the United 

States and order any other relief that the Court deems appropriate. 

Respectfully submitted, 

DAMIEN M. DIGGS 

UNITED STATES ATTORNEY 

 /s/ Michael W. Lockhart 

MICHAEL W. LOCKHART 

Assistant United States Attorney

Eastern District of Texas 

Texas Bar No. 12472200 

550 Fannin Street, Suite 1250 

Beaumont, Texas 77701 

(409) 839-2538 

(409) 839-2643 (fax) 

michael.lockhart@usdoj.gov

Case 1:23-cv-00207 Document 1 Filed 05/25/23 Page 5 of 6 PageID #: 5
Verified Complaint – Page 6 

VERIFICATION PURSUANT TO 28 U.S.C. § 1746 

I, Michael W. Lockhart, hereby state that: 

1. I am an Assistant United States Attorney for the Eastern District of Texas.

2. I have read this Complaint, and the information contained herein is true and

correct to the best of my knowledge.

3. The information contained in this Complaint comes from the official files

and records of the United States and information received from law

enforcement officers.

I state and verify under penalty of perjury that the foregoing is true and correct. 

 /s/ Michael W. Lockhart 

MICHEAL W. LOCKHART 

Assistant United States Attorney

Dated: May 25, 2023. 

Case 1:23-cv-00207 Document 1 Filed 05/25/23 Page 6 of 6 PageID #: 6