UNITED STATES V. $698,230.00 IN UNITED STATES CURRENCY: 

COMPLAINT FOR FORFEITURE IN REM PAGE 1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

TYLER DIVISION 

UNITED STATES OF AMERICA § 

Plaintiff, § 

 § 

v. § NO: 6:24-cv-00027

§ 

$698,230.00 IN UNITED STATES § 

CURRENCY § 

Defendant. § 

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 for violations of 18

U.S.C. §§ 1343 (Wire Fraud), 1349 (Conspiracy to Commit Wire Fraud), 1956 (Money 

Laundering), and 1957 (Engaging in Monetary Transactions in Property Derived from 

Specified Unlawful Activity). 

Defendant In Rem 

2. The Defendant Property is $698,230.00 in United States currency seized

from Cathay Bank account xxxx9811 in the name of LSM Trade Limited on or about 

October 30, 2023, in Plano, Texas. The Defendant Property is currently in the custody of 

the United States Secret Service. 

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UNITED STATES V. $698,230.00 IN UNITED STATES CURRENCY: 

COMPLAINT FOR FORFEITURE IN REM PAGE 2 

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 

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 18 U.S.C. § 

981(a)(1)(A) because it is personal property involved in a transaction or attempted 

transaction in violation of 18 U.S.C. §§ 1956 and 1957, or any property traceable to such 

property, and pursuant to 18 U.S.C. § 981(a)(1)(C) because it is personal property which 

constitutes or is derived from proceeds traceable to a violation of any offense constituting 

a specified unlawful activity (as defined in 18 U.S.C. § 1956(c)(7)), namely, a violation 

of 18 U.S.C. § 1343, or a conspiracy to commit such offense (18 U.S.C. § 1349). 

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UNITED STATES V. $698,230.00 IN UNITED STATES CURRENCY: 

COMPLAINT FOR FORFEITURE IN REM PAGE 3 

Facts 

7. The facts and circumstances supporting the forfeiture of the abovedescribed property are contained in the Affidavit of Special Agent Brad Schley, which is 

attached hereto and incorporated herein by reference. 

Potential Claimants 

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

a. Shiming Li 

 LSM Trade Limited 

 20 Confucius Plaza 44C 

New York, New York 10002 

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/ Robert Austin Wells 

 ROBERT AUSTIN WELLS 

 Assistant United States Attorney 

 Texas State Bar No. 24033327 

 110 N. College, Suite 700 

 Tyler, Texas 75702 

 Tel: (903) 590-1400 

 robert.wells3@usdoj.gov

 

ATTORNEYS FOR THE UNITED STATES

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