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ELIZABETH A. STRANGE

First Assistant United States Attorney

District of Arizona

MARK J. WENKER

Assistant United States Attorney

Arizona State Bar Number 018187

Two Renaissance Square

40 North Central Avenue, Suite 1800

Phoenix, Arizona 85004-4408

Telephone: (602) 514-7500

Mark.Wenker@usdoj.gov

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

United States of America, ║

║ Plaintiff, ║ VERIFIED COMPLAINT FOR ║ FORFEITURE IN REM

v. ║

║ $18,080.00 in United States Currency, ║

║ Defendant. ║

║

Plaintiff United States of America brings this complaint and alleges as follows in 

accordance with Rule G(2) of the Federal Rules of Civil Procedure, Supplemental Rules 

for Admiralty or Maritime Claims and Asset Forfeiture Actions (“Supplemental Rules”):

BASIS FOR FORFEITURE

1. This is a civil action in rem to forfeit property pursuant to 21 U.S.C. § 

881(a)(6) and 18 U.S.C. § 981(a)(1)(A) because it was furnished or intended to be 

furnished by a person in exchange for a controlled substance or listed chemical in 

violation of Title II of the Controlled Substances Act, 21 U.S.C. § 801, et seq., is 

proceeds traceable to such an exchange, or was used or intended to be used to facilitate a 

violation of Title II of the Controlled Substances Act, 21 U.S.C. § 801, et seq., or is 

property involved in a money laundering transaction or attempted transaction.

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2. This is a civil action in rem brought to forfeit property pursuant to 18 

U.S.C. § 981(a)(1)(C) because it constitutes or is derived from proceeds traceable to a 

violation of, among other things, a specified unlawful activity and 18 U.S.C. § 1952, 

travel in interstate commerce to distribute the proceeds of, and promote or facilitate the 

promotion of, an unlawful activity.

3. Venue and jurisdiction in Arizona are based upon 21 U.S.C. § 881(j) and 

28 U.S.C. §§ 1355(b) and 1395 as acts and omissions occurred in the District of Arizona 

that give rise to this forfeiture action. This Court has jurisdiction. 18 U.S.C. § 981(h)

and 28 U.S.C. §§ 1345 and 1355.

DEFENDANT IN REM

4. The Defendant consists of $18,080.00 in United States currency 

(“defendant currency”) seized on September 19, 2017, from Patrick O’Neal Ivory, Jr. 

The defendant currency currently is in the custody of the Homeland Security 

Investigations.

INTRODUCTION

5. The Arizona High Intensity Drug Trafficking Area (HIDTA) Border 

Enforcement Security Task Force (BEST) has a HSI Phoenix Special Agent (SA) 

assigned to the Phoenix Police Department (PPD) Commercial Narcotics Interdiction 

Unit (CNIU) based out of the Phoenix Sky Harbor International Airport.

6. The HSI Phoenix SA works with the PPD Detectives at the CNIU during 

their day-to-day interdiction operations as well as serving as the HSI Phoenix point of 

contact for all passenger and cargo activities regarding the Phoenix Sky Harbor 

International Airport.

7. Among other things, the HSI Phoenix SA assists detectives of the CNIU to 

identify and interdict money couriers in an effort to disrupt Drug Trafficking 

Organizations (DTOs). Based upon experience of CNIU investigators and investigations 

across the country, it is common knowledge that cities in the mid-west and east coast are 

known demand locations for illicit drugs. States such as Arizona and California are 

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considered source locations due to their close proximity to the border of Mexico and 

established drug transportation routes. Person(s) involved in the illegal drug trade, often 

hire couriers to transport drugs and or proceeds from the sale of drugs by utilizing 

commercial airlines and shipping companies. In an effort to identify and disrupt 

potential drug and/or money couriers related to drug organizations and criminal 

syndicates, investigators utilize a variety of resources, including confidential informants, 

suspicious flight itineraries, other law enforcement agencies, and prior knowledge of 

criminal activity or intelligence. 

8. Factors that constitute suspicious flight itineraries include, airfare purchase 

at the counter immediately prior to departure or short notice reservations for a one-way 

travel, sometimes paid in cash. In addition, it is common for couriers to utilize a third 

party credit card to purchase airfare and to provide inaccurate or not in-service telephone 

numbers to the airlines. Couriers travel with minimal or no luggage and will often 

attempt to board the aircraft at the last possible moment. Drug and/or money couriers 

utilize these techniques in an attempt to conceal their identities from law enforcement 

authorities and minimize their exposure to commercial airlines. 

BACKGROUND

9. On September 18, 2017, while on duty at the CNIU located at the Phoenix

Sky Harbor International Airport, HSI Special Agent Brian Derryberry (SA Derryberry) 

received information from the HSI Houston concerning an individual identified as 

Patrick O’Neal Ivory, Jr. (IVORY) who was in possession of approximately $10,000 in 

U. S. currency discovered by Houston Transportation Security Administration (TSA).

10. The TSA Agents in Houston contacted IVORY during the passenger 

screening and observed IVORY pull out several rubber-banded bundles of currency in 

his possession from his pants pockets.

11. IVORY stated that he had “$10,000 but the amount could be more.”

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12. IVORY claimed he was traveling to Los Angeles for his birthday and to go 

shopping.

13. TSA provided a physical description to SA Derryberry for IVORY and 

advised the currency was inside IVORY’s pockets.

14. Prior to the arrival of the flight in Phoenix, investigators ran a criminal 

history check on IVORY.

15. A check of federal, state and local law enforcement indices revealed 

IVORY had previous charges on possession of marijuana.

16. SA Derryberry contacted the CNIU PPD Sergeant who was able to make 

arrangements for additional CNIU members to assist with identifying IVORY upon his 

arrival.

17. IVORY purchased his one-way ticket within 48 hours of the flight and had 

no checked luggage.

18. Based on the information received and their knowledge of the drug 

demand/source relationship between Houston and the southwest states, investigators 

decided to attempt to talk with IVORY.

19. IVORY was traveling on American Airlines flight #531 from Houston to 

Los Angeles, California, with a stop in Phoenix, Arizona. 

20. Investigators approached the arrival gate and observed a male, consistent 

with an individual fitting IVORY’s description, in the terminal talking on his cellular 

phone. 

Investigators’ Contact with IVORY

21. Investigators approached the male passenger believed to be IVORY, 

identified themselves, and showed him their official badges and credentials. 

22. Investigators asked the individual if they could speak to him, and he 

agreed.

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23. The individual ended his phone call and provided investigators with his 

boarding pass and Texas identification card in the name of Patrick O’Neal Ivory, Jr.

24. Investigators explained to IVORY the purpose of their contact and 

explained they received information from the Houston TSA that he was in possession of 

a large amount of currency.

25. Investigators inquired about IVORY’s ticket purchase and his intended use 

of the currency.

26. IVORY stated he was traveling from Houston, Texas, to Los Angeles to 

shop for his birthday.

27. IVORY showed investigators his Texas identification and pointed out his 

birthday was in several days, September 22, 1993.

28. IVORY advised he had only one carry-on bag and denied traveling with 

illicit drugs or contraband. 

29. IVORY stated he had a little over $10,000.

30. When investigators asked for the specific amount, IVORY then stated he 

had $12,000.

31. IVORY showed investigators several rubber-banded bundles of currency, 

which IVORY had pulled out from his pants pocket. 

32. Investigators asked IVORY how he obtained the currency. IVORY 

responded he designed and sold clothes through his clothing line.

33. IVORY stated he intended on spending the currency on clothes for his 

birthday.

34. IVORY could not provide anything to corroborate how he obtained the 

currency.

35. IVORY did not have a wallet, driver’s license, business card or any credit 

cards.

36. Although IVORY claimed he obtained the currency from selling clothes he 

designed, he did not have a bank account, personal or business.

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37. IVORY stated he “does everything” through his mother, Cheryl Herron’s

(Herron) account.

38. IVORY told investigators his mother gave him at least $5,000 to spend 

and purchased his airline ticket because his birthday was coming up.

39. Based on the information received, investigators told IVORY they wanted 

to conduct a verification count of the currency as the amount he claimed to possess had 

changed several times.

40. Investigators advised IVORY they had more questions regarding the 

currency as IVORY initially claimed he had “around $10,000” and then claimed he had 

$12,000.

41. Investigators asked IVORY if they could continue the contact inside the 

CNIU office to conduct the count and have a narcotic canine examine the currency. 

IVORY agreed and carried his own bag.

42. IVORY denied the currency had been exposed to illicit drugs. 

43. While walking to the CNIU office, IVORY showed investigators an 

Instagram account for his clothing line and said Herron’s account was part of the 

company and handled all his money.

44. IVORY inquired about the ticket tip information, and investigators 

explained it varied in reasons from last minute ticket purchases, departure/arrival cities 

or how the ticket was purchased, and that in this instance, TSA notified CNIU.

45. While walking to the CNIU office, IVORY verified his personal 

information, mailing address and phone number.

46. IVORY stated he lived with his mother, Cheryl Herron, and his sibling.

47. IVORY did not pay rent, but had child expenses for his one-year old son.

IVORY’s Interview at CNIU Office

48. Upon arrival at the CNIU office, IVORY was asked to place the contents 

of his pockets on the table.

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49. IVORY withdrew from his pants pockets three rubber-banded bundles of 

currency, his Texas identification card, and a pre-paid debit card that IVORY stated he 

purchased at the last minute because the airline charged him extra to board the flight, 

although no explanation given as to why.

50. During a pat down, another rubber-banded bundle of currency was found 

inside IVORY’s sweater-hoodie pocket and IVORY stated, “I forgot about that.”

51. IVORY told investigators all the currency he possessed belonged to him. 

52. When asked why the currency was separated into different bundles, 

IVORY stated he did not want to carry one large bundle in his pocket so he separated it.

53. IVORY stated he had a clothing business called Pimperelli, but did not 

know the business address or phone number.

54. A check of the Texas Office of the Comptroller and other databases 

revealed Pimperelli, LLC, was registered to Effani Alexander since December 17, 2016. 

55. No other registered agents were listed for Pimperelli, LLC.

56. IVORY claimed they sold clothing via an Instagram account @pimperelli 

or www.pimperelli.com.

57. IVORY stated he started the business with “his boys” two or three years 

ago.

58. IVORY added that he was part of “LACEDFAMTX,” a group he “RAPS 

and PROMOTES” music with.

59. Investigators again asked IVORY how much currency he was carrying and 

he replied, “Honestly, I didn’t count it before I left.”

60. IVORY stated he knew his larger bundle consisted of $5,000 and the 

smaller bundles were $1,000 or $2,000.

61. IVORY could not explain why the bundles were separated into those 

specific amounts.

62. IVORY told investigators he did not have a bank account because he used

his mother’s account. 

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63. IVORY had a Texas identification card rubber-banded to one of the 

currency bundles in his pocket.

64. Investigators asked IVORY how he obtained the currency. IVORY stated 

he saved up $12,000, his mother gifted him with $5,000, and $3,000 belonged to his 

friend “TJ.”

65. IVORY did not know the last name or phone number of his friend TJ.

66. IVORY claimed TJ wanted “Yeezy” Shoes, designer Adidas tennis shoes 

by Kanye West, and they were not sold in Houston.

67. Investigators asked IVORY how he got paid for his clothing line if he did 

not have a bank account or an online payment system like PayPal or Apple Pay. IVORY 

stated he did “hand to hand sales” in the Houston area and “his boy” handled the 

shipping.

68. Investigators asked who actually owned Pimperelli. IVORY stated 

“Probably one of my other boys.”

69. When asked the specific name of “his boys,” IVORY stated “Effani.”

70. When asked what Effani’s last name was, IVORY did not know.

71. IVORY claimed the currency he had was “business money” obtained to 

purchase more merchandise in the garment district of Los Angeles.

72. When asked if the currency belonged to him (IVORY) or belonged to 

Effani, the business owner, IVORY stated it all belonged to him except the $3,000, 

which TJ gave him.

73. Investigators explained to IVORY they were trying to verify how he 

obtained the currency and it was strange he was in business with several people, but did 

not know their last names or contact numbers.

74. Investigators asked IVORY if he filed taxes and he initially stated “Yes,” 

but then admitted Efanni actually filed taxes for Pimperelli.

75. IVORY claimed he gave “his boy” cash for Pimperelli merchandise and he 

(IVORY) sets a price and sells it himself.

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76. IVORY stated he had been selling merchandise since the business was 

established and has earned over $30,000.

77. IVORY told investigators he had never personally filed taxes.

78. IVORY stated he did not have a hotel reservation and could not rent a 

vehicle in Los Angeles because he did not have a driver’s license.

79. IVORY claimed when he arrived, he would just start calling friends 

unexpectedly until someone was available to pick him up from LAX. 

80. IVORY told investigators he had several friends from Houston already in 

Los Angeles and he would just stay where they were staying, or get a hotel room.

81. IVORY could not tell investigators a specific area of Los Angeles he 

planned to stay or shop, but claimed his friends would drive him anywhere he needed to 

go.

82. IVORY later claimed his Houston-based friend “Mya Papaya” was visiting 

her friends in North Hollywood and he would just call her and stay at her friend’s 

apartment unannounced.

83. IVORY stated he needed a lot of cash because California is expensive and 

he had girls and parties to spend money on.

84. When asked why he did not keep the currency in the bank until he needed 

it, IVORY stated he did not have a personal bank account and did not have access to the 

business account.

85. IVORY said he worked with Effani and is paid in cash.

86. IVORY said he “stashes” his money at his house and his mother also saves 

money for him.

87. Investigators asked IVORY if he withdrew the currency he was traveling 

with from the bank. IVORY stated they have their own money and stash it at the house, 

and they do not deposit all the cash into his mother’s bank account.

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88. IVORY stated his mother is a massage therapist.

89. IVORY had one carry-on bag, and gave consent for his carry-on bag to be

searched.

90. During the search, several bundles of currency wrapped with rubber-bands 

were identified inside.

Canine Examination

91. Raven is a two-year old black Labrador Retriever, trained and certified to 

detect the odors of marijuana, cocaine, heroin, and methamphetamine. 

92. Raven is currently certified with the National Police Canine Association 

and last certified on January 23, 2017. Raven has been in service since November 2016.

If at any time during the examination Raven smells one of the odors she is trained to 

detect, Raven will alert with an active alert at the area she smells the odor in and/or on. 

Detective Rodriguez is Raven’s only handler. The search was conducted in the CNIU 

office area.

93. Prior to using Raven to conduct a sniff of the currency, Detective 

Rodriguez had Raven inspect and sniff the area in which the currency was to be placed. 

94. During the initial inspection, Raven did not alert to any of the four odors 

she is trained to detect. Raven was then taken out of the room, taken to a different room 

and placed back in her kennel while investigators cleared the room. 

95. Detective Blaylock and SA Derryberry then placed the currency found

during the investigation, $18,080 in U.S. currency, in a table drawer inside the 

supervisor office that Raven had previously inspected.

96. Raven was then removed from her kennel and brought back into the 

examination room.

97. Detective Rodriguez gave Raven the command to conduct an inspection of 

the area in which the $18,080 in U.S. currency had been placed. 

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98. Raven began searching the items within the office and when she began 

searching the table drawer where the currency was placed, her tail began to wag at a 

rapid pace, her breathing increased, and she began to scratch at the drawer.

99. Detective Rodriguez recognized this behavior as a positive alert indicating 

Raven could smell one or more of the four odors she is trained to detect. 

IVORY’s Continued Interview

100. Detective Rodriguez advised IVORY his narcotic canine gave a positive 

alert on the currency.

101. IVORY stated he had not smoked marijuana in several months, then 

admitted he was recently put back on probation for failing a urine analysis.

102. IVORY claimed to not know his probation officer’s full name or phone 

number, only stating her name was “Ms. Gregor or something like that.”

103. IVORY stated other people around him smoke marijuana, including his 

mother.

104. Investigators asked IVORY again what the total amount of the currency he 

was traveling with was. IVORY stated $12,000 belonged to him and he was certain of 

the amount because he counted it before leaving Houston.

105. IVORY stated his mother gave him $5,000, but he did not count it and TJ 

gave him $3,000. IVORY then stated he should have between $17,000 and $18,000.

106. During the interview, IVORY gave several conflicting stories regarding 

the amount of U.S. currency he was traveling with, the purpose of travel, to whom the 

U.S. currency belonged, where the U.S. currency came from and what the U.S. currency 

was to be used for.

107. IVORY denied investigators consent to view the contents of his cell phone 

after they explained they wanted to look through his texts and pictures for drug sale 

activity, which could implicate or exculpate him.

108. A check of IVORY’s cellular number XXX-XXX-9634 showed it is linked 

to the Facebook page “You Kno’It” Patrick Ivory.

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109. A picture of IVORY with a large amount of $100 bills was posted on the 

page.

110. Investigators verified a total amount of $18,080 in U.S. currency.

111. Investigators advised IVORY the currency would be impounded pending 

an investigation. 

112. The $18,080.00 in United States currency was seized on September 19, 

2017. 

The J’Mulan Agency

113. On September 20, 2017, CNIU received an email from Jaleks Holman of 

The J’Mulan Agency, claiming IVORY is a full-time employee working as an event 

coordinator. 

114. IVORY never mentioned his employment with The J’Mulan Agency 

during his contact with investigators. 

115. Holman attached two paychecks listing IVORY’s purported earnings, but 

the checks appeared to have been fabricated. 

116. Research of The J’Mulan Agency revealed there was no tax identification 

number.

117. Research also revealed there were no business affiliations discovered for 

Jaleska Holman.

118. When investigators searched the address printed on the pay stub for 

J’Mulan Agency, 6009 Richmond Ave., Houston TX 77057, the J’Mulan Agency could 

not be found.

119. The address 6009 Richmond Ave., Houston TX 77057, was a large 

building with a couple of businesses.

120. Investigators could not find J’Mulan and asked the current tenants. The 

current tenants had never heard of J’Mulan.

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121. The second address listed on the pay stub for J’Mulan Agency was 8795 

Antoine Dr. #107, Houston TX 77057. Investigators visited this address which was 

occupied by “Barber School Student Barbers,” but no J’Mulan was found or known.

Claim filed by IVORY

122. On or about November 2, 2017, the United States Customs and Border 

Protection received a claim, dated October 30, 2017, from IVORY along with a cover

letter from attorney Jennifer R. Grant, claiming IVORY was the legal and rightful owner 

of the $18,080 in U.S. currency.

IVORY’s Criminal History

123. IVORY has been arrested and/or charged with multiple offenses, including 

burglary, evading arrest, possession of marijuana and tampering/fabricating evidence. 

On or about July 22, 2015, IVORY was arrested by the Houston Police Department for 

Possession of Marijuana, 2 oz., was convicted on October 13, 2015, and was sentenced 

and fined.

124. On or about November 29, 2015, IVORY was arrested by the Houston 

Police Department in Texas for Tampering/Fabricating Physical Evidence and 

Possession of Marijuana 2 oz. IVORY was convicted on March 4, 2016, for Possession 

of Marijuana 2 oz., and sentenced and fined.

125. On or about November 6, 2016, IVORY was arrested by the Hempstead 

Police Department in Texas for Possession of Marijuana, 2 oz. 

 Wage and Employment Investigation

126. Investigators ran a query of IVORY’s employment history. Texas 

employment database showed no record of employment history for IVORY.

IVORY’s Flights to Los Angeles, CA

127. On July 27, 2017, IVORY flew from Los Angeles to Houston on flight 

#6038, a direct flight.

128. On August 25, 2017, IVORY flew from Houston to Los Angeles on flight 

#6064, a direct flight.

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129. On September 28, 2017, IVORY flew from Houston on flight #531 to Los 

Angeles with a stop in Phoenix, AZ.

130. On September 19, 2017 (day after interdiction at Phoenix), IVORY flew 

on a return flight from Los Angeles to Houston on flight #6038.

131. During his interview on September 18, 2017, IVORY stated he was 

traveling to Los Angeles to go shopping, visit some friends for a couple days and to 

celebrate his birthday on September 22, 2017.

132. However, from the time IVORY landed in Los Angeles on September 18, 

2017, at 3:34 p.m. to the time he departed Los Angeles on September 19, 2017, IVORY 

was in Los Angeles a total of 27 hours and 6 minutes, contradicting IVORY’s statement 

regarding the purpose and scheduled time of his travel.

Demand/Source Relationship

133. A demand/source relationship exists between Houston, Texas, and 

southwest states relating to the distribution of illegal drugs. Drug money couriers

commonly travel from the states such as Texas to Arizona and California for the purpose 

of transporting currency intended to be used to purchase illicit drugs. Due to its close 

proximity to the U.S./Mexico border, Phoenix and Los Angeles are supply locations for 

the distribution of illegal drugs throughout the United States. 

Seizure of Currency

134. The following represents a breakdown of the $18,080 in U.S. currency 

carried by IVORY:

Number of Bills Denomination Amount

65 $ 100.00 $ 6,500.00

4 $ 50.00 $ 200.00

540 $ 20.00 $ 10,800.00

58 $ 10.00 $ 580.00

Total: $ 18,080.00

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135. Twenty dollar bills are the most common denomination of currency used 

by drug traffickers and those who launder the proceeds of drug trafficking.

136. Moreover, the defendant currency was bundled in a manner that is similar 

to how drug traffickers routinely bundle their drug proceeds.

FIRST CLAIM FOR RELIEF

The defendant currency was furnished or intended to be furnished by a person in

exchange for a controlled substance or listed chemical in violation of Title II of the 

Controlled Substances Act, 21 U.S.C. ' 801 et seq., constitutes proceeds traceable to such 

an exchange, or was used or intended to be used to facilitate a violation of Title II of the 

Controlled Substances Act, 21 U.S.C. ' 801 et seq., or is property involved in a money 

laundering transaction or attempted transaction and therefore subject to forfeiture to the 

United States pursuant to 18 U.S.C. ' 981(a)(1)(A) and 21 U.S.C. § 881(a)(6).

SECOND CLAIM FOR RELIEF

The defendant currency constitutes or is derived from proceeds traceable to a 

violation of, among other things, a specified unlawful activity and travel in interstate 

commerce to distribute the proceeds of, and promote or facilitated the promotion of, an 

unlawful activity and therefore subject to forfeiture pursuant to 18 U.S.C. § 981(a)(1)(C).

WHEREFORE, the United States of America prays that process of warrant in 

rem issue for the arrest of the defendant currency; that due notice be given to all parties 

to appear and show cause why the forfeiture should not be decreed; that judgment be 

entered declaring the defendant currency be forfeited to the United States of America for

/ / /

/ / /

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disposition according to law; and that the United States of America be granted such 

other and further relief as this Court deems just and proper, together with the costs and 

disbursements of this action.

DATED this 24th day of January, 2018. 

ELIZABETH A. STRANGE

First Assistant United States Attorney

District of Arizona

S/ Mark J. Wenker

MARK J. WENKER

Assistant United States Attorney

Case 2:18-cv-00253-JJT Document 1 Filed 01/24/18 Page 16 of 16
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