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ELIZABETH A. STRANGE

First Assistant United States Attorney

District of Arizona

MARK J. WENKER 

Assistant U.S. Attorney 

Arizona State Bar No. 018187

Two Renaissance Square

40 North Central Avenue, Suite 1800

Phoenix, Arizona 85004-4408 

Telephone: (602) 514-7500

mark.wenker@usdoj.gov

Attorneys for Plaintiff

UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

United States of America,

 Plaintiff,

v.

$50,200.00 in United States Currency,

 Defendant In Rem.

VERIFIED COMPLAINT FOR 

FORFEITURE IN REM

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”):

NATURE OF THE ACTION

1. This is a civil action in rem to forfeit property to the United States pursuant 

to 21 U.S.C. § 881(a)(6) 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., or 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.

2. This is a civil action in rem to forfeit property to the United States pursuant 

to 18 U.S.C. §§ 981(a)(1)(A) and (C) because it is property involved in a transaction or 

attempted transaction in violation of 18 U.S.C. §§ 1956 and 1957 and because it 

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constitutes or is derived from proceeds traceable to a violation of a specified unlawful 

activity, including 18 U.S.C. § 1952 and 21 U.S.C. § 841. 

3. This Court has jurisdiction because the United States commenced this 

action and because it seeks forfeiture. 28 U.S.C. §§ 1345, 1355. Venue is proper in this 

District because acts or omissions giving rise to forfeiture occurred in this District and 

because the defendant property is located in this District. 28 U.S.C. §§ 1355(b), 1395(b).

THE DEFENDANT IN REM

4. The defendant consists of $50,200.00 in United States currency (the 

“Defendant Property”) seized by the Drug Enforcement Administration (“DEA”) on May 

26, 2017.

FACTS

Seizure of $50,200.00 in United States Currency

5. On May 26, 2017, law enforcement in Pittsburgh, Pennsylvania, notified

DEA agents and task force officers (“Investigators”) in Phoenix, Arizona, that a passenger 

by the name of Miguel Flores (“Flores”) was traveling aboard American Airlines Flight 

528 from Pittsburgh to Phoenix Sky Harbor International Airport with $50,000.00.

According to the tip, Flores admitted to Transportation Security Administration workers in 

Pittsburgh that he had a total of $50,000.00 cash in a black carry-on bag in the pockets of 

two pairs of pants, as well as some money on his person.

6. Pittsburgh law enforcement further advised that $34,110.00 of suspected 

drug proceeds had been seized from Flores at Phoenix Sky Harbor International Airport

on October 7, 2014. 

7. Based upon their training and experience, Investigators knew that it is

common for drug dealers to transport large amounts of currency from drug demand areas 

(such as Pennsylvania) to drug source areas (such as Arizona).

8. A records search also revealed that Flores had a criminal history that 

included arrests for possession of marijuana, drug paraphernalia, theft, and assault. Based 

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upon their training and experience, Investigators knew that drug and/or drug currency 

couriers often have criminal pasts.

9. Based on this information, Investigators decided to contact Flores upon his 

arrival in Phoenix.

10. At approximately 7:00 p.m., Investigators responded to Terminal 4, Gate 

A2, and observed a man (later confirmed to be Flores) exit the above-mentioned flight. 

Investigators initiated a consensual conversation with Flores. Flores advised that he had

$50,000.00 in his carry-on bag.

11. According to Flores, the money was given to him by his mother and he was 

going to use it to purchase a car for his father. He would drive the newly-purchased 

vehicle to Las Vegas, Nevada, from Arizona, and then decide whether or not he would 

drive the car to Ohio or transport it back there some other way.

12. When asked, Flores stated that the vehicle he intended to buy was a 2010 

GMC Sierra Denali truck for $42,000.00. One of the Investigators said that $42,000.00

was a rather high price for such an old vehicle, but Flores said that even though it was 

“pricey,” that is what they were selling for at this time. Flores said he had spoken to the 

seller earlier in the day, and that he could later provide the Investigators with the seller’s 

contact information. Flores said the Investigators could then call the seller and confirm 

Flores’ account.

13. Flores said that he did not have his mother’s phone number.

14. Flores said he had never been contacted by law enforcement at the airport 

in the past regarding the transportation of large sums of currency (which the Investigators 

knew to be untrue based upon the October 7, 2014 seizure of $34,110.00).

15. Flores also said he had never been arrested (which Investigators also knew 

to be untrue).

16. Flores then voluntarily agreed to leave the public area of the terminal and 

go to Commercial Narcotics Interdiction Unit (“CNIU”) office to discuss the currency in 

more detail.

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17. While walking to the office, Flores stated that he had worked as a parts 

manager in the past, but that he was currently unemployed. Flores said he never had any 

other type of work. Flores also told the Investigators that the currency would be in his 

carry-on bag, in the pockets of two pairs of pants.

18. Investigators were aware that in the 2014 seizure Flores also concealed 

currency in pants pockets inside his luggage. In the 2014 incident, however, Flores had 

said that he made a living selling cars as well as selling parts.

19. When Flores was asked what the denominations of the currency would be, 

he nervously replied they were primarily $20 bills, though about $5,000.00 was in $50 

bills as well. 

20. Investigators knew that $20 bills are the most common denomination used 

in street-level drug transactions. They presumed that Flores reacted nervously because he 

knew this as well.

21. Flores then said he was not sure about the denominations of the money and 

that his mother had just handed him the cash today in a bank bag. He said his mother 

would verify his story regarding his receipt of the currency from her.

22. Flores said he had removed the money from the bank bag and put it in the 

pants pockets, and then put the pants in his carry-on bag. He said he did it this way so the 

money would not all be in one place.

23. Flores said neither he nor the currency had been around any illegal drugs.

24. The Investigators took photos of the currency found in the pants pockets. 

Investigators noted that one of the pairs of pants seemed much larger than anything that 

would fit Flores. Flores said the larger pants belonged to his father.

25. Flores was carrying 17 $100 bills and 20 $10 bills on his person, as well as 

a driver’s license in the name of Crystal Ramirez (“Ramirez”). Flores said the money 

found on his person was spending money and that he keeps his girlfriend’s driver’s license 

because she always loses things.

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26. Flores said that his parents still owned the Arizona residence listed on his 

Arizona driver’s license, and that he stayed in that house whenever he visited his children 

in Arizona. He said his children were five and seven years old. The majority of the time, 

however, he said he lived with his parents at their residence located at 7396 Tiffany South, 

Youngstown, Ohio. He said his parents had just moved there five or six months earlier.

27. Flores said that his mother’s name was Lucia Flores and that his father’s 

name was Victor Flores.

28. When asked whether or not Flores was required to pay child support, Flores 

said he was supposed to pay $900.00 per month, but that he was unable to do so since he 

was unemployed.

29. When Investigators requested that Flores contact his mother so she could 

confirm his story, Flores said he had just gotten a new phone and that his mother’s number 

was not in it.

30. Flores stated that he had bought the $485.00 one-way ticket today and paid 

for it on Ramirez’ credit card. 

31. Investigators thought it was odd that Ramirez was paying for the flight 

instead of Flores’ father, since the primary purpose of Flores’ travel was to buy a vehicle 

for his father.

32. Also, based on training and experience, Investigators knew that it was 

common for passengers carrying drugs and/or drug proceeds to buy one-way tickets 

utilizing third-party credit cards in the names of others just a day or two before travel, to 

conceal their identities and minimize their exposure to commercial airlines and law 

enforcement. 

33. When questioned about the potential truck purchase, Flores claimed he had

spoken to the seller on the phone about the vehicle before coming to look at it. He further 

claimed he and the seller had exchanged text messages, too. However, when asked again 

what year the GMC Denali was, Flores seemed confused, stating it was a 2010, and then a 

2016, and finally said, “I don’t know.”

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34. The Investigators then watched as Flores looked at his phone and appeared 

to be pretending to scroll through text messages. Investigators believed Flores’ actions 

were a farce, and asked him if they could see his phone and read his text messages. Flores 

refused.

35. Flores could not provide any specific information regarding the vehicle 

purchase or the name and contact information of the seller (such as a phone number, 

website, or e-mail address). 

36. At this point the conversation between Flores and the Investigators became 

somewhat contentious as the Investigators told Flores that they thought he was lying about 

his criminal history as well as a previous money seizure. The Investigators then told 

Flores about his previous arrest record and the $34,110.00 seizure in 2014.

37. Flores’ body language and facial expression changed immediately and he 

appeared very nervous when the 2014 seizure was mentioned. 

38. Flores then became defensive and told the Investigators that he had a 

previous head injury involving a coma and that he did not remember the specifics of the

2014 incident. Additionally, he avoided talking about his earlier arrests, other than to state 

that they were not serious offenses and that they had happened when he was much 

younger. Flores further said he did not recall ever receiving any correspondence from the 

government regarding the $34,110.00 seized.

39. Investigators asked Flores how he would inform his mother about how he 

would transport the newly purchased vehicle to Ohio when he arrived in Las Vegas if he 

did not have her phone number. Flores did not give a response.

40. Strangely, however, Flores said that he did not have his father’s phone 

number either, but then changed his story and stated that he did have it, but would not give 

it to the Investigators.

41. Flores then received an incoming call from Ramirez on his phone that went 

unanswered. An Investigator, however, called Ramirez back and asked her questions 

about Flores.

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42. Ramirez confirmed that Flores was her boyfriend, but appeared hesitant and 

afraid to talk to the Investigator. Ramirez said she did not get involved in Flores’ business 

and that he did not tell her anything. She said Flores was there for the long holiday 

weekend and that he intended to visit their kids. She said Flores would stay at her home, 

but that they did not have any plans to go anywhere.

43. Flores also had a second phone, but he would not allow Investigators to 

look into this second phone either, so both his phones were seized and impounded as 

evidence.

44. Drug dealers commonly have multiple telephones to avoid detection by law 

enforcement and to assist in the trafficking of drugs and drug proceeds.

45. Flores was advised that the currency on his person and in the carry-on was 

being seized as the proceeds of drug trafficking. After an official count the Defendant 

Property was found to be $50,200.00 in United States currency. The Defendant Property 

was made up of 100 $100 bills, 200 $50 bills, 1,500 $20 bills, and 10 $10 bills.

46. When advised that the currency, both on his person as well as in his 

luggage, would be subjected to an examination by a trained narcotics canine, Flores 

appeared to be more concerned about the smaller amount being retrieved from his person, 

than the larger amount found in his carry-on bag.

47. Investigators believed this was because the currency on Flores’ person was 

likely his payment for transporting drug proceeds, while the currency in the carry-on was 

to be used solely for the purchase of drugs.

Positive Alert to $50,200.00 in U.S. Currency by Certified Narcotics Detection Canine

48. On May 26, 2017, Phoenix Police Department Detective Michael Oolman 

and his certified narcotics detection canine, Zadie, were asked to assist with the 

investigation of the Defendant Property.

49. Zadie is a three-year old Labrador/Pointer mix. She is trained and certified 

to detect the odors of marijuana, cocaine, heroin, and methamphetamine, and their 

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derivatives. Zadie is currently certified with the National Police Canine Association, and 

was last certified on January 2017.

50. Zadie does not alert to the odor of currency unless that currency has been in 

recent close proximity to a substance Zadie is trained to detect and, therefore, Zadie is a 

“sophisticated drug dog” and a positive alert is “strong evidence” of a connection to drug 

trafficking. See United States v. $132,245.00 in U.S. Currency, 764 F.3d 1055, 1058-59 

(9th Cir. 2014).

51. If at any time during a search Zadie smells one of the four odors she is 

trained to detect, or their derivatives, her behavior changes as she becomes excited, wags 

her tail, scratches at the item with the odor in and/or on it, and sits down. Detective

Oolman is Zadie’s only handler.

52. An area was set up in CNIU’s office located in Terminal 4 to conduct the 

drug examination by Zadie. The office area included numerous desks, file cabinets, and 

other miscellaneous items. Zadie was brought into the office and given the command to 

sniff the area. All items were sniffed and there were no alerts during the clearing. Zadie 

was placed into her kennel in a separate area.

53. The Defendant Property was then put inside a drawer in the previously 

cleared area. Zadie was brought back into the cleared area and given the command by 

Detective Oolman to search. At 7:41 p.m. Zadie’s behavior changed as she became 

excited, wagged her tail, scratched, and sat down near the drawer with the Defendant 

Property in it. Detective Oolman recognized Zadie’s change in behavior as a positive alert, 

meaning Zadie smelled one of the odors she was trained to detect.

Earlier Airport Seizure of $34,110.00 from Flores - October 7, 2014

54. On October 7, 2014, law enforcement in Phoenix received a tip that Flores 

had purchased a one-way ticket from Pittsburgh to Phoenix Sky Harbor International 

Airport within the past 24 hours.

55. A records check revealed Flores had numerous juvenile and adult arrests in 

Arizona.

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56. Contact was made with Flores when he arrived at Phoenix Sky Harbor

International Airport, Terminal 2, from Pittsburgh. 

57. Flores claimed he had neither drugs nor currency in his possession.

58. Flores consented to a search of his two bags. During the search law 

enforcement found several bundles of currency inside a packed pair of pants in the 

pockets.

59. Flores agreed to accompany law enforcement to its office to discuss the 

currency. Flores said the source of the currency was his savings, sales from his business 

(Flores Auto Sales), income from a separate job working at an auto parts warehouse, and 

his father’s Social Security benefits.

60. Flores, however, said he had not been able to work in several months 

because he had a brain surgery about six months earlier. He said he had injured his head in 

an ATV accident. This statement is inconsistent with Flores’ statements during the May 

26, 2017 seizure when he inferred that he suffered a brain injury after the October 2014 

seizure, which is supposedly why he could not remember the $34,110.00 being seized.

61. Flores initially said the currency totaled $9,000.00, but later said it was a 

little more than $30,000.00. A count of the funds revealed it was $34,110.00 in United 

States currency.

62. Flores said he had withdrawn $27,000.00 from his business account about a 

month ago, and that the bulk of the $34,110.00 came from that withdrawal.

63. Flores gave conflicting stories regarding why he was carrying the 

$34,110.00 in cash. Initially he said he had flown to Pittsburgh to visit his daughter in the 

hospital in Pennsylvania. He said the money was to be used to pay her medical bills, but 

his daughter’s mother had a restraining order against him, and the hospital would not let 

him on the premises. Thus, he flew back to Phoenix with the money. Later, however, he 

said part of the money was for medical bills and the rest was to help pay for his move to 

Pittsburgh so he could be closer to his daughter in Pennsylvania.

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64. Flores could not remember the name of the facility where his daughter was 

hospitalized.

65. The $34,110.00 was seized as the proceeds of drugs trafficking.

66. A certified narcotics canine alerted to the $34,110.00.

67. A financial background check revealed no business by the name of Flores 

Auto Sales registered with the Arizona Corporation Commission nor banking activity by a 

company of that name.

68. The $34,110.00 was administratively forfeited by the DEA on February 11, 

2015.

Later Airport Money Seizure of $50,000.00 (from Ramirez) – October 17, 2017

69. On October 17, 2017, just five months after the Defendant Property was 

seized from Flores, Investigators received a tip that Flores’ girlfriend, Ramirez, was 

traveling with Flores from Charlotte, North Carolina, to Phoenix Sky Harbor International 

Airport on one-way tickets purchased by Flores within the past 24 hours of travel. Flores 

and Ramirez were assigned seats next to each other.

70. Investigators were aware that Flores had two previous airport cash seizures 

and a criminal background involving drug-related arrests.

71. Investigators in Phoenix attempted to make contact with both Flores and 

Ramirez as they each exited the airplane at Phoenix Sky Harbor International Airport and 

approached the baggage return area. Ramirez exited first, and went directly to the baggage 

return area. Flores exited a few minutes later. Flores appeared to have recognized one of 

the Investigators from the earlier May 26, 2017 seizure, and upon doing so, abruptly 

headed into a nearby elevator away from the baggage claim area. Investigators were 

unable to find Flores.

72. Ramirez retrieved her luggage from baggage claim and was approached by 

Investigators.

73. Ramirez claimed to be flying home alone after a trip to North Carolina for 

fun. She said she had been there for the weekend.

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74. Ramirez stated that she had booked her travel, even though Investigators 

knew Flores had. 

75. Ramirez claimed she was not traveling with drugs or a large amount of 

currency and consented to a search of her bag. A bundle of currency was found in the 

pockets of a pair of pants in her bag.

76. When confronted with the facts that Flores had indeed reserved the flight

and traveled with her, and that they had found currency in her bag, she shrugged her 

shoulders.

77. She said that money amounted to about $20,000.00.

78. Ramirez said she had earned the money as a stripper during her trip. After 

several variations of her story regarding the source of the money (meeting people at golf 

tournaments and going to Pittsburgh to do some sort of job), she eventually claimed it was 

all made at one party as a stripper.

79. Ramirez claimed that she paid taxes on $43,000.00 in income in 2016, but 

then said she could not remember where she had worked. When challenged about the 

absurdity of not recalling her employment from the previous year, she told Investigators 

she had worked as a waitress and at a call center for Charles Schwab through a temp 

agency.

80. Ramirez continued to laugh at different times throughout the interview as 

if the situation was a joke.

81. When asked why she did not wait for Flores when he got off the plane, she 

said she was “done with him and this whole thing” and that he was “a liar.”

82. Investigators believed the “whole thing” Ramirez was referring to was 

Flores’ drug-related smuggling of currency.

83. The currency was seized and found to be $50,000.00. 

84. A trained and certified narcotics canine alerted to the currency.

85. When informed, Ramirez did not seem concerned that the $50,000.00 was 

being seized by law enforcement.

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86. The Maricopa County Attorney’s Office is currently in the process of 

forfeiting the $50,000.00 as the proceeds of drug trafficking.

Criminal Histories

87. Flores was arrested for Theft (2009), Marijuana Use and Drug 

Paraphernalia Possession/Use (2012), Driving with a Suspended/Revoked/Cancelled 

License (August 2014), Criminal Damage (November 2014), Failure to Appear (2015), 

Assault – Intent/Reckless/Injure Victim Domestic Violence (2016), Aggravated Assault 

(June 2017), and First Degree Murder (November 2017).

88. Ramirez was arrested on July 4, 2014 for Exceeding 85 Miles Per Hour and 

on July 16, 2014 for Driving with a Revoked/Suspended/Cancelled License.

Financial Histories

89. According to records from the Arizona Department of Economic Security

(“DES”), neither Flores nor Ramirez has reported any income since the first quarter of 

2016.

90. According to federal tax returns, Flores earned $32,903.00 in 2013 and 

$6,607.00 in 2014. Flores’ attorney said the reason Flores’ 2014 income was so small was 

because Flores had a brain injury part way through that year and was not able to work the 

remainder of 2014.

91. Flores also told his attorney that, other than the period of his recovery from 

his brain injury, he had worked “his entire life” and had filed tax returns since 2014 as 

well. However, Flores was unable to provide any additional tax returns to the government 

before the filing of this complaint.

92. Flores alleged that he had significant income from 2015 to 2017 is 

contradicted by information provided from DES (showing he had not had any income 

since the first quarter of 2016) as well as Flores himself (who told Investigators on May 

26, 2017 that he was unemployed).

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Administrative Claim

93. On October 11, 2017, the DEA received a valid administrative claim to the 

Defendant Property from Flores.

94. In the claim Flores asserted that he was the owner of the property.

95. Flores also alleged that the Defendant Property came from a portion of the 

Social Security death benefits Flores received when his father, Victor Manuel Flores

(“Victor Flores”), died on July 7, 1995.

96. Flores said he received these benefits from 1995 (when he was four-years 

old) until 2009 (when he turned 18).

97. Flores said that because he was a minor, his mother, Lucia Vasquez Flores

(“Lucia Flores”) received the benefits on his behalf.

98. Flores said that for 15 years (1995 to 2009) his mother cashed these Social 

Security benefits, put the cash into a safe, and never spent any of it. He said that by 2009 

the money in the safe from the Social Security benefits totaled $75,010.00.

99. Flores claimed that when he turned 18, in 2009, he asked his mother to 

continue to keep the $75,010.00 in the safe for him because he did not need it at that time.

100. According to Flores, about two months before the $50,200.00 was seized, 

he asked his mother to give him $60,000.00 from the safe. He said he intended to use the 

money to “buy property or a classic car as an investment” (which contradicted what he 

told Investigators at the time of the seizure about purchasing a car for his father).

101. Flores claimed that the “money is not the proceeds of anything illegal.”

102. Flores provided records detailing the Social Security benefit payments he 

received:

Year Amount

1995 $2,230.00

1996 $5,484.00

1997 $5,640.00

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1998 $5,400.00

1999 $4,380.00

2000 $4,488.00

2001 $4,656.00

2002 $4,764.00

2003 $4,431.00

2004 $3,948.00

2005 $4,140.00

2006 $5,268.00

2007 $8,556.00

2008 $9,192.00

2009 $2,433.00

Total $75,010.00

103. On October 19, 2017, the DEA referred the forfeiture to the United States 

Attorney’s Office – District of Arizona for judicial processing.

104. The undersigned was contacted by Flores’ attorney and requested 

documentation demonstrating how Flores could have sufficient, legitimate income to pay 

his living expenses and to accumulate the approximate $134,000.00 that had been seized. 

Flores was unable to provide such documentation. 

105. The seized money, including the Defendant Property, could not have come 

from a legitimate source. Even though Flores appeared to have received a total of 

$75,010.00 from 1995 to 2009 in Social Security payments, to assume that none of the 

money was spent in the past eight years (since 2009), let alone the past 22 years (since 

1995) appears extremely unlikely, and is unreasonable.

106. Most reasonable people would deposit $75,010.00 cash into a bank account 

instead of holding it in a safe for more than 20 years. Also, most people, especially those 

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with limited income such as Flores, typically do not acquire such a significant amount of 

money and not spend it over such a lengthy period of time.

107. The table below shows the seizures connected to Flores, as well as his 

income since that time:

Date Seizure Amount Income

2013 - $32,903.00

2014 $34,110.00 $6,607.00

2015 - No Records

2016 - No Reported Income 

Since the First 

Quarter of 2016

2017 $100,200.00* No Reported 

Income

Totals $134,310.00 $39,510.00

*This is the total of the two 2017 seizures ($50,200.00 on May 26, 2017 and $50,000.00 on October 17, 

2017).

108. Based on the Investigators’ training and experience, the Defendant Property 

(which was part of the $134,310.00 alerted to by trained and certified narcotics canines 

and found to have several suspicious indicators) was the product of drug trafficking, and 

not legitimate earnings.

Summary

109. The following are some of the factors that demonstrate that the Defendant 

Property was the proceeds of drug trafficking, that it was involved in drug trafficking, and

that it facilitated drug trafficking:

a. Flores traveling from a drug demand area (Pennsylvania) to a drug source 

area (Arizona) on May 26, 2017, on a one-way ticket purchased on the date 

of travel by his girlfriend Ramirez;

b. The nature in which the Defendant Property was concealed (bundles of 

cash hidden in the pockets of pants);

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c. The primary denomination of the Defendant Property ($20 bills);

d. Flores having a criminal history involving drugs and violence;

e. Flores’ numerous false statements during the May 26, 2017 incident 

(according to Flores, he did not have a criminal record, had not had money 

seized from him in the past, did not have money that had been near illegal 

drugs, could provide contact information for his mother and the seller of the 

car, was buying a vehicle for his father (Victor Flores), and his father was 

alive – all of which later proved to be false);

f. The alert to the Defendant Property by a trained and certified narcotics 

canine;

g. Two similar seizures of currency to that of the May 26, 2017 seizure of the 

Defendant Property involving Flores ($34,110.00 seized from Flores in 

2014 and $50,000.00 seized from his girlfriend, Ramirez, on October 17, 

2017, whom Flores was traveling with at the time. In both the October 2014 

and October 2017 seizures, the tickets were one-way purchases made 

within 48 hours of travel, the bundles of currency were alerted to by trained

and certified narcotics canines, the flights were coming from drug demand 

areas to drug source areas, the stories regarding the source and purpose of 

the currency were suspicious and nonsensical, the currency seized was 

primarily made up of $20 bills, and the currency was bundled inside of 

pants); and

h. Flores’ lack of a legitimate source of income.

FIRST CLAIM FOR RELIEF

110. The Defendant Property 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., or is proceeds traceable to such 

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

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Controlled Substances Act, 21 U.S.C. § 801 et seq., and therefore is subject to forfeiture to 

the United States pursuant to 21 U.S.C. § 881(a)(6).

SECOND CLAIM FOR RELIEF

111. The Defendant Property is property which was involved in a transaction or 

attempted transaction in violation of 18 U.S.C. §§ 1956 and 1957 and constitutes or is 

derived from proceeds traceable to a violation of a specific unlawful activity, including, 

among other things, 18 U.S.C. § 1952 and 21 U.S.C. § 841, and therefore is subject to 

forfeiture to the United States pursuant to 18 U.S.C. §§ 981(a)(1)(A) and (C).

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

issue for the arrest of the defendant property; 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 property be forfeited to the United States of America for 

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

and further relief as this Court may deem just and proper, together with the costs and 

disbursements of this action.

Respectfully submitted this 

January 26, 2018.

ELIZABETH A. STRANGE

First Assistant United States Attorney

District of Arizona

S/Mark J. Wenker

MARK J. WENKER

Assistant United States Attorney

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Case 2:18-cv-00280-GMS Document 1-1 Filed 01/26/18 Page 1 of 1
UNITED STATES DISTRICT COURT

DISTRICT OF ARIZONA

Civil Cover Sheet

This automated JS-44 conforms generally to the manual JS-44 approved by the Judicial Conference of the United States in 

September 1974. The data is required for the use of the Clerk of Court for the purpose of initiating the civil docket sheet. 

The information contained herein neither replaces nor supplements the filing and service of pleadings or other papers as 

required by law. This form is authorized for use only in the District of Arizona.

The completed cover sheet must be printed directly to PDF and filed as an 

attachment to the Complaint or Notice of Removal.

Plaintiff

(s): United States of America Defendant(s):

$50,200.00 in United States 

Currency 

County of Residence: Maricopa County of Residence: Maricopa

County Where Claim For Relief Arose: Maricopa

Plaintiff's Atty(s): Defendant's Atty(s):

Mark J. Wenker , AUSA

40 N. Central Ave. Ste. 1800

Phoenix, Arizona 85004

602 514-7500

II. Basis of Jurisdiction: 1. U.S. Government Plaintiff

III. Citizenship of Principal 

Parties (Diversity Cases Only)

Plaintiff:-N/A

Defendant:-N/A

IV. Origin : 1. Original Proceeding

V. Nature of Suit: 625 Drug Related Seizure of Property 21 USC 881

VI.Cause of Action: Forfeiture in Rem

VII. Requested in Complaint

Class Action:No

Dollar Demand:

Jury Demand:No

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Case 2:18-cv-00280-GMS Document 1-2 Filed 01/26/18 Page 1 of 2
VIII. This case is not related to another case. 

Signature: s/ Mark J. Wenker

Date: 01/26/2018

If any of this information is incorrect, please go back to the Civil Cover Sheet Input form using the Back button in 

your browser and change it. Once correct, save this form as a PDF and include it as an attachment to your case 

opening documents. 

Revised: 01/2014

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