Feds Seize $400k Allegedly Connected To Illegal Grows in Sacrameto

Case 2:18-cv-01684-JAM-AC Document 1 Filed 06/08/18 Page 1 of 9
1 McGREGOR W. SCOTT
United States Attorney
2 KEVIN C. KHASIGIAN
Assistant U. S. Attorney
3 501 I Street, Suite 10-100
Sacramento, CA 95814
4 Telephone: (916) 554-2700
5 Attorneys for the United States
8 IN THE UNITED STATES DISTRICT COURT
9 EASTERN DISTRICT OF CALIFORNIA
10
11 UNITED STATES OF AMERICA,

12 Plaintiff,
VERIFIED COMPLAINT FOR
13 v. FORFEITURE IN REM
14 APPROXIMATELY $383,040.00 IN U.S.
CURRENCY, and
15
APPROXIMATELY $7,0000.00 IN MONEY
16 ORDERS,
17 Defendants.
18
19 The United States of America, by and through its undersigned attorney, brings this complaint
20 and alleges as follows in accordance with Supplemental Rule G(2) of the Supplemental Rules for
21 Admiralty or Maritime Claims and Asset Forfeiture Action:
22 NATURE OF ACTION
23 1. This is a civil action in rem to forfeit to the United States Approximately $383,040.00 in
24 U.S. Currency and Approximately $7,000.00 in Money Orders (hereafter collectively “defendant
25 assets”) involved in violations of federal drug and money laundering laws.
26 2. The defendant $383,040.00 and defendant money orders were seized from Tan Jiang
27 (“Jiang”) and Jing Jing Chen (“Chen”) on January 24, 2018 at the Sacramento International Airport.
28 The defendant assets are in the custody of the U.S. Marshals Service, Eastern District of California.
1
Verified Complaint for Forfeiture In Rem
1 JURISDICTION AND VENUE
2 3. This Court has jurisdiction over an action commenced by the United States under 28
3 U.S.C. § 1345, over an action for forfeiture under 28 U.S.C. § 1355(a), and over this particular action
4 under 21 U.S.C. § 881.
5 4. This district is a proper venue pursuant to 28 U.S.C. § 1355 because the acts giving rise
6 to this in rem forfeiture action occurred in this district, and pursuant to 28 U.S.C. § 1395 because the
7 defendant currency was seized in this district.
8 FACTUAL ALLEGATIONS
9 5. On January 24, 2018, Jiang and Chen traveled on Southwest Airlines Flight 495 from
10 Brooklyn, New York to Sacramento, California, with a layover in Denver, Colorado. Agents with the
11 Drug Enforcement Administration (“DEA”) received information regarding suspicious travel by Jiang,
12 indicating that he purchased a one-way ticket from New York to Sacramento the day before and was
13 traveling with no checked luggage.
14 6. Law enforcement responded to the Sacramento International Airport and waited for
15 Jiang near the gate for Southwest Airlines Flight 495. Law enforcement observed Jiang exit the gate
16 and proceed towards the terminal exit, at which time law enforcement approached Jiang—he was alone
17 at this time. Law enforcement agents, with their badges in plain view, approached Jiang, verbally
18 identified themselves as law enforcement officers, and asked permission to speak with him about his
19 travel. Jiang agreed to the conversation and told law enforcement he was traveling alone and was not
20 carrying anything illegal. Jiang consented to a law enforcement search of his sole piece of carry-on
21 luggage, a rolling suitcase. The search of Jiang's carry-on rolling suitcase revealed nothing of
22 evidentiary value.
23 7. When law enforcement approached Jiang, they observed an Asian female, later
24 identified as Chen, Tan Jiang's purported wife, stare intently at the conversation as she walked by and
25 then proceeded to rapidly move away from the area. After the law enforcement concluded their
26 conversation with Jiang, they relocated Chen who was walking in an erratic manner around the airport
27 terminal before eventually walking towards the terminal exit with Jiang. Law enforcement, with their
28 badges in plain view, then approached Chen, verbally identified themselves as law enforcement
2
1 officers, and spoke with her about staring at their prior conversation with Jiang and her subsequent
2 rapid movement away from that area. Law enforcement asked Chen is she was traveling alone; Chen
3 could not form an audible response because she appeared to be hyperventilating and near fainting.
4 Law enforcement instructed Chen to calm down and restore normal breathing patterns. Law
5 enforcement then addressed Chen and Jiang, who had joined the conversation, and asked if the pair
6 knew each other. Jiang responded that he and Chen were “husband and wife.” Jiang was asked why he
7 told law enforcement was traveling by himself if he was, in fact, traveling with his wife. Jiang gave no
8 discernible response. Law enforcement then asked Chen if they could search her three items of carry-
9 on luggage, a grey and black rolling suitcase, a grey and black "Swiss-Legend" brand backpack, and a
10 small black backpack. Chen consented to law enforcement searching her carry-on bags.
11 8. The search of Chen’s "Swiss-Legend" black backpack revealed a cloth drawstring bag
12 inside the backpack. Inside the cloth bag, law enforcement observed several white bank envelopes
13 stuffed with stacks of $100 bills. Law enforcement asked Chen and Jiang how much cash was in their
14 luggage. Jiang replied “twenty-five hundred dollars.” Jiang subsequently clarified he meant
15 “$250,000.” At this point, Jiang and Chen agreed to accompany law enforcement to a quiet room to
16 continue their discussion about the cash in their carry-on bags.
17 9. Inside the quiet room, law enforcement continued their conversation with Jiang and
18 Chen. Law enforcement searched Chen’s grey and black rolling suitcase and found nothing of
19 evidentiary value. Law enforcement next searched Chen’s small black backpack and discovered
20 numerous white bank envelopes containing stacks of cash, as well as rubber-banded wallets with cash
21 stuffed inside. A complete search of the “Swiss-Legend" backpack revealed not only bank envelopes
22 full of cash, but also rubber-banded wallets of cash similar to those found in Chen’s small black
23 backpack. Law enforcement also searched Chen and found a rubber-banded wallet similar to those
24 found inside the “Swiss-Legend" and small black backpack. In total, law enforcement found eight
25 rubber-banded wallets and approximately forty white bank envelopes, all containing large sums of
26 cash. Law enforcement also found seven money orders (five USPS; two Western Union) concealed
27 within one of the white banking envelopes. Each money order was for $1,000.00.
28 10. Law enforcement asked Jiang and Chen for the total amount of cash in their bags and
3
1 they said “$250,000” and that each envelope contained as much as “$10,000.” Law enforcement again
2 asked Jiang why he initially told law enforcement he was traveling alone when he was traveling with
3 his wife (Chen). For the second time, Jiang gave no discernable response. Law enforcement asked
4 Jiang about his marriage to Chen—Jiang could not identify their wedding date. Jiang said the pair had
5 been married three years after meeting at a Chinese restaurant. Jiang told law enforcement the cash
6 seized from Chen’s bags belonged to him (Jiang) and his sister. According to Jiang, his sister, Ling
7 Yan Jiang , lived at 1751 East Roseville Parkway in Roseville and had given him the cash in New York
8 prior to her relocation to California.
9 11. Law enforcement asked Jiang what he intended to do with the cash found in Chen’s
10 carry-on bags. Jiang said he planned to invest in real estate worth “$500,000,” but could not identify
11 the property he intended to buy, the area where they would invest, or a realtor that would assist with the
12 transaction. Jiang later revised his story about the purpose of the cash—his second story was the he
13 planned to invest in “business.” When pressed for specificity, Jiang said the cash was for a
14 “restaurant.” Jiang also explained he stored the cash in a safety deposit box prior to traveling to
15 California, planned to stay in Sacramento for one week, and was going to “Uber” with the cash to his
16 sister’s house in Roseville.
17 12. Two sophisticated dogs trained to alert to the odor of narcotics on currency positively
18 alerted to the cash seized from Chen’s carry-on bags. First, a sophisticated drug detection dog
19 conducted a search of the room and separately alerted to the odor of narcotics on the cash seized from
20 Chen’s bags. A second sophisticated drug detection dog then entered the room and separately alerted
21 to the odor of narcotics on the cash seized from Chen’s carry-on bags.
22 13. A later bank count of the cash seized from Chen’s “Swiss-Legend” and small black
23 backpack totaled $383,040.00. The seized $383,040.00 in cash was comprised of 3,428 $100 bills,
24 804 $50 bills, three $10 bills, and two $5 bills.
25 Connection to Large-Scale Takedown of Illegal Residential

Marijuana Grows in Sacramento Area
26
27 14. In April 2018, federal and state law enforcement executed approximately seventy-six
28
4
1 warrants connected to a drug trafficking organization who purchases homes in the Sacramento region
2 using money from China, converts these residences into indoor marijuana cultivation sites, and then
3 traffics the processed marijuana to other parts of the country. During the operation, law enforcement
4 seized over 60,000 illegal marijuana plants, 200 kilos of processed marijuana, tens of thousands of
5 dollars in criminal proceeds, and fifteen firearms. Federal forfeiture actions were filed against more
6 than 100 houses in the Sacramento region suspected of being related to this criminal organization and
7 used as indoor marijuana grows. One of the properties searched and subject to federal forfeiture is a
8 property located at 4343 North Forty in Lincoln, California, Case Number 2:18-CV-00808-KJM-CKD.
9 15. On April 3, 2018, law enforcement executed a federal search warrant at 4343 North
10 Forty in Lincoln, California and found an active marijuana grow containing 2,158 plants. Law
11 enforcement also located five bags of processed marijuana, one jar of processed marijuana, and
12 marijuana grow equipment. Law enforcement also found and seized four generators that powered the
13 equipment for the property’s large marijuana grow. The listed owner is Qihua Pan who purchased the
14 rural property as an “investment rental” for $735,000 in October 2016.
15 16. Previously, in December 2017, law enforcement conducted surveillance at 4343 North
16 Forty and observed a Toyota minivan with California License Plate 7UAP789, registered to Zhao Hong
17 Li with an address of 9130 Nolan Street #222, Elk Grove, California. Law enforcement connected
18 Zhao Hong Li and his Nolan Street apartment to several recent large-scale marijuana grows in
19 Calaveras County. Specifically, law enforcement searched 8786 Greer Way and 6048 Amos Lane in
20 Valley Springs, California and found over 1,500 marijuana plants and 35 pounds of processed
21 marijuana. Law enforcement also discovered documents, cashier’s checks, and loan paperwork for
22 “Zhao Li” at 9130 Nolan Street #222 in Elk Grove. 8786 Greer Way and 6048 Amos Lane are subject
23 to forfeiture in Case 2:18-CV-00747-KJM-CKD.
24 17. In April 2018, law enforcement learned that on April 9, 2018, a few days after the search
25 of 4343 North Forty, Qihua Pan filed a grant deed transferring ownership of the property to Ling Yan
26 Jiang , the sister and purported sister-in-law of Jiang and Chen. Law enforcement subsequently
27 identified Ling Yan Jiang ’s address as Apartment 436, 1751 East Roseville Parkway in Roseville,
28 California, known as the "Slate Creek Apartments." Property records also identified Ling Yan Jiang as
5
1 the co-owner of property located at 13644 62nd Road, Flushing, New York. Her brother, Tan Jiang, is
2 the co-owner.
3 18. Law enforcement interviewed employees for a company called “Sacramento Deed
4 Service” that specializes in filing real property documents for individuals, often on an expedited basis.
5 Employees for the company told law enforcement that Ling Yan Jiang and Qihua Pan came to their
6 offices on or about April 5, 2018 and paid to have the grant deed recorded “as soon as possible.”
7 Federal Searches of Liang Jiang’s Roseville Residence and Storage Facility
8 19. On May 8, 2018, law enforcement executed a federal search warrant at Ling Yan Jiang’s
9 apartment: Unit 436, 1751 East Roseville Parkway, Roseville, California. A search of Ling Yan
10 Jiang’s apartment revealed a $61,563.50 wire transfer to an escrow account and a paperwork regarding
11 Liang Jiang’s rental of a storage unit in North Highlands, California. The $61,563.50 wire transfer was
12 dated August 8, 2017 and identified Ling Yan Jiang as the requestor. The wire transfer identified the
13 funds were to be designated to Placer Title for an escrow account titled “4343 North Forty Road,
14 Lincoln CA.”
15 20. On May 8, 2018, law enforcement executed a federal search warrant at Ling Yan Jiang’s
16 storage unit in North Highlands. In her storage unit, law enforcement found marijuana grow
17 equipment, including grow lights and grow fans.
18 Administrative Forfeiture Proceedings
19 21. Following the seizure, the DEA commenced administrative forfeiture proceedings,
20 sending written notice to Tan Jiang and Jing Jing Chen and publishing notice of the seizure on the
21 internet. Tan Jiang and Jing Jing Chen filed claims as “owners” of the defendant $383,040.00 seized
22 from Chen’s carry-on luggage. Ling Yan Jiang, Tan Jiang’s sister who was not present when the cash
23 was seized, also claims to be an “owner” of the $383,040.00 seized from Chen’s carry-on bags. A
24 fourth person, Xiao Juan Dong, also claims to “own” the $383,040.00 seized from Chen at the
25 Sacramento International Airport.
26 FIRST CLAIM FOR RELIEF

21 U.S.C. § 881 (a)(6)
27
28 22. Paragraphs one to twenty-one above are incorporated by reference as though fully set
6
1 forth herein.
2 23. The defendant currency is subject to forfeiture to the United States pursuant to 21 U.S.C.
3 § 881(a)(6) because it was money furnished and intended to be furnished in exchange for a controlled
4 substance or listed chemical, constituted proceeds traceable to such an exchange, and was used and
5 intended to be used to commit or facilitate a violation of 21 U.S.C. §§ 841, et seq., an offense
6 punishable by more than one year’s imprisonment.
7 SECOND CLAIM FOR RELIEF

18 U.S.C. § 981 (a)(1)(A)
8
9 24. Paragraphs one to twenty-one above are incorporated by reference as though fully set
10 forth herein.
11 25. The defendant assets are subject to forfeiture pursuant to 18 U.S.C. § 981(a)(1)(A),
12 because they were involved in violations of 18 U.S.C. §§ 1956 and 1957.
13 26. Pursuant to 18 U.S.C. § 981(a)(1)(A), “[a]ny property, real or personal, involved in a
14 transaction in violation of 1956 … of [Title 18], or any property traceable to such property,” is subject
15 to forfeiture.
16 27. Pursuant to 18 U.S.C. § 1956, commonly known as the “money laundering” statute, a
17 person who:
18 (a) (1) … knowing that the property involved in a financial transaction

represents the proceeds of some form of unlawful activity, conducts or
19 attempts to conduct such a financial transaction which in fact involves the
20 proceeds of specified unlawful activity—
21 (A) (i) with the intent to promote the carrying on of specified
unlawful activity; or
22
(ii) with intent to engage in conduct constituting a violation of
23 section 7201 or 7206 of the Internal Revenue Code of 1986; or
24 (B) knowing that the transaction is designed in whole or in part—
25 (i) to conceal or disguise the nature, the location, the source, the
ownership, or the control of the proceeds of specified unlawful
26 activity; or
27 (ii) to avoid a transaction reporting requirement under State or
Federal law, shall be guilty of a crime.
28
7
1 28. Title 18 U.S.C. § 1956(h) further provides that “[a]ny person who conspires to commit
2 any offense defined in this section [1956] or section 1957 shall be subject to the same penalties as
3 those prescribed for the offense the commission of which was the object of the conspiracy.” For
4 purposes of Section 1956, “specified unlawful activity” includes, among other things, violations of
5 federal gambling law, 18 U.S.C. § 1955. 18 U.S.C. § 1957 provides that person commits a crime
6 when s/he “knowingly engages or attempts to engage in a monetary transaction in criminally derived
7 property of a value greater than $10,000 and is derived from specified unlawful activity.”
8 29. By reason of the above, the defendant assets are subject to forfeiture pursuant to 18
9 U.S.C. § 981(a)(1)(A).
10 PRAYER FOR RELIEF
11 WHEREFORE, the United States prays that:
12 1. Process issue according to the procedures of this Court in cases of actions in rem;
13 2. Any person having an interest in said defendant assets be given notice to file a claim and
14 to answer the complaint;
15 3. This Court enter a judgment of forfeiture of the defendant currency to the United States;
16 and,
17 4. The Court grant such other relief as may be proper.
18 DATED: 6/8/2018 McGREGOR W. SCOTT

19
20 By: /s/ Kevin C. Khasigian

KEVIN C. KHASIGIAN
21 Assistant U.S. Attorney
22
23
24
25
26
27
28
8
1 VERIFICATION
2 I, Richard J. Britt, hereby verify and declare under penalty of perjury that I am a Special Agent
3 with the U.S. Drug Enforcement Administration, that I have read the foregoing Verified Complaint for
4 Forfeiture In Rem and know the contents thereof, and that the matters contained in the Verified
5 Complaint are true to the best of my knowledge and belief.
6 The sources of my knowledge and information and the grounds of my belief are the official files
7 and records of the United States, information supplied to me by other law enforcement officers, as well
8 as my investigation of this case, together with others, as a Special Agent with the Drug Enforcement
9 Administration.
10 I hereby verify and declare under penalty of perjury that the foregoing is true and correct.
11
12 Dated: 6-8-18 /s/ Richard J. Britt

Richard J. Britt
13 Special Agent
Drug Enforcement Administration
14
(Signature retained by attorney)
15
16
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9
Case 2:18-cv-01684-JAM-AC Document 1-1 Filed 06/08/18 Page 1 of 1
JS 44(Rcv 12/12) CIVIL COVER SHEET
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(a)PLAINTIFFS DEFENDANTS
Approximately $383,040.00 in U.S. Currency and Approximately
United States of Amenca $7,000.00 in Money Orders
(b)COlmty Of Residence of First Listed PlaintifF County of Residence of First Listed Defendant SaCramentO
raで EPrflv as Pttv7FF64Sa, (IN U.S. PLAINTIFF CASES ONLY)
NOTE: IN LAND CONDEMNATION CASES, USE THE LOCATION OF
THE TRACT OF LAND INVOLVED.
(C)Attomeys rFl"腸 ″`,′ 憲ヽ ,α 〃ルム

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Attomeys (If Known)
Kevin C Khasigian,AuSA
501:Street,Sulte 10-100
Sacramento CA 95814 (916)554… 2700
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Plaintiff (U.5. Government Not a Party) Cidan ofTllis Statc 口 1 日 1 IncorporatedorPrincipalPlae O 4 J 4
ofBusiness In This State
O2 U.S.Govemment O4 Diversity Citizcn ofAnother State □ 2 口 2 lncorporatedazdPrincipalPlae O 5 O 5

Defendant (Indicate Citizenship ofParties in lrem III) ofBusiness In Another State
CiLm or SubJcct ofa □ 3 日 3 ForeignNation O 6 CI6
IVo NATURE
A OF SUIT (Place an "X" in Ore Box
tt lll,榊 111蠣 W輻晰聰靡類蒸事理事鵜曇lfty聯
O ll0 Insmce PERSONAL INJURY PERSONAL INJURY 口 625 Drug Related Seizlre 口 422 Appea1 28 USC 158 □ 375 False Clalms Act
0 120 Marine 口 3 10 Alrplane O 365 Personal lnjury - ofPropeny 21 USC 881 口 423 Withdrawal ロ 400 State Reapporuonlnent
O l30MilltrAct 口 315A“ lane Product Product Liability □ 6900」ler 28 USC 157 ロ 410 Antitmst
O 140 Negotiable Imtrmmt Liability O 367 Healthcar€/ 日 430 Banks and Banking
0 150 Recoveryof Overpayment 口 320 Assault,Libel& Phamaceutical ロ 450 Cclnlmcrce
& Enforcemmt of Judgrnent Siandcr Pasonal Injury □ 820 COpynghts ロ 460 DeponatiOn
fl l5l Medicare Act 口 330 Fedcml Employcrs' Prcduct Liability 口 830 Patent □ 470 Racketeer lnluenccd and
O 152 Recovery of Defaulted Liabllity O 368 Asbestos Pssonal □ 840 Trademark Conupt Organizations
Studmt Loans 口 340 Manne lnjury hoduct □ 480 Consuner Crcdlt
(Excludes Vetms) □ 345 Manne Product Liability 〔鑢驚鷺壽■￨ホ磁■■,証機濾鯉鐵ロ 490 Cable/Sat TV
口 153 RccOvery ofOverpayment Llability PERSONAL PROPERTY I 710 Fair Labor Stmdards 口 861 HIA(1395o □ 850 Secunties/Commoこ ties/
ofVetemn's Bcnefts 口 350 Motor Vchidc D 370 Othq Fmud Act 口 862 Black Lung(923) Exchange
口 160 St∝ kholders'Sults 口 355 Motor Vehicle fl 371 Truth in Lending J 720 Labor/lvlmagment 日 863 DIWC/DIWW(405(g)) ロ 890 0ther Statutory Actlo■ s
日 190 0dler COnmct Product LiaЫ lity 0 380 Other Penonal Relations 口 864 SSID Tlde XVI ロ 891 AgnculmttJ Acts
口 195 Conmct PrOduct Liability 口 360 0ther Personal hoputy Dmage I 740 Railway Labor Act □ 865 RSI(405(3)) ロ 893 EnvirOnllllental Matters
口 196 Franchise lttuリ O 385 Prcperty Dmage J 751 Fmily md Medical ロ 895 Freedom oflnfo― tion
ロ 362 Persond ttuリー hoduct Liability Leave Act Act
Medlcal ulpracucc I 790 Othq Labor Litigation □ 896 ArbinhOn
f 791 Employee Retirement □ 899 Admmisntlve PrOcedure
□ 210 Land Condenma● o■ 口 440 0ther Ci宙 l RIghts Habms Corpus: Income Secuity Act 口 870 Taxes(U S Pldntlr Act/Revicw or Appeal of
日 220 FOrcclosure 口 441 Vojng D 463 Alien Detainee ∝ Dofcndant) Agcncy Dedsion
口 230 Rcnt Lcase&EJecment □ 442 Emplorent ll 510 Motims to Vacate 口 871 lRS― ■ 罰 Pa● 950 Cclnsitutionality of
口 240T● ●sto Land □ 443 Housing/ Sfltenc€ 26 USC 7609 State Statutes
口 245 Tolt Product Liabilty Acconll■lodanons O 530Gensal
□ 290A11 0dler Real Propery 口 445 Amer w/Disabilides‐ O 535 DeathPenalty
Emplorent Other: D 462 Nanralization Application
口 446 Amer w/Disabilides‐ O 540 Mandamu & Other 3 465 Other Imigmtion
O■er O 550 Civil tughts Actions
□ 448 Educa● on O 555 Primn Condition
O 560CivilDetainee-
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V. ORIGIN″ レο"`χ "″ θ Bα のry/

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13 2 Removed from Remanded from O 4 Reinstated or 口 5 Transferred from 口 6 Multidistrict
鴫 State Court Appellate Court Reopened Another District Litigation
841,et
VIo CAUSE OF ACTION Э
tion ofcause:
VII.REQUESTED IN CHECK IF THISIS A CLASS ACT10N DEDIIAND S CHECK YES only ifdemanded in complainti
CODIIPLAINT: UNDER RULE 23,F R CvP JURY DEDIAND: 日 Yes X No
VIIIo RELATED CASE(S)
(See irclrurions):
IF ANY DOCKET llUMBER
圏″
OF RECORD
RECEIPT# AMOUNT APPLYING IFP MAG JUDGE

1 McGREGOR W. SCOTT
Assistant U. S. Attorney
3 501 I Street, Suite 10-100
Sacramento, CA 95814
4 Telephone: (916) 554-2700
5 Attorneys for the United States
8 IN THE UNITED STATES DISTRICT COURT
9 EASTERN DISTRICT OF CALIFORNIA
10
11 UNITED STATES OF AMERICA,

12 Plaintiff,
APPLICATION AND ORDER FOR
13 v. PUBLICATION
14 APPROXIMATELY $383,040.00 IN U.S.
CURRENCY, and
15
APPROXIMATELY $7,0000.00 IN MONEY
16 ORDERS,
17 Defendants.
18
19 The United States of America applies for an order of publication as follows:

20 1. Rule G(4) of the Supplemental Rules for Admiralty or Maritime Claims and Asset
21 Forfeiture Actions (hereafter “Supplemental Rules”) provides that the United States shall cause public
22 notice of the action to be given in a newspaper of general circulation or on the official internet
23 government forfeiture site;
24 2. Local Rule 171, Eastern District of California, provides that the Court shall designate by
25 order the appropriate newspaper or other vehicle for publication;
26 3. The defendant Approximately $383,040.00 in U.S. Currency and defendant

27 Approximately $7,000.00 in Money Orders (hereafter “defendant assets”) were seized in the city of
28
1 Application and Order for Publication
1 Sacramento, in Sacramento County, California. Beginning on March 3, 2018 and March 12, 2018
2 respectively, the U.S. Drug Enforcement Administration published notice of the non-judicial forfeiture of
3 the defendant currency for 30 consecutive days on the official internet government forfeiture site
4 www.forfeiture.gov.
5 4. The United States proposes that publication be made as follows:
6 a. One publication;
7 b. Thirty (30) consecutive days;
8 c. On the official internet government forfeiture site www.forfeiture.gov;
9 d. The publication is to include the following:
10 (1) The Court and case number of the action;
11 (2) The date of the seizure/posting;
12 (3) The identity and/or description of the property seized/posted;
13 (4) The name and address of the attorney for the United States;
14 (5) A statement that claims of persons entitled to possession or claiming an
15 interest pursuant to Supplemental Rule G(5) must be filed with the Court and served on the attorney for
16 the United States no later than 60 days after the first day of publication on the official internet
17 government forfeiture site; and
18 ///
19 ///
20 ///
21 ///
22 ///
23 ///
24 ///
25 ///
26 ///
27 ///
28 ///
1 (6) A statement that answers to the Complaint or a motion under Rule 12 of the
2 Federal Rules of Civil Procedure (“Fed. R. Civ. P.”) must be filed and served within 21 days after the
3 filing of the claims and, in the absence thereof, default may be entered and condemnation ordered.
4 Dated: 6/8/2018 McGREGOR W. SCOTT

5
By: /s/ Kevin C. Khasigian
Assistant U.S. Attorney
7
8
ORDER
9
IT IS SO ORDERED.
10
11 Dated:
United States Magistrate Judge
12
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Feds Seize $400k Allegedly Connected To Illegal Grows in Sacrameto

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Feds Seize $400k Allegedly Connected To Illegal Grows in Sacrameto

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Case 2:18-cv-01684-JAM-AC Document 1 Filed 06/08/18 Page 1 of 9

5 Attorneys for the United States

8 IN THE UNITED STATES DISTRICT COURT

9 EASTERN DISTRICT OF CALIFORNIA

11 UNITED STATES OF AMERICA,

21 Admiralty or Maritime Claims and Asset Forfeiture Action:

25 assets”) involved in violations of federal drug and money laundering laws.

1 JURISDICTION AND VENUE

4 under 21 U.S.C. § 881.

7 defendant currency was seized in this district.

13 traveling with no checked luggage.

16 continue their discussion about the cash in their carry-on bags.

8 prior to her relocation to California.

16 sister’s house in Roseville.

24 804 $50 bills, three $10 bills, and two $5 bills.

25 Connection to Large-Scale Takedown of Illegal Residential

14 rural property as an “investment rental” for $735,000 in October 2016.

23 to forfeiture in Case 2:18-CV-00747-KJM-CKD.

7 Federal Searches of Liang Jiang’s Roseville Residence and Storage Facility

17 equipment, including grow lights and grow fans.

18 Administrative Forfeiture Proceedings

25 Sacramento International Airport.

26 FIRST CLAIM FOR RELIEF

5 intended to be used to commit or facilitate a violation of 21 U.S.C. §§ 841, et seq., an offense

6 punishable by more than one year’s imprisonment.

7 SECOND CLAIM FOR RELIEF

12 because they were involved in violations of 18 U.S.C. §§ 1956 and 1957.

13 26. Pursuant to 18 U.S.C. § 981(a)(1)(A), “[a]ny property, real or personal, involved in a

18 (a) (1) … knowing that the property involved in a financial transaction

10 PRAYER FOR RELIEF

11 WHEREFORE, the United States prays that:

14 to answer the complaint;

17 4. The Court grant such other relief as may be proper.

18 DATED: 6/8/2018 McGREGOR W. SCOTT

20 By: /s/ Kevin C. Khasigian

5 Complaint are true to the best of my knowledge and belief.

12 Dated: 6-8-18 /s/ Richard J. Britt

(C)Attomeys rFl"腸 ″`,′ 憲ヽ ,α 〃 ルム

II.BASIS OF JURISDICTION rP″ α″γ""ο ″Bα ttry/ IⅡ o CITIZENSHIP OF PRINCIPAL PARTIESrPね ο

O2 U.S.Govemment O4 Diversity Citizcn ofAnother State □ 2 口 2 lncorporatedazdPrincipalPlae O 5 O 5

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RECEIPT# AMOUNT APPLYING IFP MAG JUDGE

5 Attorneys for the United States

8 IN THE UNITED STATES DISTRICT COURT

9 EASTERN DISTRICT OF CALIFORNIA

11 UNITED STATES OF AMERICA,

19 The United States of America applies for an order of publication as follows:

23 government forfeiture site;

26 3. The defendant Approximately $383,040.00 in U.S. Currency and defendant

5 4. The United States proposes that publication be made as follows:

7 b. Thirty (30) consecutive days;

8 c. On the official internet government forfeiture site www.forfeiture.gov;

9 d. The publication is to include the following:

10 (1) The Court and case number of the action;

11 (2) The date of the seizure/posting;

12 (3) The identity and/or description of the property seized/posted;

14 (5) A statement that claims of persons entitled to possession or claiming an

17 government forfeiture site; and

4 Dated: 6/8/2018 McGREGOR W. SCOTT

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(C)Attomeys rFl"腸 ″`,′ 憲ヽ ,α 〃ルム