Verified Complaint for Forfeiture in Rem — United States v. One 2000 SUV Lexus LX 470 and $18,000 (Dkt. 1)

Summary

Verified Complaint for Forfeiture In Rem filed by the United States of America against a 2000 SUV Lexus LX 470 and $18,000 in United States currency, Case 0:03-cv-60484-PCH, Document 1, entered on the docket March 21, 2003, in the U.S. District Court for the Southern District of Florida. The complaint seeks forfeiture under 21 U.S.C. §§ 881(a)(4) and (a)(6) and alleges that on June 12, 2002, DEA Special Agents working with the Broward County Sheriff's Office stopped the vehicle, driven by Avraham Timsit. It alleges that agents found Ecstasy tablets in the vehicle, at a storage facility and at a residence, along with approximately $18,000.00 in currency, and that an indictment, Case No. 02-20575-CR-HUCK, included a forfeiture allegation. The verification is by Michael Maxwell, Special Agent of the Drug Enforcement Administration.

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Case 0:03-cv-60484-PCH Document1 Entered on FLSD Docket 03/21/2003 Page 1 of 6

UNITED STATES OF AMERICA,

Vv.

ONE 2000 SUV LEXUS LX 470
VIN JT6HTOOW7 Y0090393
LICENSE NUMBER 4JTW818

and

$18,000 IN UNITED STATES
CURRENCY,

UNITED STATES DISTRICT ALP 7 6 0 4 8 A.

SOUTHERN DISTRICT OF FLORIDA

CASE NO.

Plaintiff,

Defendants.
/

States:

1.

VERIFIED COMPLAINT FOR FORFEITURE IN REM

Plaintiff, the United States of America, files this verified complaint for forfeiture in rem and

This is a civil action for forfeiture in rem of ONE 2000 SUV LEXUS LX 470, VIN

JT6HTOO0W7Y0090393, LICENSE NUMBER 4JTW8 18 and $18,000 IN UNITED STATES
CURRENCY (hereinafter “Lexus or defendant vehicle and $18,000.00 in United States
currency or defendant currency”).

Jurisdiction is vested in this court pursuant to 28 U.S.C. §§1345 and 1355.

Venue lies in this district pursuant to 28 U.S.C. §1395, in that the defendant vehicle and
defendant currency are located within the Southern District of Florida and will remain within
the district during the pendency of these proceedings.

The United States seeks forfeiture of the defendant vehicle and defendant currency pursuant

\
" Case 0:03-cv-60484-PCH Document1 Entered on FLSD Docket 03/21/2003 Page 2 of 6

to 21 U.S.C. §§ 881(a)(4) and (a)(6).
STATEMENT OF FACTS

5. On June 12, 2002, United States Drug Enforcement Administration Special Agents
(hereinafter “DEA Agents”) working in conjunction with the Broward County Sheriff’s
Office conducted a traffic stop on a 2000 SUV LEXUS LX 470, VIN
JT6HTOOW7 Y0090393, License Number 4JTW8 18, driven by Avraham Timsit in Broward
County, Florida.

6. Timsit consented to a search of the LEXUS which he owned, after which the agents
discovered approximately thirty thousand (30,000) tablets of 3, 4-
methylenediox ymethamphetamine (MDMA or Ecstasy)(hereinafter “Ecstasy” in the trunk.

7. After the discovery of the 30,000 Ecstasy tablets in the trunk of Timsit’s Lexus, Timsit
continued to cooperate with the DEA agents and told them of the location where he stored
an additional 25,000 tablets of Ecstasy. The DEA Agents accompanied Timsit to the A Plus
Mini Storage Facility, located at 4021 S.W. 47" Avenue, Unit 1001, Davie, Florida where
they recovered an additional 25,000 tablets of Ecstasy.

8. Timsit further advised the DEA Agents and Broward County Deputy Sheriffs present that
he had an additional 15,000 tablets of Ecstasy at his residence.

9. The DEA Agents and Broward County Deputy Sheriffs proceeded to Timsit’s residence
which is located at 3836 S.W. 50" Street, Dania, Florida, and with Timsit’s consent, searched
the premises and found 15,000 tablets of Ecstasy in the master bathroom.

10. During the search of Timsit’s residence, the DEA Agents and Broward County Deputies

discovered, in another bedroom, a cardboard box, containing approximately $18,000.00 in
'‘ Case 0:03-cv-60484-PCH Document1 Entered on FLSD Docket 03/21/2003 Page 3 of 6

United States currency.

11. Timsit told the DEA Agents and Deputy Sheriffs that he was employed in the cabinet making
business but failed to indicate in what capacity or could he explain the source of the
$18,000.00 in United States currency or how he had paid off the 2000 SUV Lexus in less
than one year. Documents recovered at Timsit’s residence indicated that his total annual
income was approximately $15,000.00.

12. Following the recovery of the Ecstasy tablets from his Lexus, his storage facility and his
residence, as well as the finding of the $18,000.00 in United States currency at his residence,
Timsit was indicted by a Federal Grand Jury in Miami, Florida in the case of the United

States of America v. Avraham Timsit, Case No. 02-20575-CR-HUCK for violations of the

federal narcotics laws. Included in that Indictment was a general Forfeiture Allegation. By
the filing of a Bill of Particulars, the United States sought the forfeiture of Timsit’s Lexus
and the $18,000.00 in United States currency.

13. On June 27, 2002, Timsit was released on bond. He has fled the jurisdiction and remains a
fugitive.

14. Plaintiff seeks forfeiture of the defendant vehicle and defendant currency pursuant to 21

U.S.C. § 881(a)(4) and (a)(6).
‘ Case 0:03-cv-60484-PCH Document1 Entered on FLSD Docket 03/21/2003 Page 4 of 6

WHEREFORE, Plaintiff, United States of America requests the Court issue a warrant and
summons for the arrest and seizure of the defendant vehicle and defendant currency; that notice of
this action be given to all persons known or thought to have an interest in or right against the
defendant vehicle and defendant currency to file and serve their verified claims and answers as
required by the Supplemental Rules for Certain Admiralty and Maritime Claims or suffer default
thereof; that the defendant vehicle and defendant currency be condemned and forfeited to the United

States of America, and that Plaintiff have such other and further relief as may be just and proper.

Respectfully submitted,

MARCOS DANIEL JIMENEZ
UNITED STATES ATTORNEY

By: ee) Abbe

WILLIAM C. HEALY 7”

ASSISTANT UNIT ae STATES ATTORNEY
Florida Bar No. 0848395

99 N.E. 4" Street - 7 Floor

Miami, Florida 33132

(305) 961-9438: Telephone

(305) 536-7599: Fax

william.healy @usdoj.gov
- Case 0:03-cv-60484-PCH Document1 Entered on FLSD Docket 03/21/2003 Page 5 of 6

VERIFICATION
Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury, that I have read the
foregoing Complaint for Forfeiture In Rem and that the contents are true to the best of my

knowledge and belief.

Executed on March 20 2003.

~

Michael Maxwell
Special Agent
United States Drug Enforcement Administration


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