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Complaint for Forfeiture — United States v. One 1997 Toyota 4 Runner (S.D. Fla., Dkt. 1)

Summary

A complaint for forfeiture in rem in United States of America v. One 1997 Toyota 4 Runner, Case No. 1:02-cv-21691, in the U.S. District Court for the Southern District of Florida, entered on the docket June 7, 2002 (Doc. 1). It seeks forfeiture of One trailer attached to the vehicle under 21 U.S.C. § 881(a)(4), on grounds that the defendant vehicle was used or intended for use to transport marijuana. The statement of probable cause alleges that on or about June 20, 2001, Special Agents from the Drug Enforcement Agency seized 71.5 pounds of marijuana from Raul Herrera, who drove the defendant vehicle to a parking lot in Miami, Florida. The verification block names Brian McKnight, Special Agent, DEA.

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“Complaint for Forfeiture — United States v. One 1997 Toyota 4 Runner (S.D. Fla., Dkt. 1).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-02-cv-21691-dkt-1-s-d-fla-75c7fbb166/, SHA-256 4e0b1d2ffa140bf4285af2b85e95e877535e7ef565fa7f94b689d2785c67a99f.

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Case 1:02-cv-21691-KMM Document 1 Entered on FLSD Docket 06/07/2002 Page 1of5

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COMPLAINT FOR FORFEITURE

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

1. This is a civil action for forfeiture in rem of One trailer attached to One 1997 Toyota
4 Runner, VIN JT3GN86V0045038 (hereinafter “defendant vehicle”). Jurisdiction is vested in this
Court pursuant to 28 U.S.C. §§ 1331 and 1355.

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

3. The United States seeks forfeiture of the defendant vehicle pursuant to 21 U.S.C. §
881(a)(4) on grounds that the defendant vehicle is property which is used or intended for use, to
transport, or in any manner to facilitate the transportation, sale, receipt, possession or concealment

of marijuana.
Case 1:02-cv-21691-KMM Document 1 Entered on FLSD Docket 06/07/2002 Page 2 of 5

STATEMENT OF PROBABLE CAUSE

4. On or about June 20, 2001, Special Agents from the Drug Enforcement Agency
(“DEA”) seized seventy one and a half pounds (71.5) pounds of marijuana from Raul Herrera.

5. Raul Herrera drove the defendant vehicle with the marijuana inside to the Mall of
Americas parking lot in Miami, Florida, where he met with his co-conspirators.

6. Raul Herrera was arrested and charged with marijuana trafficking and the vehicle
seized as a conveyance which was used to transport marijuana pursuant to 21 U.S.C. § 881 (a)(4).

7. By reason of the foregoing, the defendant vehicle is forfeit to the United States
pursuant to 21 U.S.C. §§ 881 (a)(4) in that the defendant vehicle constitutes conveyance which was
used, or intended for use to transport, or in any manner to facilitate the transportation, sale, receipt,
possession or concealment of marijuana in violation of 21 U.S.C. § 841(a)(1).

WHEREFORE, Plaintiff, United States of America requests the Court to declare the
defendant vehicle condemned and forfeit to the United States of America, and further requests the
Court to direct any and all persons having any claim to the vehicle to file and serve their verified
claims and answers as required by Rule C (6) of the Supplemental Rules for Certain Admiralty and
Maritime Claims and Title 18 United States Code, Section 983 (a)(4)(A) and (B), or suffer default

thereof, to declare the defendant property condemned and forfeit to the United States of America,
Case 1:02-cv-21691-KMM Document 1 Entered on FLSD Docket 06/07/2002 Page 3 of 5

pursuant to Title 18, United States Code, Section 981 (a)(1), for disposition according to law; and
to grant the United States such other further relief as the Court deems just and proper, together with
costs and disbursements of this action.

Respectfully submitted,

GUY A. LEWIS
UNITED STATES ATTORNEY

ASSISTANT U.S. ATTORNEY
Fla. Bar No. 035955

99 N.E. 4th Street

Seventh Floor

Miami, Florida 33132

Tel: (305) 961-9294

Fax: (305) 536-7599
Case 1:02-cv-21691-KMM Document 1 Entered on FLSD Docket 06/07/2002 Page 4 of 5

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 ont | 5 , 2002.

BRIAN MCKNIGHT
SPECIAL AGENT, DEA

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