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Profissional Documentos
Cultura Documentos
O~G N _
1~
1.
DEC 13 2005
IN THE UNITED STATES DISTRICT COURT L[.#! llcr !s~,i oj i :'. C,~~'rI <
FOR THE NORTHERN DISTRICT OF GEORGIA
~.~~~~~
ATLANTA DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
CIVIL ACTION NO .
v.
$ 1 3,630 .00
CURRENCY,
1 :05-CV-3134
I N UNIT E D STATES
Defendant .
COMPLAINT FOR FORFEITURE
COMES NOW the United States of America, Plaintiff in the
above-styled civil action, pursuant to 21 U .S .C . 881(a)(6), and
On July 1,
2005,
4 .
S.
Officer Dewald approached the Chevrolet Tahoe, which was
occupied by Jose Guerrero, his wife Bernardine Guerrero, and four
young children .
9 .
10 .
Jose Guerrero gave officer Dewald a North Carolina driver's
license and told him that he had been visiting relatives at 2587
Boland Drive ("Boland Drive") .
11 .
2005
16 .
Officer Dewald asked Jose Guerrero how much money was in the
Chevrolet Tahoe, and Jose Guerrero stated that there was
approximately $10,000 .00 inside the vehicle .
17 .
Jose Guerrero told Officer Dewald that he earned the money
from his job at Southern Pan in Lithonia, Georgia .
18 .
Officer Dewald asked Bernardine Guerrero how much money was
inside the car and she said approximately $5,000 .00,
20 .
Officer Dewald asked Jose Guerrero again how long he would be
staying in Mexico, and this time he stated three weeks, conflicting
with his original statement of one week .
21 .
Officer Dewald asked Bernardine Guerrero where the money was
located, and she reached down to the floorboard of the car and
pulled a bag out of a duffle bag and then retrieved two small
stacks of money .
22 .
located, and Jose Guerrero retrieved a black bag from the front
passenger side door, pulled out a white bag, and handed it to
Officer Dewald .
27 .
Inside the white bag were five (5) packets of money, bound
with rubber bands . There was a piece of yellow paper on each
bundle . The dollar amount and quantity of each denomination in the
('IDEA")
33 .
On November 3,
2005,
(1)
This
/;
Respectfully submitted,
DAVID E . NAHMIAS
UNITED STATES ATTORNEY
US LL PHILLI
ASSISTANT U .S . ATTORNEY
GEORGIA BAR NO . 576335
600 UNITED STATES COURTHOUSE
75 SPRING STREET, S .W .
ATLANTA, GA 30303
(404)581-6239 - PHONE
(404)581-6156 - FAX
Plaintiff,
CIVIL ACTION NO .
v.
$13,630 .00 IN UNITED STATES
CURRENCY,
Defendant .
in this action and state that its contents are true and correct to
the best of my knowledge and belief .
Pursuant to 28 U .S .C . 1746, T declare under penalty of
perjury that the foregoing is true and correct .
This ~ day of December, 2005 .