IN THE CIRCUI: COURT OF THE FOURTEENTH JUvICIAL CIRCUIT, WHITESIDE COUNTY, ILLINOIS THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff, vs. FILED $17, 248.00 in United States Currency; | CIRCUIT COURT.WHITESIDE COUNTY One (1) 2014 Black Chevrolet Corvette Singy VN aT: One (1) 1991 White Pontiac Firebird (VIN i 2nd One (1) 2006 Black Chevrolet Impala No. 16-mr_4 ¢ (ae. (VIN Defendants in rem. AFFIDAVIT IN SUPPORT OF FORFEITURE 1, Lam Inspector Douglas Wade, with the Illinois State Police Blackhawk Area Task Force; 2. That on or about May 17, 2016, the above-captioned property was seized at or near Timber Drive, Sterling, Whiteside County, Illinois; 3. Notices of Seizure For Forfeiture were furnished to such interest holder(s) in the above-captioned property, as were known at the time of seizure, including registered owners and lien holders of said vehicles and said notices included the date, time and place of the judicial preliminary review. It should be noted that in addition to a lien holder, there are two registered owners of the 2006 Black Chevrolet Impala (VIN |, Apolinar Jaramillo and Naomi R. Lopez, Rock Falls, Illinois, 61071. Notice of seizure for forfeiture was not provided to Naomi R. Lopez. However, notice was provided to the Apolinar Jaramillo at the vehicle’s registered address i HH Rock Falls, Illinois 61071, at which time Apolinar indicated Naomi R. Lopez lives in Colorado. Thave reasons to believe that the above-captioned property may be subject to forfeiture to the State of Illinois, based on one or more of the following facts: (see attached Exhibit A, incorporated here) s Further your Affiant sayeth naught. Under penalties as provided by law pursuant to Section 1-109 of the Code of Civil Procedure, the undersigned certifies that the statements set forth in this instrument are true and correct, except as to matters therein stated to be on information and belief and as to such matters the undersigned certifies as aforesaid that he veyitybelicVes the same to be true. tz : 7a NOTARY PUBLIC - STATE OF ILLINOIS“ [MY COMMISSION EXPIRES.040320EXHIBIT A This attachment concerns the following property, and is submitted for the limited purpose of proving preliminary probable cause that this property may be subject to forfeiture: $17, 248.00 in United States Currency One (1) 2014 black Chevrolet Corvette Stingray vehicle vn ii One (1) 1991 white Pontiac Firebird vehicle VON One (1) 2006 black Chevrolet Impala vehicle On iii In February 2014, the Illinois State Police Blackhawk Area Task Force identified Jody Canas (H/M, DOB: 12/23/1971 EE Timber Drive, Sterling, Whiteside County, IL) as a suspect in a Criminal Drug Conspiracy. Between the dates of December 16, 2015, and March 7, 2016, three (3) controlled purchases of cocaine totaling approximately 41.9 grams (approximately 1 % ounces with a street value of $4100.00) have been made from Jody Canas. Alll three purchases were made at Canas’s residence (Property purchased on or about January 15, 2010, by Violeta “Violet” L. Jaramillo JINN Timber Drive, Sterling, Whiteside County, IL). On April 16, 2016 approximately 817.5 grams of cannabis (approximately 1 % pounds with a street value of $20,437.50) and additional cannabis oils were seized in this case through a co-defendant Lynn H. “Scootie” Robinett (M/W, DOB: 05/06/1971, i Dixon, IL). An intercept of telephonic wire communications showed Canas utilized a 3" party (Robinett) to acquire the drugs to minimize his contact with law enforcement. On May 17, 2016, Illinois State Police Blackhawk Area Task Force executed a search warrant at Canas’s residence (Timber Drive, Sterling, Whiteside County, IL). Immediately upon entering the residence the smell of fresh cannabis was noted. During the search of the residence approximately two (2) ounces of cocaine and two (2) pounds of cannabis were located, The cocaine seized field-tested positive for the presumptive presence of cocaine. In addition to the illegal drugs, approximately $17,248.00 in cash was located in the bathroom closet of the residence in a shave kit bag. The cash was rubber banded and bundled in a manner consistent with that of drug proceeds. Cannabis was found throughout the residence often in plain view. In approximately 2003, Canas was shot in the face with a weapon and suffered vision loss. Since that time no verifiable legitimate income has been found for Canas other than social security/disability and state aid (food stamps). During the search of the residence, Violeta Jaramillo’s 2015 tax records were located. Violeta’s adjusted gross income was $100,924.00, to include a $9068.00 loss for her business, The Grapevine Wine and Martini Bar. In June 2014, The Grapevine Wine and Martini Bar, 205 West 2 Street, Rock Falls, IL was purchased in the name of Violeta L. Jaramillo. The Grapevine was opened in approximately September 2014. Between August 2014 and May 2016 Canas has made numerous statements identifying the Grapevine as his bar.In August 2014, Canas was in’ epted during documented wire comm’ _ zations stating he was hoping to have his bar up and running in the next month. He said he had Tom Cushman doing the plumbing, and he had the electricians and framers completing the work. Canas also provided Brandon Carter, Canas’s address of “J Timber Drive”. On April 18, 2016, documented wire communications were intercepted, and surveillance was documented, wherein Canas met with co-conspiting partners at The Grapevine during non-operating hours to exchange currency related to the ongoing criminal drug enterprise being investigated. During the search warrant at Canas and Jaramillo’s residence, after M/Sgt. Todd Shaver verbally provided Canas his Illinois State Police Miranda Rights advisement, Canas explained that this residence, (I Timber Drive) was not his. Canas also told M/Sgt Shaver that the 2014 Chevrolet Corvette Stingray, the 1991 Pontiac Firebird, and the 2006 Chevrolet Impala were not his. Canas explained that the Corvette Stingray was his wife’s, the Pontiac Firebird was his mother’s and the Chevrolet Impala was Violet's parent’s vehicle. All three vehicles were present at the residence during the execution of search warrant. The Corvette Stingray was purchased for $70,000.46 in the name of Violeta L. Jaramillo on 5/20/2015. Jaramillo purchased the vehicle with $5000 cash, a $16,000 personal check from her account, and a $14,000 check from the Grapevine Wine and Martini Bar account (the same business showing a loss of $9068.00 during 2015). Investigations and documented wire communications show Canas providing maintenance, insurance and storage care to the Corvette. The 1991 Pontiac Firebird is titled in the name of Natividad Canas (Jody’s mother), EE, Rock Falls, IL. Investigations and documented wire communications show Canas speaking of his Firebird, attempting to obtain service to the vehicle and several thousands of dollars in high performance upgrades from 2000-current. Documented wire communications show Canas often utilizing the 2006 Chevrolet Impala as his daily driving vehicle and using the vehicle to further his criminal drug enterprise. On April 22, 2016, reported that Canas utilized the Chevrolet Impala to make a drug payment to [i HR ins the parking lot of the Sauk Valley Chamber of Commerce parking lot in Sterling, Illinois. The Chevrolet Impala is in the name of Apolinar “Polo” Jaramillo (Violet’s father). On or about September 30, 2013, Jody Canas purchased Ii West 20" Street, Rock Falls, Whiteside County, IL. Documentation obtained from the Whiteside County Recorder’s Office, shows Canas purchased the residence for $28,500, and currently has an owner occupied exemption for taxation purposes. The property tax bills are mailed to Jody Canas, MI Timber Drive, Sterling, Whiteside County, IL. According to Whiteside County Recorder’s documents, Canas financed $7604.69 for the purchase. The residence was and is currently being rented by Donald Godare, conspiring co-defendant in this Criminal Drug Conspiracy. On or about June 19, 2014, Violeta L. Jaramillo purchased 205 West 2" Street, otherwise known as The Grapevine Wine and Martini Bar. Whiteside County Recorder’s Office documents show a mortgage in the amount of $65,000 through Sauk Valley Bank, Rock Falls, IL. On May 25, 2016, I spoke with Tom Cushman of Cushman Plumbing. I was provided documentation from Cushman showing $4500.00 in billed service to the Grapevine. Cushman advised the service work was directed by Jody Canas. Invoices also show $3500.00 was paid in the form of cash for Cushman’s service. Cushman recalled Violet Jaramillo as the payee for the service work. On or about October 8, 2015, Violet Jaramillo purchased IiWest 12"" Street, Sterling, IL for the purchase price of $42,000 with a remaining principal of $22,000 from the owner, Ronald Lilly. Duringthis investigation, documente? ‘re communications show Canas cond: _ng landlord duties renting and doing maintenance improvements to the residence. During execution of search warrant at [Timber Drive, a receipt ledger was located identifying consistent $1000 cash payments from Jody Canas to Ronald Lilly. On May 25, 2016, I spoke with Dave Jackley of Jackley Septic. Jackley explained that in the last approximately 5 months, Jackley pumped the septic at llWest 12" Street, Sterling, IL at the request of Jody Canas. Jackley stated Canas paid for the septic service in cash in the amount of approximately $150.00. On May 6, 2016 and May 7, 2016, an interception of telephonic communications was obtained between Brandon Joshua Carter (M/W; DOB:11/23/84, A. Harmon, IL) and Canas about a parcel being delivered to Tammy Wilson (W/F; DOB:11/04/1965). Wilson, a third party, received a parcel in the mail, believed to be cannabis, and documented conversations led to the probability that Canas received this parcel. Attempts to intercept this parcel were made, but were unsuccessful. In June 200 Harmon, Lee County, IL was sold for $92,000. Tammy Wilson, once owner o} ‘Harmon, IL, sold the house to Canas on or about April 20, 2007 for $50,000. The home was not advertised for sale and the assessed value of the residence was $91,000. On or about February 3, 2014, Canas sold the home to Rawshua Inc. (Brandon Carter). The current owmer is listed as Jody Canas, but there is a Memorandum of Agreement (private contract between owner Jody Canas and contract purchaser Rawshu’a, Inc.) which was recorded Feb. 3, 2014. The memorandum does not disclose the sale price. Based on my law enforcement experience, I know that persons involved in the illicit distribution of controlled substances and cannabis nearly always attempt to conceal their identities, as well as the location at which drug transactions take place. They are also known to have vehicles, properties, utilities, and other purchases under fictitious names and/or the names of other individuals to conceal their criminal activity and financial transactions. I know that the members of such drug trafficking organizations have developed and employ sophisticated systems in their attempts to insulate themselves from law enforcement, often utilizing lower level members of the drug organization to handle the day-to-day drug operations and transportation of drugs. T have also learned through my experiences as a drug investigator that these same individuals will utilize remote storage locations and other unique methods of concealing their illegal products, financial gains and other assets derived from the sales of drugs. : In summary, Canas and Jaramillo reside together, and knowingly share mutual investments. Because of the facts above I also believe that the $17,248.00 in cash described above constitutes drug proceeds, and that Jody Canas and Violet Jaramillo have used drug proceeds to purchase the vehicles mentioned above, and real estate, to include the Grapevine Wine and Martini Bar. The sources of my information and the ground of my belief of the above is based upon information contained within records and files of the Illinois State Police, information obtained directly and indirectly by myself, and information obtained by other law enforcement officials and representatives during the course of this investigation. Illinois State May 26 2016IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT, WHITESIDE COUNTY, ILLINOIS THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff, vs. FILED CIRCUIT COURT WHITESIDE COUNTY oe Be Tate d = f No. 16-MR Yk $17, 248.00 in United States Currency; One (1) 2014 Black Chevrolet Corvette See VN One (1) 1991 White Pontiac Firebird (VIN#| sand One (1) 2006 Black Chevrolet Impala VN Defendants in rem. REQUEST FOR PRELIMINARY DETERMINATION OF PROBABLE CAUSE THAT ABOVE-CAPTIONED PROPERTY MAY BE SUBJECT TO FORFEITURE (725 ILCS 150/3.5) AND AFFIDAVIT OF PROBABLE CAUSE NOW COMES the Plaintiff, the People of the State of Illinois (herein State), by Lisa Madigan, Illinois Attorney General, and her assistant Suzanne B. Carmody, Assistant Attomey General, and pursuant to 725 ILCS 150/1, ef seq., state as follows: 1. The above-captioned property was knowingly used or intended tobe used inthe commission or in facilitation of, or was attributable to, or derived from, the manufacture, sale, transportation, distribution, possession, or use of substances in violation of the Ilinois Controlled Substances Act or the Cannabis Control Act, and/or was found in close proximity to forfeitable substances, or to forfeitable drug manufacturing or distributing paraphernalia, or to forfeitable records of the importation, manufacture, or distribution of substances. 2. On May 17, 2016, the Illinois State Police Blackhawk Area Task Force seized the above- captioned property during the execution of a search warrant at MJ Timber Drive, Sterling, Whiteside County, Illinois.3. The above-captioned property is subject to forfeiture under the provisions of 720 ILCS 550/12, 720 ILCS 570/505, and 725 ILCS 150/3, et seg. for the reasons detailed within the attached affidavit of probable cause. WHEREFORE, the State asks this Court to enter an order finding that probable cause for forfeiture exists and enter a restraining order or injunction or take other action as appropriate to ensure that the property is not removed from the Court’s jurisdiction and is not concealed, destroyed, or otherwise disposed of by the property owner or interest holder before a forfeiture hearing is conducted. Respectfully submitted, PEOPLE OF THE STATE OF ILLINOIS By: Lisa Madigan, Illinois Attorney General oe SPELL jody, ARDC #6311021 Assistant Attomey General Office of the Attorney General, Statewide Grand Jury Bureau 100 West Randolph Street, 11" Floor Chicago, IL 60601-3271 Phone: (312) 814-2086 Fax: (312) 814-4971 email: scarmody @atg.state.il.us By:IN THE CIRCUIT COURT OF THE FOURTEENTH JUDICIAL CIRCUIT, WHITESIDE COUNTY, ILLINOIS THE PEOPLE OF THE STATE OF ILLINOIS, Plaintiff CIRCUIT COURT WHITESIDE COUNTY MAY 27 2016 vs. ) ) ) ) ) $17, 248.00 in United States Currency; ) ) CIRCUIT CLERK One (1) 2014 Black Chevrolet Corvette ) Sirny VV ) ) One (1) 1991 White Pontiac Firebird ) VT: ) ) One (1) 2006 Black Chevrolet Impala ) No. 16-MR_ YB a ) ) ) Defendants in rem. ORDER DETERMINING PROBABLE CAUSE THAT ABOVE-CAPTIONED PROPERTY MAY BE SUBJECT TO FORFEITURE THIS CAUSE coming before the Court for determination of probable cause under 725 ILCS 150/3.5, the People of the State of Illinois (herein State), by Lisa Madigan, Illinois ‘Attorney General, and her assistant Suzanne B. Carmody, Assistant Attomey General, and the Court, being fully advised in the premises, HEREBY FINDS: Probable cause does NOT exist ¥ Probable cause does exist and the above-captioned property may be subject to farther forfeiture proceedings and shall be held until the conclusion of proceedings or order of Court. The Court further orders that all owners and interest holders of the property are enjoined and restrained from removing the property from the Court’s jurisdiction and from concealing, destroying, or otherwise disposing of the property before further order of Court. ska feore Dated: 2016 Judge