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Plaintiff, United States of America, by its undersigned counsel, alleges the following for
its action against the defendant in accordance with Supplemental Rule G(2) of the Federal Rules
of Civil Procedure.
in United States Currency. On or about December 30, 2016, Homeland Security Investigations
(“HSI”) seized the defendant from Giovanni Crawford, following a traffic stop on northbound
Hamilton Avenue, which was initiated by the Regional Narcotics Unit (“RENU”) Highway
Interdiction Squad.
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controlled by the U.S. Customs and Border Protection, Fines, Penalties and Forfeiture Office,
4. Plaintiff brings this action in rem in its own right to forfeit and condemn the
defendant pursuant to 21 U.S.C. § 881(a)(6). This Court has jurisdiction over an action
commenced by the United States under 28 U.S.C. § 1345 and over an action for forfeiture under
28 U.S.C. § 1355(a).
5. This Court has in rem jurisdiction over the defendant pursuant to 28 U.S.C.
§ 1355(b)(1)(A) because acts and omissions giving rise to the forfeiture occurred in the Southern
District of Ohio.
and omissions giving rise to the forfeiture occurred in the Southern District of Ohio and pursuant
to 28 U.S.C. § 1395 because the defendant was found in the Southern District of Ohio.
represents proceeds traceable to such an exchange, or was used or intended to be used to facilitate
any violation of 21 U.S.C. § 841 or a conspiracy to commit such offense in violation of 21 U.S.C.
§ 846.
FACTS
8. On or about December 30, 2016, at approximately 2:00 p.m., Agent Anthony Lange
(“Agent Lange”) of RENU observed the driver of a black 2017 Ford Escape following another
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9. Agent Lange initiated a traffic stop on the Ford Escape, which was a rental vehicle
registered to EAN Holdings LLC, d/b/a Enterprise Rent-A-Car (“Enterprise”). Agent Lange
approached the driver of the vehicle who was later identified as Giovanni Crawford (“Crawford”).
10. Agent Lange advised Crawford of the violation, requested Crawford’s driver’s
license and rental agreement, and asked where Crawford was headed. Crawford stated that he
11. Crawford apologized for not having his driver’s license with him and produced the
rental agreement for the Ford Escape. Agent Lange asked Crawford if he had a valid driver’s
license. Crawford stated that he did and that he was listed on the Ford Escape’s rental agreement.
Agent Lange observed that Crawford was becoming increasingly nervous during questioning.
12. In an attempt to verify Crawford’s identity, Agent Lange asked Crawford for his
Social Security number and date of birth. Crawford stated that he was going to be late and asked
if all the questions were necessary. Agent Lange asked Crawford again for his Social Security
number, and Crawford complied. Agent Lange wrote the number on the back of the Enterprise
rental agreement and repeated the number back to Crawford for confirmation.
13. Agent Lange requested that Crawford turn the vehicle off and remove the keys from
14. Agent Lange also requested that Crawford turn over the keys to the vehicle to
ensure that Crawford would not leave the scene. Crawford asked Agent Lange if that was
necessary and stated that he was not going to do anything with his child in the car. Agent Lange
stated that the keys would be returned once he had confirmed Crawford’s identity, the validity of
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15. Agent Lange returned to his police vehicle and conducted computer queries on
Crawford. The Social Security number that Crawford provided was returned as belonging to a
white female.
16. Agent Lange returned to the Ford Escape and asked Crawford to exit the vehicle.
Crawford was talking on one cell phone and attempting to record Agent Lange with another.
17. Agent Lange again asked Crawford to exit the vehicle. Crawford stated that he
did not want to do this in front of his child and asked if he could just go to the barber shop. Agent
Lange then ordered Crawford out of the vehicle. Crawford continued to stall but eventually chose
18. Agent Lange escorted Crawford to the front of his police vehicle to scan his
fingerprints for identity confirmation. Agent Lange patted down Crawford for weapons and
observed a large bulge of what felt like currency. Agent Lange then captured Crawford’s
fingerprints.
19. Agent Lange asked Crawford if there were any weapons, drugs, or large sums of
money in the vehicle. Crawford was slow to answer but stated that there was nothing illegal in
the vehicle.
20. Crawford also said that his brother’s money was in the vehicle. Agent Lange
asked Crawford why his brother had given him money, and Crawford boasted that his brother was
Adrien Broner and that he always gave Crawford money to hold for him.
21. Crawford’s son blurted out, “AB did not give my dad the money; another man did.”
22. Meanwhile, RENU Agent Jeffrey Scott (“Agent Scott”), who was serving as
backup, determined that Crawford had a suspended driver’s license, resulting from a drug offense
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violation out of Warren County, Ohio. Agent Scott also determined that Crawford had a failure
23. Agent Lange reviewed the rental agreement for the Ford Escape. The rental
agreement listed only one name, “Monay Little,” and specified that there were no additional drivers
operate the Ford Escape. Enterprise advised Agent Lange that no additional drivers were
permitted and requested that Crawford not be allowed to have the vehicle. Enterprise then
25. An agent advised Crawford that Enterprise was coming to take possession of the
vehicle and asked if there was anything else in the vehicle besides the money his brother had given
him. Crawford stated that he had about $7,000.00 in his coat in the front passenger seat.
26. RENU Sergeant Gregory Morgan (“Sgt. Morgan”) and Agent Rick Haun (“Agent
Haun”) inventoried the Ford Escape and recovered rubber-banded bundles of United States
currency, totaling $14,005.00, from under the front seat of the vehicle.
27. Sgt. Morgan and Agent Haun also recovered receipts from a local Kroger, which
identified eight money orders in the amount of $1,000.00 each. Agents located a United Parcel
Service receipt, which identified a package that recently had been sent to North Hollywood,
28. HSI attempted to interdict the package before it arrived at its destination in North
29. Crawford’s son was released to a family member at the scene. Crawford then was
transported to the Hamilton County Sheriff’s Patrol Headquarters (“Patrol Headquarters”) for
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person.
30. At Patrol Headquarters, Sgt. Morgan and Agent Scott conducted an interview of
Crawford. Sgt. Morgan advised Crawford of his Miranda Rights as Crawford followed along on
a corresponding form. After being advised of his Miranda Rights, Crawford stated that he
31. Sgt. Morgan informed Crawford that agents had recovered a large amount of
currency from the Ford Escape. Sgt. Morgan asked Crawford how the currency ended up under
the driver’s seat when Crawford initially had indicated that the currency was in the pocket of his
32. Crawford told Sgt. Morgan that the currency must have fallen out of his pocket.
Sgt. Morgan advised Crawford that he was not telling the truth because the amount of currency
could not just fall out of a pocket, and the large bundles could not fit in the pockets of a jacket.
33. Crawford then changed his story and stated that $7,000.00 was placed under the
driver’s seat when he went to the barber shop for his son’s haircut.
34. Sgt. Morgan questioned Crawford about the money order receipts. Crawford
became extremely nervous and made nonsensical statements. According to Crawford, his
brother, “AB,” paid for the rental. Crawford also claimed that other unknown individuals used
the Ford Escape and tried to tie the recovered evidence to them.
35. Sgt. Morgan advised Crawford that agents intended to obtain a search warrant for
his cell phones. Although Crawford previously had identified the two cell phones in the vehicle
as belonging to him, upon learning that Sgt. Morgan intended to search the phones, Crawford
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36. Sgt. Morgan confronted Crawford with what appeared to be clear evidence of drug
activity by referencing the large amount of currency and receipts for money orders sent to
California. Sgt. Morgan advised Crawford that he had investigated numerous marijuana
organizations where individuals often sent money orders to their suppliers, using the mail system
37. Crawford maintained that some of the currency was given to him by his brother.
Crawford gave his brother’s cell phone number to Sgt. Morgan, but when Sgt. Morgan called the
number, an assistant told him that Crawford’s brother was not available and that he would call the
38. Ohio BEST Team III, HSI Special Agent Michael Nimmo (“SA Nimmo”)
responded to the Patrol Headquarters after receiving information that RENU had encountered
Crawford and had requested record checks and assistance with a bulk cash and narcotics-
smuggling joint investigation that appeared to involve money orders being sent from Cincinnati
by persons with drug histories. Crawford and Adrien Broner were known to SA Nimmo as being
associated with other BEST Team III and RENU narcotics and money laundering investigations.
39. SA Nimmo advised Crawford that HSI was seizing the currency, which included
the $14,005.00 from under the front seat of the rental vehicle and the $1,090.00 on Crawford’s
person for a total of $15,095.00 (the defendant). Crawford was released and advised to turn
40. At the Hamilton County Sheriff’s Office (“HCSO”), Agent Haun and his trained
First, Agent Haun ran K9 Chica through a locker bay in the HCSO garage. K9 Chica showed no
alert behavior. The defendant then was placed in one of the lockers. The second time Agent
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Haun ran K9 Chica through the locker bay, she showed a positive alert for the odor of narcotics
41. On January 3, 2017, Agent Scott obtained a search warrant from the Honorable J.
Patrick Foley III of the Hamilton County Court of Common Pleas for the LG cell phone and iPhone
42. The agents were not able to search the iPhone; however, the text message data from
the LG cell phone revealed Crawford’s involvement in narcotics trafficking. Nearly all of the
text messages contained on the phone related to the purchase, sale, and distribution of narcotics.
43. For example, on December 13, 2016, beginning at approximately 9:23 a.m., the text
message data shows that Crawford and an individual called “Phil” exchanged the following text
messages:
44. On December 14, 2016, beginning at approximately 11:05 a.m., the text message
data shows that Crawford and Phil exchanged the following text messages:
PHIL: Im up yo way
CRAWFORD: Just got out the shower about to go meet up with
my guy
CRAWFORD: How much was it short?
PHIL: Bet
CRAWFORD: Imma bring one of the new ones that came in today
PHIL: 49 and i need more than one bro ha
CRAWFORD: I need 34 big bro
CRAWFORD: Im not getting no good deal i take it to the west and
downtown and get 36 or 35
CRAWFORD: Im not even making shit really off you
PHIL: But im buyin 10 what bout 3250 meet in the middle
ha
CRAWFORD: 3300 bro i gotta make sometbing
PHIL: Just bring 5 just n case but i wanna see em
CRAWFORD: Ok big bro you know i would go for that but i gottA
make at least 200 make it worth it
PHIL: Understandable
45. On December 21, 2016, beginning at approximately 1:33 p.m., the text message
data shows that Crawford and an unidentified individual (“UI”) with the phone number (513) 591-
would
CRAWFORD: It suppose to be 460 bag weigh 12 plus 448
CRAWFORD: Ok nah its cool big bro
UI: Nah weigh another bag the one i just weighed was
damn near 20
CRAWFORD: Ok about to you got a turkey bag?
UI: Nah i weighed one of the ones from bra
CRAWFORD: Mean 16
CRAWFORD: I just weigh it my self
CRAWFORD: 464 with bag
UI: Yea one was 16 but none of the bags was weighin
under that
UI: U puttin em in the ziplock joints?
CRAWFORD: About to be there
CRAWFORD: Everything on
UI: Ok
UI: Ok 20mins
CRAWFORD: Ok im here
CRAWFORD: You only going to be 20 mins right
UI: Yea leavin downtown nw
CRAWFORD: Ok here
UI: Ok
CRAWFORD: How much longer?
UI: Less than ten on pippin
CRAWFORD: Lol man you stalling me gotta take my dude 4 of
these to
46. On December 23, 2016, beginning at approximately 12:45 p.m., Crawford and UI
47. On December 24, 2016, beginning at approximately 8:39 a.m., Crawford and UI
48. On December 30, 2016, the date that the defendant was seized from Crawford,
beginning at approximately 9:11 a.m., the text message data shows the following conversation
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49. After the defendant was seized, an official count revealed the following
denominations.
DENOMINATION QUANTITY
$100 13
$50 21
$20 570
$10 82
$5 102
$1 15
50. Narcotics trafficking is a cash business. As indicated above, the majority of the
51. Crawford received timely notice of the administrative forfeiture of the defendant
and submitted two petitions for remission, asserting his ownership interest in the currency. Both
petitions were denied for lack of proof of interest and/or legitimate source.
52. On September 10, 2019, Crawford submitted a claim, asserting his interest in the
defendant. Crawford claims that the defendant was payment from Adrien Broner Enterprises for
his services as Adrien Broner’s manager. Crawford has not supplied any documents or other
53. Based on the foregoing facts, the United States asserts that the defendant is subject
to forfeiture to the United States under 21 U.S.C. § 881(a)(6) because it represents property
traceable to such an exchange, or was used or intended to be used to facilitate any violation of 21
12
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(a) pursuant to Rule G(3)(b)(i), Supplemental Rules, the Clerk issue a warrant of arrest
in rem, directing the United States to arrest and seize the defendant and to retain the same in its
(b) the Court, pursuant to Rule G(4), Supplemental Rules, direct the United States to
give notice to all persons and entities having an interest in the defendant to assert in conformity
with the law a statement of any interest they may have, including notice by publication on the
(c) the forfeiture of the defendant to the United States be confirmed, enforced, and
(d) the Court thereafter order the United States to dispose of the defendant as provided
by law; and
(e) the Court award the United States all other relief to which it is entitled, including
Respectfully submitted,
DAVID M. DEVILLERS
United States Attorney
s/Deborah D. Grimes
DEBORAH D. GRIMES (0078698)
Assistant United States Attorney
Attorney for Plaintiff
221 East Fourth Street, Suite 400
Cincinnati, Ohio 45202
(513) 684-3711 / Fax (513) 684-6385
Deborah.Grimes@usdoj.gov
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VERIFICATION
I, Michael R. Nimmo, hereby verify and declare under the penalty of perjury that I am a
Special Agent with Homeland Security Investigations, that I have read the foregoing Verified
Complaint for Forfeiture in rem and know the contents thereof, and that the matters contained in
the complaint are true to my own knowledge, except that those matters stated to be alleged on
The sources of my knowledge and information and the grounds of my belief are the official
files and records of the United States, information supplied to me by other law enforcement
I hereby verify and declare under the penalty of perjury that the foregoing is true and
correct.
Dated:
1 2,.... a ... u,°t
------
I
MICHAEL R. NIMMO, Special Agent
Homeland Security Investigations
Case: 1:19-cv-01040-SJD Doc #: 1-1 Filed: 12/09/19 Page: 1 of 1 PAGEID #: 15
JS44 (Rev o2ile) cIV[ COVER SHEET
The JS 44 civil cover sheet and the information contained herern neither replace nor supplement the filing and service ofpleadings or other papers as required by law, except as
provided by local rules ofcourt. This form, approved by the Judicial Conference oftheUnited States in September 1974, is required for the use ofthe Clerk ofCourt for the
purpose of initiating the civil docket sheet. (SEE TNSTR(ICTIONS ON NEXT PAGE oF' TH\S F)RM.)
(C) Amomevs rl:tm Name. Atldress. antl Teleohone Numbert Attomeys (lf Known)
Ddb6rah D. Grimes, Assistant United States Atforney
221 E. Fourlh Street, Suite 400
Cincinnati, Ohio 45202 (513) 684-3711
II. BASIS OF JURISDICTION 1ero"" on "x" in one Box onty) III. CITIZENSHIP OF PRINCIPAL PARTIES (Ptoce an "x" in one Boxfor Ptainrtf
([:or Diversity Cases Only) aru) One Boxfor Defendant)
il f Govemment
U.S. 0 3 Federal Question PTF DEF PTF DEF
Plaintiff (U.5. Govemmenl Not a I'arty) CitizenofThisState Ol O I IncorporatedorPrincipalPlace O4 A4
ofBusiness h This State
D Il0 Insumce PERSONAL INJURY PERSONAL INJURY d 625 Dmg Related Seirue O 422 Appeal 28 USC 158 D 375 False Claims Act
O 120 Maine fl 310 Airplme D 365 Personal Injury - ofProperty 2l USC 881 O 423 Withdrawal O 376QuiTm(31 USC
O 130 Miller Act O 315 Airplme Product Product Liability D 690 Other 28 USC 157 3729(a))
D 140 Negotiable Instment Liability O 367 HealthCare/ O 400 State Reapportioment
D 150 Recovery of Overpayment D 320 Assault, Libel & Phamaceutical D 410 Antitrust
& Enforcement of Judgment Slmder Personal Injury o 820 Copyrights O 430 Bmks md Banking
il t5l Medicue Act 0 330 Federal Employers' Product Liability o 830 Patent D 450 Comrnerce
0 152 Recovery ofDefaulted Liability D 368 Asbestos Personal o 835 Patent - Abbreviated D 460 Deportation
Student Loms O 340 Muine Injury Product New Drug Application D 470 Racketeer Influenced ud
(Excludes Veterms) D 345 Mrine Product Liabiliy 0 840 Trademuk Compt Orgmiations
0 153 Recovery ofoverpalment Liability PERSONAL PROP[,RTY D 480 Consumer Credit
of Veterm's Benefits 0 350 Motor Vehicle O 370 Other Fraud O 710 Fair Labor Stmd{ds D 861 HrA(1395tr) D 485 Telephone Consumer
D 160 Stockholders' Suits 3 355 Motor Vehicle D 371 Tnrth in Lending Act D 862 Black Lung (923) Protection Act
0 l90OthqContract Product Liability 3 380 Other Personal 0 720 LaborA4magement o 863 DIwC/DIww (405(e)) D 490 Cable/Sat TV
0 195 Contract Product Liability 0 360 Other Personal Property Dmage Relations d 864 SSID TitIC XVI O 850 Secuities/CommoditieV
0 t96 Fmchise Irjury D 385 Property Damage D 740 Railway Labor Act D 865 RSI (405(9)) Exchmge
O 362 Pusonal Injury - koduct Liabrlity D 751 FmilymdMedical D 890 Other Statutory Actions
Medical Malpractice Leave Act D 891 Agricultual Acts
CTVIL RJGHTS O 790 Other Labor Litigation D 893 Enviromental Matters
D 210 Lmd Condemtion O 440 Other Civil tughts Habeas Corpus: 0 791 Employee Retirement O 870 Tues (U.S. Plaintiff O 895 Freedorn oflnfonnation
0 220 Foreclosue O 441Voting O 463 Alien Detainee Income Secuity Act or Defendant) Act
D 230 Rent Lease & Ejectment D 442 Employmmt I 510 Motions to Vacate D 871 IRS-ThirdParty O 896 Arbitration
O 240 Torts to Lmd D 443 Housing/ Sentence 26 USC 7609 D 899 Administrative Procedue
D 245 Tort Product Liabilitr, Accomodations O 530 General Act8eview or Appeal of
D 290 All Other Real Property D 445 Amer. w/Disabilities D 535 Death Penalty IMlIIIGRATION Agency Decision
Employment Other: D 462 Natualization Application O 950 Constitutionality of
0 446 Amer. w/Disabilities D 540 Mmdamus & Other D 465 Other Imigration State Statutes
Other D 550 Civil tughts Actions
0 448 Education O 555 Prison Condition
O 560 Civil Detainee -
Conditions of
Confinement