Case 4:18-cv-04332 Document 1 Filed in TXSD on 11/15/18 Page 1 of 6

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
UNITED STATES OF AMERICA,
Plaintiff
v.
$125,000.00 in U.S. CURRENCY,
Defendant

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CIVIL ACTION NO. 4:18-cv-04332

COMPLAINT FOR FORFEITURE IN REM
The United States of America files this action for forfeiture and alleges upon information
and belief:
Nature of the Action
1.

This is an action to forfeit property to the United States pursuant to 21 U.S.C. §

881(a)(6).
Defendant Property
2.

The Defendant is $125,000.00 in United States currency (the “Defendant Cash”).

3.

On or about May 3, 2018, law enforcement seized the Defendant Cash from Jessica

Bucio in Houston, Texas. The Defendant Cash is currently in a bank account within the custody
of the U.S. Marshal’s Service.
Jurisdiction and Venue
4.

This Court has subject-matter jurisdiction pursuant to 28 U.S.C. §§ 1345 and 1355.

5.

Venue is proper in this Court pursuant to 28 U.S.C. §§ 1355(b)(1), 1391(b), and

1395.
Statutory Basis for Forfeiture
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6.

The Defendant Cash is subject to forfeiture under 21 U.S.C. § 881(a)(6), which

provides for the forfeiture of all moneys furnished or intended to be furnished by any person in
exchange for a controlled substance or listed chemical in violation of the Controlled Substances
Act (21 U.S.C. § 801, et seq.), all proceeds traceable to such an exchange, and all moneys used or
intended to be used to facilitate any violation of the Controlled Substances Act.
Facts
7.

On or about May 3, 2018, Jessica Bucio (“Bucio”) exited a bus that had arrived in

Houston, Texas from Atlanta, Georgia. While Bucio was still at the bus station, Houston Police
Department (“HPD”) Officers A. Alvarez and T. Walker, approached her, identified themselves
as HPD officers by showing their police identification and badges, and asked to speak with her.
Bucio agreed to speak with them.
8.

Bucio appeared to be nervous throughout the conversation.

9.

When asked where she was traveling from, Bucio stated that she was coming from

Columbia, South Carolina and was continuing on to Morelia, Mexico, where she has a home.
Bucio told the HPD officers that she flew from Mexico City to Atlanta on May 1, 2018 and then
on to Columbia, South Carolina.
10.

After Officer Walker asked Bucio if she had any identification, she produced a U.S.

passport.
11.

When asked about the nature of her travel to Columbia, South Carolina, Bucio

responded that she went to Columbia to sell a ranch in her hometown of Morelia, Mexico. Officer
Walker noticed that as the conversation progressed, Bucio’s tone became more hesitant and unsure.

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12.

Officer Alvarez asked Bucio if she had any narcotics or narcotics proceeds, and

Bucio said no. Bucio consented to a search of the bag she was carrying and handed her purse to
the officer. Officer Alvarez advised Bucio that she was not under arrest and had no obligation to
allow officers to access her bags. Officer Alvarez told Bucio he could feel rectangular-shaped
objects behind the lining in her purse. When asked what it was, Bucio responded that it was
money. When asked how much money, Bucio responded that it was about $110,000. Bucio said
she did not count the money. Bucio’s suitcase was also searched; no money was found in her
suitcase.
13.

When asked where the money found in her purse came from, Bucio responded that

the money belonged to her and that she had sold some property in Morelia, Mexico to a neighbor
in Morelia. When asked the neighbor’s name, Bucio said that she could not recall. Officer Walker
asked Bucio why she had the sales proceeds with her if the property had been sold in Mexico.
Bucio responded that the buyer lives in Morelia, Michoacan, Mexico but that the buyer told her
that the money was in the United States so she flew from Mexico City to Atlanta to Columbia,
South Carolina to pick up the money. Bucio said that an unknown male came to her hotel room
in Columbia, gave her cash in a Dillard’s shopping bag, and told her that the cash was separated
in $5,000 bundles.
14.

The Defendant Cash found in Bucio’s purse was comprised of several stacks of

cash that were bundled in rubber-bands in a manner consistent with proceeds from drug trafficking.
The Defendant Cash, which totaled $125,000, was in the following denominations:
•
•
•
•

$100
$ 50
$ 20
$ 10

x
x
x
x

483
125
3507
31
3

=
=
=
=

$
$
$
$

48,300.00
6,250.00
70,140.00
310.00

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15.

A package of rubber-bands was found in Bucio’s purse in the same area where the

Defendant Cash was found.
16.

A trained canine alerted to the odor of narcotics coming from the Defendant Cash.

17.

The Defendant Cash constitutes money furnished or intended to be furnished in

exchange for a controlled substance, proceeds traceable to such an exchange, or money used or
intended to be used to facilitate a violation of the Controlled Substances Act.
Notice to Any Potential Claimants
YOU ARE HEREBY NOTIFIED that if you assert an interest in Defendant Cash which is
subject to forfeiture and want to contest the forfeiture, you must file a verified claim which fulfills
the requirements set forth in Rule G of the Supplemental Rules for Admiralty or Maritime Claims
and Asset Forfeiture Actions. A verified claim must be filed no later than thirty-five (35) days
from the date this Complaint has been sent. An answer or motion under Rule 12 of the Federal
Rules of Civil Procedure must be filed no later than twenty-one (21) days after filing the claim.
The claim and answer must be filed with the United States District Clerk for the Southern District
of Texas at United States Courthouse, 515 Rusk Avenue, Houston, Texas 77002, and a copy must
be served upon the undersigned Assistant United States Attorney at United States Attorney’s
Office, 1000 Louisiana, Suite 2300, Houston, Texas 77002.
Requested Relief
Wherefore, the United States of America prays that judgment of forfeiture be entered
against the Defendant Cash in favor of the United States of America under 21 U.S.C. § 881(a)(6)
in addition to such costs and other relief to which the United States of America may be entitled.
Respectfully submitted,
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Ryan K. Patrick
United States Attorney
By:

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s/Lori S. Roth
Lori S. Roth
Email: lori.roth@usdoj.gov
Texas State Bar No. 24076691
SDTX Bar No. 1383270
Assistant United States Attorney
United States Attorney’s Office
1000 Louisiana, Suite 2300
Houston, TX 77002
Telephone: (713) 567-9000
Fax: (713) 718-3300

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