Case 5:23-cv-70454-MFU Document 1 Filed 07/24/23 Page 1 of 6 Pageid#: 1

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF VIRGINIA
ROANOKE DIVISION

UNITED STATES OF AMERICA )

)
v. ) Case No. __________________
7:23cv00454
)
APPROXIMATELY $71,980.00 IN U.S. )
CURRENCY

VERIFIED COMPLAINT FOR FORFEITURE IN REM

The United States brings this Complaint for Forfeiture In Rem and alleges as follows in

accordance with Supplemental Rule G(2) of the Federal Rules of Civil Procedure:

NATURE OF THE ACTION

1. This is a civil action in rem brought to forfeit certain personal property assets to the use

and benefit of the United States, pursuant to Forfeiture Provision, for violations of 21 U.S.C. § 841.

THE DEFENDANTS IN REM

2. The defendant property consists of the following property:

(a) Approximately $71,980.00 in U.S. currency that was seized from Reuben Dixon on

January 26, 2023, at the following location: Interstate 81 in Frederick County, Virginia, and is

presently in the custody of the United States Marshals Service in Richmond Virginia.

JURISDICTION AND VENUE

3. 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).

4. This Court has in rem jurisdiction over the defendant property under 28 U.S.C. § 1355(b).

5. Venue is proper in this district pursuant to 28 U.S.C. §1355(b)(1) because the acts giving

rise to this forfeiture occurred in this district.

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BASIS FOR FORFEITURE

6. The defendant property is subject to forfeiture pursuant to 21 U.S.C. § 881(a)(6), as a thing

of value constituting proceeds, facilitating property, and/or property furnished or intended to be

furnished in exchange for a controlled substance.

FACTS

7. On January 26, 2023, at approximately 1:37 a.m., Deputy Davis with the Frederick County

Sheriff’s Office observed a 2013 black Beamer with temporary Georgia license plates registered

to an individual in California swerving in its lane on Interstate 81. Deputy Davis then initiated a

traffic stop of the vehicle for suspicion of driving under the influence.

8. Upon pulling over, Deputy Davis made contact with the driver who was the lone occupant

of the vehicle. Deputy Davis identified the driver by his New York driver’s license as Reuben

Dixon. Dixon was not the registered owner of the vehicle.

9. Dixon told Deputy Davis he was coming from Roanoke, Virginia, back to his residence in

New York after attending a family reunion in Roanoke.

10. Deputy Davis asked Dixon whether he had anything to drink, and Dixon stated he does not

drink or smoke. Then, unprompted, Dixon showed Deputy Davis his diabetes medication.

11. Deputy Davis then asked Dixon whether there was anything illegal in the vehicle, to which

Dixon responded, “No, no, you can search it, I give you consent to search.”

12. When deputies searched the vehicle, they noticed multiple empty voids in the center

console and dash of the vehicle. These voids are consistent with hiding or concealing narcotics or

large amounts of currency for purchasing narcotics.

13. The vehicle did not contain any luggage consistent with someone who was traveling and

staying overnight.

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14. While searching the vehicle, deputies located a plastic grocery bag on the floor in the rear

of the vehicle next to an open box of dryer sheets. Inside of the grocery bag was another grey

plastic bag containing a clear plastic vacuum sealed pack of U.S. currency as well as paper towels

sprayed with cologne or other type of aromatic masking agent. The currency inside was separated

into stacks with small, various colored rubber bands.

15. Drug traffickers place strongly scented items, such as dryer sheets and cologne, next to

currency to disguise the smell of the currency and narcotics on the currency.

16. At approximately 1:58 a.m., the deputies informed Dixon he was being detained and read

his Miranda warning.

17. Dixon then offered the deputies a different reason for being in Roanoke. He now told

deputies that he was in Roanoke not for a family reunion, but to collect money from family

members so he could purchase racehorses.

18. The deputies asked Dixon how much money was in the plastic bag and why the currency

was packaged in the manner it was. Dixon told the deputies he did not know how much currency

was in the bag, and that it was packaged that way because someone had been smoking “weed”

around the money and he did not want drug sniffing dogs to smell it.

19. Deputy Suire and his narcotics canine from the Frederick County Sheriff’s Office arrived

at the scene of the traffic stop to assist. Deputy Suire had his narcotics canine conduct an open-air

sniff around the vehicle, and the narcotics canine alerted to the presence of narcotics on the driver’s

side of the vehicle where Dixon was seated.

20. The narcotics canine is trained to detect odors of cocaine, ecstasy, heroin, and

methamphetamine.

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21. DEA Task Force Officers Foster and Kahle, who had also arrived on the scene, also

questioned Dixon about the money found in the vehicle. Dixon told TFO Foster and TFO Kahle

that the money was to purchase racehorses, which he keeps at multiple stables. TFO Kahle asked

Dixon how many horses Dixon has, to which Dixon responded, “Zero.”

22. Dixon told TFO Kahle that the name of his stable was “Day One Syndicate.”

23. An internet search for “Day One Syndicate” does not reveal any business, including a

business related to horseracing or horse stables.

24. Dixon told TFO Foster that he had obtained the money from friends and family members

in Roanoke, Virginia, not just from family as he had told the deputies.

25. TFO Foster asked Dixon the names of the friends and family who had given him the money,

and Dixon told him that the friends and family all go by aliases. Dixon then told TFO Foster that

one of the individuals who gave him the money was his cousin “Robert,” but he did not know

Robert’s last name, address, or phone number. Dixon told TFO Foster that he met Robert in the

parking lot of a Food Lion in Roanoke to obtain the money, which was arranged by other family

members for whom Dixon did not provide a name or contact information.

26. The facts supporting this Complaint are stated in the attached Declaration of Task Force

Officer Steven M. Kahle with the Drug Enforcement Administration and are incorporated by

reference herein.

WHEREFORE, the United States of America respectfully requests that the Clerk of Court

issue a Warrant of Arrest in rem pursuant to Supplemental Rule G(3)(b); that due notice be given

to all parties to appear and show cause why the forfeiture should not be decreed; that judgment be

entered declaring the defendant property to be condemned and forfeited to the United States for

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disposition according to law; and that the United States be granted such other and further relief as

this Court may deem just and proper, together with the costs and disbursements of this action.

CHRISTOPHER R. KAVANAUGH
United States Attorney

/s/ Krista Consiglio Frith

Krista Consiglio Frith
Assistant United States Attorney
Virginia State Bar No. 89088
P. O. Box 1709
Roanoke, VA 24008-1709
Telephone: (540) 857-2250
Facsimile: (540) 857-2283
E-mail: Krista.frith@usdoj.gov

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