El Rodeo Lawsuit (Redacted)

7/22/2019 El Rodeo Lawsuit (Redacted)

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STATE OF INDIANATIPPECANOE COUNTY

)

STATE OF INDIANA, and the )Tippecanoe County Prosecutor' s Office, the )Lafayette Police Department, the West Lafayette)Police Department, the Tippecanoe County )Sheriff s Department, the Purdue University )Police Department, and the Indiana State Police )

Plaintiffs

vs. ))EL RODEO MEXICAN RESTAURANT 2, )Inc. )

$95 ,854.31 in U.S. Currency,Located in First Bank RichmondAcct. No. 891083287JOSE MELENDEZ,As His Interest May Appear,

FRANCISCO SALGADO,As His Interest May Appear,JESUS MELENDEZ,As His Interest May Appear,R.P . MONTERDY,As His Interest May Appear,

EL RODEO MEXICAN RESTAURANT akaEL RODEO 10, LLC$42,968.39 in U.S. Currency,Located in First Bank RichmondAcct. No. 591001712

JOSE MELENDEZ,As His Interest May Appear,

FRANCISCO SALGADO,As His Interest May Appear,JESUS MELENDEZ,As His Interest May Appear,

FRANCISCO JOSE PROPERTIES, LLC$2,355.54 in U.S. Currency,Located n First Bank RichmondAcct. No. 0191013813-8JOSE MELENDEZ,As His Interest May Appear,

FRANCISCO SALGADO,As His Interest May Appear,JESUS MELENDEZ,

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SS: IN THE TIPPECANOE SUPERIOR COURT I

CAUSE NO . 79D01-1402-PL- t \

LED

This document was edited by the Journal & Courier to redact the addresses where the individuals were served.No other information was changed.


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As His Interest May Appear,JOSE MELENDEZ$25,754.75 in U.S. Currency, )

Located in BMO Harris BankAcct. No. 2590000905EL JARIPEO 3, LLC$331.68 in U.S . Currency, )

Located in BMO Harris BankAcct. No. 4805751541JOSE MELENDEZ,As His Interest May Appear,FRANCISCO SALGADO,As His Interest May Appear,FRANCISCO V. MUNOZ,As His Interest May Appear, )ENRJQUE MELENDEZ

As His Interest May Appear, )ALFREDO MELENDEZ$23,309 .57 in U.S. Currency,

Located in Key Bank )Acct. No . 141942000508,LOS TOROS MEXICAN RESTAURANT 2,INC. $1,601.88 in U.S. Currency,

Located in Key BankAcct. No. 149681010810ENRJQUE MELENDEZ-AGUIRRE,As His Interest May Appear,ALFREDO MELENDEZ-AGUIRRE,As His Interest May Appear,NOE 0 . FERNANDEZ

As His Interest May Appear,JORGE M ELENDEZ-AGUIRRE,As His Interest May Appear,LOS TOROS ME XICAN RESTAURANT 2,INC. $18,355 .92 in U.S. Currency,

Located in Key BankAcct. No. 149681007600ENRJQUE MELENDEZ-AGUIRRE,As His Interest May Appear,ALFREDO MELENDEZ-AGUIRRE,As His Interest May Appear,

NOE 0 FERNANDEZAs His Interest May Appear,JORGE MELENDEZ-AGUIRRE,


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As His Interest May Appear, ))LOS TOROS MEXICAN RESTAURANT )$31,857.26 in U.S. Currency, )Located in Key Bank )Acct. No. 149681007592 )ALFREDO MELENDEZ-AGUIRRE, )As His Interest May Appear, )ENRIQUE MELENDEZ-AGUIRRE, )

As His Interest May Appear, )LUIS M. RUIZ, )As His Interest May Appear, )PHILIP STARK, )As His Interest May Appear, )

ENRIQUE MELENDEZ-AGUIRRE, )$2,413.87 in U.S. Currency, )Located in Key Bank )Acct. No. 141942009236 )

THE TOROS PROPERTY, LLC, )$249,000 in U.S. Currency, )Located in Key Bank )Acct. No. 149681017823 )ENRIQUE MELENDEZ-AGUIRRE, )

As His Interest May Appear, )ALFREDO MELENDEZ-AGUIRRE, )As His Interest May Appear, )JOSE & FRANCISCO PROPERTIES, LLC )

$9,532.09 in U.S. Currency, )Located in Chase Bank )Acct. No. 675003735 )JOSE MELENDEZ-PEREZ, )

As His Interest May Appear, )FRANCISCO SALGADO, )

As His Interest May Appear, ))

EL JARIPEO 3 aka EL JARIPEO 3, LLC )$272.88 in U.S. Currency, )Located in Chase Bank )Acct. No. 969915883 )

JOSE MELENDEZ )As His Interest May Appear, )FRANCISCO SALGADO, )

As His Interest May Appear, )ENRIQUE MELENDEZ )As His Interest May Appear, )FRANCISCO SALGADO )$7,868.20 in U.S. Currency, )


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Located in Chase BankAcct. No . 500077663329EL JARIPEO 2 aka EL JARlPEOMEXICAN RESTAURANT 2, INC.$8,036.72 in U.S . Currency

Located in PNC BankAcct. No 4618519363JOSE MELENDEZ,

As His Interest May Appear,JOSE BERNAL,As His Interest May Appear,FRANCISCO SALGADO,As His Interest May Appear,JESUS MELENDEZ,As His Interest May Appear,FELIPE BERNAL,As His Interest May Appear,

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FRANCISCO & CONCEPCION SALGADO, )$107,797.73 in U.S. Currency )Located in PNC Bank )Acct. No. 4617720997 )ADRIANA SALGADO, )As Her Interest May Appear,GABRIELLE SALGADO,As Her Interest May Appear,FRANCISCO & CONCEPCION SALGADO,$201 ,414.14 n U.S. Currency

Located in PNC BankAcct. No. 4618033232ADRIANA SALGADO,As Her Interest May Appear,JOSE BERNAL,$1,755.99 n U.S. CurrencyLocated in PNC BankAcct. No. 4618400047,JOSE BERNAL,$871.43 in U.S . Currency

Located in PNC BankAcct. No. 46 7574598,EL RODEO aka EL RODEO LLC$967,840.81 in U.S. CurrencyLocated in PNC BankAcct. No. 4804542997JOSE MELENDEZ,As His Interest May Appear,

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FRANCISCO SALGADO,As His Interest May Appear,

EL RODEO 21 aka EL RODEO 21 LLC$24,767.91 in U.S. CurrencyLocated in PNC BankAcct. No. 4804542911JOSE MELENDEZ,As His Interest May Appear,


SONIA CERVANTES,As Her Interest May Appear,

SERGIO AGUIRRE CERVANTES,As His Interest May Appear,

)EL RODEO 25 aka EL RODEO 25 LLC

$13,917.94 in U.S. CurrencyLocated in PNC Bank )Acct. No. 4804542938



EL RODEO 20 aka EL RODEO 20 LLC$43,440.53 in U.S. CurrencyLocated in PNC BankAcct. No. 4804542946

FRANCISCO SALGADO,As His Interest May Appear,JOSE MELENDEZ,As His Interest May Appear, )

)EL RODEO 9 aka EL RODEO 9 LLC

$105,212.43 in U.S. Currency )Located in PNC BankAcct. No. 4804542954



ENRIQUE A. MELENDEZ,As His Interest May Appear,SERGIO CERVANTES,

As His Interest May Appear,EL RODEO 24 ~ R O E O 24 LLC )

$36,937.82 in U.S. CurrencyLocated in PNC BankAcct. No. 4804542962


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JOSE MELENDEZ, )As His Interest May Appear, )FRANCISCO SALGADO, )As His Interest May Appear, ))JOSE FRANCISCO PROPERTIES, LLC )

17,642.66 in U.S. Currency )Located PNC Bank )Acct. No. 4804543009 )JOSE MELENDEZ, )As His InterestMay Appear, )FRANCISCO SALGADO, )As His Interest May Appear, ))INDY MEX PROPERTIES, )5,320.22 in U.S. Currency )Located in PNC Bank )Acct. No. 4804543017 )

JOSE MELENDEZ, )As His Interest May Appear, )FRANCISCO SALGADO, )As His Interest May Appear, )ALFREDO MELENEDEZ, )As His Interest May Appear, ))JOSE M. PEREZ aka JOSE MELENDEZ, )7,984.67 in U.S. Currency )Located in Fifth Third Bank )Acct. No. 7650190486, ))

LA CARRETA 3 aka LA CARRETA )RESTAURANT AND BAR, INC. )84,153.17 in U.S. Currency )Located in Fifth Third Bank )Acct. No. 7654938617 )ARNULFO GONZALEZ, )As His Interest May Appear, )JAMIE G. GONZALEZ, )As His Interest May Appear, )JOSAFAT GONZALEZ, )As His Interest May Appear, )RAFAELGONZALEZ, )

As His Interest May Appear, ))EL RODEO aka EL RODEO 17 LLC, )40,007.91 in U.S. Currency )Located in Fifth Third Bank )Acct. No. 7652578712 )JOSE M. PEREZ aka JOSE l\rffiLENDEZ, )As His Interest May Appear, )FRANCISCO SALGADO, )


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As His n t e r e s t ~ Appear, )._ )FRANCISCO SALGADO, )$216,101.99 in U.S. Currency )Located at Fifth Third Bank )Acct. No. 7652596698 )CONCEPCION SALGADO, )As Her Interest May Appear, )

)FRANCISCO SALGADO, )$106,718.81 in U.S. Currency )Located at Fifth Third Bank )Acct. No. 9974952906 )GABRIELLA SALGADO, )

As Her Interest May Appear, ))

ANTONIO S. PASTRANA PATRICIA F. )CARRANZA )

$7,603.67 in U.S. Currency )Located in Huntington Bank )Acct. No . 2405860115 ))

ANTONIO S. PASTRANA aka ANTONIO )SALGADO PASTRANA )$1,994.83 in U.S. Currency )Located in Huntington Bank )Acct. No. 4401822414 ))EL JARIPEO 5 aka EL JARIPEO 5 LLC, )$910.06 in U.S. Currency )

Located in First Merchants Bank )d/b/a Lafayette Bank & Trust )Acct. No. 520001385 )FRANCISCO SALGADO, )

As His Interest May Appear, )JOSE MELENDEZ )

As His Interest May Appear, )JOSE BERNAL )

As His Interest May Appear, )FELIPE BERNAL )

As His Interest May Appear, ))EL RODEO aka EL RODEO MEXICAN )RESTAURANT, )$31,803.98 in U.S . Currency )Located in Regions Bank )Acct. No. 87520559 )JOSE MELENDEZ-PEREZ aka JOSE )MELENDEZ )



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As His Interest May Appear, )ABEL BUSTOS , )

As His Interest May Appear, ))

ABEL BUSTOS, )$2,521.73 in U.S. Currency )Located at Regions Bank )Acct. No. 186329758, ))

EL RODEO 19 aka EL RODEO 19 LLC )$11 ,381.59 n U.S. Currency )Located at Old National Bank )Acct. No. 116701705 )JOSE MELENDEZ, )


As His Interest May Appear, )ABEL BUSTOS , )

As His Interest May Appear, )LUIS ANTONIO BUSTOS, )As His Interest May Appear, )

LA C R R E T a LA CARRBTA ))RESTAURANT BAR, INC. )

37 ,052.43 in U.S. Currency )Located at Old National Bank )Acct. No. 4502194424 )

ARNULFO GONZALEZ, )As His Interest May Appear, )

JAMIE GONZALEZ, )As His Interest May Appear, )RAFAEL GONZALEZ, )As His Interest May Appear, )

)JOSE V. BUSTOS or KARENA BUSTOS )$681.53 in U.S. Currency )

Located at Old National Bank )Acct. No . 122583035, ))

RAFAEL GONZALEZ or CECILIA )GONZALEZ )$318,314.04 in U.S. Currency )Located at Old National Bank )Acct. No. 2150010702, ))LA CARRETA 1 aka LA CARRETA )RESTAURANT BAR, INC. )$14,276.96 in U.S. Currency )

Located at Old National Bank )Acct. No . 4511555744 )ARNULFO GONZALEZ, )


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As His Interest May Appear, )RAFAEL GONZALEZ, )s His Interest May Appear, )

JOSE MELENDEZ, )$128,633.60 in U.S. Currency )Located at Old National Bank )Acct. No. 122224460, )

EL RODEO aka EL RODEO 22, LLC, )$57,705.70 in U.S. Currency )Located at Old National Bank )Acct. No. 4505877158 )FRANCISCO SALGADO, )As His Interest May Appear, )JOSE MELENDEZ, )As His Interest May Appear, )RAFAEL GONZALEZ, )As His Interest May Appear, )

EL RODEO 7 aka EL RODEO 7 LLC, )$77,339.78 in U.S. Currency )Located at Old National Bank )Acct. No. 4511555949 )JOSE MELENDEZ, )As His Interest May Appear, )FRANCISCO SALGADO, )As His Interest May Appear, )R F ELGONZ LEZ, )As His Interest May Appear, )JOSE MELENDEZ )$834.06 in U.S. Currency )Located at Old National Bank )Acct. No. 4505877131 , )EL RODEO 3 aka EL RODEO 3 LLC, )$15,663.56 in U.S. Currency )Located at Old National Bank )Acct. No. 116701694, )JOSE MELENDEZ, )As His Interest May Appear, )FRANCISCO SALGADO, )As His Interest May Appear, )ABEL BUSTOS, )As His Interest May Appear, )JOSE V. BUSTOS, )As His Interest May Appear, )$63.83 IN U.S. CURRENCY and L )CARRETA MEXICAN RESTAURNANT & )


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$525.00 in U.S. CURRENCY and ABEL )BUSTOS and ROSALINDA A VILACORONEL,Located at 425 S. Brookfield Dr.,

Lafayette, IN,$2,650.00 in U.S. CURRENCY andJOSE ANGEL BUSTOS,

Located at El Rodeo MexicanRestaurant, 140 Frontage Rd., Ste. 5,Lafayette, IN,EL RODEO :MEXICAN RESTAURANT akaELRODE0 1As Its Interest May Appear,$1,423.30 in U.S. CURRENCY and ELRODEO 1 ffiXICAN RESTAURANT, INC.aka EL RODEO # 1,

Located at 140 Frontage Rd., Ste. 5, )Lafayette, Il J,JOSE :MELENDEZ, )- As His Interest May Appear,

FRANCISCO SALGADO,As His Interest May Appear,- ABEL BUSTOS,As His Interest May Appear, )

$30,310 .25 in U.S . CURRENCY and ELRODEO :MEXICAN RESTAURANT #2,Located at 3611 E. Main St.,

Richmond, INJOSE :MELENDEZ,As His Interest May Appear,

FRANCISCO SALGADO,As His Interest May Appear,R.P. MONTERDYAs His Interest May Appear,

$1,601.04 in U.S. CURRENCY and EL )RODEO #7, LLC,Located at 4000 W. 106t St., Ste. 185,

Carmel, INJOSE MELENDEZ,As His Interest May Appear,FRANCISCO SALGADO, )As His Interest May Appear, )$1,440.00 in U.S. CURRENCY and SERGIOCERVANTES ,Located at El Rodeo #9, LLC, 45 7Town Center Dr. N. , Mooresville, IN )


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EL RODEO 9 LLC,As Its Interest May Appear

1 ,145.82 in U.S . CURRENCY and ELRODEO 9, LLC,Located at 457 Town Center Dr. N.,

Mooresville, INJOSE MELENDEZAs His h1terest May Appear,

FRANCISCO SALGADO,As His Interest May Appear,ENRIQUE A MELENDEZ,As His h1terest May Appear,1 ,970.00 in U.S . CURRENCY and JOSE

BERNALLocated at El Jaripeo MexicanRestaurant 2, 2330 N. Lebanon St.,Lebanon, INEL JARlPEO MEXICAN RESTAURANT, 2,INC.,As Its Interest May Appear,

$2,133.15 in U.S. CURRENCY and ELJARIPEO :MEXICAN RESTAURANT 2,INC., aka EL JARIPEO 2Located at 2330 N. Lebanon St.,Lebanon, IN

JOSE MELENDEZAs His futerest May Appea[s . ._

FRANCISCO SALGADO,As His Interest May Appear,JESUS ME LENDEZ,As His Interest May Appear,FELIPE BERNALAs His Interest May Appear, )1 ,163.20 in U.S. CURRENCY and ELJARIPEO 3, LLC

Located at 2605 Main St., Plainfield,INJOSE MELENDEZAs His Interest May Appear,


ENRIQUE :MELENDEZ,As His Interest May Appear,

1 ,460.00 in U.S . CURRENCY and W NVILLALVA CHAVEZ, )Located at El Jaripeo 4, LLC, 3020


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State Road 32 E., Westfield, IN )EL JARIPEO 4, LLC, )As Its Interest May Appear, )$1080.79 in U.S. CURRENCY and EL )JARIPEO 4 LLC, )

Located at 3020 State Road 32 E., )Westfield, IN )JOSE MELENDEZ, )As His Interest May Appear, )FRANCISCO SALGADO, )As His Interest May Appear, )JUAN M. VILLALVA, )As His Interest May Appear, )$1688.20 in U.S . CURRENCY and EL )RODE0 17,LLC, )Located at 11452 Olio Rd., Fishers, )

IN )JOSE MELENDEZ, )As His Interest May Appear, )FRANCISCO SALGADO, )As His Interest May Appear, )$18,183.20 in U.S. CURRENCY and EL )RODEO 18, LLC, )Located at 8128 E. U.S. Hwy. 36, )Avon, IN )JOSE MELENDEZ, )As His Interest May Appear, )FRANCISCO SALGADO, )As His Interest May Appear, )$3,394.00 in U.S. CURRENCY and LUIS )BUSTOS, )Located at El Rodeo 9 LLC, 109 )Beck Lane, Ste. 120, Lafayette, IN )EL RODEO 9 , LLC, )As Its Interest May Appear, )$1185.77 in U.S. CURRENCY and EL )RODEO 19, LLC, )Located at 109 Beck Lane, Ste. 120, )Lafayette, IN )JOSE MELENDEZ, )As His Interest May Appear, )FRANCISCO SALGADO, )As His Interest May Appear, )ABEL BUSTOS, )As His Interest May Appear, )


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$2008.44 in U.S. CURRENCY and EL )RODEO 21, LLC, )Located at 3113 W. Smith Valley Rd., )Ste. A., Greenwood, IN )JOSE E L E N D E ~ )

As His Interest May Appear, )FRANCISCO SALGADO, )As His Interest May Appear,SOJ\lJA CERVANTES,

As Her Interest May Appear,$2,145.36 in U.S. CURRENCY and ELRODEO 16, LLC,

Located at 14160 Mundy Dr., Ste. 900,Noblesville, INJOSE MELENDEZ,

As His Interest May Appear,FRANCISCO SALGADO,

As His Interest May Appear,$1,267.00 in U.S. CURRENCY and JOSEVICTOR BUSTOS,

Located at 140 Howard Ave., WestLafayette, INEL RODEO 13, LLC,

As Its Interest May Appear,$401.53 in U.S . CURRENCY and ELRODEO 13, LLC,Located at 140 Howard Ave., West

Lafayette, INJOSE MELENDEZ,As His Interest May Appear,


ABEL BUSTOS,As His Interest May Appear,

$2044.04 in U.S. CURRENCY andELRODEO 10, LLC,Located at 2404 National Rd. W.,Richmond, INJOSE MELENDEZ,As His Interest May Appear,FRANCISCO SALGADO,

As His Interest May Appear,JESUS MELENDEZ,As His Interest May Appear,

$650 .00 in U.S. CURRENCY and EUGENIASANTANA,

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Located at Indy Mex Properties, LLC, )805 S. Girls School Rd., Indianapolis, )IN . )INDY MEX PROPERTIES, LLC, )As Its Interest May Appear, )JOSE MELENDEZ, )

As His Interest May Appear, )FRANCISCO SALGADO, )As His Interest May Appear,

ALFREDO JvfELENDEZ,As His Interest May Appear,

71.00 in U.S. CURRENCY and INDY MEXPROPERTIES, LLC, and EL RODEO & ELJARIPEO OFFICE,

Located at 805 S. Girls School Rd. ,Indianapolis, INJOSE MELENDEZ,

As His Interest May Appear,FRANCISCO SALGADO,As His Interest May Appear,

ALFREDO MELENDEZ,As His Interest May Appear,

2642.89 in U.S. CURRENCY and LACARRETA MEXICAN RESTAURANT &BAR, 3 INC.,

Located at 717 U.S. Hwy. 41,Schererville, IN 46375ARNULFO GONZALEZ,

As His Interest May Appear,2437.00 in U.S. CURRENCY and LA

CARRETA MEXICAN RESTAURANT &BA R, 2 INC.,

Located at 630 Kimmel Rd.,Vincennes, N

ARNULFO GONZALEZ,As His Interest May Appear,$1,204.13 in U.S. CURRENCY and LACARRETA MEXICAN RESTAURANT &BAR, INC.

Located at 269 U.S. 30 , Merrillville,IN

ARNULFO GONZALEZ,As His Interest May Appear,

$337.05 in U.S . CURRENCY and ELJARIPEO 6 LLC,

Located at 38 W. Main St., New

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Palestine, IN )ANTONIO SALGADO PASTRANA, )As His Interest May Appear, )$1192.40 in U.S . CURRENCY and EL )JARIPEO 5 LLC, )

Located at 2000 E. Wabash St., )Frankfort, IN )JOSE MELENDEZ, )As His Interest May Appear, )FRANCISCO SALGADO, )As His Interest May Appear, )FELIPE BERNAL, )As His Interest May Appear, )$1079.89 in U.S. CURRENCY and EL )RODEO 22 LLC, )Located at 6673 State Road 334, )

Zionsville, IN )JOSE MELENDEZ, )As His Interest ay Appear, )FRANCISCO SALGADO, )As His Interest May Appear, )

COMPL INT FOR FORFEITURE AA 'D TO ENJOIN R CKETEERING CTIVITY

Come now the Plaintiffs, by counsel, and complain of each of the above-named Defendants andclaim for relief, allege and say:COUNT I

1 On or about November 18, 2013, officers of the Plaintiffs seized from the Defendants, the abovecaptioned sums of money from each of the above-captioned Defendants as a result of searchwarrants served.2 Said property, currency, and/or money had been furnished or was intended to be furnished by anyperson in exchange for an act that is in violation of an Indiana criminal statute; was used tofacilitate any violation of an Indiana criminal statute; or is traceable as proceeds of a violation ofan Indiana criminal statute; or said property, currency, and/or money is the object of a corruptbusiness influence violation; as provided in I.C. 34-24-1-1 or as otherwise provided as subject to

forfeiture in I.C. 34-24-1-1.COUNT IT

3. Plaintiffs incorporate all above allegations in Paragraphs l and 2.4 The above-captioned Defendants, have participated in , constructed, and continued to operate oneor more corrupt business enterprise, through a pattern of racketeering activity, as defined in I.C.

35 -45-6-2. This conduct has continued as a pattern of racketeering activity, and not as isolated


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instances, all in violation of the criminal statutes of the State of Indiana. The crimes which haveformed the business of the enterprise includes the commission, the attempted commission, theconspiracy to com.. llit, or aiding and abetting the commission of, but not limited to, the followingoffenses as listed in I.C. 35-45-6-1 e):1) Money launde1ing as defined in IC 35-45-15-5;2) Theft as defined in I.C. 35-43-4-2; 3) Forgery as defined in I.C. 35-43-5-2; or4) Perjury as defmed in I.C. 35-44.1-2-1.

5. Offenses involving Money Laundering took the form of receiving, concealing, possessing,transferring, or transporting the proceeds of criminal activity, and/or conducting, supervising, orfacilitating transactions involving the proceeds of criminal activity and consists at least two suchincidents of such criminal conduct over time including, but not limited to, all relevant time framesas outlined in I.C. 35-45-6-1 d).

6. Offenses involving Theft took the form of exerting unauthorized control over the property of theState of Indiana by illicitly retaining and failing to report money owed to the State of Indiana assales taxes, use taxes, or other taxes on several occasions over time including, but not limited to,all relevanttime frames as outlined in LC. 35-45-6-1 d).

7. Offenses involving Forgery and Perjury took the form of the making, uttering and signing ofvarious tax documents, business fonnation documents, employment records, tax returns, andother documents while knowing that the information was false and/or misleading on severaloccasions over time including, but not limited to, all relevant time frames as outlined in I C. 35-45-6-l d).8. Further, other offenses listed in I.C. 35-45-6-l e), may also form the business of the enterprise;the conduct of which is part of the pattem of racketeering activity.

9. Pursuant to LC. 34-24-2-2, the above captioned property was used in the course of, intended foruse in the course of, derived from, or realized through conduct in violation ofl C 35-45-6-2.WHEREFORE, the Plaintiffs demand judgment against each Defendant listed above for the forfeiture

of the above-captioned sums of currency, money, and/or property seized, against each of the abovecaptioned Defendants; and for delivery of said currency, money, and/or property to the State uponforfeiture as provided in I. C. 34-24-1-1 and I. C. 34-24-2-2, and for all other just and proper relief in thepremises including the following relief pursuant to I.C. 34-24-2-1:A. For a judgment against the Defendants granting permanent injunction against the furtheroperation of racketeering activity within the enterprise identified herein;B. For a judgment of forfeiture of the property of the Defendant which the court shall determineto be appropriate under the statutes cited herein; including specifically all property seized atthe locations described; which, thus, includes forfeiture by the Defendants of the property

listed in the caption of this cause;C. Order the Defendants to divest themselves of any interest in the above mentioned Restaurantsand/or Businesses and to deliver the funds of the divestments to the Plaintiffs;D. For an order prohibiting the De fendants from engaging in the same type of endeavor in whichthe defendants were engaged in violation of Indiana law;E. For an order disso lving and preventing the reorganization of said businesses, and to deliverthose divestments to the Plaintiffs;


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F For an order forfeiting the chmters o said Re staurants and/or Businesses, which allows saidRestaurants and/or Businesses to operate and to act as a corporation organized under the lawso the State o Indiana and including the revocation o a certificate authorizing a o r ~corporation to conduct business within the state pursuant to I.C. 34-24-2-1 5);

G For the revocation o any professional license possessed by the Defendants and granted bythe State o Indiana;H. For disgorgement o all proceeds o illegal activity that this Court may determine that theDefendants possess and/or have possessed;I For the cost o this action, for the costs o the enforcement o the underlying case which theDefendants are prosecuted criminally, and for the reasonable attorney fees incurred by thePlaintiff in prosecuting o this and the criminal action, and for all oth lief just and properin the premises.

CERTIFIC TE OF SERVICEI hereby certifY that on the 1. 1._-fl..ctay o FE&It1 j, 2014, I mailed a copy o this Complaint and acopy o the Complaint to each defendant by first class mail, certified, at the address below.


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Documents

El Rodeo Lawsuit (Redacted)