United States of America v. Contents of Bank America, Account No. X4630, In The Name of Jianguo Zheng et al

UNITED STATES DISTRICTCOURT
SOUTHERNDISTRICTOF OHIO
WESTERN DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
V.
CONTENTS OF BANK OF AMERICA,
ACCOUNT NO. X4630 IN THE NAME
OF JIANGUO ZHENG, et al.,
Defendants.
CaseNo. 3:25-cv-00104
District JudgeWalter H. Rice
Magistrate Judge Caroline H. Gentry
DEFAULTJUDGMENTAND DECREEOF FORFEITURE
This matter comes before the Court on the motion of the United States for a default
judgment and decree of forfeiture (Doc. 78). The instant motion seeks a default judgment against
certain defendants, potential claimants, and all other persons and entities who might have an
interest in the defendants. This Orderpertains to the following property (the "subject defendants"):
Defendant 3, Contents of Bank of America, Account No. X7917, in the Name of
X&Y Inc.;
Defendant 5, Contents of Bank of America, Account No. X1557, in the Name of
J&W Service 168 Inc.;
Defendant 7, Contents of Bank of America, Account No. Xl 378, in the Name of
Kaiyuan Service LLC;
Defendant 22, One 2019 Chevrolet Express G3500, VIN:
1GAZGPFGXK1281875, with All Attachments;
Defendant 23, One 2019 Chevrolet Express G3500, VIN: 1GAZGPFG7K1362316,
with All Attachments;
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Defendant 24, One 2017 Chevrolet Express G3500, VIN: 1GAZGPFG5H1172278,
with All Attachments;
Defendant 25, One 2018 Chevrolet Express G3500, VIN: 1GAZGPFG2J1333983,
with All Attachments;
Defendant 26, One 2018 Chevrolet Express G3500, VD4: 1GAZGPFG3J1313192,
with All Attachments;
Defendant 27, One 2024 Mercedes-Benz Sprinter, VIN: W1Z4KFHY4RT173063,
with All Attachments;
Defendant 28, One 2019 Mercedes-Benz Sprinter, VIN: W1Z70FGY8KT016890,
with All Attachments;
Defendant 30, One 2018 Ford Transit, VIN: 1FBZX2YM7JKB39462, with All
Attachments;
Defendant 31, One 2023 Mercedes GLE350, VIN: 4JGFB4KBXPA915691, with
All Attachments;
Defendant 33, One 2020 Ford F-150 FX4 Crew Cab, VIN-
1FTEW1EP1LFB78257, with All Attachments;
Defendant 34, One 2020 Ford F-250, VIN: 1FT7X2BN6LEE36163, with All
Attachments; and
Defendant 35, One 2021 Toyota Tacoma, VIN: 3TMGZ5ANXMM427295, with
All Attachments.
The United States filed a Verified Complaint for Forfeiture In Rem on April 2, 2025,
againstforty (40) defendant assets, including the contents ofbankaccounts (Defendants 1 through
7), real property (Defendants 8 through 21), vehicles (Defendants 22 through 36), and luxury
items and one firearm (Defendants 37 through 40). (Doc. No. 1. ) Tyler J. Simpson, who is a
Special Agent with the U. S. Immigration and Customs Enforcement, Homeland Security
Investigations, verified the complaint. (Id)
The complaint alleges that the defendants are subject to forfeiture under the following
bases: as vehicles that have been used in the commission of a violation of 8 U. S. C. § 1324(a) for
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the purpose of commercial advantage and private financial gain, the gross proceeds of such
violation, and any property traceable to such vehicles or proceeds, pursuant to 8 U. S. C.
§ 1324(b)(l); as property involved in a transaction or attempted transaction in violation of 18
U. S. C. § 1956(a)(l)(A)(i), 18 U. S. C. § 1956(a)(l)(B)(i), 18 U. S. C. § 1956(h), and/or 18 U. S. C.
§ 1957, or property traceable to such property, pursuant to 18 U. S. C. § 981(a)(l)(A); as property
which constitutes or is derived from proceeds traceable to an offense constituting specified
unlawful activity, namely, harboring, concealing, and/or transporting illegal aliens in violation of
8 U. S. C. § 1324(a) or a conspiracy to commit such offense, pursuant to 18 U. S. C. § 981(a)(l)(C);
and the United States intends to rely on the provisions of 18 U. S. C. § 984 to establish that the
defendant bank accounts are subject to forfeiture. (Id)
A Warrant of Arrest In Rem, issued by the Court on April 11, 2025, directed the U. S.
Immigration andCustoms Enforcement, Homeland Security Investigations ("HSI");U. S. Customs
and Border Protection ("CBP"); any duly authorized law enforcement officer; and/or their
delegates for the Southern District of Ohio to arrest Defendants 1 through 7 and 22 through 40.
(Doc. No. 5. ) In accordance with the warrant, HSI and CBP arrested these defendants, bringing
them within the jurisdiction of the Court. (Doc. No. 69.)
Pursuant to Rule G(4)(b)(i) ofthe Supplemental Rules for Admiralty or Maritime Claims
andAsset Forfeiture Actions ("Supplemental Rules"), "[t]he government must send notice ofthe
action with a copy of the complaint to any person who reasonably appears to be a potential
claimant on the facts known to the government before the end ofthe time for filing a claim under
Rule G(5)(a)(ii)(B). " The direct notice instructs thepotential claimant or thepotential claimant's
attorney ofthe following: 1) the date when the notice was sent, 2) the deadline for filing a claim
which is at least 35 days after the notice was sent, 3) that an answer or a motion under Rule 12
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must be filed no later than 21 days after filing the claim, and 4) the name of the government
attorney to be served with the claim and answer. Supplemental Rule G(4)(b)(ii). "The notice
must be sentby means reasonably calculated to reach the potential claimant. " Supplemental Rule
G(4)(b)(iii)(A).
In this case, the United States, on May 9, 2025, sent direct notice of this action with a
copy of the complaint to all known potential claimants described below, advising them that the
deadline for filing a claim was June 13, 2025.
As to Defendant 3, the United States sent notice and a copy of the complaint to potential
claimants Zhongxu Sun for X&Y Inc. ; Zhongxu Sun c/o Zhou Wang, Esq. ; and Ying Xiong for
X&Y Inc. (Doc. No. 66 at PageID 1945-49, 1921-23.)
As to Defendant 5, the United States sent notice and a copy of the complaint to potential
claimants J&W Service 168 Inc. ; Jianwen Wei; and Jianwen Wei c/o Stacey Van Maiden, Esq.
{Id. atPageID 1882-87, 1939-41.)
As to Defendant 7, the United States sent notice and a copy of the complaint to potential
claimants Wei Lui, Individually and Tmstee for Kaiyuan Tmst c/o Paul V. Wolf, Esq. ; and Guo
Qiang Lin and Yi Mei Lin c/o Michael P. Harvey, Esq. (Id. at PageID 1909-14.)
As to Defendants 22, 24, and25, the United States sentnotice and a copy ofthe complaint
to potential claimants Zhongxu Sun c/o Zhou Wang, Esq. ; Zeyu Zhao; andZeyu Zhao c/o Marion
A. Primes, Esq. (Id. at PageID 1948-49, 1900-02, 1906-08.)
As to Defendant 23, the United States sent notice and a copy ofthe complaint to potential
claimants Zhi Lin c/o Joseph A. Dubyak, Esq. ; Yun Chen; and Yun Chen c/o Zhou Wang, Esq.
(Id. atPageID 1888-90, 1942-44, 1948-49.)
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As to Defendant 26, the United States sent notice and a copy ofthe complaint to potential
claimant Jianguo Zheng. (Id. at PageID 1894-99.)
As to Defendants 27, 28, and 31, the United States sent notice and a copy of the complaint
to potential claimant JianwenWei. (Id. at PageID 1885-87, 1939-41.)
As to Defendant 30, the United States sent notice and a copy of the complaint to potential
claimant Hengyang Zhu. {Id. at PageID 1879-81.)
As to Defendant 33, the United States sent notice and a copy of the complaint to potential
claimants Fei Un and First Commonwealth Bank. (Id. at PageID 1864-66, 1873-75.)
As to Defendant 34, the United States sent notice and a copy ofthe complaint to potential
claimant Zeyu Zhao. (Id. atPageID 1900-02, 1906-08.)
As to Defendant 35, the United States sent notice and a copy ofthe complaint to potential
claimants Jiahui Yu c/o Connor P. Reilly, Esq. and Fifth Third Bank. (Id. at PageID 1867-69,
1870-72.)
Pursuant to Rule G(4)(a)(iv)(C) of the Supplemental Rules, the United States is required
to publish notice in a manner reasonably calculated to notify potential claimants of the civil
forfeiture action on anofficial internet government forfeiture site for at least 30 consecutive days.
The United States posted notice of this civil forfeiture action on the official internet
government forfeiture site, (www. forfeiture. gov), beginning onMay 15, 2025, for 30consecutive
days. (Doc. No. 64.)
On September 30, 2025, the Clerk of this Court entered a default against the subject
defendants, as authorized by Rule 55(a) ofthe Federal Rules of Civil Procedure. (Doc. No. 71.)
No person or entity has filed a claim to the subject defendants or an answer to the
complaint, and the time to do so has expired.
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Therefore, it is hereby ORDERED that, in accordance with Rule 55(b)(2) of the Federal
Rules ofCivil Procedure, a default judgment is granted to the United States against the following:1
1. Defendant 3, Contents of Bank of America, Account No. X7917, in the Name of
X&Y Inc.;
2. Defendant 5, Contents of Bank of America, Account No. Xl 557, in the Name of
J&W Service 168 Inc.;
3. Defendant 7, Contents of Bank of America, Account No. X1378, in the Name of
Kaiyuan Service LLC;
4 Defendant 22, One 2019 Chevrolet Express G3500, VIN
1GAZGPFGXK1281875, with All Attachments;
5 Defendant 23, One 2019 Chevrolet Express G3500, VIN: 1GAZGPFG7K1362316,
with All Attachments;
6. Defendant 24, One 2017 Chevrolet Express G3500, VIN: 1GAZGPFG5H1172278,
with All Attachments;
7 Defendant 25, One 2018 Chevrolet Express G3500, VIN: 1GAZGPFG2J1333983,
with All Attachments;
8. Defendant 26, One 2018 Chevrolet Express G3500, VIN: 1GAZGPFG3J1313192,
with All Attachments;
9. Defendant 27, One 2024 Mercedes-Benz Sprinter, VIN: W1Z4KFHY4RT173063,
with All Attachments;
' Wei Lui, Individually and Tmstee for Kaiyuan Trust; Guo Qiang Lin; Yi Mei Lin; Zhi Lin; Zeyu
Zhao; and Jianguo Zheng have filed timely claims and answers to other assets in this case. (Doc.
Nos. 9, 10, 13, 15, 16, 20, 21, 26-28, 42, 43, 45, 46, 47, 49-57, 59-61. ) Therefore, a default
judgment is granted against these parties only as to any right, title, and interest that they may have
in the subject defendants.
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10. Defendant 28, One 2019 Mercedes-Benz Sprinter, VIN: W1Z70FGY8KTO 16890,
with All Attachments;
11 Defendant 30, One 2018 Ford Transit, VIN: 1FBZX2YM7JKB39462, with All
Attachments;
12. Defendant 31, One 2023 Mercedes GLE350, VIN: 4JGFB4KBXPA915691, with
All Attachments;
13 Defendant 33, One 2020 Ford F-150 FX4 Crew Cab, VIN
1FTEW1EP1LFB78257,with All Attachments;
14 Defendant 34, One 2020 Ford F-250, VIN: 1FT7X2BN6LEE36163, with All
Attachments;
15 Defendant 35, One 2021 Toyota Tacoma, VW: 3TMGZ5ANXMM427295, with
All Attachments;
16. X&Y Inc.;
17. J&W Service 168 Inc.;
18. JianwenWei;
19. Wei Lui, Individually and Trustee for Kaiyuan Tmst;
20. Quo Qiang Lin;
21. YiMeiLin;
22. Zhongxu Sun;
23. ZeyuZhao;
24. Zhi Lin;
25. Yun Chen;
26. Jianguo Zheng;
7
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27. Jianwen Wei;
28. Hengyang Zhu;
29. Fei Lin;
30. First Commonwealth Bank;
31. JiahuiYu;
32. Fifth Third Bank; and
33. All other persons and entities who might have an interest in the subject defendants,
for failure to file a claim and answer pursuant to 18 U. S. C. § 983(a)(4)(A) and (B) and Rule G of
the Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions.
It is further ORDERED,ADJUDGED,and DECREEDthat:
1. All right, title, and interest in the subject defendants is CONDEMNED and
FORFEITED to the United States, pursuant to 8 U. S. C. § 1324(b)(l), as vehicles that have been
used in the commission of a violation of 8 U. S. C. § 1324(a) for the purpose of commercial
advantage andprivate financial gain, the gross proceeds ofsuchviolation, or property traceable to
such vehicles or proceeds; pursuant to 18 U. S. C. § 981(a)(l)(A), as property involved in a
transaction or attempted transaction in violation of 18 U. S. C. § 1956(a)(l)(A)(i), 18 U. S. C.
§ 1956(a)(l)(B)(i), 18 U. S. C. § 1956(h), and/or 18 U. S. C. § 1957, or property traceable to such
property; and/orpursuant to 18 U. S. C. § 981(a)(l)(C), as property which constitutes or is derived
from proceeds traceable to an offense constituting specified unlawful activity, namely, harboring,
concealing, and/or transporting illegal aliens in violation ofSU. S. C. § 1324(a) or a conspiracy to
commit such offense;
2. All right, title, and interest in the subject defendants is vested in the United States,
and no right, title, or interest shall exist in any other person or entity;
8
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3. The U. S. Immigration and Customs Enforcement, Homeland Security
Investigations; U. S. Customs and Border Protection; or an authorized agent thereof shall dispose
of the subject defendants in accordance with the law; and
4. The Court shall retain jurisdiction to enforce the terms of this Order.
IT IS SO ORDERED.
Dated: ^^-^ 	C^L. ^ I, -(^ \^t>/
WALTERH. RICE
UNITED STATES DISTRICT JUDGE
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