On August 18, 2011 a
Complaint,Petition
was filed
for OTHER CIVIL
in the District Court of Franklin County.
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E1249-"- 078 e e
IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO
CIVIL DIVISION
STATE OF OHIO CASENO. FICVH BY 0297
v. JUDGE
Ana Raquel Torres Mondragon
694 Maurine Drive
Columbus, Ohio 43228
IN RE: FORFEITURE OF: $2,042.00 in U. S. Currency; and 39 plastic wrapped and
balloons of Heroin,
a
me a
AND 22 2
o &
UNKNOWN CLAIMANTS OF AN INTEREST 7 o
IN ABOVE PROPERTY, ADDRESS UNKNOWN, S =
PETITION FOR FORFEITURE a 2 26
tom 35S
The State of Ohio brings this action for forfeiture and alleges: 2° =
1. This is a civil action for forfeiture for property subject to forfeiture that constitutes
contraband, is proceeds derived from or acquired through the commission of an offense, or is an
instrumentality that was used in or intended to be used in the commission or [acilitation of an
offense that is sufficient to. warrant forfeiture under Chapter 2981 of the Ohio Revised Code.
2. This Court has jurisdiction under Section 2981.02 and/or 2981.03 and/or 2981.05 of
the Ohio Revised Code.
3. Ron O’Brien, as Prosecuting Attomey of Franklin County. Ohio, is authorized to bring
this action by Section 2981.02 and/or 2981.03 and/or 2981.05 of the Ohio Revised Code.
4. ‘The property sought to be forfeited subject to any existing liens duly established in
this case is described as follows: $2,042.00 in U. S. Currency: and 39 plastic wrapped and
balloons of ITeroin. The property is owncd, possessed. concealed, transported. received,
purchased, sold, leased, rented. or otherwise translerred by Ana Raquel Torres Mondragon.£1249. - O79 e e
5. The property described above was scized by the Franklin County Sheriff's Office on
July 28, 2011, pursuant to the authority of Section 2981.03 of the Ohio Revised Code.
6. The property described above is property that is subject to forfeiture pursuant to
Section 2981.02(A)(1). (2), or (3) of the Ohio Revised Code as the property is contraband
involved in an offense, or proceeds derived from or acquired through the commission of an
offense, or is an instrumentality that was used in or was intended to be used in the commission or
facilitation of an offense when the use or intended usc is sufficient to warrant forfeiture under
Chapter 2981 of the Ohio Revised Code. ,
WHEREFORE, the petitioner requests that the Court order a forfeiture of the property to
the Franklin County Sheriff's Office and the Office of the Franklin County Prosecuting Attorney.
Respectfully submitted,
RON O'BRIEN
PROSECUTING ATTORNEY
FRANKLIN COUNTY, OHIO
ssistant Prosecuting Atlorney
3 Soul vigh Street, 13" Floo
Fax: (614) 525- 6012
E-mail: jerogers@franklincountyohio.gov
Attomey for Petitioner
Document Filed Date
August 18, 2011
Case Filing Date
August 18, 2011
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E1249-"- 078 e e IN THE COURT OF COMMON PLEAS, FRANKLIN COUNTY, OHIO CIVIL DIVISION STATE OF OHIO CASENO. FICVH BY 0297 v. JUDGE Ana Raquel Torres Mondragon 694 Maurine Drive Columbus, Ohio 43228 IN RE: FORFEITURE OF: $2,042.00 in U. S. Currency; and 39 plastic wrapped and balloons of Heroin, a me a AND 22 2 o & UNKNOWN CLAIMANTS OF AN INTEREST 7 o IN ABOVE PROPERTY, ADDRESS UNKNOWN, S = PETITION FOR FORFEITURE a 2 26 tom 35S The State of Ohio brings this action for forfeiture and alleges: 2° = 1. This is a civil action for forfeiture for property subject to forfeiture that constitutes contraband, is proceeds derived from or acquired through the commission of an offense, or is an instrumentality that was used in or intended to be used in the commission or [acilitation of an offense that is sufficient to. warrant forfeiture under Chapter 2981 of the Ohio Revised Code. 2. This Court has jurisdiction under Section 2981.02 and/or 2981.03 and/or 2981.05 of the Ohio Revised Code. 3. Ron O’Brien, as Prosecuting Attomey of Franklin County. Ohio, is authorized to bring this action by Section 2981.02 and/or 2981.03 and/or 2981.05 of the Ohio Revised Code. 4. ‘The property sought to be forfeited subject to any existing liens duly established in this case is described as follows: $2,042.00 in U. S. Currency: and 39 plastic wrapped and balloons of ITeroin. The property is owncd, possessed. concealed, transported. received, purchased, sold, leased, rented. or otherwise translerred by Ana Raquel Torres Mondragon.£1249. - O79 e e 5. The property described above was scized by the Franklin County Sheriff's Office on July 28, 2011, pursuant to the authority of Section 2981.03 of the Ohio Revised Code. 6. The property described above is property that is subject to forfeiture pursuant to Section 2981.02(A)(1). (2), or (3) of the Ohio Revised Code as the property is contraband involved in an offense, or proceeds derived from or acquired through the commission of an offense, or is an instrumentality that was used in or was intended to be used in the commission or facilitation of an offense when the use or intended usc is sufficient to warrant forfeiture under Chapter 2981 of the Ohio Revised Code. , WHEREFORE, the petitioner requests that the Court order a forfeiture of the property to the Franklin County Sheriff's Office and the Office of the Franklin County Prosecuting Attorney. Respectfully submitted, RON O'BRIEN PROSECUTING ATTORNEY FRANKLIN COUNTY, OHIO ssistant Prosecuting Atlorney 3 Soul vigh Street, 13" Floo Fax: (614) 525- 6012 E-mail: jerogers@franklincountyohio.gov Attomey for Petitioner