El Rodeo Lawsuit (Redacted)

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

STATE OF INDIANA

)

SS:: IN THE TIPPECANOE SUPERIOR COURT I SS

TIPPECANOE COUNTY

STATE OF INDIANA, and the ) Tippecanoe County Prosecutor Prosecutor'' s Office, the ) Lafayette Police Department, the West Lafayette)

CAUSE NO . 79D01-1402-PL-  

Police Department, the Tippecanoe County Sheriff s Department Department, , the Purdue University

)) Police Department, and the the Indiana State Police ) Plaintiffs   Plaintiffs

vs. EL RODEO MEXICAN RESTAURANT

Inc.

2,

$95 , 854.31 in U.S. Currency, Located in First Bank Richmond Acct. No. No . 891083287

JOSE MELENDEZ , As His Interest May Appear, FRANCISCO SALGADO, As His Interest May Appear Appear,, JESUS MELENDEZ, As His Interest May Appear, R .P . MONTERDY, As His Interest May Appear, EL RODEO MEXICAN RESTAURANT aka

10, LLC 10, $42,968.39 in U.S. Currency, Located in First Bank Richmond Acct. No. 591001712

EL RODEO

JOSE MELENDEZ, As His Intere Interest st May

Appear,

FRANCISCO SALGADO, SALGADO , As Hi s Interest May Appear,

JESUS MELENDEZ, As His Intere Interesst May Appear, FRANCISCO JOSE PROPERTIES, LLC

$2,355.54 in U.S. Currency Currency,, Located n First Bank Richmond Acct. No. 0191013813-8 JOS E MELENDEZ, As His Interest May Appear Appear,, FRANCISCO SALGADO SALGADO,, As His Interest May Ap App p ear, JESUS MELENDEZ ,

) ) ) ) ) )

)

) )

LED

t\

 

As His Interest May Appear Appear,, JOSE MELENDEZ

$25,754.75 in U.S. Currency, Located in BMO Harris Bank Acct. No. 2590000905

)

EL JARIPEO

3, LLC $331.68 in U.S . Currency, Located in BMO Harris Bank Acct. No. 480575 4805751541 1541 JOSE MELENDEZ , As His Interest May Appear, FRANCISCO SALGADO, As His Interest May Appear, FRANCISCO V. MUNOZ, As His Interest May Appear Appear,, ENRJQUE MELENDEZ As His Interest May Appear,

)

) )

ALFRED O MELENDEZ

$23,, 30 9 .57 in U.S. Currency, $23 Currency , Located in Key Bank Acct. No . 141942000508,

LOS

)

TOROS MEXICAN RESTAURANT 2,

INC.

$1,601.88 in U.S. Currency, in Key Bank Acct. No. 149681010810 ENRJQUE MELENDEZ-AGUIRRE , As His Interest May Appear, ALFREDO MELENDEZ-AGUIRRE, A s His Interest May Appear, NOE 0 . FERNANDEZ As His Interest May Appear, JORGE M ELENDEZ-AGUIR ELENDEZ-AGUIRRE RE, As His Interest May Appear, Located

LOS TO R OS ME X ICAN RESTAURANT

INC.

$18,355 .92 in U.S. Currency, Located in Key Bank Acct. No. 14968100 149681007600 7600 ENRJQUE MELENDEZ -AGUIRRE, As His Interest May Ap p ea earr, ALFREDO MELENDEZ-AGUIRRE, As His Interest May Appear, NOE 0 FERNANDEZ His Intere Interesst May Appear, JO RGE As MELENDEZ-AGUIRRE ,

2,

 

As His

Interest May Appear,

) ) ) ) ) ) ) ) ) ) ) ) ) )

TOROS MEXICAN RESTAURANT $31,857.2 $31, 857.2 6 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, LOS

ENRIQUE MELENDEZ-AGUIRRE,

) ) ) )

THE

TOROS PROPERTY, LLC, $249,000 in U.S. Currency, Located in Key Bank Acct. No. 14968101782 149681017823 3 ENRIQUE MELENDEZ-AGUIRRE, As His Interest May Appear, ALFREDO MELENDEZ-AGUIRRE, As His Interest May Appear,

) ) ) ) ) ) ) )

& 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

)) ) ) ) ) ) ) ) ) ) ) )

$2,413.87 in U.S. Currency, Located in Key Bank Acct. No. 141942009236

JOSE

Appear,

EL JARIPEO

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

JOSE MELENDEZ

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

ENRIQUE MELENDEZ

As His Interest May Appear, FRANCISCO SALGADO

$7,868.2 0 in U.S. Currency,

) )

 

Located in Chase Bank Acct. No . 500077663329

)

EL JARIPEO

2 aka EL JARlPEO MEXICAN RESTAURANT 2, INC. $8,036.72 in U.S . Currency Located in PNC Bank Acct.. No 4618519363 Acct JOSE MELENDEZ , As His Interest May Appear 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,

& CONCEPCION SALGADO SALGADO,, $107 , 797.73 in U.S. Currency $107, Located in PNC Bank Acct. No. 4617720997 ADRIANA SALGADO , As Her Interest May Appear Appear,, GABRIELL E SALGADO, As Her Interest May Appear, FRANCISCO

& CONCEPCION SALGADO , $201 ,41 414 4 . 14 n U.S. Currency Located in PNC Bank Acct. No. 4618033232 ADRIANA SALGADO, As Her Interest May Appear,

)

)

) ) ) ) ) )

) )

FRANCISCO

)

JOSE BERNAL , $1,755 .99 n U.S. Currency Located in PNC Bank

Acct. No. 4618400047, 4618400047,

JOSE BERNAL,

$ 871.43 in U.S . C urrency Locate d in PNC Bank Acct. No. 4 6 75745 98 98,,

)

)

aka EL RODEO LLC E L RODEO $967,840.81 in U. U.S S . C urren urrency cy Located in PNC Bank Acct. No. 4804542997

)

JOSE MELENDEZ,

)

As His Interest Interest May Appear,

 

FRANCISCO SALGADO,

A s His Interest May Appear, EL RODEO 21 aka EL RODEO

21 LLC

$24,767.91 in U.S. Currency Located in PNC Bank Acct. No. 4804542911 JOSE MELENDEZ,

As His Interest May Appear, FRANCISCO SALGADO,

As His Interest May Appear, SONIA CERVANTES,

As Her Interest May Appear, SERGIO AGUIRRE CERVANTES,

A s His Interest May Appear,

) 25 aka EL RODEO 25 LLC $13,917.94 in U.S. Currency Located in PNC Bank Acct. No. 4804542938

EL RODEO

)

JOSE MELENDEZ,

As His Interest May Appear, FRANCISCO SALGADO, As His Interest May Appear, E L RODEO

20 aka EL RODEO

20 LLC

$43,440.53 in U.S. Currency Located in PN C Bank Acct. No. 4804542946 FRANCISCO SALGADO,

As His Interest May Appear, JOSE MELENDEZ,

As His Interest May Appear, E L RODEO

9 aka E L RODEO

) )

9 LLC

$105,212.43 in U.S. Currency Located in PNC Bank

)

Acct. No. 4804542954 JOSE MELENDEZ,

As His Interest May Appear, FRANCISCO SALGADO,

A s His Interest May Appear, ENRIQUE A. MELENDEZ,

As His Interest May Appear, SERGIO CERVANTES,

A s His Interest May Appear,

EL RODEO

24

~

R

O

E

O

24 LLC

$36,937.82 in U.S. Currency Located in PNC Bank Acct. No. 4804542962

)

 

JOSE MELENDEZ, As His Interest May Appear Appear,, FRANCI SCO SALGADO, As His Interest May Appea Appear, r,

) ) ) ) )

JOS E

FRANCISC O PROPERTIES, LLC FRANCISCO 17,642.66 17,642 .66 in U.S. Currency Located PNC Bank Acct. No. 4804543009 JOSE MELENDEZ, As His InterestMay Appear, FRANCI SCO SALGADO, As His Interest May Appear 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 FRANCISC O SALGADO,

) ) ) ) ) ) )

As His Interest May Appear, ALFREDO MELENEDEZ, As His Interest May Appea Appear, r,

)) ) )

JOSE M. PERE PEREZ Z aka JOSE MELENDEZ 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 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 JOSAF AT 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. 765257 7652578712 8712 JOSE JOS E M. PER PEREZ EZ aka JOS JOSE E l\rf l\rffiLE fiLENDE NDEZ, Z,

) ) ) ) )

As His Interest May Appear, FRANCIS CO SALGADO,

) )

 

As His

._ Appear,

) ) ) ) ) )

n t e r e s t ~

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 . 240586 2405860115 0115 ANTONIO S. PASTRANA aka ANTONIO SALGADO PASTRANA

$1,994.83 in U.S. Currency Located in Huntington Bank Acct. No. 4401822414 5 aka EL JARIPEO 5 LLC, $910..06 in U.S. Currency $910 Located in First Merchants Bank d/ b /a Lafayette Bank & Trust Acct. No. 520001385 FRANCISCO SALGADO, As His Interest May Appear, EL JARIPEO

) ) ) ) ) ) ) )

)) ) ) ) ) ) ) ) ) ) ) ) )

MELENDEZ

) ) ) ) ) ) ) ) ) ) ) ) ) )

As His Interest May Appear, FRANCISCO SALGADO SALGADO,,

) )

JOSE MELENDEZ A s 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

 

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. 18632 186329758 9758,,

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

EL RODEO

JOSE MELENDEZ,

As His Interest May Appear, FRANCISCO SALGADO, As His Interest May Appear, ABEL BUSTOS , As His Interest May Appear, LUIS ANTONIO BUSTOS, As His Interest May Appear,

R R E T   a LA CARRBTA RESTAURANT BAR, INC. 37 , 052.43 in U.S. Currency Located at Old National Bank LA C

Acct. No. 4502194424 ARNULFO GONZALEZ, As His Interest May Appear 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 U.S.. Curre ncy

Located at Old National National Ba nk Acct. No . 122583035 122583035,, RAFAEL GONZALEZ or CECILIA GONZALEZ $318,,31 4 . 04 in U.S. Currency $318

Located at Old National Bank Acct. No. 215001070 2150010702, 2, LA CARRETA 1 aka LA CARRETA RESTAURANT BAR, INC.

$ 14 14,27 ,276.96 6.96 in U.S. Currency Located at Old National Bank

Acct. No . 4511555744 ARNULFO GONZALEZ,

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

)

) )

) ) )

 

As His Interest May Appea Appear, r, RAFAEL GONZALEZ, s His Intere st May Appear,

) ) )

JOSE MELENDEZ MELENDEZ,, $128,,633.60 in U.S. Currency $128 Located Locat ed 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 App Appear, ear, JOSE MELENDEZ, As His Interest May Appea Appear, r, RAFAEL GONZALEZ GONZALEZ,, As His Interes Interestt May Appear,

) ) ) ) ) ) ) ) ) )

EL RODEO 7 aka EL RODEO 7 LLC ,

)

$77,,339.78 $77 in U.S. Currency Located at Old National Bank Acct. No. 4511555949 JOSE MELENDEZ MELENDEZ,, As His Interest May Appear, FRANCISCO SALGADO, As His Intere Interest st May Appear, R F ELGONZ LEZ , As His Interest May Appea Appear, r,

)) ) ) ) ) ) ) )

JOSE MELEND EZ $834.06 in U.S. Currency Located at Old Nation National al Bank Acct. No. 4505877131 ,

) ) ) )

EL RODEO 3 aka EL RODEO 3 LLC, $15,, 663.56 in U.S. Currency $15 Located at Old National Bank Acct. No. 116701694, JOSE MELENDEZ, As His Interest May Appear Appear,, FRANCISCO SALGADO, SALGADO , As His Interest May Appear, Appear, ABEL BUSTOS, As His Interest May Appear, JOSE JOS E V. BU STOS, As His Interes Interest May Appear,

) ) ) ) ) ) ) ) ) ) ) )

$63.83 IN U .S . CURRENCY and L CARRETA MEXICAN RESTAURNANT &

) )

 

BAR 2, INC. INC.,, Located at 630 Kimmel Rd ., Vincennes, IN 47591

ARNULFO GONZALEZ

As His Interest May Appear,

$31,560.41

n

U.S. CURRENCY and

ANTONIO S . PASTRANA and SORIANO ESMERALDO Located at 7790 Red Sunset Wa y ,

Avon, IN 46123 or on Antonio Salgado,

) )

$34,081.80 in U.S. CURRENCY and JESUS MELENDEZ Located at 315 NW

IN,

8th

) ) St., Richmo nd, ) )

$1273.25 in U.S. CURRENCY and LUIS ANTONIO BUSTOS and ROSA CASTRO , Located at 5629 Bingham Lane , Lafayette,, IN, Lafayette $2371.10 in U.S. CURRENCY and El\:'RJQUE MELENDEZ and MARTIN BANUELOS and TIODOLO BANUELOS , Located at 45 S . Warman Ave., Indianapolis,, IN, Indianapolis ) ) $189.18 in U.S . CURRENCY and JOSE BERNAL and FELIPE BERNAL LOPEZ, ) Located at 1011 Fair ane Dr., Lebanon, IN, $3,743.00 in U.S. CURRENCY and JOSE V. BUSTOS and ANTONIA BUSTOS Located 4357 English Lane, Lafayette Lafayette,,

IN ,

$29,563.70 in U.S. CURRENCY and LUCIANO SANTANA and EU GENIA

) ) ) ) )

SANTANA Located at

82

Rud Ru d gate Drive , Avon,

IN, $1463.00 in U .S . CURRENCY and ALFREDO ) ) MELENDEZ and RAFAEL GONZALEZ and CECILIA MELENDEZ ) Located at 6962 Antelope Drive ) Indianapolis, Indianapoli s, IN,

)

 

)

$525.00 in U.S. CURRENCY and ABEL BUSTOS and RO SALINDA A VILA CORONEL, Located at 425 S. Brookfield Dr., Dr. , Lafayette, IN IN,, $2,650.00 in U.S. CURRENCY and JOSE ANGEL BU STOS, Located at El Rodeo

Mexican Restaurant, 140 Frontage Rd. Rd.,, Ste. 5, 5, Lafayette,, IN , Lafayette EL RODEO :MEXICAN RESTAURANT aka ELRO D E0 1

A s Its Inter Inter est May Appear, $1,423.30 in U .S . CURRENCY and EL RODEO 1 ffiXICAN RESTAURANT, INC. aka E L RODEO # 1, Located at 140 Frontage Rd., Ste. 5, Lafayette, Il J , J OSE :MELENDEZ,

)

)

·- As His Interest May Appear, FRANCISCO SALGADO,

-

As His Interest May Appear,

ABEL BUSTOS ,

As His Interest May Appear Appear,,

)

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

Richmond, IN Richmond, JOSE :MELENDEZ, :MELENDEZ, As His Inte Interr est May Appear, FRANCISCO SALGADO, As His Interest May Appear, Appear , R.P. MONTERDY As His Intere Interesst May Appear Appear,, $1,601.04 in U.S. CURRENCY and EL ) R OD E O #7, LLC, Located at at 4000 W . 106t St., Ste. 185, Carmel,, IN Carmel JOS E MELENDEZ, As His Intere Interesst May Appear, ) FRANCISCO SALGADO SALGADO,, As Hi s Inte Interr est May Appear, ) $1,440.00 in U. U.S S . CURRENCY and SERGIO CERVANTES , Located at E l Rodeo # 9 , LLC, 45 7 Town Cente Centerr Dr. N. , Moore Mooressville ville,, IN

)

 

EL RODEO

9 LL C ,

As Its Interest May Appear

1 , 145 145..82 in U.S . CURRENCY and EL RODEO 9, LL C , Located at 457 Town Center Dr. N. N.,,

Mooresville, IN JOSE MELENDEZ As His h1terest May Appear, FRANCISCO SALGADO, SALGADO , As His Interest May Appear Appear,,

MELENDEZ, As His h1terest May Appear,

ENRIQUE

A

1 , 970.00 in U.S . CURRENCY and JOSE BERNAL

Located at El Jaripeo Mexican Restaurant 2, 2330 N. Lebano n St. St.,, Lebanon , IN EL JARlPEO MEXICAN RESTAURANT, 2, INC. , As Its Interest May Appear Appear,,

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

As His futerest May Appea[s . ._ FRANCISCO SALGADO, As His Intere st May Appear, JESUS ME LENDE Z, As His Interest May Appear, FELIPE BERNAL

As His Interest May Appear Appear,,

)

1 , 163.20 in U .S. CURRENCY and EL

JARIPE JARIP E O 3, LLC Located at

2605 Main St., Plainfield,

IN

JOS JO S E MELENDEZ As His Intere Interesst May Appear, FRANCISCO SALGADO, As His Intere Interesst May Appear, ENRIQUE :MELENDEZ, As His Interest May Ap p ear, 1 ,4 ,460.00 60.00 in U.S . CURRENCY and W VILLALVA CHAVEZ, Located at El Jaripeo

N

4, LLC, 3020

)

 

State Road 32 E ., Westfield, IN EL JARI JARIPEO PEO 4, LLC, As Its Interest May Appea Appearr ,

) ) )

$1080.7 9 in U.S. CURRENCY and EL $1080.79 JARIPEO 4 LLC, Located at 3020 State Road 32 E.,

) ) )

Westfield, IN JOSE JOS E MELENDEZ, As His Interest May Appear, FRANCISCO SALGA SALGADO, DO, As His Interest May Appear, JUAN M. VILLALVA, As His Interest May Appear,

)) ) ) ) ) )

$1688.20 in U.S . CURRENCY and EL Located at 11452 Olio Rd. Rd.,, Fishers, IN JOSE MELENDEZ, As His Interest May Appear,

) ) ) ) ) )

FRANCISCO As HisSALGADO, Interesst May Appear, Intere

))

$18,183.20 in U.S. CURRENCY and EL RODEO 18, LLC, Located at 8128 E. U.S. Hwy. 36, Avon,, IN Avon JOSE MELENDEZ, As His Interest May Appear, FRANCISCO SALGAD SALGADO, O, As His Interest May Appear,

) ) ) ) ) ) ) )

$3,394.00 in U.S. CURRENCY and LUIS BUSTOS, BUS TOS,

) )

Located at El Rodeo 9 LLC, 109 Beck Lane, Ste Ste.. 120, Lafayette, IN EL ROD RODE EO 9 , LLC LLC,, As Its Interest May Appear,

) ) ) )

$1185.77 in U.S. CURRENCY and EL RODEO 19 19,, LLC, Located at 109 Beck Lane, Ste. 120, 120 , Lafayette, IN JOSE JOS E MELENDEZ, As His Interest May Appear, FRANCISCO SALGADO, As His Interest May Appear, ABEL BUSTOS, BUSTOS ,

) ) ) ) ) ) ) ) )

As His Interest May Appear,

)

RODE0   17,LLC,

 

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

) ) ) ) ) ) )

E L E N D E ~

His Interest May Appear, FRANCISCO SALGADO , As

As His Interest May Appear, SOJ\lJA CERVANTES, As Her Interest May Appear,

$2,145.36 in U.S. CURRENCY and EL RODEO 16, LLC, Located at 14160 Mundy Dr., Ste. 900, ) Noblesville, IN JOSE MELENDEZ,

As His Interest May Appear, FRANCISCO

SALGADO,

As His Interest May Appear Appear,,

$1,267.00 in U.S. CURRENCY and JOSE

)

VICTOR BUSTOS, Located at 140 Howard Ave. Ave.,, West

Lafayette, IN EL RODEO 13, LLC, As Its Interest May Appear,

$401.53 in U.S . CURRENCY and EL RODEO 13, LL C , Located at 14 140 0 Howard Ave., West Lafayette, IN JOSE MELENDEZ , As His Interest May Appear, FRANCISCO SALGADO, As His Interest May Appear,

) )

ABEL BUSTOS, As His Interest May Appear,

$2044.04 in U.S. CURRENCY andEL R O D EO 10, LLC, Located at 2404 National Rd. W., Richmond, IN JOSE MELENDEZ, As His Interest May Appear Appear,,

FRANCISCO SALGADO ,

)

As His Interest May Appear Appear,,

JESUS MELENDEZ , As His Intere Interess t May Appear, $650 .00 in U.S. CURRENCY SANTANA,

and EUGENIA

)

 

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 MEX

PROPERTIES, LLC, and EL RODEO & EL JARIPEO OFFICE, Located at 805 S. S . Girls School Rd. ,

) )

Indianapolis,, IN Indianapolis JOSE 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 LA

CARRETA MEXICAN RESTAURANT & BAR, 3 INC., Located at 717 U.S. Hwy. 41,

Schererville, IN 46375

)

)

ARNULFO 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 LA CARRETA MEXICAN RESTAURANT & BAR, INC. Located at 269 U.S. 30 , Merrillville,

)

IN ARNULFO GONZALEZ, As Hi s Interest May Appear,

)

$337.05 in U. S . CURRENCY and EL JARIPEO 6 LL C , Located at 38 W. Main St., New

 

Palestine, IN ANTONIO SALGADO PASTRANA, As His Interest May Appear,

) ) )

$1192.40 in U.S . CURRENCY and EL JARIPEO 5 LLC, Located Locate d 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 $1079. RODEO 22 LLC, Located at 6673 State Road 334, 334 , Zionsville, IN JOSE JOS E MELENDEZ, As His Interest ay Appear,

) ) ) ) ) )

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

) )

COMPL

INT FOR FORFEITURE AA 'D TO ENJOIN R

CKETEERING

CTIVITY

Come now the Plaintiffs, Plaintiffs , by counsel, counsel, and complain o f each of the above-named Defendants and claim for relief, allege a llege and say: COUNT I 1

On or about November 18 18,, 2013, office officers rs o f the Plaintiffs seized from the Defendants, the above captioned sum umss of money from each o f the above-captioned Defendants as a result of search warrants served served..

2

Said property, property , currency, and/or money had been furnished or was intended to be furnished by any person in exchange for an act that is in violation o f an Indiana criminal statute; was used to facilitate any violation of an Indiana criminal statute; statute; or is trac traceabl eablee as proceeds of a violation o f an Indiana criminal statute; or said property, property , currency currency,, and/or money is the object o f a corrupt business influence vio violati lation; on; as provided in I. C. 34-24-1-1 o r as otherwise provided as subject to forfeiture in I.C. 34-24-1-1. COUNT IT

3.

Plainti ffs incorporate all above allegations in Paragraphs l and 2. Plaintiffs 2.

4

The above-cap above-captioned tioned Defendants Defendants,, have participated

in ,

constructed, and continued to operate one

or more corrupt business enterprise, through a pattern of rackete racketeeering activity, as defined in I. C. 35 -45-6-2. This con conduct duct has continued as a pattern o f racketeerin g activity, and not as iso solated lated

 

instances, all in violation o f the criminal statutes of the State o f India Indiana. na. The crimes which have formed the business o f the enterprise includes the commission, the attempted commission, the conspiracy to com.. llit, or aiding and abetting the commission of, but not limited to, to , the following offenses 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) Forge Forgery ry as defined in I.C. 35-43-5-2; or 4) Perjury as defmed in I.C. 35-44.1-2-1. 5. Offenses involving Money Laundering took the form of receiving, concealing, possess posse ssing ing,, transferring,, or transportin transferring transporting g the proceeds o f criminal activity, activity , and/or conducting, conducting, supervising, or facilitating transactions involving the proceeds of criminal activity and consists at least two such incidents o f such criminal conduct over time including, but not limited to, all relevant time frames as outlined in I.C . 35-45-6-1 d). 6.

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

7.

Offenses involving Forgery and Perjury took the form o f the making, making, uttering and signing o f various tax documents, documents , busin business ess fonnati on documents, employ employ ment records, tax returns, and other documents while knowing that the information was false and/or misleading on several occasions over time including, but not limited to, all relevant time frames as outlined in I C. 3545-6-l d).

8.

Further, other offenses listed in I.C. 35-45-6-l e), may also form the business Further, the conduct o f which is part of the pattem o f racketeering activity.

9.

Pursua nt to LC. 34 -2 4-2-2, the above captioned property was used in the course of, intended for use in the course of, derived from, from , or realized through conduct in violation ofl C 35-45-6-2.

o f the

enterprise;

WHEREFORE, the Pla Plaintiff intiffss demand judgment against each De Defendan fendantt listed above for the forfeiture o f the above-captioned sums of currency, money money,, and/or property seized, against each o f the above captioned Defendants; Defendants ; and for delivery of said currency, currency, money money,, and/or propert property y to the State upon forfeiture as provided in I. C. 34-24-1-1 and I. C. 34-24-2 34-24-2--2, and for all other just and proper relief in the premises premi ses including the following reli ef pursuant to I. I .C. 34-24-2-1: A. For a judg ment against the Defendants gran granting ting permanent injunction against the further operation of racketeering activity within the enterprise identified herein; B. For a judgment of forfeiture of the property o f th thee Defendant which the court shall determine to be appropriate under the sta statute tutess cited herein; including specifically all pr pro o perty se seiize zed d at the location locationss described; which, thus, includes forfeiture by the Defendants o f the property li sted in the caption of this cause; C . Order the Defendant Defendantss to dives dive st themselves of any interest in the above mentioned Resta Re staurants urants and/or Bu siness es and to deli deliver ver the funds o f the divestments to the Plaintiffs; D . For an order prohibiting the De fendants from engaging in the same type o f endeavor in which the defendan defendantt s were engaged in violation of Indiana law; E.

For an order di disso sso lvin lving g and preventing the reor reorganiza ganization tion those tho se dive divestme stment ntss to the Plaintif Plaintifffs;

o f said

businesses, a nd to deliver

 

For an order forfeiting the chmters o said Re staurants and/or Businesses, Businesses, which allows said Restaurants and/or Businesses to operate and to act as a corporation organized under the laws o 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 by the State o Indiana; H . For disgorgement o all proceeds o illegal activity that this Court may determine that the F

I

Defendants posse ss and/or have possessed; For the cost o this action action,, for the costs o the enforcement o the underlying case which the Defendants are prosecuted criminally, and for the reasonable attorney fees incurred by the Plaintiff in prosecuting o this and the criminal action, and for all oth lief just an and d prop proper er in the premises.

CERTIFIC

copy

o

TE OF SERVICE

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

 

 

 

 

 

 

 

 

 

 

 

 

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