United States v. Approximately $42,800.00 in U.S. Currency

I. BACKGROUND

8 A. Factual Allegations 9 The following factual recitation comes from Plaintiff’s uncontested verified complaint for 10 forfeiture in rem. (ECF No. 1). 11 On November 17, 2019, the Fresno Police Department (FPD) responded to a house to 12 investigate a reported homicide, locating ten victims with gunshot wounds, four of whom died. FBD and the FBI began an investigation into the shooting and its connection to local criminal gangs—the Asian Crips and the Mongolian Boys Society—and disputes over interstate drug trafficking territory. On December 26, 2019, law enforcement executed eighteen search warrants on various locations associated with local criminal gangs and residences of individuals with connections to the shooting. Pertinent here, a search warrant was executed at 1442 N. 8th Street, Fresno, California— an address connected to Kong Vang, an admitted broker of illegal marijuana. Kong Vang has a criminal history including multiple felony arrests, many drug-related, and misdemeanor convictions for burglary and domestic violence. 21 Law enforcement encountered five individuals at this address; Kong Vang and his 22 girlfriend…