El Rodeo Lawsuit (Redacted)

STATE OF INDIANA
TIPPECANOE 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 Richmond
Acct. No. 891083287
JOSE MELENDEZ,
As His Interest May Appear,
FRANCISCO SALGADO,
JESUS MELENDEZ,
R.P. MONTERDY,
EL RODEO MEXICAN RESTAURANT aka
EL RODEO #10, LLC
$42,968.39 in U.S. Currency,
Acct. No. 591001712
JOSE MELENDEZ,
FRANCISCO SALGADO,
JESUS MELENDEZ,
FRANCISCO JOSE PROPERTIES, LLC
$2,355.54 in U.S. Currency,
Acct. No. 0191013813-8
JOSE MELENDEZ,
FRANCISCO SALGADO,
JESUS MELENDEZ,
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
SS: IN THE TIPPECANOE SUPERIOR COURT I
CAUSE NO. 79D01-1402-PL- 000 t \
FI LED
This document was edited by the Journal & Courier to redact the addresses where the individuals were served.
No other information was changed.
As His Interest May 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. 4805751541 )
JOSE MELENDEZ, )
FRANCISCO SALGADO, )
FRANCISCO V. MUNOZ, )
ENRJQUE MELENDEZ, )
)
ALFREDO MELENDEZ )
Located in Key Bank )
Acct. No. 141942000508, )
)
LOS TOROS MEXICAN RESTAURANT #2, )
INC. )
Acct. No. 149681010810 )
ENRJQUE MELENDEZ-AGUIRRE, )
ALFREDO MELENDEZ-AGUIRRE, )
NOE 0 . FERNANDEZ, )
JORGE MELENDEZ-AGUIRRE, )
)
LOS TOROS MEXICAN RESTAURANT #2, )
INC. )
$18,355 .92 in U.S. Currency, )
Acct. No. 149681007600 )
ENRJQUE MELENDEZ-AGUIRRE, )
NOE 0. FERNANDEZ, )
JORGE MELENDEZ-AGUIRRE, )
)
LOS TOROS MEXICAN RESTAURANT )
Acct. No. 149681007592 )
ENRIQUE MELENDEZ-AGUIRRE, )
LUIS M. RUIZ, )
PHILIP STARK, )
)
Acct. No. 141942009236 )
)
THE TOROS PROPERTY, LLC, )
$249,000 in U.S. Currency, )
Acct. No. 149681017823 )
)
JOSE & FRANCISCO PROPERTIES, LLC )
Located in Chase Bank )
Acct. No. 675003735 )
JOSE MELENDEZ-PEREZ, )
)
EL JARIPEO #3 aka EL JARIPEO #3, LLC )
$272.88 in U.S. Currency, )
Located in Chase Bank )
Acct. No. 969915883 )
JOSE MELENDEZ, )
ENRIQUE MELENDEZ, )
)
FRANCISCO SALGADO )
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
JOSE MELENDEZ,
JOSE BERNAL,
FRANCISCO SALGADO,
JESUS MELENDEZ,
FELIPE BERNAL,
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
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,
FRANCISCO & CONCEPCION SALGADO,
$201 ,414. 14 in U.S. Currency
Located in PNC Bank
Acct. No. 4618033232
ADRIANA SALGADO,
JOSE BERNAL,
Located in PNC Bank
Acct. No. 4618400047,
JOSE BERNAL,
$871.43 in U.S. Currency
Located in PNC Bank
Acct. No. 461 7574598,
EL RODEO #11 aka EL RODEO #11 LLC
Located in PNC Bank
Acct. No. 4804542997
JOSE MELENDEZ,
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
EL RODEO #21 aka EL RODEO #21 LLC )
Acct. No. 4804542911 )
JOSE MELENDEZ, )
SONIA CERVANTES, )
As Her Interest May Appear, )
SERGIO AGUIRRE CERVANTES, )
)
Acct. No. 4804542938 )
JOSE MELENDEZ, )
)
Located in PN C Bank )
Acct. No. 4804542946 )
JOSE MELENDEZ, )
)
Acct. No. 4804542954 )
JOSE MELENDEZ, )
ENRIQUE A. MELENDEZ, )
SERGIO CERVANTES, )
)
EL RODEO #24 ~ R O E O #24 LLC )
Acct. No. 4804542962 )
JOSE MELENDEZ, )
)
JOSE & FRANCISCO PROPERTIES, LLC )
Located PNC Bank )
Acct. No. 4804543009 )
JOSE MELENDEZ, )
As His InterestMay Appear, )
)
INDY MEX PROPERTIES, )
Acct. No. 4804543017 )
JOSE MELENDEZ, )
ALFREDO MELENEDEZ, )
)
JOSE M. PEREZ aka JOSE MELENDEZ, )
Located in Fifth Third Bank )
Acct. No. 7650190486, )
)
LA CARRETA #3 aka LA CARRETA )
RESTAURANT AND BAR, INC. )
Acct. No. 7654938617 )
ARNULFO GONZALEZ, )
JAMIE G. GONZALEZ, )
JOSAF AT GONZALEZ, )
RAFAELGONZALEZ, )
)
EL RODEO aka EL RODEO# 17 LLC, )
Acct. No. 7652578712 )
JOSE M. PEREZ aka JOSE l\rffiLENDEZ, )
As His Appear, )
.. ._,
)
Located at Fifth Third Bank )
Acct. No. 7652596698 )
CONCEPCION SALGADO, )
)
Located at Fifth Third Bank )
Acct. No. 9974952906 )
GABRIELLA SALGADO, )
)
ANTONIO S. PASTRANA & PATRICIA F. )
CARRANZA, )
Located in Huntington Bank )
Acct. No. 2405860115 )
)
ANTONIO S. PASTRANA aka ANTONIO )
SALGADO PASTRANA, )
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 )
JOSE MELENDEZ, )
JOSE BERNAL, )
FELIPE BERNAL, )
)
EL RODEO aka EL RODEO MEXICAN )
RESTAURANT, )
Located in Regions Bank )
Acct. No. 87520559 )
JOSE MELENDEZ-PEREZ aka JOSE )
MELENDEZ, )
ABEL BUSTOS, )
)
ABEL BUSTOS, )
Located at Regions Bank )
Acct. No. 186329758, )
)
EL RODEO # 19 aka EL RODEO 19 LLC )
Located at Old National Bank )
Acct. No. 116701705 )
JOSE MELENDEZ, )
ABEL BUSTOS, )
LUIS ANTONIO BUSTOS, )
LA t LA CARRBTA
)
)
RESTAURANT & BAR, INC. )
Acct. No. 4502194424 )
ARNULFO GONZALEZ, )
JAMIE GONZALEZ, )
RAFAEL GONZALEZ, )
)
JOSE V. BUSTOS or KARENA BUSTOS )
Acct. No. 122583035, )
)
RAFAEL GONZALEZ or CECILIA )
GONZALEZ )
Acct. No. 2150010702, )
)
LA CARRETA # 1 aka LA CARRETA )
RESTAURANT & BAR, INC. )
Acct. No. 4511555744 )
ARNULFO GONZALEZ, )
RAFAEL GONZALEZ, )
)
JOSE MELENDEZ, )
Acct. No. 122224460, )
)
EL RODEO aka EL RODEO #22, LLC, )
Acct. No. 4505877158 )
JOSE MELENDEZ, )
RAFAEL GONZALEZ, )
)
EL RODEO #7 aka EL RODEO #7 LLC, )
Acct. No. 4511555949 )
JOSE MELENDEZ, )
RAFAELGONZALEZ, )
)
JOSE MELENDEZ )
Acct. No. 4505877131 , )
)
EL RODEO #13 aka EL RODEO #13 LLC, )
Acct. No. 116701694, )
JOSE MELENDEZ, )
ABEL BUSTOS, )
JOSE V. BUSTOS, )
)
$63.83 IN U.S. CURRENCY and LA )
CARRETA MEXICAN RESTAURNANT & )
BAR #2, INC. ,
Located at 630 Kimmel Rd.,
Vincennes, IN 47591
ARNULFO GONZALEZ,
$31,560.41 in U.S. CURRENCY and
ANTONIO S. PASTRANA and SORIANO
ESMERALDO,
Located at 7790 Red Sunset Way,
Avon, IN 46123 or on Antonio
Salgado,
)
)
)
)
)
)
)
)
)
)
)
)
)
$34,081.80 in U.S. CURRENCY and JESUS )
MELENDEZ, )
Located at 315 NW 18th St., Richmond, )
IN, )
$1273.25 in U.S. CURRENCY and LUIS
ANTONIO BUSTOS and ROSA CASTRO,
Located at 5629 Bingham Lane,
Lafayette, IN,
$2371.10 in U.S. CURRENCY and El\:'RJQUE
MELENDEZ and MARTIN BANUELOS and
TIODOLO BANUELOS,
Located at 45 S. Warman Ave.,
Indianapolis, IN,
$189.18 in U.S. CURRENCY and JOSE
BERNAL and FELIPE BERNAL LOPEZ,
Located at 1011 Fair lane Dr., Lebanon,
IN,
$3,743.00 in U.S. CURRENCY and JOSE V.
BUSTOS and ANTONIA BUSTOS,
Located 4357 English Lane, Lafayette,
IN,
$29,563.70 in U.S. CURRENCY and
LUCIANO SANTANA and EUGENIA
SANTANA,
Located at 1821 Rudgate Drive, Avon,
IN,
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
$1463.00 in U.S. CURRENCY and ALFREDO )
MELENDEZ and RAFAEL GONZALEZ and )
CECILIA MELENDEZ, )
Located at 6962 Antelope Drive, )
Indianapolis, IN, )
)
$525.00 in U.S. CURRENCY and ABEL )
BUSTOS and ROSALINDA A VILA )
CORONEL, )
Located at 425 S. Brookfield Dr., )
Lafayette, IN, )
)
$2,650.00 in U.S. CURRENCY and )
JOSE ANGEL BUSTOS, )
Located at El Rodeo Mexican )
Restaurant, 140 Frontage Rd. , Ste. 5, )
Lafayette, IN, )
EL RODEO :MEXICAN RESTAURANT aka )
ELRODE0#1 )
As Its Interest May Appear, )
)
$1,423.30 in U.S. CURRENCY and EL )
RODEO 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, )
. ~
-
ABEL BUSTOS, )
)
RODEO :MEXICAN RESTAURANT #2, )
Located at 3611 E. Main St., )
Richmond, IN )
JOSE :MELENDEZ, )
R.P. MONTERDY )
)
RODEO #7, LLC, )
Located at 4000 W. 106th St., Ste. 185, )
Carmel, IN )
JOSE MELENDEZ, )
)
$1,440.00 in U.S. CURRENCY and SERGIO )
CERVANTES, )
Located at El Rodeo #9, LLC, 457 )
Town Center Dr. N. , Mooresville, IN )
EL RODEO #9 LLC, )
As Its Interest May Appear )
)
$1 , 145.82 in U.S. CURRENCY and EL )
RODEO #9, LLC, )
Located at 457 Town Center Dr. N. , )
Mooresville, IN )
JOSE MELENDEZ, )
As His h1terest May Appear, )
ENRIQUE A. MELENDEZ, )
As His h1terest May Appear, )
)
$1 ,970.00 in U.S. CURRENCY and JOSE )
BERNAL, )
Located at El Jaripeo Mexican )
Restaurant #2, 2330 N. Lebanon St., )
Lebanon, IN )
EL JARlPEO MEXICAN RESTAURANT, #2, )
INC. , )
)
$2, 133.15 in U.S. CURRENCY and EL )
JARIPEO :MEXICAN RESTAURANT #2, )
INC. , aka EL JARIPEO #2 )
Located at 2330 N. Lebanon St., )
Lebanon, IN )
JOSE MELENDEZ, )
As His futerest May Appea[s .,,._ )
JESUS MELENDEZ, )
FELIPE BERNAL, )
)
$1, 163.20 in U.S. CURRENCY and EL )
JARIPEO #3, LLC )
Located at 2605 Main St., Plainfield, )
IN )
JOSE MELENDEZ, )
ENRIQUE :MELENDEZ, )
)
$1,460.00 in U.S. CURRENCY and WAN )
VILLALVA CHAVEZ, )
Located at El Jaripeo #4, LLC, 3020 )
State Road 32 E., Westfield, IN )
EL JARIPEO #4, LLC, )
)
$1080.79 in U.S. CURRENCY and EL )
JARIPEO #4 LLC, )
Located at 3020 State Road 32 E., )
Westfield, IN )
JOSE MELENDEZ, )
JUAN M. VILLALVA, )
)
RODE0 #17,LLC, )
Located at 11452 Olio Rd. , Fishers, )
IN )
JOSE MELENDEZ, )
)
RODEO # 18, LLC, )
Located at 8128 E. U.S. Hwy. 36, )
Avon, IN )
JOSE MELENDEZ, )
)
$3,394.00 in U.S. CURRENCY and LUIS )
BUSTOS, )
Located at El Rodeo # 19 LLC, 109 )
Beck Lane, Ste. 120, Lafayette, IN )
EL RODEO #19, LLC, )
)
RODEO #19, LLC, )
Located at 109 Beck Lane, Ste. 120, )
Lafayette, IN )
JOSE MELENDEZ, )
ABEL BUSTOS, )
)
RODEO #21, LLC, )
Located at 3113 W. Smith Valley Rd., )
Ste. A. , Greenwood, IN )
JOSE E L E N D E ~ )
SOJ\lJA CERVANTES,
$2,145.36 in U.S. CURRENCY and EL
RODEO #16, LLC,
Located at 14160 Mundy Dr., Ste. 900,
Noblesville, IN
JOSE MELENDEZ,
FRANCISCO SALGADO,
$1,267.00 in U.S. CURRENCY and JOSE
VICTOR BUSTOS,
Located at 140 Howard Ave., West
Lafayette, IN
EL RODEO #13, LLC,
As Its Interest May Appear,
$401.53 in U.S. CURRENCY and EL
RODEO #13, LLC,
Located at 140 Howard Ave., West
Lafayette, IN
JOSE MELENDEZ,
FRANCISCO SALGADO,
ABEL BUSTOS,
$2044.04 in U.S. CURRENCY andEL
RODEO# 10, LLC,
Located at 2404 National Rd. W.,
Richmond, IN
JOSE MELENDEZ,
FRANCISCO SALGADO,
JESUS MELENDEZ,
$650.00 in U.S. CURRENCY and EUGENIA
SANTANA,
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
Located at Indy Mex Properties, LLC, )
805 S. Girls School Rd., Indianapolis, )
IN . )
INDY MEX PROPERTIES, LLC, )
JOSE MELENDEZ, )
ALFREDO JvfELENDEZ,
$71.00 in U.S. CURRENCY and INDY MEX
PROPERTIES, LLC, and EL RODEO & EL
JARIPEO OFFICE,
Located at 805 S. Girls School Rd. ,
Indianapolis, IN
JOSE MELENDEZ,
FRANCISCO SALGADO,
ALFREDO MELENDEZ,
$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,
$2437.00 in U.S. CURRENCY and LA
BAR, #2 INC.,
Located at 630 Kimmel Rd.,
Vincennes, IN
ARNULFO GONZALEZ,
$1,204.13 in U.S. CURRENCY and LA
BAR, INC.
Located at 269 U.S. 30, Merrillville,
IN
ARNULFO GONZALEZ,
$337.05 in U.S. CURRENCY and EL
JARIPEO 6 LLC,
Located at 38 W. Main St., New
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
Palestine, IN )
ANTONIO SALGADO PASTRANA, )
)
JARIPEO #5 LLC, )
Located at 2000 E. Wabash St., )
Frankfort, IN )
JOSE MELENDEZ, )
FELIPE BERNAL, )
)
RODEO #22 LLC, )
Located at 6673 State Road 334, )
Zionsville, IN )
JOSE MELENDEZ, )
)
)
COMPLAINT FOR FORFEITURE AA"'D TO ENJOIN RACKETEERING ACTIVITY
Come now the Plaintiffs, by counsel, and complain of each of the above-named Defendants and
claim for relief, allege and say:
COUNT I
1. On or about November 18, 2013, officers of the Plaintiffs seized from the Defendants, the above-
captioned sums of money from each of the above-captioned Defendants as a result of search
warrants served.
2. Said 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 of an Indiana criminal statute; was used to
facilitate any violation of an Indiana criminal statute; or is traceable as proceeds of a violation of
an Indiana criminal statute; or said property, currency, and/or money is the object of a corrupt
business 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 one
or 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
instances, all in violation of the criminal statutes of the State of Indiana. The crimes which have
formed the business of the enterprise includes the commission, the attempted commission, the
conspiracy to com..'llit, or aiding and abetting the commission of, but not limited 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) Forgery 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, possessing,
transferring, or transporting the proceeds of criminal activity, and/or conducting, supervising, or
facilitating transactions involving the proceeds of criminal activity and consists at least two such
incidents of 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 of exerting unauthorized control over the property of the
State of Indiana by illicitly retaining and failing to report money owed to the State of Indiana as
sales 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 of
various tax documents, business fonnation documents, employment 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. 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 for
use 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 above-
captioned Defendants; and for delivery of said currency, money, and/or property to the State upon
forfeiture 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 the
premises including the following relief pursuant to I. C. 34-24-2-1:
A. For a judgment against the Defendants granting permanent injunction against the further
operation of racketeering activity within the enterprise identified herein;
B. For a judgment of forfeiture of the property of the Defendant which the court shall determine
to be appropriate under the statutes cited herein; including specifically all property seized at
the 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 Restaurants
and/or Businesses and to deliver the funds of the divestments to the Plaintiffs;
D. For an order prohibiting the Defendants from engaging in the same type of endeavor in which
the defendants were engaged in violation of Indiana law;
E. For an order dissolving and preventing the reorganization of said businesses, and to deliver
those divestments to the Plaintiffs;
F. For an order forfeiting the chmters of said Restaurants and/or Businesses, which allows said
Restaurants and/or Businesses to operate and to act as a corporation organized under the laws
of the State of Indiana and including the revocation of 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 of any professional license possessed by the Defendants and granted by
the State of Indiana;
H. For disgorgement of all proceeds of illegal activity that this Court may determine that the
Defendants possess and/or have possessed;
I. For the cost of this action, for the costs of the enforcement of the underlying case which the
Defendants are prosecuted criminally, and for the reasonable attorney fees incurred by the
Plaintiff in prosecuting of this and the criminal action, and for all oth liefjust and proper
in the premises.
CERTIFICATE OF SERVICE
I hereby certifY that on the 1.!1._-fl..ctay of FE&It1!j, 2014, I mailed a copy of this Complaint and a
copy of the Complaint to each defendant by first class mail, certified, at the address below.

J

El Rodeo Lawsuit (Redacted)

Загружено:

Сведения о документе

Авторское право

Доступные форматы

Поделиться этим документом

Поделиться или встроить документ

Параметры публикации

Этот документ был вам полезен?

Это неприемлемый материал?

Авторское право:

Доступные форматы

El Rodeo Lawsuit (Redacted)

Загружено:

Авторское право:

Доступные форматы

STATE OF INDIANA

Вам также может понравиться