Complaint for forfeiture of cash and firearms following a search warrant execution.

IN THE SUPERIOR COURT OF COLUMBIA COUNTY
STATE OF GEORGIA
 
STATE OF GEORGIA
Plaintiff,                                              CASE NO.: 2025ECV1423
TWO THOUSAND NINE DOLLARS &
00/100 CENTS IN U.S. CURRENCY
($2,009.00)
     First Defendant(s) in rem
ONE THOUSAND THREE HUNDRED
TEN DOLLARS & 00/100 CENTS IN
U.S. CURRENCY ($1,310.00)
     Second Defendant(s) in rem
GLOCK FIREARM SIN: BZTY735
     Third Defendant(s) in rem
GLOCK FIREARM SIN: CDRZ546
     Fourth Defendant(s) in rem
GLOCK FIREARM SIN: CCTT295
     Fifth Defendant(s) in rem
GLOCK FIREARM SIN: CATB980
     Sixth Defendant(s) in rem
RUGER AR-556 SIN: 859-43717
     Seventh Defendant(s) in rem
AR 15 RUGER PISTOL SIN: SDJ03581
     Eighth Defendant(s) in rem
(9) ROUNDS 5.56 AMMUNITION, (28)
ROUNDS OF .380 AMMUNITION, (21)
ROUNDS OF 5.7X28 AUMMUNITION,
(24) ROUNDS OF 5.56 AMMUNITION,
(1) 5.7X28 MAGAZINE, (1) .380
MAGAZINE & (1) 5.56 MAGAZINE,
     Ninth Defendant(s) in rem
RICARDO GONZALEZ
     Tenth Defendant/CIaimant
SALINA RIVERIA
      Eleventh Defendant/Claimant
ALONZO LAW-GAMERO
     Twelfth Defendant/Claimant
 
COMPLAINT FOR FORFEITURE
COMES NOW NATALIE PAINE, Acting District Attorney for the Columbia Judicial Circuit, and files this Complaint pursuant to O.C.G.A. 9-16-12 and O.C.G.A 16-13-49 and shows the Court the following:
1.
The property sought to be forfeited is described in the above-styled caption. The propeny is presently in the custody of the Columbia County Sheriffs Office located in Columbia County and venue and jurisdiction are proper.
2.
On August 15, 2025, Investigator Muniz and several other deputies of the Columbia County Sheriff's Office executed a search warrant at the home of Tenth and Eleventh Defendants/Claimants, hereinafter referred to as Gonzales and Rivera, located at 1169 Dartmore Trail, Evans, Georgia 30809.
4.
The search revealed four Glock firearms, an AR 15 firearm, $2,009.00 cash on the bathroom counter next to a Mclaren jewelry chain and watch set that had been reported stolen. The search also revealed 282.5 grams of marijuana and four vials of testosterone. Additionally, the search revealed a Jeep Grand Cherokee Trackhawk confirmed stolen from Los Angeles, California and a Cadillac Escalade confirmed stolen from Nashville, Tennessee. Field tests were conducted with positive results for THC/CBD.
5.
On August 15, 2025, Investigator Muniz obtained a search warrant for the home of Twelfth Defendant/Claimant Alonzo Law-Gamero, hereinafter referred to as Law-Gamero, located at 3903 Miramar Drive Ext., Martinez, Georgia 30907 as it was relevant to his investigation of Gonzalez and Rivera.
6.
On August 15, 2025, Investigator Long and Investigator Easler with the Columbia County Sheriff s Offce executed the search warrant which revealed a Ruger AR-15 Rifle, (24) rounds of ammunition in the magazine, (9) rounds of green tip 5.56 ammunition, (28) rounds of .380 ammunition, (21) rounds of5.7x28 magazine, (1) .380 magazine, $1,310.00 cash, a digital scale, 10 grams of THC gummies, (20) 30 mg., (1) amphetamine pill, 899.9 grams of marijuana, 491 grams of marijuana, (6) THC vapes, 5.2 grams of MDMA pills, 1 gram of
cocaine, 5.4 grams of THC live resin, (35) THC vapes and 23.4 grams of Psilocybin mushrooms. Additionally, (2) THC vapes were located in the Chevrolet Blazer parked in the driveway. Multiple field tests were conducted on the marijuana, THC gummies, THC live resin and THC vape cartridges, MDMA pills, Psilocybin mushrooms, and cocaine, with positive results for each respective illegal substance.
6.
Gonzalez and Rivera were both indicted with the following charges:
1. Involvement with Motor Vehicle having Identification Removed (O.C.G.A. S 40-4-22), for that the said accused, in the County of Columbia and the State of Georgia, on the 15th day of August, 2025, did unlawfully receive and possess a Cadillac Escalade, a motor vehicle, from which the manufacturer's serial numbers had been altered for the purpose of concealing and misrepresenting the identity of said motor vehicle;
2. Involvement with Motor Vehicle having Identification Removed (O.C.G.A. S 40-4-22), for that the said accused, in the county ofColumbia and the State of Georgia, on the 15th day of August, 2025, did unlawfully receive and possess a Jeep Grand Cherokee, a motor vehicle, from which the manufacturer's serial numbers had been altered for the purpose of concealing and misrepresenting the identity of said motor vehicle;
3. Theft by Receiving Stolen Property (O.C.G.A. 16-8-7), for that the said accused, in the county of Columbia and the State of Georgia, on the 15th day of August, 2025, did unlawfully receive and retain stolen property, to-wit: a Cadillac Escalade being the property of Courtney Haines, with the value greater than $5,000.00, which said accused knew and should have known was stolen, said property not having been received and retained with intent to restore it to said owner;
4. Theft by Receiving Stolen Property (O.C.G.A. 16-8-7), for that the said accused, in the county of Columbia and the State of Georgia, on the 15th day of August, 2025, did unlawfully receive and retain stolen property, to-wit: A Jeep Grand Cherokee being the property of Lucia Mendez, with the value greater than $5,000.00, which said accused knew and should have known was stolen, said property not having been received and retained with intent to restore it to said owner;
5. Possession of a Schedule III Controlled Substance (O.C.G.A. S 16-13-30(a)), for that the said accused, in the county of Columbia and the State of Georgia, on the 15th day of August, 2025, did unlawfully possess testosterone, a schedule III Controlled Substance, in violation of the Georgia Controlled Substances Act
6. Counterfeit Substances (O.C.G.A. S 16-13-78.2), for that the said accused, in the county of Columbia and the State of Georgia, on the 15th day of August, 2025, did unlawfully possess a counterfeit substance, to wit: a substance held out to be marijuana;
7. Possession of Marijuana with Intent to Distribute (O.C.G.A. 16-13-30(j)), or that the said accused, in the county of Columbia and the State of Georgia, on the 15th day ofAugust, 2025, did unlawfully possess marijuana with the intent to distribute in violation of the Georgia Controlled Substances Act; and
8. Possession of a Firearm During Commission of a Felony (O.C.G.A. 16-11-106), for that the said accused, in the county of Columbia and the State of Georgia, on the 15th day of August, 2025, did unlawfully have a firearm within arm's reach of their person during the commission of the felony crime of possession ofmarijuana with intent to distribute, said crime being a violation of the Georgia Controlled Substances Act.
7.
Law-Gamero was indicted with the following charges:
1. Possession of Marijuana with Intent to Distribute (O.C.G.A. 16-13-30(j)), or that the said accused, in the county of Columbia and the State of Georgia, on the 15th day of August, 2025, did unlawfully possess marijuana with the intent to distribute in violation of the Georgia Controlled Substances Act;
2. Possession of a Firearm During Commission of a Felony (O.C.G.A. 16-11-106), for that the said accused, in the county of Columbia and the State of Georgia, on the 15th day of August, 2025, did unlawfully have a firearm within arm's reach of their person during the commission of the felony crime of possession of marijuana with intent to distribute, said crime being a violation of the Georgia Controlled Substances Act;
3. Possession of a Schedule I Controlled Substance with Intent to Distribute (O.C.G.A. 16-13-30(b)), for that the said accused, in the county of Columbia and the State of Georgia, on the 15th day of August, 2025, did unlawfully possess with intent to distribute tetrahydrocannabinol, a Schedule I controlled substance, in violation of the Georgia Controlled Substances Act;
4. Possession of a Schedule I Controlled Substance with Intent to Distribute (O.C.G.A. 16-13- 30(b)), for that the said accused, in the county of Columbia and the State of Georgia, on the 15th day of August, 2025, did unlawfully possess with intent to distribute MDMA, a Schedule I controlled substance, in violation of the Georgia Controlled Substances Act;
5. Possession of a Schedule I Controlled Substance with Intent to Distribute (O.C.G.A. S 16-13- 30(b)), or that the said accused, in the county of Columbia and the State of Georgia, on the 15th day of August, 2025, did unlawfully possess with intent to distribute psilocybin, a Schedule I controlled substance, in violation of the Georgia Controlled Substances Act;
6. Possession of Cocaine with Intent to Distribute (O.C.G.A. 16-13-30(b)), for that the said accused, in the county of Columbia and the State of Georgia, on the 15th day of August, 2025, did unlawfully possess with intent to distribute cocaine, a Schedule II Controlled Substance, in violation of the Georgia Controlled Substances Act; and
7. Possession of a Schedule II Controlled Substance with Intent to Distribute (O.C.G.A. 16-13- 30(b)), for that the said accused, in the county of Columbia and the State of Georgia, on the 15th day of August, 2025, did unlawfully possess with intent to distribute oxycodone, a Schedule II Controlled Substance, in violation of the Georgia Controlled Substances Act.
8.
The name and address of all persons in possession of said property at the time ofseizure are listed as
follows:
Ricardo Gonzalez 2022 Helmsdale Lane Augusta, Georgia 30909
Salina Rivera 1169 Dartmore Trail Evans, Georgia 30809
Alonzo Law-Gamero 413 N. Belair Road Evans, Georgia 30809
9.
The seized property is declared to be contraband and is subject to forfeiture to the State pursuant to O.C.G.A 16-13-49 and O.C.G.A S 9-16-1 et seq. because of one or a combination of the following statutory violations:
(1) the seized property is a controlled substance, raw material, or controlled substance analog that has been manufactured, distributed, dispensed, possessed or acquired in violation of Article 2 of Chapter 13 of Title 16 of the Official Code ofGeorgia, including felony offenses, attempts and conspiracies thereof, under O.C.G.A 16-13-20 et seq., the Georgia Controlled Substance Act;
(2) the seized property is property, or proceeds thereof, which is, directly or indirectly, used or intended for use in any manner to facilitate a violation of Article 2 of Chapter 13 of Title 16 of the Official Code of Georgia, including felony offenses, attempts, and conspiracies thereof, under O.C.G.A 16-13-20 et seq.; the Georgia Controlled Substance Act;
(3) the seized property is property, or proceeds thereof, located in this state which was, directly or indirectly, used or intended for use in any manner to facilitate a violation of Article 2 of Chapter 13 of Title 16 of the Official Code of Georgia, including felony offenses, attempts, and conspiracies thereof, under O.C.G.A 16-13-20 et seq., the Georgia Controlled Substances Act, or the laws of the United States relating to controlled substances that is punishable by imprisonment for more than one year;
(4) and the seized property is property found in close proximity to a controlled substance or other property subject to forfeiture under O.C.G.A 16-13-49.
10.
Moreover, any of the seized property that is a firearm is declared to be contraband and is additionally subject to forfeiture to the State pursuant to the provisions of O.C.G.A 16-13-49 and O.C.G.A 9-16-1 et. seq., because the seized property is a weapon available for any use in any manner to facilitate a violation of Article 2 of Chapter 13 of Title 16 of the Official Code of Georgia, including violations under O.C.G.A 16-13-20 et seq., of the Georgia Controlled Substance Act.
WHEREFORE THE STATE OF GEORGIA PRAYS FOR DUE PROCESS TO ENFORCE THE FORFEITURE AND FOR THE COURT TO FIND AND ORDER:
1) That a copy of the summons and complaint be personally served on any person known to bean owner or interest holder and any custodian or person who is in possession of the property; provided that, if real property is the subject of the complaint for forfeiture or the owner or interest holder is unknown or resides out of this State or departs this State or cannot after due diligence be found within this State or conceals himself or herself so as to avoid service, that a copy of the notice of the complaint for forfeiture be published once a week for two consecutive weeks in the legal organ of the County in which the complaint for forfeiture is pending with such publication deemed notice to any and all persons having an interest in or right affected by such complaint for forfeiture and from any sale of the property resulting therefrom, but shall not constitute notice to an interest holder unless that person is unknown or resides out of this State or departs this State or cannot after due diligence be found within this State or conceals himselfor herself to avoid service;
2) That pursuant to subsection (e) of O.C.G.A. 9-16-12, if at the expiration of 30 days after the service or the summons and complaint, or, if service is made by publication and personal service has not been made, at the expiration of 30 days of the final publication, no answer has been filed, the State may seek a default judgment as provided in Code Section 9-11-55 and, if granted, the Court shall order the disposition of the seized property as provided for in Code Section 9-16-19;
3) That pursuant to subsection (f) of O.C.G.A. S 9-16-12, if an answer is filed, a bench trial be held within 60 days after the last claimant was served with the complaint; provided, however, that such trial may be continued by the Court for good cause shown;
4) That, after due process has been afforded pursuant to law, the Court enter judgment in favor of the State and declare the seized in rem defendant propeny or any part thereof forfeited to the State pursuant to the provisions of O.C.G.A. 16-13-49 and O.C.G.A 9-16-19;
5) That the Court retain jurisdiction to direct the proper disposition and distribution of the forfeited property as provided by O.C.G.A. S 9-16-19; and
6) That the State of Georgia be afforded any and all such other relief and remedies as are available under the law and for due process to enforce the forfeiture.
This 24th day of November, 2025.
/s/ E. Grace Jolly
E. Grace Jolly
Assistant District Attorney
Columbia Judicial Circuit
GA Bar No. 939710
STATE OF GEORGIA
COUNTY OF COLUMBIA
VERIFICATION
I hereby verify that the facts and information contained in the foregoing Complaint for Forfeiture are true and correct to the best of my knowledge.
/s/ Jesus Muniz
Investigator Jesus Muniz
Columbia County Sheriff's Office
Sworn to and subscribed before me,
this 25 day of November, 2025
/s/ Carmen Chang
Notary Public
My Commission Expires
CARMEN CHANG
Notary Public, Georgia
Columbia County
- My Commission Expires
March 07, 2028
12082056