IN THE SUPERIOR COURT OF Muscogee COUNTY STATE OF GEORGIA CIVIL ACTION FILE NO. SU2025CV002705 STATE OF GEORGIA, Plaintiff, V. CARLOS ALBERTO RECINOS-JUAREZ, to wit: (1.) One Hundred Thirty Seven Thousand Seven Hundred Seventy Eight and 99/100 Dollars ($137,778.99) of US Currency; (2.) 2005 Toyota Tacoma PreRunner, VIN: 5TEKU72N85Z020163; (3.) 2013 Toyota Tacoma, Green in Color, VIN: 5TFLU4EN2DX075115; (4.) 2014 Toyota RAV4 Utility 4X4 LE 4, Red In Color, VIN: 2T3BFREV2EW153594; (5.) 1 Gold Ring with Blue Stone Center; (6.) Gold in Color Bracelet; (7.) Gold Ring; (8.) Elephant With Clear Stones Gold Ring; (9.) Horseshoe with Racehorse Gold Ring; (10.) Gold Necklace (Costume Jewelry); (11.) Gold Bracelet "Carlos"; (12.) Gold Necklace "Elephant Emblem"; (13.) Gold Ring; (14.) Bag No. 10 with Gold Emblem "R"; (15.) Gold Ring; (16.) Silver in Color Watch With Clear Stones; (17.) Gold in Color Necklace "Butterfly Emblem" Costume Jewelry; (18.) Gold in Color Necklace, Costume Jewelry; (19.) Gold Ring, Blue Stone Center; (20.) Figaro Style Bracelet - Costume Jewelry Defendant(s), In Rem RE PROPERTY OF Carlos Alberto Recinos-Juarez, Purported Owner(s)/Interest Holders COMPLAINT FOR FORFEITURE COMES NOW THE STATE OF GEORGIA, by and through W. Donald Kelly, District Attorney for the Chattahoochee Judicial Circuit, and files this Complaint For Forfeiture pursuant to the Official Code of Georgia Annotated Sec. 16-13-49(b) and 9-16-12 and shows the Court the following: 1. The personal property sought to be forfeited is described in the above-styled caption and is incorporated herein by reference as Defendant In Rem or defendant personal property. 2. The defendant personal property is presently in the custody of the Muscogee County Sheriff's Office, 1000 5th Ave., Columbus, GA 31901 and is within the venue and subject to the jurisdiction of this Court. 3. On October 16, 2025, a Consent to Search of real property located at 1714 44th Street, Columbus, Georgia 31904, revealed approximately 61 grams of cocaine and approximately 300 grams of methamphetamine. 4. The search of the real property, including the residence and curtilage, resulted in the seizure of the above contraband and the defendant personal property described in Paragraph 1. 5. All of the defendant personal property described in Paragraph 1, above, is contraband and subject to forfeiture to the State of Georgia pursuant to the provisions of O.C.G.A. 16-13-49(b), in that the defendant personal property was directly or indirectly used or intended for use to facilitate: a) Trafficking of cocaine in violation of O.C.G.A Section 16-13-31 and 1) are proceeds derived therefrom and/or 2) was found in close proximity to the cocaine. b) Trafficking of methamphetamine in violation of O.C.G.A Section 16-13-31, and 1) are proceeds derived therefrom and/or 2) was found in close proximity to methamphetamine. c) Possession of Firearm During Commission of a Felony in violation of O.C.G.A. Section16-11-106, in that, 1) are proceeds derived therefrom and/or 2) was found in close proximity to cocaine and methamphetamine. 6. Additionally, the defendant weapon is contraband and subject to forfeiture to the State of Georgia pursuant to O.C.G.A. 16-13-49(b) in that the weapon is in violation of O.C.G.A. Section 16-11-106, was available for use to facilitate O.C.G.A. Section 16-13-31 Trafficking In Cocaine, Illegal Drugs, Marijuana, Or Methamphetamine (methamphetamine) and O.C.G.A. Section 16-13-31 Trafficking In Cocaine, Illegal Drugs, Marijuana, Or Methamphetamine (cocaine). 7. Carlos Alberto Recinos-Juarez violated O.C.G.A. Section 16-13-31 Trafficking In Cocaine, Illegal Drugs, Marijuana, Or Methamphetamine, O.C.G.A. Section 16-13-31 Trafficking In Cocaine, Illegal Drugs, Marijuana, Or Methamphetamine, and O.C.G.A. Section16-11-106 Possession Of Firearm Or Knife During Commission Of Or Attempt To Commit Certain Felonies, in that he did on or about October 16, 2025, at 1710 44th Street, Apartment B., Columbus, GA 31904, in Muscogee County, possess 61 grams of cocaine; in excess of 28 grams, 300 grams of methamphetamine; in excess of 200 grams, and a Taurus G2 9mm handgun. 8. The names and addresses of all known persons who may be interest holders of the defendant personal property are as follows: Carlos Alberto Recinos-Juarez 1710 44th Street, Apartment B. Columbus, GA 31904 WHEREFORE THE STATE OF GEORGIA PRAYS: 1) That all purported owners and/or interest holders listed herein be personally served with a copy of the complaint and summons; 2) That the custodians of the defendant property be personally served a copy of the complaint and summons herein; 3) That the Court hold a hearing within sixty (60) days of the service of this complaint as provided by O.C.G.A. 9-16-12(f); 4) That the Court enter judgment in favor of the State of Georgia declaring the defendant property or any part thereof forfeited to the State of Georgia pursuant to the provisions of O.C.G.A. 16-13-49; 5) That the Court retain jurisdiction to direct the proper disposition and distribution of the forfeited property as provided by O.C.G.A. 9-16-19; and 6) That the State of Georgia be afforded such other relief and remedies as are available under law and for due process to enforce the forfeiture. Respectfully Submitted, W. Donald Kelly District Attorney Chattahoochee Judicial Circuit State Bar No. 413176 /s/ Wesley Lambertus Wesley Lambertus Chief Assistant District Attorney State Bar No. 496933 wlambertus@columbusga.org VERIFICATION Pursuant to the provisions of O.C.G.A. 9-16-12(a), I hereby verify that the information contained in the forgoing complaint for forfeiture is true and correct to the best of my knowledge and belief. Inv. Michael Gross Muscogee County Sheriff's Office SUMMONS To all owners and interest holders of Defendant Property In Rem: You are hereby summoned and required to file with the Clerk of this Court and serve upon Plaintiff's attorney, Wesley Lambertus, Chief Assistant District Attorney, Chattahoochee Judicial Circuit, Office of the District Attorney, 100 East Tenth Street - 3rd Floor, Columbus, GA 31902-1340, an answer to the VERIFIED COMPLAINT FOR FORFEITURE, which is herewith served upon you, within thirty (30) days after personal service, if you wish to be heard by the Court. If you fail to do so, judgment by default will be taken against you for the relief demanded in the VERIFIED COMPLAINT FOR FORFEITURE. RULE NISI The State of Georgia's VERIFIED COMPLAINT FOR FORFEITURE, having been read and considered it is hereby ORDERED that the Claimant(s) shall appear and show cause before this Court if they wish to be heard on February 24, 2026, at 10:00 a.m., before Judge Bemon G. McBride, III., Government Center - Tower, 100 10th Street, Columbus, GA 31901, why the relief prayed for in said complaint should not be granted. /s/ Wesley Lambertus Wesley Lambertus, Chief Assistant District Attorney Chattahoochee Judicial Circuit Georgia State Bar No. 496933 Office of the District Attorney 100 East Tenth Street - 3rd Floor Columbus, GA 31902-1340 Phone: 706-225-4336; Fax: 706-225-3384 Email: wlambertus@columbusga.org W00000000 Dec 17,24 2025