DC-24-04823
`
`FILED
`4/4/2024 11:06 AM
`FELICIA PITRE
`DISTRICT CLERK
`DALLAS CO., TEXAS
`Phyllis Vaughn DEPUTY
`
`NO. __________________
`
`IN THE DISTRICT COURT
`
`
`DALLAS COUNTY, TEXAS
`
`192nd
`
`
`_____ JUDICIAL DISTRICT
`
`§
`
`§ § § §
`
`
`§
`
`Deposit For Costs Not Complied With
`
`1 CIT - PCT 4
`
`
`
`STATE OF TEXAS
`
`VS.
`
`THREE
`THOUSAND
`SEVEN
`HUNDRED SIXTY-NINE DOLLARS
`AND EIGHTY CENTS IN UNITED
`STATES CURRENCY
`
`
`
`
`
`ORIGINAL NOTICE OF SEIZURE
`AND INTENDED FORFEITURE
`
`COMES NOW Joon Kim #9365, an officer of the Dallas Police Department and in the name
`
`and for the State of Texas, files this Original Notice of Seizure and Intended Forfeiture of SEVEN
`
`THOUSAND THREE HUNDRED SIXTY-NINE DOLLARS AND EIGHTY CENTS ($7,369.80)
`
`IN UNITED STATES CURRENCY, and in support of such relief would show the following:
`
`
`
`I.
`
`This suit is brought in accordance with Chapter 59 of the Texas Code of Criminal Procedure,
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`is within the Court’s jurisdiction, is filed as a Level One discovery case, is seeking monetary relief of
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`$250,000.00 or less, and is governed by the expedited actions process.
`
`
`
`II.
`
`Plaintiff complains of Min Jung Kim, DOB 12-23-1974, who may be served with process at
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`6740 Marbella Drive, Irving, Dallas County, Texas 75063.
`
`III.
`
`Plaintiff asserts that the said currency is contraband and is subject to seizure and forfeiture as
`
`provided by Chapter 59 of the Texas Code of Criminal Procedure.
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`
`
`
`
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`ORIGINAL NOTICE OF SEIZURE AND INTENDED FORFEITURE - Page 1
`L\Forfeiture\Petition\Min Jung Kim
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`

`

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`IV.
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`Plaintiff asserts that the seizure of the aforementioned contraband occurred on the 5th day of
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`March 2024, in Dallas County, Texas.
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`
`
`V.
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`Plaintiff alleges that the seizure of the aforementioned contraband was made pursuant to a
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`search warrant.
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`
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`VI.
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`Plaintiff alleges that the said currency was contraband in that it was used or intended to be
`
`used in the commission of a felony under Chapter 71 of the Texas Penal Code, Engaging in
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`Organized Criminal Activity or Section 43.04 of the Texas Penal Code, Aggravated promotion of
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`Prostitution; or was the proceeds gained from the commission of aggravated promotion of
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`prostitution and money laundering.
`
`
`
`VII.
`
`Plaintiff alleges that on March 5, 2024, the contraband became subject to forfeiture in that
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`Affiant executed search warrants at (1) 21 Therapy Spa, 11113 Harry Hines Blvd., #B, Dallas,
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`Dallas County, Texas; (2) Bali Therapy Spa, 9780 Walnut St., #148, Dallas, Dallas County, Texas;
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`(3) Phoenix Spa, 8010 N. Stemmons Fwy, #101, Dallas, Dallas County, Texas; and (4) 1851
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`Knightsbridge Road, #1202, Farmers Branch, Dallas County, Texas. Dallas officers learned of an
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`illicit massage parlor being operated at 11113 Harry Hines Blvd #B, Dallas, Dallas County, Texas.
`
`On March 5, 2024, Dallas officers executed search warrants at all three spas in Dallas. During
`
`search, officers seized money from various locations inside of each spa.
`
`Plaintiff believes that the $7,369.80 in United States currency seized from Claimant Min
`
`Jung Kim was used, was intended to be used, or was the proceeds from the commission of the
`
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`ORIGINAL NOTICE OF SEIZURE AND INTENDED FORFEITURE - Page 2
`L\Forfeiture\Petition\Min Jung Kim
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`

`

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`Aggravated Promotion of Prostitution or Engaging in Organized Criminal Activity, which both are
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`felonies in the State of Texas.
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`
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`VIII.
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`Plaintiff, acting in compliance with Article 59.04(b), attaches the sworn statement of the
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`seizing officer as Exhibit A.
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`
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`IX.
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`Plaintiff would state that the said currency is more particularly described in Schedule A of
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`the seizing officer's sworn statement.
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`WHEREFORE, PREMISES CONSIDERED, Plaintiff prays that this petition be considered
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`an Original Notice of Seizure and Intended Forfeiture and that citation issue to those parties as set
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`out in this petition; that upon hearing this Court find that said SEVEN THOUSAND THREE
`
`HUNDRED SIXTY-NINE DOLLARS AND EIGHTY CENTS ($7,369.80) IN UNITED STATES
`
`CURRENCY is contraband as defined in the Texas Code of Criminal Procedure, Article 59.01(2)
`
`and that the Court allow forfeiture of the above described property to the State of Texas by and
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`through the office of the Criminal District Attorney of Dallas County, Texas as agent for the State
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`and in accordance with its local agreement with the Dallas Police Department, subject only to any
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`interest of the bona fide holder of the perfected lien or perfected security interest on said contraband
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`and that the property be disposed of pursuant to Article 59.06 of the Texas Code of Criminal
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`Procedure and that all costs be taxed against the Claimant in this cause and for such other relief at
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`law and equity as the Plaintiff shall be entitled to receive.
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`
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`ORIGINAL NOTICE OF SEIZURE AND INTENDED FORFEITURE - Page 3
`L\Forfeiture\Petition\Min Jung Kim
`
`

`

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`
`
`
`Respectfully submitted,
`
`John Creuzot
`Dallas County District Attorney
`Dallas County, Texas
`
`
`
`Jason L. Mathis
`Assistant District Attorney
`Texas Bar No. 24041415
`Records Building
`500 Elm Street, Suite 6300
`Dallas, Texas 75202
`(214) 653-6703
`Jason.Mathis@dallascounty.org
`
`
`ATTORNEY FOR PLAINTIFF
`
`
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`ORIGINAL NOTICE OF SEIZURE AND INTENDED FORFEITURE - Page 4
`L\Forfeiture\Petition\Min Jung Kim
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`

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`EXHIBIT A
`EXHIBIT A
`
`

`

`AFFIDAVIT
`
`Came unto me this day, Joan Kim #9365, a person known to me and upon oath sears as follows:
`
`I am over the age of eighteen (18), have personal knowledge of the facts
`My name is Joan Kim #9365.
`asserted in this affidavit, and am competent to testify to those facts.
`I swear the following is true and
`correct to the best of my knowledge.
`
`is employed as a Police Officer by the City of Dallas, Department of Police, for
`Affiant, Joan Kim #9365,
`approximately 16 years and is presently assigned to the Human Trafficking Unit based in Jack Evans
`Headquarters.
`
`Investigations Division Vice Unit received several
`On July 14, 2020, Dallas Police Department Special
`complaints regarding an illicit massage parlor being operated at 11113 Harry Hines Blvd #B, Dallas, Dallas
`County, Texas. During initial
`investigation, the location was called "Sun Spa" and undercover Vice
`Detectives were able to make prostitution cases at the location, but the location closed down due to Covid(cid:173)
`19.
`
`On April 29, 2022, Affiant interviewed a victim who made an outcry regarding prostitution related
`offenses at various spas including Bali Spa on 9780 Walnut St #148. During an interview, victim stated 2
`female owners operated several spas, 11113 Harry Hines Blvd #B and 9780 Walnut St #B, and online
`brothels utilizing apartments in Irving and Farmers Branch.
`
`From December 8, 2022 to March 3"%, 2024, Affiant conducted investigation including interviewing
`another victim for Aggravated Promotion of Prostitution occurring at 11118 Harry Hines Blvd #Band 9780
`Walnut St #148. Victim identified Min Jung Kim (A/F 12-23-1974) and Chaemok Juong (A/F 05-16-1967) as
`owners/operators of both spas and online brothel called Sunflowergirls.net and Kfestival.net. Victim was
`also able to corroborate her outcry against Ms. Jung Kim and Ms. Juong via her texts messaging between
`them. Affiant was also able to identify another spa being owned and operated by Ms. Jung Kim and Ms.
`Juong, Phoenix Spa on 8010 N Stemmons Fwy #101. Several undercover prostitution operations were
`conducted at all three spas, which resulting in several prostitution cases. Affiant also worked with Irving
`Police Department Vice Detective K. Chiasson who conducted investigation on Ms. Jung Kim and Ms. Juong
`online brothels which were operating on apartment in Irving and Farmers Branch.
`
`On March 4, 2024, at approximately 9:30 A.M., several arrest warrants including Engaging in Organized
`Criminal Activity warrant# F2475464 and F2475466, Aggravated Promotion of Prostitution warrant#
`F2475465 and F2475467 for Ms. Jung Kim and Ms. Juong by Dallas Magistrate Don Adams. Several search
`warrants including 21 Therapy Spa (11113 Harry Hines Blvd #B), Bali Spa (9780 Walnut St #148), Phoenix
`Spa (8010 N Stemmons Fwy #101), and Suspect Chaemok Juong's residence (1851 Knightsbridge Rd #1202
`in Farmers Branch) were signed by Dallas County District Judge B. Birmingham.
`
`

`

`On March 5, 2024, at approximately 10:00 A.M., Affiant executed search warrants at all three spas in
`Dallas. During search, Affiant seized following money from various locations inside of each spa and
`Suspect's residence as following:
`
`21 Therapy Spa at 11113 Harry Hines Blvd #B, Dallas, Dallas County, Texas. $1,124.00
`3- $100.00 bills
`3-$50.00 bills
`25 - $20.00 bills
`2- $10.00 bills
`22 -$5.00 bills
`4- $2.00 bills
`36-$1.00 bills
`
`The money was seized and taken to the Baylor St. Property Room under Money Tag# 024485M.
`
`Bali Therapy Spa at 9780 Walnut St #148, Dallas, Dallas County, Texas. $1,826.00
`6-$100.00 bills
`60 - $20.00 bills
`2- $5.00 bills
`1- $2.00 bills
`14- $1.00 bills
`
`The money was seized and taken to the Baylor St. Property Room under Money Tag# 006234M.
`
`Phoenix Spa at 8010 N Stemmons Fwy #101, Dallas, Dallas County, Texas. $2,015.00
`1- $100.00 bills
`4- $50.00 bills
`85 - $20.00 bills
`3- $5.00 bills
`
`The money was seized and taken to the Baylor St. Property Room under Money Tag# 20863M.
`
`Chaemok Juong's residence at 1851 Knightsbridge Rd #1202, Farmers Branch, Dallas County, Texas.
`$2,404.80
`24 - $100.00 bills
`1- $1.00 bills
`9-.25 cents
`4-.10 cents
`1-.05 cents
`10-.01 cents
`
`The money was seized and taken to the Baylor St. Property Room under Money Tag# 024612M.
`
`

`

`Affiant J. Kim #9365 believes the money seized from Ms. Jung Kim and Ms. Juong and the locations are
`proceeds from prostitution dates by multiple females under Suspects promoted. Affiant believes that Ms.
`Jung Kim and Ms. Juong are involved in Aggravated Promotion of Prostitution and Engaging in Organized
`Criminal Activity.
`
`

`

`•
`
`Affiant seized $7,369.80 in US currency described in schedule "A" attached hereto. Affiant
`contends that said currency is contraband and that said currency was used or was intended to be
`used in Aggravated Promotion of Prostitution and Engaging in Organized Criminal Activity.
`
`SUBIARIBEtND SWORN TD before me, the undersigned authority, on this the 2 Z day
`o Ah ,202a
`
`AFFIANT
`
`MARIA JONES
`NOTARY PUBLIC
`STATE OF TEXAS
`MY COMM. EXP, 03/02/26
`NOTARY 1D 13360601-6
`
`

`

`SCHEDULE 'A'
`
`SEIZED CURRENCY
`
`UNITED STATES FEDERAL RESERVE NOTE
`
`$100
`
`UNITED STATES FEDERAL RESERVE NOTE
`
`UNITED STATES FEDERAL RESERVE NOTE
`
`UNITED STATES FEDERAL RESERVE NOTE
`
`UNITED STATES FEDERAL RESERVE NOTE
`
`UNITED STATES FEDERAL RESERVE NOTE
`
`UNITED STATES FEDERAL RESERVE NOTE
`
`UNITED STATES FEDERAL RESERVE COIN
`
`UNITED STATES FEDERAL RESERVE COIN
`
`UNITED STATES FEDERAL RESERVE COIN
`
`UNITED STATES FEDERAL RESERVE COIN
`
`$50
`
`$20
`
`$10
`
`$5
`
`$2
`
`$1
`
`$.25
`
`$.10
`
`$.05
`
`$.01
`
`+'
`
`QUANTITY AMOUNT
`
`34
`
`7
`
`170
`
`2
`
`27
`
`5
`
`52
`
`9
`
`4
`
`1
`
`10
`
`$3,400.00
`
`$350.00
`
`$3,400.00
`
`$20.00
`
`$135.00
`
`$10.00
`
`$52.00
`
`$2.25
`
`$0.40
`
`$0.05
`
`$0.10
`
`SUBTOTAL:
`
`$7,367.00
`
`TOTAL COIN: $2.80
`
`TOTAL:
`
`$7,369.80
`
`

`

`Automated Certificate of eService
`This automated certificate of service was created by the efiling system.
`The filer served this document via email generated by the efiling system
`on the date and to the persons listed below. The rules governing
`certificates of service have not changed. Filers must still provide a
`certificate of service that complies with all applicable rules.
`Jessica Bahena on behalf of Jason Mathis
`Bar No. 24041415
`jessica.bahena@dallascounty.org
`Envelope ID: 86288683
`Filing Code Description: Original Petition
`Filing Description:
`Status as of 4/4/2024 11:34 AM CST
`
`Case Contacts
`
`Name
`JASON MATHIS
`
`BarNumber Email
`Jason.Mathis@dallascounty.org
`
`TimestampSubmitted
`4/4/2024 11:06:53 AM
`
`Status
`SENT
`
`