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Case 3:17-cv-00500-JLS-WVG Document 20 Filed 08/17/17 PageID.

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1 ALANA W. ROBINSON
Acting U.S. Attorney
2 BENJAMIN J. KATZ
California State Bar No. 272219
3 MARC PLETCHER
Colorado State Bar No. 034615
4 Assistant U.S. Attorney
Federal Office Building
5 880 Front Street, Room 6293
San Diego, California 92101-8893
6 Telephone: (619) 546-9604
E-mail: benjamin.katz@usdoj.gov
7
Attorneys for Plaintiff
8 United States of America
9 UNITED STATES DISTRICT COURT
10 SOUTHERN DISTRICT OF CALIFORNIA
11 UNITED STATES OF AMERICA, Case No. 17cv500-JLS
12 Plaintiff, AMENDED COMPLAINT
FOR FORFEITURE
13 v.
14 REAL PROPERTY KNOWN AS 5904 AND
5908 GRASSHOPPER ROAD,
15 BIRCHWOOD, TENNESSEE,
16 REAL PROPERTY KNOWN AS 2520,
2522, 2424, 2538 KEITH STREET NW,
17 CLEVELAND, TENNESSEE,
18 REAL PROPERTY KNOWN AS BAKER
LANE & BLYTHE FERRY LANE,
19 PARCELS 071-048.04 & 072-105 IN
BIRCHWOOD, TENNESSEE,
20
REAL PROPERTY KNOWN AS 3601
21 BLYTHE FERRY LANE IN
BIRCHWOOD, TENNESSEE,
22
INCLUDING ALL APPURTENANCES,
23 IMPROVEMENTS, AND ATTACHMENTS
THEREON,
24
Defendants.
25
26 By way of verified amended complaint against the above Defendants, 5904
27 and 5908 Grasshopper Road, Birchwood, Tennessee (hereinafter Defendant
28 Property #1); 2520, 2522, 2424, 2538 Keith Street NW, Cleveland, Tennessee
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1 (hereinafter Defendant Property #2); Baker Lane & Blythe Ferry Lane, Parcels 071-
2 048.04 and 072-105 in Birchwood, Tennessee (hereinafter Defendant Property #3);
3 and 3601 Blythe Ferry Lane, Birchwood, Tennessee (hereinafter Defendant
4 Property #4), (collectively Defendant Properties), the United States alleges:
5 1. This Court has jurisdiction over this action by virtue of the provisions of
6 Title 28, United States Code, Section 1355, and Title 18, United States Code,
7 Sections 1956(a)(2)(A), 1956(h), 981(a)(1)(A), and 981(a)(1)(C), because the
8 defendants are properties involved in the offenses of money laundering and
9 conspiracy to money launder, and also are properties constituting proceeds traceable
10 to specified unlawful activity, in violations of Title 18, United States Code, Sections
11 1347 and 1956.
12 2. Venue is proper within the Southern District of California pursuant to
13 Title 28, United States Code, Sections 1391 and 1355(b)(1)(A), and Title 18, United
14 States Code, Section 981(h) because some of the acts or omissions giving rise to the
15 forfeiture occurred in this district.
16 3. The defendant real properties, with all appurtenances, improvements,
17 and attachments thereon, are located in the Eastern District of Tennessee. They are
18 more fully identified and described as follows:
19 Defendant Property #1
20 5904 and 5908 Grasshopper Road, Birchwood, Tennessee
21 BEGINNING on the Southern Right of Way of Grasshopper
Road, said point also being the Northeasternmost comer of the
22 William Carpenter property as described in Book 3971, page 734,
in the Register's Office of Hamilton County, Tennessee; thence
23 from said point of beginning and following along said right of
way, South 59 degrees 40 minutes 90 seconds East, 52.45 feet to
24 a point; thence leaving said right of Way South 12 degrees 43
minutes 35 seconds West, 241.64 feet to a point; thence South 32
25 degrees 28 minutes 45 seconds West, 241.78 feet to a point;
thence South 22 degrees 00 minutes 25 seconds West, 523.44 feet
26 to a point; thence South 40 degrees 18 minutes 11 seconds West,
771.65 feet to a point; thence South 42 degrees 58 minutes 46
27 seconds East, 360.45 feet to a point; thence South 26 degrees 39
minutes 06 seconds West, 588.36 feet to a point;- thence South 27
28 degrees 36 minutes 05 seconds West, 392.68. feet to a point;
thence South 30 degrees 07 minutes 57 seconds West, 158.32 feet
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to a point; thence South 54 degrees 01 minutes 23 seconds West,


1 365.54. feet to a point; thence South 33 degrees 09 minutes 55
seconds West, 647.14 feet to a point; thence North 62 degrees 42
2 minutes 23 seconds West, 1006.82 feet to a point; thence North
25 degrees 39 minutes 05 seconds East, 2274.75 feet to a point;
3 thence South 61 degrees 25 minutes 55 seconds East, 919.55 feet
to a point; thence North 40 degrees 18 minutes 11 seconds East,
4 757.;71 feet to a point; thence North 22 degrees 00 minutes 25
seconds East, 519.98 feet to a point; thence North 32 degrees 28
5 minutes 45 seconds East, 237.65 feet to a point; thence North 12
degrees 43 minutes 35 seconds East, 248.79 feet to a point on the
6 Southern right of way of Grasshopper Road and being the point of
beginning. All as shown on a survey by Jimmy L Richmond, TN
7 registered surveyor #917 and dated July 15, 2004.
8 and
BEGINNING at the Northeast line of Grasshopper Road at its
9 intersection with the Northwest comer of property of Bazemore,
et al (Book 5199, page 643, ii) the Register's Office of Hamilton
10 County, Tennessee); thence South 1l degrees 37 minutes 01
seconds East, 88.78 feet; thence South 13 degrees 53 minutes 07
11 seconds West, 56.70 feet; thence South 25 degrees 11 minutes 35
seconds West, 43.96 feet; thence South 29 degrees 13 minutes 59
12 seconds West, 132.94 feet; thence South 22 degrees 25 minutes
54 seconds East, 190.91 feet; thence South 30 degrees 40 minutes
13 16 seconds East, 168.69 feet; thence 30 degrees 37 minutes 19
seconds East, 83.01 feet; thence South 33 degrees 56 minutes 27
14 seconds East, 137.12 feet; thence South 30 degrees 03 minutes 14
seconds East, 72.92 feet; thence North 58 degrees 33 minutes 41
15 seconds East, 75.31 feet; thence South 29 degrees 17 minutes 00
seconds East, 50.85 feet; thence South 20 degrees 35 minutes 59
16 seconds West, 305.80 feet; thence South 24 degrees 53 minutes 3
J seconds West, J 02.42 feet; thence South 08 degrees 35 minutes
17 09 seconds West, 51.52 feet; thence South 16 degrees 13 minutes
05 seconds East, 36.30 feet; thence South 32 degrees 51 minutes
18 59 seconds East, 35.38 feet; thence South 58 degrees 48 minutes
02 seconds East, 37.79 feet; South 66 degrees 30 minutes 36
19 seconds East, 25.43 feet; thence South 69 degrees 20 minutes 51
seconds East, 220.63 feet; thence South 58 degrees 37 minutes 00
20 seconds East, 21.10 feet; thence South 49 degrees 29 minutes 46
seconds East, 22.54 feet; thence South 32 degrees 25 minutes 54
21 seconds East, 22.72 feet; thence South 20 degrees 33 minutes 37
seconds East, 55.61 feet; thence South 02 degrees 45 minutes 50
22 seconds East, 169.79 feet; thence South 11 degrees 07 minutes 59
seconds East, 131.53 feet; thence South 17 degrees 58 minutes 00
23 seconds East, 323. 78 feet to an iron pin found; thence along the
line of property of P. Tyree, et ux (Book 7249, page 348, in the
24 said Register's Office), South 75 degrees 54 minutes 12 seconds
West, 1,517.65 feet; thence North 82 degrees 01 minutes 05
25 seconds West, 432.65 feet; thence North 81 degrees 34 minutes
44 seconds West. 492.42 feet thence North 44 degrees 44 minutes
26 38 seconds West, 360.79 feet to a wood post found; thence along
property of W. Carpenter, and access flag of Tyree, (Book 3971,
27 page 734, in the said Register's Office), North 38 degrees 31
minutes 59 seconds East,, 771.65 feet; thence North 20 degrees
28 14 minutes 14 seconds E3st, 523.41 feet; thence North 30 degrees
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41 minutes 42 seconds East, 241.80 feet; thence North IO degrees


1 58 minutes 06 seconds East, 241.64 feet; thence South 61 degrees
28 minutes 06 seconds East, 5.86 feet; thence along the line of
2 Grasshopper Road, on a left-handed curve, South 80 degrees 42
minutes 48 seconds East, radius =275.00 feet; length= 184.78
3 feet, chord a distance of 181.28 feet; thence North 80 degrees 02
minutes 30 seconds East, 279.21 feet; thence on a left-handed
4 curve, North 62degrees 05 minutes 57 seconds East,
radius=300.00 feet; length =187.89 feet, a chord distance of
5 184.84 feet; thence North 44 degrees 09 minutes 24 seconds East,
588.40 feet; thence on a right-handed curve, North 51 degrees 48
6 minutes 57 seconds East, radius =575.76 feet; length =153.93
feet; a chord distance of 153.47 feet; thence on a right-handed
7 curve, North 61 degrees 021 seconds 27 minutes East, radius
=575.76 feet, length =31.48 feet; a chord distance of3 l.47 feet to
8 the beginning point. Said tract containing 84.56 acres as shown
by survey of John T. Kinder of Cleveland Surveying Company,
9 TRLs#1519 dated March 14, 2014 styled "Boundary Survey for-
Julian DeFreise Estate".
10
11 Defendant Property #2
12 2520, 2522, 2424, 2538 Keith Street NW, Cleveland, Tennessee
13 LOTS ONE (1), TWO (2), AND THREE (3), COLONY
SQUARE, as shown by Plat of record in Plat Book 29, page 88,
14 in the Register's Office of Bradley County, Tennessee (ROBCT),
to which reference is made for a more specific description.
15
16 Defendant Property #3
17 Baker Lane & Blythe Ferry Lane, Parcels 071-048.04 & 072-105, Birchwood,
18 Tennessee
19 TRACT ONE:
20 LOCATED IN THE FIRST CIVIL DISTRICT OF MEIGS
COUNTY, TENNESSEE, TO-WIT:
21
LOT ONE (1), FINAL PLAT OF LOTS 1 & 2 BATTON
22 SUBDIVISION, AS SHOWN BY PLAT OF RECORD IN PLAT
CABINET 334, PAGES B-B, IN THE REGISTERS OFFICE
23 OF MEIGS COUNTY, TENNESSEE.
24 TRACT TWO:
25 LOCATED IN THE FIRST CIVIL DISTRICT OF MEIGS
COUNTY, TENNESSEE, TO-WIT:
26
TRACT TWO (2), BOUNDARY SURVEY FOR C. BRUCE
27 BATTEN AND B & B FARMS, LLC, PREPARED BY
CORNERSTONE SURVEYING, LLC, 7023 SNOW HILL RD,
28 OOLTEWAH, TN 37363, JOB NO. 53-09, DATED OCTOBER
6, 2009, AND BEING MORE PARTICULARLY DESCRIBED
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AS FOLLOWS: TO FIND THE POINT OF BEGINNING,


1 START AT THE SOUTHWEST CORNER OF TRACT 1 IN
DEED OF RECORD IN WARRANTY DEED BOOK B5, PAGE
2 412, IN THE REGISTER'S OFFICE OF MEIGS COUNTY,
TENNESSEE, AT THE INTERSECTION OF BAKER LANE
3 AND BLYTHE'S FERRY ROAD; THENCE ALONG THE
EASTERN RIGHT OF WAY OF BAKER LANE THE
4 FOLLOWING CALLS AND DISTANCES:
5 NORTH 35 DEGREES 52 MINUTES 20 SECONDS EAST,
29.02 FEET TO A POINT; THENCE ALONG A CURVE TO
6 THE LEFT WITH AN ARC LENGTH OF 115.76 FEET, A
RADIUS LENGTH OF 737.00 FEET, AND A CHORD
7 BEARING OF NORTH 31 DEGREES 22 MINUTES 21
SECONDS EAST AND DISTANCE OF 115.64 FEET, TO A
8 POINT; THENCE NORTH 26 DEGREES 52 MINUTES 22
SECONDS EAST, 558.41 FEET TO A POINT; THENCE
9 ALONG A CURVE TO THE LEFT WITH AN ARC LENGTH
OF 43.20 FEET, A RADIUS LENGTH OF 507.00 FEET, AND
10 A CHORD BEARING OF NORTH 24 DEGREES 25 MINUTES
55 MINUTES EAST AND DISTANCE OF 43.19 FEET, TO A
11 POINT; THENCE NORTH 21 DEGREES 59 MINUTES 27
SECONDS EAST, A DISTANCE OF 354.09 FEET TO A
12 POINT; THENCE ALONG A CURVE WITH AN ARC
LENGTH OF 17.53 FEET, A RADIUS LENGTH OF 493.00
13 FEET, A CHORD BEARING OF NORTH 23 DEGREES 00
MINUTES 35 SECONDS EAST, AND DISTANCE OF 17.53
14 FEET TO A POINT; THENCE NORTH 24 DEGREES 01
MINUTES 43 SECONDS EAST, A DISTANCE OF 101.85
15 FEET TO A POINT; THENCE CROSSING OVER TO THE
WESTERN RIGHT-OF-WAY OF BAKER LANE, NORTH 65
16 DEGREES 58 MINUTES 17 SECONDS WEST, A DISTANCE
OF 14.00 FEET TO A POINT; THENCE ALONG A 50 FOOT
17 INGRESS/EGRESS AND UTILITY EASEMENT, NORTH 25
DEGREES 12 MINUTES 50 SECONDS EAST, A DISTANCE
18 OF 316.14 FEET TO A POINT, SAID POINT BEING THE
SOUTHEAST CORNER OF THE HEREIN DESCRIBED
19 TRACT AND THE POINT OF BEGINNING; THENCE
CONTINUING ALONG SAID EASEMENT, NORTH 25
20 DEGREES 12 MINUTES 50 SECONDS EAST, A DISTANCE
OF 545.44 FEET TO A POINT, THE NORTHEAST CORNER
21 OF THE HEREIN DESCRIBED PROPERTY; THENCE
NORTH 66 DEGREES 15 MINUTES 41 SECONDS WEST, A
22 DISTANCE OF 750 FEET TO T.V.A. MONUMENT 662-3;
THENCE SOUTH 66 DEGREES 44 MINUTES 49 SECONDS
23 WEST, A DISTANCE OF 750.69 FEET TO T.V.A.
MONUMENT 664-1 AND 662-4; THENCE SOUTH 66
24 DEGREES 25 MINUTES 50 SECONDS EAST, A DISTANCE
OF 1,248.01 FEET TO THE POINT OF BEGINNING. LEGAL
25 DESCRIPTION TAKEN FROM PRIOR DEED.
SUBJECT TO AND ALSO CONVEYED HEREWITH A
26 UTILITY AND INGRESS/EGRESS EASEMENT BEING
FIFTY FEET IN WIDTH AND ADJOINING THE EASTERN
27 LINE OF THE ABOVE DESCRIBED TRACT, AND
INCLUDING THE ENTIRETY OF THE BAKER LANE
28 RIGHT-OF-WAY AS IT EXTENDS FROM BLYTHE'S FERRY
ROAD AS DESCRIBED ABOVE AND EXTENDING 36 FEET
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EASTWARDLY FROM SAID RIGHT-OF-WAY


1 ADDITIONALLY, FOR A TOTAL DISTANCE OF 50 FEET,
AS SET FORTH IN WARRANTY DEED BOOK B5, PAGE
2 412, IN THE REGISTER'S OFFICE OF MEIGS COUNTY,
TENNESSEE (ROMCT).
3
4 Defendant Property #4
5 3601 Blythe Ferry Lane, Birchwood, Tennessee
6 Lot One (1), FINAL PLAT of Lots 1 & 2 Batton Subdivision, as
shown by plat of record in Plat Cabinet 334, Pages B-B in the
7 Registers Office of Meigs County, Tennessee.
8 4. Title to the Defendants is held as follows:
9 a. Defendant Property #1: Collins Family Farms, LLC
10 b. Defendant Property #2: CCT Investments, with a lien held by
11 Cleveland Investment Group
12 c. Defendant Property #3: Collins Family Farms, LLC
13 d. Defendant Property #4: Ashley B. Collins
14 5. As set forth below and in further detail in the Affidavit of Defense
15 Criminal Investigative Service Special Agent Gina Rouza, (Dkt #8, incorporated
16 herein by reference) the United States Investigation has determined that the
17 Defendant Properties were purchased, acquired and maintained with proceeds of a
18 health care fraud and are properties involved in the offense of money laundering
19 carried out by Jimmy Collins and Ashley Collins.
20 6. TRICARE is the healthcare program for active, retired, reserve, and
21 guard, uniformed service members and their families. DHA is a joint, integrated
22 agency that supports the delivery of health services to military health system
23 beneficiaries. DHA exercises management responsibility for TRICARE, and
24 receives, processes, and pays claims on behalf of TRICARE.
25 7. According to the TRICARE Policy Manual, in order for a doctor to
26 conduct telemedicine service, interactive audio and video telecommunications must
27 be used, permitting real-time communication between the TRICARE authorized
28 provider and the TRICARE beneficiary. The Policy Manual also requires that the

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1 beneficiary be located where an otherwise authorized TRICARE provider normally


2 offers professional medical or psychological services, such as the office of a
3 TRICARE authorized provider. A patients home is not an authorized originating
4 site for telemedicine service.
5 8. Compounding is generally understood as the process in which a licensed
6 pharmacist combines, mixes, or alters ingredients in response to a doctors
7 prescription to create unique medications tailored to meet the needs of a particular
8 patient. Through the compounding process, compounded medications benefit
9 patients who need, for example, specific dosage strengths, medicine administered by
10 a particular route (e.g. oral, topical), or ingredients excluded due to allergies or other
11 sensitivities. Compounding pharmacies are businesses that specialize in creating
12 compounded medications.
13 9. THE MEDICINEE SHOPPE #863 (hereinafter THE MEDICINE
14 SHOPPE) was a traditional pharmacy, a compounding pharmacy, and a medical
15 supply store located in Bountiful, Utah.
16 10. In or around December 2014, THE MEDICINE SHOPPE was
17 purchased by two individuals T.S. and W.W.
18 11. A motivating factor for the purchase of THE MEDICINE SHOPPE was
19 its license to ship medications to California.
20 12. CHOICE MD is a medical clinic located in Cleveland, Tennessee, that
21 is owned and operated by J. COLLINS and A. COLLINS.
22 13. J. COLLINS and A. COLLINS also control the related companies of
23 RMI HOLDING CORPORATION, Inc. and RXPRESS MEDICAL, Inc.
24 14. Between December 2014 and May 2015, CHOICE MD employed S.V.,
25 an emergency room physician licensed in Tennessee.
26 15. Between December 2014 and May 2015, CHOICE MD employed C.C.,
27 a nurse practitioner, who was authorized to write prescriptions under the supervision
28 of S.V.

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1 16. Between January 2015 and May 2015, CHOICE MD employed C.L., an
2 emergency room physician licensed in Georgia.
3 17. Between December 2014 and May 2015, CHOICE MD paid S.V., C.C.,
4 and C.L. to write 3,759 prescriptions for compounded medications for TRICARE
5 beneficiaries located mainly in the Southern District of California.
6 18. These compounded prescriptions were filled by THE MEDICINE
7 SHOPPE and shipped from Utah to California.
8 19. Nobody at CHOICE MD treated or examined the TRICARE
9 beneficiaries before prescribing them the compounded medications.
10 20. CHOICE MD did not bill TRICARE for medical examinations or other
11 services, as is customary when providing legitimate services to insured patients.
12 21. Instead, J. COLLINS and A. COLLINS profited via kickback payments
13 from THE MEDICINE SHOPPE. These payments were in exchange for J.
14 COLLINS and A. COLLINS recruiting TRICARE beneficiaries to receive
15 compounded medications from THE MEDICINE SHOPPE and employing doctors to
16 write prescriptions for these beneficiaries that could be filled by THE MEDICINE
17 SHOPPE.
18 22. THE MEDICINE SHOPPE submitted claims to TRICARE for filling
19 the compounded prescriptions written by doctors employed by CHOICE MD and
20 was paid a total of $62,589,666 based these claims.
21 23. Between September 2014 and May 2015, a total of approximately
22 $45,369,567.87 was transferred to J. COLLINS and A. COLLINS from bank
23 accounts associated with two companies controlled by the owners of THE
24 MEDICINE SHOPPE, CD Medical, Inc. and MEDWORX Compounding, LLC.
25 24. To find TRICARE beneficiaries to whom prescriptions could be written,
26 J. COLLINS, A. COLLINS, and others, paid a number of active duty marines
27 stationed in the Southern District of California to recruit their colleagues.
28 //

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1 25. In exchange, J. COLLINS and A. COLLINS paid a portion of the


2 reimbursements that they received from the prescriptions to the recruiters working on
3 their behalf as commissions.
4 26. The marines that served as recruiters often told those they signed up to
5 receive the compounded medications that they were doing so as part of a medical
6 study and that they would be paid for doing so. The recruiters paid between $100
7 and $300 per month to the TRICARE beneficiaries who received compounded
8 medications.
9 27. J. COLLINS and A. COLLINS paid recruiters working on their behalf
10 more than $4,4000,000 in commission payments between January 2015 and June
11 2015.
12 28. Defendant Property #1 was purchased by J. COLLINS and A.
13 COLLINS on June 15, 2015, and titled in the name of Collins Family Farms, LLC.
14 The total purchase price was $575,000 and there is no mortgage lien. The purchase
15 was made via wire transfers from an account held in the name of Collins Family
16 Farms, LLC. The source of the funds in this account was the kickback payments
17 made to J. COLLINS and A. COLLINS from CD Medical, Inc and RXPRESS
18 Medical, Inc.
19 29. Defendant Property #2 was purchased by J. COLLINS with $3,000,000
20 in funds from an account held in the name of Collins Family Farms, LLC. There is
21 no mortgage lien on the property. The source of the funds in this account was the
22 kickback payments made to J. COLLINS and A. COLLINS from CD Medical, Inc
23 and RXPRESS Medical, Inc. The deed of trust shows J. COLLINS as beneficiary
24 and lender of the property and the titled purchaser as CCT Investments.
25 30. Defendant Property #3 was purchased by J. COLLINS and A.
26 COLLINS on May 29, 2015 and titled in the name of Collins Family Farms, LLC.
27 The total purchase price was $1,274,418.85 and there is no mortgage lien. The
28 purchase was made with funds from a checking account held in the names of J.

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1 COLLINS and A. COLLINS. The source of funds in this account was the kickback
2 payments made to J. COLLINS and A. COLLINS from CD Medical, Inc and
3 RXPRESS Medical, Inc.
4 31. Defendant Property #4 was purchased by J. COLLINS and A.
5 COLLINS on February 17, 2015, and deeded in the name of A. COLLINS. The total
6 purchase price was $843,149.69 and there is no mortgage lien. The purchase was
7 with funds from a checking account for which J. COLLINS and A. COLLINS were
8 the authorized signatories. The source of funds in this account was the kickback
9 payments made to J. COLLINS and A. COLLINS from CD Medical, Inc. and
10 RXPRESS Medical, Inc.
11 32. By virtue of the acts set forth in the attached Affidavit, the Defendant
12 Properties are subject to forfeiture pursuant to Title 18, United States Code, Section
13 981(a)(1)(A) and/or 981(a)(1)(C).
14 33. The United States does not request authority from the Court to seize the
15 Defendant Properties at this time. The United States has, as provided by Title 18,
16 United States Code, Section 985(b)(1) and (c)(1):
17 a. Post notice of the Complaint on the Defendant Properties; and
18 b. Served notice of this action on the Defendant Property owners
19 along with a copy of the Complaint; and
20 c. Filed lis pendens notices in county records of the Defendant
21 Properties status as defendants in this in rem forfeiture action.
22 34. The United States will at an appropriate time execute a writ of entry for
23 the purpose of conducting an inspection and inventory of the property; and, as
24 provided by Title 18, United States Code, Section 985(b)(1) and (c)(1).
25 //
26 //
27 //
28 //

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1 WHEREFORE, the United States prays that due process issue to enforce the
2 forfeiture of the Defendant Properties and that due notice be given to all interested
3 parties to appear and show cause why said forfeiture of the defendant real properties
4 should not be decreed, that the defendant real properties be condemned and forfeited
5 to the United States to be disposed of according to law, and for such other and further
6 relief as this Honorable Court may deem just and proper.
7 DATED: August 17, 2017
8 Respectfully submitted,
9 ALANA W. ROBINSON
Acting U.S. Attorney
10
s/ Benjamin J. Katz
11 BENJAMIN J. KATZ
MARC PLETCHER
12 Assistant U.S. Attorneys
Attorneys for the United States
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