Free Claim - District Court of California - California

Case 3:08-cv-03093-WHA

Document 22

Filed 08/18/2008

Page 1 of 2

1 2 3 4 5 6 7 8 9

STEPHEN F. JOHNSON, SBN 205244 MANNON, KING AND JOHNSON 200 North School Street, Suite 304 Post Office Box 419 Ukiah, California 95482 Telephone: (707) 468-9151 Facsimile: (707) 468-0284 Attorneys for Claimant Barnum Timber Company

UNITED STATES BANKRUPTCY COURT NORTHERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

10 Plaintiff, 11 v. 12 13 14 15 Defendants. 16 17 REAL PROPERTY AND IMPROVEMENTS IDENTIFIED BY MENDOCINO COUNTY APN 051180-08, APN 051-180-09 and APN 051-180-10, et al.

Case No. CV 08-3080 EMC VERIFIED STATEMENT OF INTEREST IN REAL PROPERTY

Pursuant to 18 U.S.C. §983(a)(4)(A) and pursuant to Rule C of the Supplemental Rules 18 for Certain Admiralty and Maritime Claims, Barnum Timber Company, a California Limited 19 20 21 22 23 24 25 26 27 28
Verified Statement of Interest in Real Property

Partnership, in response to Amended Complaint for forfeiture filed on July 29, 2008, herein asserts its right to defend against the above-referenced action. Claimant Barnum Timber Company has a legal interest in the defendant "Real Property" identified as Mendocino County parcel numbers APN 051-290-04, APN 051-300-02, APN 051-310-01 and APN 051-320-01 as it is the beneficiary of a deed of trust recorded against the Real Property. Dated: August 18, 2008 /s/ Stephen F. Johnson Stephen F. Johnson, Esq. Attorney for Claimant Barnum Timber Company

1

Case 3:08-cv-03093-WHA

Document 22

Filed 08/18/2008

Page 2 of 2

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Verified Statement of Interest in Real Property

VERIFICATION UNITED STATES V. REAL PROPERTY MENDOCINO COUNTY APN 051-108-09, et al. Case No. CV 08-3093 WHA I, C. Robert Barnum declare as follows: I am the General Partner of Barnum Timber Company, a California Limited Partnership. I have read the foregoing Verified Statement of Interest of Real Property and know the contents thereof. The contents of said Statement are true of my own knowledge, except as to those matters which are stated therein upon my information and belief, and as to those matters, I believe them to be true. I declare under penalty of perjury that the foregoing is true and correct and that this Verification was executed this 18th day of August, 2008 at Eureka, California.

/s/ C. Robert Barnum C. Robert Barnum, General Partner Barnum Timber Company, A California Limited Partnership

2

Case 3:08-cv-03093-WHA

Document 22-2

Filed 08/18/2008

Page 1 of 1

1 2

PROOF OF SERVICE
I am a citizen of the United States of America and am employed in the County of Mendocino,

3 State of California, where this service occurs. I am over the age of eighteen years and not 4 a party to the within action. My business address is Law Office of Mannon, King and 5 Johnson, Post Office Box 419, Ukiah, California 95482. 6 On August 18, 2008 I served the attached foregoing document, namely, 7 · 8 AMENDED COMPLAINT 9 · 10 on the individual(s) listed below: 11 12 X 13 placing them in the U.S. mail at Ukiah, California. 14 (BY FAX) by transmitting the document(s) listed above via facsimile from 15 (707)468-0284 16 17 18 19 20 21 22 I declare under penalty of perjury under the laws of the State of California, that the foregoing 23 is true and correct. Executed on August 18, 2008, in Ukiah, California. 24 25 26 27 28 _/s/ Gretchen Anderson Gretchen Anderson Legal Assistant Courtesy copy via Fed Ex: Honorable William H. Alsup United States District Court 450 Golden Gate Ave.., 16th Fl., Rm 1111 San Francisco, CA 94102 AUSA Susan B. Gray United States Attorney's Office Northern District of California 450 Golden Gate Avenue, 10th Fl, Box 36055 San Francisco, CA 954102 (BY MAIL) I mailed the document(s) listed above, with prepaid postage thereon, by VERIFIED STATEMENT OF INTEREST IN REAL PROPERTY CLAIMANT BARNUM TIMBER COMPANY'S ANSWER TO PLAINTIFF'S