Free Motion for Return of Property - District Court of Connecticut - Connecticut

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,Case 3:00-cr-00249-JCH Document 191 Filed 02/08/2005 Page 1 of 3
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UNITED STATES DIS'&&'§..,C _
l
DISTRICT OF C "llI§U§; I2: 2 L, l
UNITED STATES OF AMERICA’l_:5_ 3:00 CR 249(JCH)
i2JllJ!EE§°E1RT.
V. : `
JEFFREY NAT}-IENSON : FEBRUARY 4, 2005 1
MOTION FOR RETURN OF PROPERTY
1
l
The undersigned respectfully moves the property of Jeffrey Nathenson be
returned. I
Respectfully Submitted,
THE DEFENDANT, J EFF N
BY:
FREDERICK DPAOLETTI, ESQ.
Paoletti & Gusmano
Fed. Bar No.: CT 09223 p
3301 Main Street l
(203) 371-1000 Fax (203) 373-9888
Bridgeport, CT 06604
This is to certify that a copy of the foregoing was mailed, postage prepaid on this
date to all counsel and pro se parties of record as follows:
AUSA Michael Sklaire
Office of the U.S. Attorney l
141 Church Street, 23"‘ Floor y
New Haven, Connecticut 06510
Joseph Zampano
United States Probation Office
915 Lafayette Blvd. i
Bridgeport, CT 06604 i 5 f / e·:ii` ?
Frederick D. Paoletti Jr.





- pm <-.£ »é1Se.3:0.0:cr—OO249=JCH -- Document 191 Filed O2/08/2005 ‘ Page 2 of 3 {
I l UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
OFFICE OF THE CLERK
_. UNITED STATES COURTHOUSE ;
_` 9l5 LAFAYETTE BOULEVARD
. BRIDGEPORT, CT 06604 `
I KEVIN F. ROWE TEL.NO.579·586l | VICTORIA C.MINOR ·
CLERK (AREA CODE 203) CHIEFDEFUTY CI,F.RK
_ _ CHRYSTINECODY
i _ l February 2, 2005
Frederick D. Paoletti, Jr.
Paoletti & Gusmano
3301 Main St. _
‘ Bridgeport, CT 06606 I {
Re: 3:00cr249(.T CH)
USA v Nathanson
Dear Counselor:
Inasmuch as the above—entitled case has been disposed of in this court, I am requesting that you g
file a rnotion for return of property by 02/14/2005 forthefollowing items: j
Mortgage Papers for
33 Rolling Wood Drive L
rmmbuii, cr j
Any objection to the return of this property shall be filed by 02/22/2005 .
n If no motion or objection has been filed by 02/28/2005 , the property will be disposed of
accordingly. R
I
. Kevin F. Rowe, Clerk -
By u · 2
Dep ty Clerk
. , l
cc; AUSA I

E
~ Case 3:00-cr-00249- 1 ` e 02/08/2005 Pa e 3 of 3 _
· Ul91I:l|`ED[SQlS;1gJltES.1tI)ISlfRIé:”lJ cdouar 9 t
DISTRICT OF CONNECTICUT .
To: William F. Dow, III UNITED STATES OF AMERICA
Jacobs, Grudberg, Belt & Dow, P.C. i ` .
350 Orange Street v.[· jg--; F i [I: is gy; ji jj; i
P.O. Box 606 I I I __
New Haven, CT 06503-0606 ONE 2000 FORD; EXPEDITION 1 _
VIN IFMPUI 8L9`YI.tA48898 ` l
Civil N0. 3:05CV00l2l(.ICH) . g
WAIVER OF SER VICE OF PROCESS
I acknowledge receipt of your request that I waive service of a Verified Complaint of F orfeiture in the _
above—captioned case in the United States District Court for the District of Connecticut. I have also received a l
copy of the Warrant of Arrest in Rem, two copies of this waiver of service of process form, and a return Q
envelope, postage prepaid. W
I
I agree to save the cost of service of process of the above-described documents in this lawsuit by not I
requiring that I (or the entity on whose behalf I am acting) be served with judicial process in the manner
provided by Rule 4 of the Federal Rules of Civil Procedure.
I (or the entity on whose behalf I am acting) will retain all defenses or objections to the lawsuit or to the
jurisdiction or venue of the court except for objections based on a defect in the process or in the service of the 2
pl`OC€SS. n
I understand that a judgment may be entered against me (or the party on whose behalf I am acting) if a t
claim is not served upon you within thirty (30) days from Januar 26 2005, and answer within twenty (20) I
days of the filing of the claim.
I declare under penalty of perjury that if I am being served ' my individual capacity, I am not in
the milita service of the United States and I co person of suitable age to receive legal
papers. K •
Date ignature
William F. Dow III I
Printed/Typed Name
Attorney for Claimant Mark Motors
Relationship to Entity/Authority to Receive Service of Process
Duty to Avoid Unnecessary Costs of Service of Summons
Rule 4 ofthe Federal Rules of Civil Procedure requires certain parties to cooperate in saving unnecessary costs of service ofthe summons and complaint. A
defendant who, after being notified of an action and asked to waive service of a summons, fails to do so will be required to bear the cost of such service unless good cause
be shown for its failure to sign and return the waiver.
It is not good cause for a failure to waive service that a party believes that the complaint is unfounded, or that the action has been brought in an improper place or
in a court that lacks jurisdiction over the subject matter ofthe action or over its person or property. A party who waives service ofthe summons retains all defenses and I
objections (except any relating to the summons or to the service of the summons), and may later olnect to the jurisdiction ofthe court or to the place where the action has
been brought. _
A defendant who waives service must within the time spechiled on the wai ver form serve on the plaintiffs attorney ( or unrepresentedplaintw a response to the _
complaint and m ust also file a signed copy ofthe response with the court. if the answer or motion is not served within this time, a default judgment may be taken against . I
the defendant. By waiving service, a defendant is allowed more time to answer than K the summons has been actualhi served when the request for waiver of service was a
received.
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