Free Motion for Default Judgment - District Court of Connecticut - Connecticut

Case 3:03-cv-01031-SRU

Document 32

Filed 07/27/2005

Page 1 of 3

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA, : : Plaintiff, : : v. : : ONE PARCEL OF PROPERTY : LOCATED AT 38 JEFFERSON AVENUE, : NEW LONDON, CONNECTICUT, : WITH ALL APPURTENANCES AND : IMPROVEMENTS THEREON, AND : : Defendant. : : [CLAIMANTS: MARIA M. FERNANDES, : ROBERT A. VENTURINI, JR., AND : PEOPLE'S BANK.] :

Civil No. 3:03CV1031 (SRU)

July 25, 2005

MOTION FOR DEFAULT JUDGMENT AGAINST ROBERT A. VENTURINI, JR. The United States of America, hereby moves for Default Judgment, and represents as follows: On June 11, 2005, a Verified Complaint of Forfeiture was filed for the forfeiture of the Defendant, one parcel of property located at 38 Jefferson Avenue, New London, Connecticut, with all appurtenances and attachments thereon ("Defendant Property"). The Complaint alleges that the Defendant Property was used or intended to be used in any manner or part to commit or to facilitate the commission of a violation of the Controlled Substances Act, 21 U.S.C. §§ 801 et seq., and is therefore subject to forfeiture to the United States pursuant to 21 U.S.C. § 881(a)(7). On June 18, June 25, and July 2, 2003, notice of this action was published in the Hartford Courant newspaper.

Case 3:03-cv-01031-SRU

Document 32

Filed 07/27/2005

Page 2 of 3

On June 25, 2003, Robert A. Venturini, Jr. was personally served by the United States Marshals Service with the Verified Complaint of Forfeiture , Lis Pendens, Notice of Complaint of Forfeiture against Real Property, Motin for Writ of Entry, Memorandum in Support of Motion for Writ of Entry, and proposed Writ of Entry. No claim, answer or other defense having been filed by Robert A. Venturini, Jr. in this case as required by Rule C(6) of the Supplemental Rules for Certain Admiralty and Maritime Claims, the United States moved to default Robert A. Venturini, Jr., and all other persons and entities, except Maria M. Fernandes and People's Bank, for failure to defend. On July 6, 2005, the Court granted the United States of America's request and defaulted Robert A. Venturini, Jr. The United States now moves for entry of a default judgment in accordance with the Court's default of Robert A. Venturini, Jr. A proposed Default Judgment is submitted herewith. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY

JULIE G. TURBERT ASSISTANT U.S. ATTORNEY P.O. BOX 1824 NEW HAVEN, CT 06508 (203) 821-3700 FEDERAL BAR # ct23398

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Case 3:03-cv-01031-SRU

Document 32

Filed 07/27/2005

Page 3 of 3

CERTIFICATE OF SERVICE This is to certify that a copy of the within and foregoing Motion for Default Judgment Against Robert A. Venturini, Jr., has been mailed, postage prepaid, this 25th day of July, 2005 to: Anthony Basilica, Esq. 37 Granite Street New London, CT 06320 John J. Nazzaro, Esq. 164 Hemstead Street New London, CT 06320 Robert A. Venturini, Jr. Osborne Correctional Institution Inmate No. 250620 100 Bilton Road Somers , CT 06071 People's Bank 850 Main Street, 11th Floor Bridgeport, CT 06604 Attn: Legal Department Bank of America 475 CrossPoint Parkway PO Box 9000 Getzville, NY 14069-9000 JULIE G. TURBERT ASSISTANT U.S. ATTORNEY