Free Answer to Complaint - District Court of Connecticut - Connecticut

Case 3:03-cv-01031-SRU

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA Plaintiff VS. : : Civil No.3:03CV1031(SRU)

ONE PARCEL OF PROPERTY : LOCATED AT 38 JEFFERSON AVENUE NEW LONDON, CONNECTICUT, WITH ALL APPURTENANCES AND IMPROVEMENTS THEREON, AND Defendant [CLAIMANTS: MARIA M. FERNANDES, BANK OF AMERICA, AND ROBERT A. VENTURINI, JR.]

July 1, 2005

AMENDED ANSWER TO VERIFIED COMPLAINT OF FORFEITURE The claimant, Maria Fernandes, hereby files this Answer to the Verified Complaint of Forfeiture filed against One Parcel of Property located at 38 Jefferson Avenue, New London, Connecticut, with all appurtenances and improvements thereon, and (Claimants: Maria M. Fernandes, Bank of America, and Robert A. Venturini, Jr.). 1. As to the allegation contained in paragraph one,

it is denied. 2. As to the allegation contained in paragraph two,

it is admitted. 3. As to the allegation contained in paragraph three,

it is admitted.

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4.

As to the allegation contained in paragraph four,

it is admitted. 5. As to the allegation contained in paragraph five,

it is denied. 6. As to the allegations contained in paragraph six,

the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 7. As to the allegations contained in paragraph

seven, it is admitted. 8. As to the allegations contained in paragraph Maria M. Fernandes, has insufficient

eight, the Claimant,

knowledge upon which to form a belief and therefore leaves the Government to its proof. 9. As to the allegations contained in paragraph nine,

it is admitted. 10. As to the allegations contained in paragraph ten,

the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 11. As to the allegations contained in paragraph

eleven, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof.

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12.

As to the allegations contained in paragraph

twelve, the Claimant, Maria M. Fernandes, it is denied. 13. As to the allegations contained in paragraph

thirteen, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 14. As to the allegations contained in paragraph

fourteen, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 15. As to the allegations contained in paragraph

fifteen, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 16. As to the allegations contained in paragraph

sixteen, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 17. As to the allegations contained in paragraph

seventeen, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 18. As to the allegations contained in paragraph

eighteen, the Claimant, Maria M. Fernandes, has insufficient

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knowledge upon which to form a belief and therefore leaves the Government to its proof. 19. As to the allegations contained in paragraph

nineteen, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 20. The Claimant, Maria M. Fernandes, admits that he

has a criminal record consisting of convictions on various dates. 21. As to the allegations contained in paragraph

twenty-one, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 22. As to the allegations contained in paragraph

twenty-two, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 23. As to the allegations contained in paragraph

twenty-three, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 24. As to the allegations contained in paragraph

twenty-four, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and

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therefore leaves the Government to its proof. 25. As to the allegations contained in paragraph

twenty-five, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 26. As to the allegations contained in paragraph

twenty-six, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 27. As to the allegations contained in paragraph

twenty-seven, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 28. As to the allegations contained in paragraph

twenty-eight, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 29. As to the allegations contained in paragraph

twenty-nine, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 30. As to the allegations contained in paragraph

thirty, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves

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the Government to its proof. 31. As to the allegations contained in paragraph

thirty-one, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 32. As to the allegations contained in paragraph

thirty-two, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 33. As to the allegations contained in paragraph

thirty-three, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 34. As to the allegations contained in paragraph

thirty-four, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 35. As to the allegations contained in paragraph

thirty-five, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 36. As to the allegation contained in paragraph

thirty-six, it is denied. 37. As to the allegations contained in paragraph

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thirty-seven, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 38. As to the allegations contained in paragraph

thirty-eight, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 39. As to the allegations contained in paragraph

thirty-nine, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 40. As to the allegations contained in paragraph

forty, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 41. As to the allegations contained in paragraph

forty-one, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 42. As to the allegations contained in paragraph

forty-two, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 43. As to the allegations contained in paragraph

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forty-three, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 44. As to the allegation contained in paragraph forty-

four, it is admitted. 45. As to the allegations contained in paragraph

forty-five, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 46. As to the allegations contained in paragraph

forty-six, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 47. As to the allegations contained in paragraph

forty-seven, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 48. As to the allegations contained in paragraph

forty-eight, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 49. As to the allegations contained in paragraph

forty-nine, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and

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therefore leaves the Government to its proof. 50. As to the allegations contained in paragraph

fifty, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 51. As to the allegations contained in paragraph

fifty-one, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 52. As to the allegations contained in paragraph

fifty-two, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 53. As to the allegations contained in paragraph

fifty-three, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 54. As to the allegations contained in paragraph

fifty-four, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 55. As to the allegations contained in paragraph

fifty-five, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and

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therefore leaves the Government to its proof. 56. As to the allegation contained in paragraph fifty-

six, it is admitted. 57. As to the allegations contained in paragraph

fifty-seven, the Claimant, Maria M. Fernandes, has insufficient knowledge upon which to form a belief and therefore leaves the Government to its proof. 58. As to the allegation contained in paragraph fifty-

eight, it is denied. Wherefore, the Claimant, Maria M. Fernandes, requests judgment enter in favor of the Claimant, Maria M. Fernandes, and the court enter an order of return of the property located at 38 Jefferson Avenue, New London, Connecticut, to the Claimant. Respectfully submitted,

By________________________ John J. Nazzaro Fed. Bar No. 05579 164 Hempstead Street New London CT 06320 (860) 440-2755 (860) 440-2757 facsimile

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CERTIFICATION OF SERVICE I certify that I mailed a copy of the within Answer to the following on July 2005: Office of the U.S. Attorney Julie Turbert, AUSA P. O. Box 1824 New Haven CT 06508 Bank of America 100 North Tryon Street Charlotte NC 28255 Robert A. Venturini, Jr. MacDougall-Walker Correctional Institution 1153 East Street South Suffield CT 06080

By________________________ John J. Nazzaro Fed. Bar No. 05579 164 Hempstead Street New London CT 06320 (860) 440-2755 (860) 440-2757 facsimile