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

Case 3:02-cv-00981-EBB

Document 15-2

Filed 12/08/2005

Page 1 of 7

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA, : : Plaintiff, : : v. : : (1) CONTENTS OF ACCOUNT NUMBER : 204498895, HELD IN THE NAMES OF : NANCY AND RAANAN LIEBERMANN, : AT THE JANUS SERVICE : CORPORATION, DENVER, : COLORADO, : : (2) CONTENTS OF ACCOUNT NUMBER : 020-001331766, HELD IN THE NAMES : OF NECHAMA NANCY AND RAANAN : LIEBERMANN, AT AMERICAN : CENTURY, KANSAS CITY, MISSOURI, : : (3) CONTENTS OF ACCOUNT NUMBER : 022-001892231, HELD IN THE NAMES : OF NECHAMA NANCY AND RAANAN : LIEBERMANN, AT AMERICAN : CENTURY, KANSAS CITY, MISSOURI, : : (4) CONTENTS OF ACCOUNT NUMBER : 041-000276075, HELD IN THE NAMES : OF NECHAMA NANCY AND RAANAN : LIEBERMANN, AT AMERICAN : CENTURY, KANSAS CITY, MISSOURI, : : (5) CONTENTS OF ACCOUNT NUMBER : 043-000006932, HELD IN THE NAMES : OF NECHAMA NANCY AND RAANAN : LIEBERMANN, AT AMERICAN : CENTURY, KANSAS CITY, MISSOURI, :

Civil No. 3:02CV981 (EBB)

Case 3:02-cv-00981-EBB

Document 15-2

Filed 12/08/2005

Page 2 of 7

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT (6) CONTENTS OF ACCOUNT NUMBER : 104-000024779, HELD IN THE NAMES : OF NECHAMA NANCY AND RAANAN : LIEBERMANN, AT AMERICAN : CENTURY, KANSAS CITY, MISSOURI, : : (7) CONTENTS OF ACCOUNT NUMBER : 921-009657981, HELD IN THE NAMES : OF NECHAMA NANCY AND RAANAN : LIEBERMANN, AT AMERICAN : CENTURY, KANSAS CITY, MISSOURI, : : (8) CONTENTS OF ACCOUNT : NUMBER 941-009004834, HELD IN THE : NAMES OF NECHAMA NANCY AND : RAANAN LIEBERMANN, AT : AMERICAN CENTURY, KANSAS : CITY, MISSOURI, : : (9) CONTENTS OF ACCOUNT : NUMBER 020-001337060, HELD IN : THE NAME OF REVENUE CONTROLS : CORPORATION, AT AMERICAN : CENTURY, KANSAS CITY, MISSOURI, : : (10) CONTENTS OF ACCOUNT : NUMBER 022-001925092, HELD IN : THE NAME OF REVENUE CONTROLS : CORPORATION, AT AMERICAN : CENTURY, KANSAS CITY, MISSOURI, : : (11) CONTENTS OF ACCOUNT : NUMBER 030-000254518, HELD IN : THE NAME OF REVENUE CONTROLS : CORPORATION, AT AMERICAN : CENTURY, KANSAS CITY, MISSOURI, :

2

Case 3:02-cv-00981-EBB

Document 15-2

Filed 12/08/2005

Page 3 of 7

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT (12) CONTENTS OF ACCOUNT NUMBER 039-000158352, HELD IN THE NAME OF REVENUE CONTROLS CORPORATION, AT AMERICAN CENTURY, KANSAS CITY, MISSOURI, (13) CONTENTS OF ACCOUNT NUMBER 041-000281552, HELD IN THE NAME OF REVENUE CONTROLS CORPORATION, AT AMERICAN CENTURY, KANSAS CITY, MISSOURI, (14) CONTENTS OF ACCOUNT NUMBER 043-000008597, HELD IN THE NAME OF REVENUE CONTROLS CORPORATION, AT AMERICAN CENTURY, KANSAS CITY, MISSOURI, (15) CONTENTS OF ACCOUNT NUMBER 921-009669764, HELD IN THE NAME OF REVENUE CONTROLS CORPORATION, AT AMERICAN CENTURY, KANSAS CITY, MISSOURI, (16) CONTENTS OF ACCOUNT NUMBER 633-115613, HELD IN THE NAME OF RAANAN LIEBERMANN, AT CREDIT SUISSE FIRST BOSTON DIRECT, LLC, JERSEY CITY, NEW JERSEY, (17) CONTENTS OF ACCOUNT NUMBER 119114692, HELD IN THE NAME OF NANCY AND RAANAN LIEBERMANN, AT T. ROWE PRICE SERVICES, INC., BALTIMORE, MARYLAND, : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : :

3

Case 3:02-cv-00981-EBB

Document 15-2

Filed 12/08/2005

Page 4 of 7

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT (18) CONTENTS OF ACCOUNT NUMBER 0491594314, HELD IN THE NAME OF NANCY AND RAANAN LIEBERMAN, AT PUTNAM INVESTMENTS, BOSTON, MASSACHUSETTS, : : : : : : : AND : : (19) $20,000.00 IN UNITED STATES : CURRENCY, IN ACCOUNT NUMBER, : 5ML-164891, HELD IN THE NAMES OF : NANCY AND RAANAN LIEBERMANN : AT METLIFE SECURITIES, INC., : NEW YORK, NEW YORK, : : [CLAIMANTS: RAANAN LIEBERMANN : NECHAMA NANCY LIEBERMANN, : AND REVENUE CONTROLS : CORPORATION] :

PARTIAL DECREE OF FORFEITURE On June 10, 2002, a Verified Complaint of Forfeiture against the Defendant Accounts Numbered 1 through 19 ("Defendant Accounts") was filed on behalf of the Plaintiff, United States of America. The Complaint was brought to enforce the provision of Title 18, United States Code, Section 981(a)(1)(A) for the forfeiture of property involved in a financial transaction in violation of Title 18, United States Code, Sections 1956 and 1957, and to enforce the provision of Title 18, United States Code, Section 981(a)(1)(C) for the forfeiture of property which constitutes or is derived from proceeds traceable to an offense constituting "specified

4

Case 3:02-cv-00981-EBB

Document 15-2

Filed 12/08/2005

Page 5 of 7

unlawful activity" (as defined in 18 U.S.C. § 1956(c)(7)), namely wire fraud in violation of 18 U.S.C. § 1343, or conspiracy to commit such offense. It appearing that process was fully issued in this action according to law: That pursuant to Warrants of Arrest In Rem issues by this Court on June 10, 2002, the Internal Revenue Service seized the Defendant Accounts on June 20, 2002; and That on August 21, 28, and September 4, 2002, notice of this action was published in the Connecticut Post; and That on March 14, 2005, the United States and Claimants Raanan Liebermann and Revenue Controls Corporation entered into a Stipulated Forfeiture Agreement ("Stipulation") as to Defendant Accounts (9 - 16) in which Claimants agreed to the forfeiture of Defendant Accounts (9 - 16) to the United States of Ameica, to be disposed of according to law; and That on March 22, 2005, the Stipulation was filed with the Court; and That on March 24, 2005, the Court endorsed the Stipulation; Now, therefore, on motion of the Plaintiff, United States of America, for as Partial Decree of Forfeiture, it is hereby ORDERED, ADJUDGED AND DECREED that the default as to all persons having any right, title or interest in the Defendant Assets under seizure in this action be and hereby is entered herein, and it is further ORDERED, ADJUDGED AND DECREED that Defendant Accounts 9; Contents of Account Number 020-001337060, Held in the Name of Revenue Controls Corporation, at American Century, Kansas City, Missouri, 10; Contents of Account Number 022-001925092, Held in the Name of Revenue Controls Corporation, at American Century, Kansas City, 5

Case 3:02-cv-00981-EBB

Document 15-2

Filed 12/08/2005

Page 6 of 7

Missouri, 11; Contents of Account Number 030-000254518, Held in the Name of Revenue Controls Corporation, at American Century, Kansas City, Missouri, 12; Contents of Account Number 039-000158352, Held in the Name of Revenue Controls Corporation, at American Century, Kansas City, Missouri, 13; Contents of Account Number 041-000281552, Held in the Name of Revenue Controls Corporation, at American Century, Kansas City, Missouri, 14; Contents of Account Number 043-00008597, Held in the Name of Revenue Controls Corporation, at American Century, Kansas City, Missouri, 15; Contents of Account Number 921009669764, Held in the Name of Revenue Controls Corporation, at American Century, Kansas City, Missouri, and 16; Contents of Account Number 633-115613, Held in the Name of Raanan Liebermann, at Credit Suisse First Boston Direct, LLC, Jersey City, New Jersey, be forfeited to the United States of America and disposed of according to law. Dated at New Haven, Connecticut this ______ day of ______________________, 2005.

_________________________________ HONORABLE ELLEN BREE BURNS UNITED STATES DISTRICT JUDGE

6

Case 3:02-cv-00981-EBB

Document 15-2

Filed 12/08/2005

Page 7 of 7

CERTIFICATE OF SERVICE This is to certify that the within and foregoing Proposed Partial Decree of Forfeiture, has been mailed, postage pre-paid, this 8th day of December, 2005 to: E. Gates Garrity-Rokous, Esq. Wiggin & Dana 265 Church Street, P.O. Box 1832 New Haven, CT 06508 Kurt F. Zimmermann Silverstein & Osach 234 Church Street, Suite 902 P.O. Box 1727 New Haven, CT 06510 ________________________________ DAVID X. SULLIVAN

7