Free Motion for Default Entry 55(a) - District Court of Connecticut - Connecticut

Case 3:01-cv-02090-PCD

Document 30

Filed 04/26/2004

Page 1 of 1

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA, : : v. : : (1) ONE 37.5 FOOT BAJA SPORT : CRUISER MOTORBOAT, ID NO. : AGCB5523J889, NAMED "MADE YA : LOOK," WITH ALL APPURTENANCES : AND ATTACHMENTS THEREON, : ET AL : : [CLAIMANTS: DEBBIE C. KERPEN, : A/K/A DEBORAH KERPEN, : KAY F. ANDREWS, WILLIAM : NATION, ROBERT C. KERPEN, JR., : CHRISTOPHER AND/OR LISA : PFEFFER, AND FORD MOTOR : CREDIT COMPANY] :

Civil No. 3:01CV02090 (PCD)

April 26, 2004

MOTION FOR DEFAULT JUDGMENT AGAINST KAY ANDREWS The United States of America, hereby moves for Default Judgment, and represents as follows: On November 8, 2001, a Verified Complaint of Forfeiture was filed for the forfeiture of twenty defendant assets, consisting of a motorboat, a Ford Expedition, a horse trailer, a John Deere tractor, and sixteen items of currency ("Defendants 1 - 20"). The Complaint alleges that the Defendants 1 - 20 were involved in transactions or attempted transaction in violation of 18 U.S.C. § 1956 , or represent property which constitutes or is derived from proceeds traceable to violation of 18 U.S.C. § 1952, or constitute property derived from proceeds traceable to an offense constituting "specified unlawful activity" (as defined in 18 U.S.C. § 1956(c)(7)), namely racketeering in violation of 18 U.S.C. § 1952, or conspiracy to commit such offense, and are therefore subject to forfeiture to the United States pursuant to 18 U.S.C. § 981(a)(1)(C).