Case 3:00-cv-02009-EBB
Document 95
Filed 08/16/2007
Page 1 of 3
UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA, Plaintiff, v. $662,310.79 IN UNITED STATES CURRENCY SEIZED FROM ACCOUNT NUMBER 100080907, HELD IN THE NAME OF FRANKLIN CREDIT SERVICES, INC., AT FIRST TENNESSEE BANK, FRANKLIN, TENNESSEE, $146,000.00 and $3,315.57 IN UNITED STATES CURRENCY SEIZED FROM ACCOUNT NUMBER 100057691, HELD IN THE NAME OF FRANKLIN CREDIT SERVICES, INC., AT FIRST TENNESSEE BANK, FRANKLIN, TENNESSEE, $185,000.00 IN UNITED STATES CURRENCY SEIZED FROM ACCOUNT NUMBER 100057691, HELD IN THE NAME OF FRANKLIN CREDIT SERVICES, INC., AT FIRST TENNESSEE BANK, FRANKLIN, TENNESSEE, $149,000.00 IN UNITED STATES CURRENCY SEIZED FROM ACCOUNT NUMBER 100057691, HELD IN THE NAME OF FRANKLIN CREDIT SERVICES, INC., AT FIRST TENNESSEE BANK, FRANKLIN, TENNESSEE, Defendants. : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : : :
Civil No. 3:00CV2009 (EBB)
August 16, 2007
AMENDED MOTION FOR DECREE OF FORFEITURE
The Plaintiff, United States of America, respectfully moves to amend its motion for entry of a Decree of Forfeiture which was filed on August 8, 2007, pursuant to Rule 55 of the Federal
Case 3:00-cv-02009-EBB
Document 95
Filed 08/16/2007
Page 2 of 3
Rules of Civil Procedure, and Rule G(5) of the Supplemental Rules for Admiralty or Maritime and Asset Forfeiture Claims. The purpose of this amended motion is to include in the Decree of Forfeiture the in rem defendant described as $149,000.00 in United States currency seized from account number 100057691, held in the name of Franklin Credit Services, Inc., at First Tennessee Bank, Franklin, Tennessee. This in rem defendant, which was added to this case by Second Amended Verified Complaint of Forfeiture, dated May 12, 2004 and filed on July 14, 2007, was inadvertently omitted from the proposed Decree of Forfeiture filed on August 8, 2007. The Plaintiff, United States of America, respectfully requests that the revised Decree of Forfeiture filed herewith, which includes reference to the $149,000.00, be substituted for the Decree previously filed on August 8, 2007. An amended supporting memorandum is also filed herewith. Respectfully submitted, KEVIN J. O'CONNOR UNITED STATES ATTORNEY
JULIE G. TURBERT ASSISTANT U.S. ATTORNEY ATTORNEY BAR # ct23398 157 CHURCH STREET NEW HAVEN, CT 06510 TELEPHONE: (203) 821-3700 FAX: (203) 773-5373 EMAIL: [email protected]
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Case 3:00-cv-02009-EBB
Document 95
Filed 08/16/2007
Page 3 of 3
CERTIFICATE OF SERVICE This is to certify that a copy of the within and foregoing Amended Motion for Decree of Forfeiture has been sent via electronic mail on this 16th day of August, 2007, to:
Susan B. Loving, Esq. Lester, Loving & Davies 1701 South Kelly Edmond, Oklahoma 73013-3018 email: [email protected] Douglas J. Schmidt, Esq. Terrance Summers, Esq. Blackwell Sanders Peper Martin 4801 Main Street, Suite 1000 Kansas City, Missouri 64112 email: [email protected] email: [email protected] Andrew B. Campbell, Esq. Wyatt, Tarrant & Combs 2525 West End Avenue, Suite 1500 Nashville, Tennessee 37203 email: [email protected] and by first class mail to: Steve A. Uhrynowycz, Esq. 1200 West Third Street, Room 340 Little Rock, Arkansas 72201-1904
Douglas S. Skalka, Esq. Neubert, Pepe & Monteith 195 Church Street, 13th Floor New Haven, Connecticut 06510 email: [email protected] Charles G. Copeland, Esq. Janet G. Arnold, Esq. Copeland, Cook, Taylor & Bush 1062 Highland Colony Parkway P.O. Box 6020 Ridgeland, Mississippi 39157 email: [email protected] email: [email protected]
JULIE G. TURBERT ASSISTANT U.S. ATTORNEY
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