Free Response to Motion - District Court of Delaware - Delaware

Case 1:08-cr-00015-GIVIS Document 12 Filed O4/29/2008 Page 1 of 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
v. ) Criminal Action N0. 08-15 GMS
)
JEMAIN Z. DAVIS, )
)
Defendant. )
RESPONSE OF JEMAIN Z. DAVIS TO PLAINTIFF’S MOTION FOR A
PRELIMINARY ORDER OF FORFEITURE
In response to plaintiffs motion for a preliminary order of forfeiture, defendant J emain
Z. Davis states as follows:
1. The Court has accepted a Memorandum of Plea Agreement as described by
plaintiff. U A
2. Defendant’s liability for the proceeds derived hom the offense ($225,284.87) is
"joint and several" with his convicted co—defendants (Stefano Russo and Anthony Loflnk).
3 Any money judgment entered in this matter should reflect said joint and several
liability with the above-named co-defendants.
WHEREFORE, defendant respectfully requests the Court forfeiture reflective of the
above-described joint and several liability.
/s/ James J. Haley, Jr. (#2997)
JAMES J. HALEY, JR., ESQUIRE
FERRARA, HALEY & COLLINS
1716 Wawaset Street
P. O. Box 188
Wilmington, DE 19899
(302) 656-7247
Dated: April 29, 2008

Case 1:08-cr-00015-GMS

Document 12

Filed 04/29/2008

Page 1 of 1