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Case 1:13-cv-02754-WDQ Document 12-1 Filed 07/08/14 Page 1 of 7

UNITED STATES DISTRICT COURT

DISTRICT OF MARYLAND

Northern Division

Criminal No.: WDQ-13-2754










UNITED STATES OF AMERICA,

Plaintiff,

-against-


$50,000 in U.S. Currency,


Defendant.


-------------------------------------------------X






PLAINTIFF UNITED STATES OF AMERICA=S FIRST SET OF SPECIAL

INTERROGATORIES TO CLAIMANT JOE E. AVETIA

Plaintiff, United States of America, pursuant to Rule G(6)(a) of the Supplemental Rules for

Admiralty or Maritime Claims and Asset Forfeiture Actions hereby propounds the following

special interrogatories to be answered under an oath within twenty-one (21) days of service hereof:



SPECIAL INTERROGATORY NO. 1:

State your current and all prior names, including aliases or nicknames, dates and places of

birth, Social Security numbers, visa or green card numbers, current address, and all addresses for

the last five (5) years. For each address, please list the inclusive months and years you or your

spouse lived at each address.



SPECIAL INTERROGATORY NO. 2:

If you have ever been arrested or convicted of a crime in any country, please state the date

of the arrest or conviction, the charges, the name and address of the court in which you were

Case 1:13-cv-02754-WDQ Document 12-1 Filed 07/08/14 Page 2 of 7

convicted, the offense you were charged with or were convicted of, and the sentence or other

outcome. If probation was imposed, list the time period during which you were under probation

and the name, address, and telephone number of your probation officer. If you were incarcerated,

list the institution where you were incarcerated and the period of time during which you were

incarcerated. If you were paroled, list the date of your parole and the name, address, and

telephone number of your parole officer. If you have been charged in a criminal case which is

currently pending before any court, please state the date of arrest, the charges(s), the name and

address of the court in which you were charged, and provide the current status of the court case,

including whether a guilty plea has been entered.



SPECIAL INTERROGATORY NO. 3:



Identify the states, provinces and foreign countries in which you have obtained a driver=s

license, driving permit, or state identification, including, where applicable, the license, permit, or

identification number, and state whether the license, permit, or identification is currently valid.



SPECIAL INTERROGATORY NO. 4:

In your claim filed October 22, 2013, you state under penalty of perjury that you are the

Aowner@ of the $50,000.00 of the Defendant Currency (hereinafter Athe Defendant Currency@).

The term Aowner@ is defined for purposes of this action in 18 U.S.C. ' 983(d)(6). With reference

to that definition, state the nature of your ownership interest.



SPECIAL INTERROGATORY NO. 5:

State in detail the circumstances in which you acquired your ownership interest (as defined

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Case 1:13-cv-02754-WDQ Document 12-1 Filed 07/08/14 Page 3 of 7

in 18 U.S.C. ' 983(d)(6)) in the Defendant Currency, including but not limited to, the following: 1)

the date, time and place in which you acquired the currency, 2) the reason you acquired the

currency, 3) the manner in which the currency was delivered to your possession, 4) the identity of

the person(s) from whom you acquired the currency; and 5) the identity of all persons who were

present when you obtained the currency. For each person identified in response to this

interrogatory, provide the person=s name, address and telephone number.



SPECIAL INTERROGATORY NO. 6:

If you have any records, documents, or tangible items that document or relate in any way to

your response to Interrogatory No. 5, or are otherwise relevant to your interest in the Defendant

Currency or your claim to the Defendant Currency, identify each piece of evidence with

specificity, including the name, address and telephone number of its custodian. In lieu thereof,

you may produce copies of the records, documents, or tangible items.



SPECIAL INTERROGATORY NO. 7:

If the currency, or any portion thereof, was obtained by you in the form of a check and

converted to cash, list the payor and payee of the check(s), the amount thereof, the approximate

date the check was written, the date and place where the check was cashed or deposited, and the

places where the cash has been kept since the check was converted to cash. If you originally

received any portion of the Defendant Currency in some other form besides cash or check, list the

form of payment, the amount of the payment, and the reason such payment was made to you or to

such other person or organization. Please identify each witness (by name, address and telephone

number) and each document (and the name, address and telephone number of the custodian of the



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Case 1:13-cv-02754-WDQ Document 12-1 Filed 07/08/14 Page 4 of 7

document) that supports your answer.





SPECIAL INTERROGATORY NO. 8:

State the names and current addresses and telephone numbers of all persons known or

believed by you to have knowledge of or information pertaining to your ownership of the

Defendant Currency so that these persons may be deposed.



SPECIAL INTERROGATORY NO. 9:

If you are claiming that any portion of the Defendant Currency belongs to a third party,

state the name of such third party and the amount that belongs to him or her.



SPECIAL INTERROGATORY NO. 10:

If any portion of the Defendant Currency belongs to a third party, state the reason you were

in possession of such portion of the Defendant Currency and the date you took possession of such

portion of the Defendant Currency.



SPECIAL INTERROGATORY NO. 11:

State, in detail, the nature of your trucking business. Including the name of the business, the

name and contact information for anyone employed by the business, and the names of anyone who

supplies produce to this business.



SPECIAL INTERROGATORY NO. 12:





In your Verified Claim you stated that the defendant currency was acquired through your

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Case 1:13-cv-02754-WDQ Document 12-1 Filed 07/08/14 Page 5 of 7

business and from buying and selling truck parts. Please state any earnings from 2012-2013, and

whether or not you reported any wages earned in Maryland in 2012-2013. If any wages were

reported please attach the appropriate documents to prove that these wages were reported. Also

identify by tax year and Form number all income tax returns for the period(s) when you

accumulated the Defendant Currency that reflect your income as from lawful employment and

enterprises, and the names and telephone numbers of any tax preparers who may have copies of

such tax returns.



SPECIAL INTERROGATORY NO. 13:

State whether you have ever had currency seized from you by a law enforcement agent on

any other occasion. If so, state the date and place of such seizure, the circumstances of the

seizure, the amount of currency seized, the title of any judicial proceeding that resulted from the

seizure and the court where such proceeding was filed, and the disposition of the seizure (i.e.,

whether you recovered the currency, defaulted or did not contest the seizure, or litigated but failed

to recover the currency).



SPECIAL INTERROGATORY NO. 14:

Provide the name of any bank or financial institution in which you are an account holder or

have been an account holder within the past five (5) years.



SPECIAL INTERROGATORY NO. 15:

State the names and addresses of all persons who assisted you in preparing answers to these

interrogatories (except clerical personnel), and specify the interrogatory numbers each person



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Case 1:13-cv-02754-WDQ Document 12-1 Filed 07/08/14 Page 6 of 7

assisted you with.





Sign the attached declarations and forward along with your responses. (Signature of

counsel is not acceptable.)








This 6th day of June, 2014.
Respectfully submitted,

ROD J. ROSENSTEIN
UNITED STATES ATTORNEY


_________________________________
Stefan D. Cassella
Assistant United States Attorney
36 South Charles Street
Fourth Floor
Baltimore, MD 21201

(410) 209-4800

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Case 1:13-cv-02754-WDQ Document 12-1 Filed 07/08/14 Page 7 of 7

UNITED STATES DISTRICT COURT

DISTRICT OF MARYLAND

Northern Division



Criminal No.: WDQ-13-2754













UNITED STATES OF AMERICA,



Plaintiff,

-against-


$50,000 in U.S. Currency,




Defendant.


-------------------------------------------------X




DECLARATION

I, ________________________________, do hereby declare, certify and verify,

under penalty of perjury as provided by federal law, that I have read the foregoing Answers to

Interrogatories and that every answer is true and correct.



Executed on: ____________________



______________________________

CLAIMANT






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