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Rita A. Crundwell - Forfeiture Complaint/Horses

Rita A. Crundwell - Forfeiture Complaint/Horses

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Published by: saukvalleynews on May 01, 2012
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05/24/2012

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UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF ILLINOISWESTERN DIVISIONUNITED STATES OF AMERICA,))Plaintiff,))v.)No.)HAVE FAITH IN MONEY, A QUARTER )HORSE AND 310 OTHER QUARTER )HORSES, ALL HORSES IDENTIFIED )ON ATTACHMENT A,))Defendants.)
JURY TRIAL DEMANDEDVERIFIED COMPLAINT FOR FORFEITURE
The UNITED STATES OF AMERICA, by PATRICK J. FITZGERALD, United StatesAttorney for the Northern District of Illinois, for its verified complaint against the above-nameddefendant properties, alleges in accordance with Supplemental Rule G(2) of the Federal Rules of Civil Procedure as follows:1.This complaint for forfeiture is verified by the attached affidavit of Patrick J. Garry,Special Agent with the Federal Bureau of Investigation (“FBI”), which is fully incorporated herein.
Jurisdiction and Venue
2.This is an
in rem
forfeiture action brought pursuant to Title 18, United States Code,Section 981(a)(1)(C), for forfeiture of Have Faith in Money, a quarter horse and 310 other quarterhorses, all horses identified on Attachment A (“defendant properties”), as properties whichconstitute and are derived from proceeds obtained from violations of Title 18, United States Code,Section 1343.
 
3.This court has
in rem
 jurisdiction over the defendant properties pursuant to Title 28,United States Code, Sections 1355(b)(1)(A) and (d), as the acts giving rise to the forfeiture occurredwithin the Northern District of Illinois.4.Venue is proper under 28 U.S.C. § 1395(b) because the acts giving rise to theforfeiture occurred in this district.
Statutory Authority
5.This
in rem
forfeiture action is brought pursuant to Title 18, United States Code,Section 981(a)(1)(C).
Specific Allegations
6.From approximately 1983 to April 17, 2012, Rita A. Crundwell (“Crundwell”) wasemployed as the Comptroller for the City of Dixon. As Comptroller, Crundwell handled all of thefinances for the City of Dixon.7.At least as early as 1999, Crundwell controlled an account ending in the numbers9530 at a financial institution in Dixon (hereinafter "9530 account"). Bank records for the 9530account for the time period of July 2006 through March 2012 show that the primary account holderfor the 9530 account is the City of Dixon, with a joint account holder listed as "RSCDA." Monthlybank statements for the 9530 account list the account holder as "City of Dixon, P.O. Box 386,RSCDA, Dixon, Illinois 61021-0386,” and the checks written on the 9530 account list the accountholder as "R.S.C.D.A., C/O Rita Crundwell, P.O. Box 482, Dixon, IL 61021."8.Additional records from Fifth Third Bank and US Bank show that the City of Dixonmaintained the following accounts between September 2011 and March 2012: 1) Fifth Third Bank "Corporate Fund" account ending in the numbers 2563 ("2563 account"); 2) Fifth Third Bank "Sales2
 
Tax Fund" account ending in the numbers 8373 ("8373 account"); 3) Midland States Bank "CapitalProject Fund" account ending in the numbers 0066 ("0066 account"); 4) Midland States Bank "Motor Fuel Fund" account ending in the numbers 3675 ("3675 account"); 5) US Bank MoneyMarket account ending in the numbers 1128 ("1128 account"); and 6) Fifth Third Bank "CapitalDevelopment Fund" account ending in the number 7503 ("7503 account").9.Records obtained from US Bank show that between September of 2011 and Februaryof 2012, approximately $2,783,912 of tax funds were electronically deposited into the 1128 account,including:$1,315,828Municipal 1% Share of Sales Tax$456,575Local Share of Income Tax$398,285Non-Home Rule Sales Tax$264,709Personal Property Replacement Tax$198,017Motor Fuel Tax$108,288Local Share of State Use Tax$42,210Simplified Mun. Telecommunications Tax10.US Bank records show that the above distributions were derived from a localgovernment investment pool called The Illinois Funds. The total of $2,783,912 represents the Cityof Dixon's share of distributions made by the State of Illinois from September of 2011 throughFebruary of 2012.11.Between September of 2011 and February of 2012, Crundwell, in her capacity asComptroller for the City of Dixon, caused $3,039,000 to be wired out of the 1128 account into otherCity of Dixon accounts, as follows:$1,788,000Wires into 7503 Account$796,000Wires into 2563 Account$255,000Wires into 8373 Account$200,000Wires into 3675 Account3

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