UNITED STATES DISTRICT COURTNORTHERN DISTRICT OF ILLINOISWESTERN DIVISIONUNITED STATES OF AMERICA))Case No. 12 CR 50027v.))Judge Phillip G. ReinhardRITA A. CRUNDWELL)
AGREED MOTION FOR A PROTECTIVE ORDER DIRECTINGTHE INTERLOCUTORY SALE OF CERTAIN PROPERTY
The United States of America, through PATRICK J. FITZGERALD, UnitedStates Attorney for the Northern District of Illinois, moves for entry of a protectiveorder directing the interlocutory sale of certain property pursuant to the provisions of Title 21, United States Code, Section 853(e)(1)(A), as incorporated by Title 28, UnitedStates Code, Section 2461(c), and in support thereof submits the following:1.On May 1, 2012, a federal grand jury returned an indictment chargingdefendant RITA A. CRUNDWELL with wire fraud, in violation of Title 18, UnitedStates Code, Section 1343.2.The indictment seeks forfeiture to the United States, pursuant to 18U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c), of any and all right, title, and interestthe defendant may have in any property constituting and derived from the proceedstraceable to the wire fraud violation, including but not limited to:a.the single family residence located at 1679 U.S. Route 52, Dixon,Illinois (Route 52 property);b.the horse farm property located at 1556 Red Brick Road, Dixon,Illinois (Red Brick Road horse farm);c.a single family residence located at 1403 Dutch Road, Dixon,Illinois (Dutch Road property);
Case: 3:12-cr-50027 Document #: 22 Filed: 05/25/12 Page 1 of 6 PageID #:58
d.approximately 80 acres of vacant land located in Lee County,Illinois with Lee County property identification number 14-09-07-100-014 (80 acres vacant land); ande. a single family residence located at 821 East Fifth Street,Englewood, Florida (Florida property);3.Defendant RITA A. CRUNDWELL is the record owner of the foregoingreal properties.4.To preserve its interest in the real properties, the United States recorded
lis pendens
notices with the Lee County, Illinois Recorders Office or Charlotte County,Florida, Recorders Office against each of the real properties.5.There are two outstanding mortgages secured by the Dutch Roadproperty, the first recorded December 6, 2007 with the Lee County Clerk and assigneddocument number 2007008620 and the second recorded March 26, 2010 with the LeeCounty Clerk and assigned document number 2010001402. The mortgages and notesare held by the First National Bank of Amboy. The sole borrower identified in themortgages and notes is defendant RITA A. CRUNDWELL.6.The United States requests action by this Court because financialresponsibilities relating to the subject properties are burdensome and the defendantdoes not have the means to meet the obligations. The financial responsibilities includebut are not limited to the mortgages secured by the Dutch Road property; regular careand maintenance of all the subject real properties, including buildings and grounds;and payment of the utility bills at each of the subject real properties. Additionally,there are crops located at the Dutch Road property and 80 acres of vacant land that2
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require care and maintenance. Moreover, permitting the sale of the properties nowwould increase the amount, after satisfaction of obligations, that will be available forforfeiture to the United States upon conviction.7.Pursuant to 21 U.S.C. § 853, this Court has jurisdiction to enter ordersor to take other action to preserve and to protect property to insure that property or itsequity will be available for forfeiture in the event of conviction.8.Title 21, United States Code, Section 853(e)(1) provides in pertinent part:Upon application of the United States, the Court may enter arestraining order or injunction, require the execution of asatisfactory performance bond, or take any other action to preservethe availability of property described in subsection (a) of thissection for forfeiture under this section -(A)upon the filing of an indictment or informationcharging a violation of this subchapter or subchapter II of this chapter for which criminal forfeiture may be orderedunder this section and alleging that the property withrespect to which the order is sought would, in the event of conviction, be subject to forfeiture under this section.9.Accordingly, in order to preserve the availability of the equity in the realproperties subject to forfeiture, the United States, along with defendant RITA A.CRUNDWELL, agree to the interlocutory sale of the property by the United StatesMarshals Service, and agree that the proceeds from the sales, after payment of certainverifiable costs, be retained in an escrow account maintained by the United StatesMarshals Service, pending further order of this Court. Although the defendant,through her attorneys, does not object to the issuance of the entry of a protective order3
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Rita Crundwell case: Protective Order Requesting Assets Sale
Federal prosecutors want permission to sell certain properties of former Dixon Comptroller Rita A. Crundwell, including five land parcels and a luxury motor home, before she is convicted. According to a motion filed, prosecutors want to…
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