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John Wiley Price Government Complaint

John Wiley Price Government Complaint

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Published by: The Dallas Morning News on May 31, 2012
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Case 3:12-cv-00893-D Document
11
Filed 05/29/12 Page 1 of
12
PageiD 48
IN THE
UNITED
STATES
DISTRICT
COU
,
I
FOR
THE NORTHERN
DISTRICT
OF TEXAjS
DALLAS DIVISION
I
UNITED
STATES OF
AMERICA
Plaintiff,v.
§§§§
§$229,590.00 in United States Currency
§
Seized from a Safe in
the
Home
of
§
Dallas County CommissionerJohn Wiley Price$230,763.47 from Dallas CountyCommissioner
John
Wiley
Price's
Sale
of7001
Grady
Niblo
Road, Dallas,TexasDefendants
In Rem.
§
§§
§
§§§§§
!
l
3:12-CV-893-D
U.S.DISTRICT
COURTNORTHERN
DISTRICT
OF
TEXAS
FILED
CLERK,
~ISTJUcrcomrr
~ - - - - ~ ~ ~ - - - - -
FIRST
AMENDED
COMPLAINT
FOR
FORFEITURE
IN
REM
P1aintiffUnited States
of
America ("the Government") files this first amendedcomplaint
in rem
against
the
Defendant property, to wit: $229,590.00 in United Statescurrency seized from a safe in the
home
of
Dallas County Commissioner John WileyPrice and $230,763.47 from Dallas County Commissioner John Wiley
Price's
Sale
of
7001 Grady Niblo Road, Dallas, Texas ("Defendant property") and alleges the followingin accordance with Supplemental Rule G(2)
of
the Federal Rules
of
Civil Procedure'sSupplemental Rules for Admiralty or Maritime Claims and
Asset
Forfeiture Actions.
STATUTORY BASIS
FOR
THE
ACTION
1.
This is an action to forfeit property
to
the United States based
upon
18 U.S.C.
§
981(a)(l)(A)
for violations
of
18 U.S.C. § 1956(h) [Conspiracy to Commit
Money
First
Amended
Complaint for ForfeiturePage 1 of12
 
Case 3:12-cv-00893-D Document
11
Filed 05/29/12 Page 2 of
12
PageiD 49
Laundering under
18
U.S.C. § 1956 and Conspiracy to Engage in MonetaryTransactions in Property Derived from Specified Unlawful Activity under
18
U.S.C. § 1957] and
18
U.S.C. § 981(a)(l)(C) for conspiracies to violate
18
U.S.C.§ 152 [Concealment
of
Assets in Bankruptcy, hereafter "Bankruptcy Fraud"] and
18
U.S.C. § 666 [Theft or Bribery Concerning Programs Receiving FederalFunds]. Rule G
of
the Supplemental Rules for Admiralty or Maritime Claims andAsset Forfeiture Actions is also applicable.
JURISDICTION AND VENUE
2.
This Court has subject matter jurisdiction over a civil forfeiture action commencedby the United States by virtue
of28
U.S.C. § 1345 and 28 U.S.C. § 1355(a).3. The Court has
in rem
jurisdiction over the defendant property based on 28 U.S.C.
§§
1355(b)(l)(A) and 1355(b)(l)(B).4. Venue is proper under 28 U.S.C. §1355(b)(l)(A) and 28 U.S.C. § 1395.
THE
DEFENDANTS IN
REM
5.
The defendant property consists of:
a.
$229,590.00
1
in United States currency seized from a safe in the home
of
Dallas County Commissioner John Wiley Price at 510 East
5th
Street inDallas County, Dallas, Texas that was seized on June 27, 2011 pursuant toa search warrant; and
b.
$230,763.47 from Dallas County Commissioner John Wiley Price's Sale
of
7001 Grady Niblo Road, Dallas, Texas consisting of:
1
This cash is also being held as evidence in a parallel criminal investigation.
First
Amended
Complaint for ForfeiturePage 2
of
12
 
Case 3:12-cv-00893-D Document
11
Filed 05/29/12 Page 3 of
12
PageiD
50
1.
$50,000 due to Dallas County Commissioner John Wiley Price fromhis sale of7001 Grady Niblo Road, Dallas, Texas that was seized onDecember 19, 2011 from W.O. Henry at 2450 North I-35E inLancaster, Texas pursuant to a seizure warrant after the sale
of
theproperty. This same property was later re-seized on March 18, 2012pursuant to a second seizure warrant after the title company requiredwhat was essentially a second closing on the property.n. $180,763.47 due to Dallas County Commissioner John Wiley Price'sSale of7001 Grady Niblo Road, Dallas, Texas that was seized onMarch 18, 2012 from Republic Title at 2626 Howell Street, Dallas,Texas 75204 pursuant to a seizure warrant.
6.
The $229,590.00 in United States currency seized from a safe in the home
of
Dallas County Commissioner John Wiley Price is more particularly described asfollows:
a.
$32,700.00 with a bank bag marked Dallas International Bank,Commerce and Field Street. There
is
one bank strap marked LakesideNational Bank, $2,000, dated April
12,
2011. Another bank strap
is
marked $2,000, with no other markings. All cash appears to be in $100dollar bills.
b.
$38,000.00 with a manila envelope with "40" written and crossed outand "38" written beside it. All the cash appears to be 100 dollar billsand there are four bank straps:
First
Amended
Complaint for ForfeiturePage 3 of12

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