2. The United States Homeland Security Investigations (“HSI”) constructivelyseized the defendant property from the Toledo Museum of Art (“TMA”), 2445 Monroe Street,Toledo, Ohio 43620, on June 7, 2012. HSI is a component of the United States Immigration andCustoms Enforcement (“ICE”), United States Department of Homeland Security (“DHS”). Byagreement between HSI and TMA, the defendant property remains in the physical possession of TMA for safekeeping.
The Kalpis is currently valued by the Italian government at €500,000(approximately $665,435).3. This Court has subject matter jurisdiction over an action commenced by theUnited States under 28 U.S.C. § 1345, and over an action for forfeiture under 28 U.S.C. §1355(a).4. This Court has in rem jurisdiction over the defendant properties pursuant to 28U.S.C. § 1355(b)(1)(A), because the acts or omissions giving rise to the forfeiture occurred inthis district; and pursuant to 28 U.S.C. § 1355(b)(1)(B), incorporating 28 U.S.C. § 1395, becausethe action accrued, and the defendant property was found, in this district.5. Venue is proper in this district pursuant to 28 U.S.C. § 1355(b)(1)(A), because theacts or omissions giving rise to the forfeiture occurred in this district; and pursuant to 28 U.S.C.§ 1395, because the action accrued, and the defendant property was found, in this district.6. The Court will have control over the defendant property pursuant to the service of an arrest warrant in rem pursuant to Supplemental Rule G(3)(b), which the Plaintiff will executeupon the property pursuant to 28 U.S.C. § 1355(d) and Supplemental Fed. R. Civ. P. G(3)(c).
Case: 3:12-cv-01582 Doc #: 1 Filed: 06/20/12 2 of 10. PageID #: 2