IN THE DISTRICT COURT OF THE UNITED STATES

FOR THE MIDDLE DISTRICT OF ALABAMA

NORTHERN DIVISION

UNITED STATES OF AMERICA, *

*

Plaintiff, *

*

V. * CASE NO. 2:2006-CV-736-WKW

*

SEVENTY-FOUR THOUSAND SEVEN *

HUNDRED DOLLARS ($74,700) *

IN UNITED STATES CURRENCY, *

*

Defendant. *

ANSWER TO COMPLAINT 

FOR FORFEITURE

Comes now the Claimant, George E. Jones, by and through The Law Offices of Bruce

Maddox, and having previously filed a Claim with the Drug Enforcement Administration in this

cause, files this Answer to the Complaint For Forfeiture, and respectfully says as follows:

1. The Claimant admits the allegations in paragraph one as to the nature of the

complaint and date of seizure, but denies that the property was lawfully seized for

violations of Title II of the Controlled Substances Act, Title 21, United States

Code, Sections 801 et seq.

2. The Claimant denies the allegations in paragraph two of the complaint.

3. The Claimant admits the allegations in paragraph three of the complaint, but does

not admit any specific acts or ommissions.

4. The Claimant admits the allegations contained in paragraph four of the complaint.

5. a. The Claimant denies the allegations contained in paragraph 5a of the complaint.

b. The Claimant denies the allegations contained in paragraph 5b of the complaint.

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c. The Claimant denies the allegations contained in paragraph 5c of the complaint

upon the grounds that said search warrant was neither lawfully issued nor lawfully

executed.

d. The Claimant is without sufficient knowledge to admit or deny the allegations

contained in paragraph 5d of the complaint.

e. The Claimant is without sufficient knowledge to admit or deny the allegations

contained in paragraph 5e of the complaint.

f. The Claimant denies the allegations contained in paragraph 5f of the complaint

upon the grounds that claimant contends that he was unlawfully questioned. 

g. The Claimant is without sufficient knowledge to admit or deny the allegations

contained in paragraph 5g of the complaint.

h. The Claimant is without sufficient knowledge to admit or deny the allegations

contained in paragraph 5h of the complaint. 

6. The Claimant denies the allegations contained in paragraph six of the complaint.

7. The Claimant denies the allegations contained in paragraph seven of the

complaint.

8. The Claimant denies the allegations contained in paragraph eight of the complaint

and demands strict proof thereof. 

Respectfully submitted this the 27th day of September, 2006.

S/Bruce Maddox

Bruce Maddox (MAD013)

Attorney for George E. Jones

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Of Counsel:

Law Offices of Bruce Maddox

6728 Taylor Court

Montgomery, Alabama 36117

Phone: (334) 244-7333

Fax: (334) 260-9600

CERTIFICATE OF SERVICE

I hereby certify that on this 27th day of September, 2006, I electronically filed the

foregoing with the Clerk of Court using the CM/ECF system which will send notification of

such filing to John Harmon Asst. United States Attorney.

Respectfully submitted.

S/Bruce Maddox

Of Counsel

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