COMPLAINT in rem FOR FORFEITURE Page 1 of 3 

BILLY J. WILLIAMS, OSB #901366 

United States Attorney 

District of Oregon 

AMY E. POTTER 

amy.potter@usdoj.gov 

Assistant United States Attorney 

United States Attorney=s Office 

405 E. 8th Street, Suite 2400 

Eugene, Oregon 97401-2708 

Telephone: 541-465-6771 

Facsimile: 541-465-6917 

 Attorneys for the United States 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

EUGENE DIVISION 

UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

85 ASSORTED FIREARMS, in rem, (FURTHER DESCRIBED IN EXHIBIT 1, 

ATTACHED) 

 Defendants. 

 Case No. 6-16-CV-00053-MA 

COMPLAINT, in rem, 

FOR FORFEITURE 

 Plaintiff, United States of America, by Billy J. Williams, United States Attorney for the 

District of Oregon, and Amy E. Potter, Assistant United States Attorney, for its complaint in rem 

for forfeiture, alleges: 

I. 

 This Court has subject matter jurisdiction, in rem jurisdiction, and venue pursuant to 

18 U.S.C. §§ 922 and 924; 28 U.S.C. §§ 1345, 1355, 1356, and 1395; and 19 U.S.C. § 1610. 

Case 6:16-cv-00053-MA Document 1 Filed 01/13/16 Page 1 of 3
COMPLAINT in rem FOR FORFEITURE Page 2 of 3 

II. 

 Defendants, in rem, 85 Assorted Firearms, further described in Exhibit 1 attached to this 

Complaint, are now and during the pendency of this action will be within the jurisdiction of this 

Court. 

III. 

 Defendants, in rem, 85 Assorted Firearms, were used or intended to be used in any 

manner or part to commit or to facilitate in the commission of a violation of 18 U.S.C. §§ 

922(b)(5), 922(d)(1), 922(m), and 922(t), and are forfeitable to the United States pursuant to the 

provisions of 18 U.S.C. § 924(d), as more particularly set forth in the declaration of Caleb Enk, 

Special Agent Bureau of Alcohol, Tobacco, Firearms, and Explosives, marked as Exhibit A, 

attached and fully incorporated herein by this reference. 

 WHEREFORE, plaintiff, United States of America, prays that due process issue to 

enforce the forfeiture of defendants, in rem, 85 Assorted Firearms; that due notice be given to all 

interested persons to appear and show cause why forfeiture of these defendants, in rem, should 

not be decreed; that due proceedings be had thereon; that these defendants be forfeited to the 

United States; that the plaintiff United States of America be awarded its costs and disbursements 

incurred in this action, and that plaintiff have such other and further relief as is just and 

equitable. 

 Respectfully submitted this 13th day of January 2016. 

 BILLY J. WILLIAMS 

 United States Attorney 

 s/ Amy E. Potter 

 AMY E. POTTER 

 Assistant United States Attorney 

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VERIFICATION

 I, CALEB ENK declare, under penalty of perjury, pursuant to the provisions of 28 U.S.C. 

Section 1746, that I am a Special Agent with the Bureau of Alcohol, Tobacco, Firearms, and 

Explosives and that the foregoing Complaint in rem for Forfeiture is made on the basis of 

information officially furnished and upon the basis of such information the Complaint in rem for 

Forfeiture is true as I verily believe. 

 s/ Caleb Enk 

 CALEB ENK 

 Special Agent 

 Bureau of Alcohol, Tobacco, Firearms, and Explosives 

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