IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO

Civil Action No. 11-CV-02106-PAB-CBS

UNITED STATES OF AMERICA,

Plaintiff,

v.

DEFENDANT NO 1: ONE PARCEL PROPERTY LOCATED AT

927 COLE STREET, GOLDEN, COLORADO, WITH ALL

APPURTENANCES, IMPROVEMENTS AND ATTACHMENTS

THEREON;

DEFENDANT NO 2: ONE 2008 TOYOTA HIGHLANDER,

VIN # JTEES42A182076495;

Defendants.

STATUS REPORT - DECEMBER 21, 2011

COMES NOW The United States of America, byand through AttorneyGeneral of the United

States Eric Holder, Barry R. Grissom, United States Attorney for the District of Kansas, through

Special Attorneys Richard L. Hathaway and Christine E. Kenney, and submits the following Status

Report.

1. On August 11, 2011, the United States filed a Verified Complaint for Forfeiture In

Rem under seal against the above defendants. (Doc. 1).

2. On August 15, 2011, the Court issued an Order for Warrant of Arrest of Property

In Rem. (Doc. 8.) A copy of the Verified Complaint and Writ of Entry (Doc. 9), were served

upon the daughter of Marie Dalton, titled owner of Defendant No. 1, who informed Dalton of the

Verified Complaint.

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Case No. 1:11-cv-02106-PAB-CBS Document 22 filed 12/21/11 USDC Colorado pg 1 of 4
3. On September 1, 2011, the Court filed a Minute Order directing that a status

report be filed every ninety (90) days, beginning November 30, 2011. (Doc. 14.) On October 4,

2011, the above case was unsealed. (Doc. 19.)

4. On September 21, 2011, Marie Dalton, titled owner of Defendant No. 1, filed a

Verified Claim. (Doc. 16.) No other claims have been filed.

5. On October 19, 2011, an Indictment was returned against Marie Dalton and

Richard Dalton in case no. 11-cr-430-CMA. The Indictment includes a notice that Defendant

No. 1 and Defendant No. 2 are subject to criminal forfeiture. 

5. On October 25, 2011, a copy of the Verified Complaint and a copy of the Notice

of Complaint for Forfeiture in Rem (Doc. 13), were served on Marie Dalton, titled owner of

Defendant No. 1, and on Richard Dalton, representative of the titled owner of Defendant No. 2.

6. The United States anticipates no other claims will be filed in this case. No

answers have been filed in this case. 

7. The United States plans to file a motion for interlocutory sale of the property. 

Said motion should be on file in the next week.

8. The United States suggests this case is ripe for a scheduling conference. 

9. Although both interested parties, Marie Dalton and Richard Dalton, are

represented by counsel in the criminal case, neither interested party is represented by counsel in

the instant case. 

DATED this 21 day of December, 2011. st

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Case No. 1:11-cv-02106-PAB-CBS Document 22 filed 12/21/11 USDC Colorado pg 2 of 4
Respectfully submitted,

ERIC H. HOLDER, JR.

ATTORNEY GENERAL OF THE UNITED STATES

&

BARRY R. GRISSOM, # 10866

UNITED STATES ATTORNEY

DISTRICT OF KANSAS

barry.grissom@usdoj.gov

by:

s/Richard L. Hathaway

rich.hathaway@usdoj.gov

&

s/Christine E. Kenney

christine.kenney@usdoj.gov

Special Attorneys 

444 SE QUINCY, SUITE 290

TOPEKA, KS 66683

Phone: (785) 295-2850

Fax: (785) 295-2853

Attorneys for Plaintiff

CERTIFICATE OF MAILING

I hereby certify that on this 21 day of December, 2011, I electronically filed the st

foregoing with the Clerk of Court using the ECF system, and true copies were mailed via 

certified mail, return receipt requested, to:

Marie Dalton #11-5145 Cert # 7009 1680 0000 4542 2024 

Douglas County Jail

4000 Justice Way

Castle Rock, CO 80109

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Case No. 1:11-cv-02106-PAB-CBS Document 22 filed 12/21/11 USDC Colorado pg 3 of 4
Richard Dalton Cert # 7009 1680 0000 4542 2017

FCI ENGLEWOOD

FEDERAL CORRECTIONAL INSTITUTION

9595 WEST QUINCY AVENUE

LITTLETON, CO 80123

s/Christine E. Kenney

christine.kenney@usdoj.gov

Special Attorneys 

444 SE QUINCY, SUITE 290

TOPEKA, KS 66683

Phone: (785) 295-2850

Fax: (785) 295-2853

Attorney for Plaintiff

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