2011V00180

PAUL J. FISHMAN 

United States Attorney 

By: PETER W. GAETA

Assistant United States Attorney 

970 Broad Street, Suite 700

Newark, New Jersey 07102

Tel: 973.645.2927

Fax: 973.297.2042

peter.gaeta@usdoj.gov

UNITED STATES DISTRICT COURT

 DISTRICT OF NEW JERSEY

UNITED STATES OF AMERICA, 

Hon. Stanley R. Chesler, U.S.D.J. 

Plaintiff, 

Civil Action No. 11-458

 - against - 

NOTICE OF FORFEITURE

$120,342.12, INCLUDING BUT NOT 

LIMITED TO

$70,342.12 CONTAINED IN 

ACCOUNT NUMBER 14224410 

IN THE NAME AND/OR FOR THE 

BENEFIT OF ERICK GREENE AT 

JP MORGAN CHASE BANK, 

LOCATED AT 200 W. SECOND 

STREET, SUITE 101, PLAINFIELD 

NEW JERSEY 07060;

AND

$50,000.00 CONTAINED IN 

ACCOUNT NUMBER 14112172 IN 

THE NAME AND/OR FOR THE 

BENEFIT OF ERICK GREENE AT 

JP MORGAN CHASE BANK,

LOCATED AT 200 W. SECOND 

STREET, SUITE 101, PLAINFIELD 

NEW JERSEY 07060

 Defendant in rem. 

- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - 

 

Case 2:11-cv-00458-SRC Document 3 Filed 02/04/11 Page 1 of 3 PageID: 17
A civil complaint seeking forfeiture pursuant to 31 U.S.C. § 5317(c)(2), which provides

for the forfeiture to the United States of any property involved in a violation of 31 U.S.C. § 5324,

was filed on January 25, 2011, in the United States District Court for the District of New Jersey

by Peter W. Gaeta, Assistant United States Attorney on behalf of the United States of America,

plaintiff, against the defendant property, namely $120,342.12 including but not limited

to $70,342.12 contained in account number 14224410 in the name and/or for the benefit of Erick

Greene at JP Morgan Chase Bank, located at 200 W. Second Street, Suite 101, Plainfield New

Jersey 07060; and $50,000.00 contained in account number 14112172 in the name and/or for the

benefit of Erick Greene at JP Morgan Chase Bank, located at 200 W. Second Street, Suite 101,

Plainfield New Jersey 07060 (hereinafter the “defendant property”).

The United States hereby gives notice of its intention to dispose of the seized defendant

property in such manner as the United States Attorney General may direct.

Any person claiming an interest in, or right against, the defendant property must file a

conforming Claim under penalty of perjury identifying the specific property claimed, identifying

the claimant, and stating the claimant’s specific interest in the property, in the manner set forth in

Rule G(5)(a) of the Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture

Actions, Federal Rules of Civil Procedure and 18 U.S.C. § 983(a)(4)(A), which claim must be

filed within 35 days of the date of this notice. In addition, any person having filed such a

conforming Claim must also file an Answer to the Complaint or a Motion to Dismiss in lieu of

an Answer under Rule 12 of the Federal Rules of Civil Procedure within 21 days after filing the

conforming Claim.

All such Claims and Answers or Motions must be filed with the Office of the Clerk,

United States District Court, Martin Luther King Jr. Federal Building and U.S. Courthouse,

Case 2:11-cv-00458-SRC Document 3 Filed 02/04/11 Page 2 of 3 PageID: 18
Room 4105, 50 Walnut Street, Newark, New Jersey 07102, with a copy sent to Assistant United

States Attorney Peter W. Gaeta, United States Attorney’s Office, 970 Broad Street, 7 Floor, th

Newark, New Jersey 07102. If you fail to timely file a conforming Claim, or fail to file an

Answer or Motion, the United States will seek judgment by default for the relief demanded in the

Complaint. 

The defendant property is currently in the custody of the Department of the Treasury,

Internal Revenue Service, Criminal Investigation (“IRS-CI”), Springfield, New Jersey.

Additional procedures and rules governing this forfeiture action are set forth in 

18 U.S.C. § 981 and 19 U.S.C. §§ 1602-1619. All persons and entities who have an interest in

the defendant property may, in addition to filing a Claim or in lieu of filing a Claim, submit a 

Petition for Remission or Mitigation of the forfeiture for non-judicial determination of this action

pursuant to 28 C.F.R. § 9.

PAUL J. FISHMAN

United States Attorney

 S/Peter W. Gaeta 

 By: PETER W. GAETA

 Assistant United States Attorney

Asset Forfeiture Coordinator

Dated: February 4, 2011

Case 2:11-cv-00458-SRC Document 3 Filed 02/04/11 Page 3 of 3 PageID: 19