NOTICE OF SEIZURE AND INTENDED FORFEITURE
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1 ACERTlflED COPY lliomas A. WILDER DISTRICT a.erk TARRANT COUNTY, TEXAS FILED TARRANT COUNTY /24/ :41 :29 AM THOMAS A. WILDER DISTRICT CLERK THE STATE OF TEXAS IN THE v. $16, IN U.S. COURT CURRENCY; $9, IN U.S. CURRENCY ; $ IN U. S. CURRENCY; 2001 HARLEY DAVIDSON; 1998 NISSAN; 2002 LINCOLN AND FIREARMS TARRANT COUNTY, TEXAS NOTICE OF SEIZURE AND INTENDED FORFEITURE TO THE HONORABLE JUDGE OF SAID COURT : COMES NOW, The State of Texas, Petitioner herein, and files this Notice of Seizure and Intended Forfeiture pursuant to Chapter 59, Texas Code of Criminal Procedure and for cause of action would show the Court as follows : I. The Petitioner is the State of Texas. Discovery, if any, will be conducted under level two (2 ), pursuant to Rule of the Texas Rules of Civil Procedure. Petitioner affirmatively pleads that she seeks monetary relief of $100, or less, and non- monetary relief. The damages sought, if any, are within the jurisdictional limits of the Court. Notice of Seizure and Intended Forfeiture Page 1 File No
2 II. The following persons and/or entities may be owners or interest holders of the property made the subject of this cause of action and may be served with process at the addresses provided : JESSE DON COLEMAN DOUGLAS WAYNE FAULK (Fed Reg# ) (Fed Reg# ) C/O Fort Worth FCI C/O Fort Worth FCI 3150 Horton Road 3150 Horton Road Fort Worth, Texas Fort Worth, Texas REYNA RENAY RANEY WILLIAM NIXON HOLLEY (Fed Reg# ) 4220 Kay Lynn Lane Federal Detainee Arlington, Texas C/0 Parker County Jail 129 Hogle Street JADE ANN KUHN Weatherford, Texas Mimosa Park Richland Hills, Texas MICHAEL DUANE CADE 1108 Darlene Lane JOSE FRANCISCO AGUILAR Arlington, Texas Catalina Way Irving, Texas III. On or about the date and at the place below, the property described below was seized by peace officers of the State of Texas under Chapter 59, Texas Code of Criminal Procedure, as further alleged and described by the Sworn Statement of the Seizing Peace Officer, C. Notice of Seizure and Intended Forfeiture Page 2
3 Drew, No. 3916, attached hereto and incorporated herein by reference for all purposes. Property A: Date of Seizure : October 27, 2015 Location : Description : 4700 IH 30, Fort Worth, Tarrant County, Texas. Sixteen Thousand Two Hundred Sixty Four & No/100 Dollars ($16, ) in U. S. Currency Seizing Officer (s ) : C. Drew, No Potential Owners, Lienholders, Others With Interest : REYNA RENAY RANEY DOUGLAS WAYNE FAULK (Fed Reg# ) (Fed Reg# ) Federal Detainee C/O Fort Worth FCI C/0 Parker County Jail 3150 Horton Road 129 Hogle Street Fort Worth, Texas Weatherford, Texas Property A is contraband and is subject to forfeiture under Chapter 59 of the Texas Code of Criminal Procedure for the reason that the same was used or intended to be used in the commission of a felony under Chapter 481, Health and Safety Code (Texas Controlled Substances Act ). Property A is contraband and is Notice of Seizure and Intended Forfeiture Page 3
4 Chapter 481, Health and Safety Code (Texas Controlled Substances Act ). Property A is contraband and is used or intended to be used in the commission of a Chapter 34, Texas Penal Code. Property A is contraband and is Chapter 34, Texas Penal Code. Property B: Date of Seizure : October 27, 2015 Location : 600 Jones Street, Fort Worth, Tarrant County, Texas. Description : Nine Thousand One Hundred & No/100 Dollars ($9, ) in U. S. Currency Notice of Seizure and Intended Forfeiture Page 4
5 Seizing Officer (s ) : C. Drew, No Potential Owners, Lienholders, Others With Interest : DOUGLAS WAYNE FAULK (Fed Reg# ) C/O Fort Worth FCI 3150 Horton Road Fort Worth, Texas Property B is contraband and is subject to forfeiture under Chapter 59 of the Texas Code of Criminal Procedure for the reason that the same was used or intended to be used in the commission of a felony under Chapter 481, Health and Safety Code (Texas Controlled Substances Act ). Property B is contraband and is of Criminal Procedure for the reason that the same i s Chapter 4 81, Health and Safety Code (Texas Controlled Substances Act ). Property B is contraband and is Notice of Seizure and Intended Forfeiture Page 5 File No
6 0396-S used or intended to be used in the commission of a Chapter 34, Texas Penal Code. Property B is contraband a nd is Chapter 34, Texas Penal Code. Property C: Date of Seizure : Location : Description : October 27, Mossy Oak Street, Arlington, Tarrant County, Texas. Five Hundred Forty One & No/100 Dollars ($ ) in U. S. Currency Seizing Officer (s ) : C. Drew, No Potential Owners, Lienholders, Others With Interest : JESSE DON COLEMAN (Fed Reg# ) C/O Fort Worth FCI 3150 Horton Road Fort Worth, Texas Property c is contraband and is subject to forfeiture under Chapter 59 of the Texas Code of Criminal Procedure for the reason that the same was used Notice of Seizure and Intended Forfeiture Page 6
7 or intended to be used in the commission of a felony under Chapter 481, Health and Safety Code (Texas Controlled Substances Act ). Property C is contraband and is Chapter 481, Health and Safety Code (Texas Controlled Substances Act ). Property C is contraband and is used or intended to be used in the commission of a Chapter 34, Texas Penal Code. Property C is contraband and is of Criminal Procedure for the reason that the same is Chapter 34, Texas Penal Code. Property D: Notice of Seizure and Intended Forfeiture Page 7
8 0396-S Date of Seizure : October 27, 2015 Location : 200 Jones Street, Fort Worth, Tarrant County, Texas. Description : One (1) 2001 Harley Davidson Motorcycle bearing VIN 1HD4CAM111K and contents therein Seizing Officer (s) : C. Drew, No Potential Owners, Lienholders, Others With Interest : DOUGLAS WAYNE FAULK MICHAEL DUANE CADE (Fed Reg# ) 1108 Darlene Lane C/0 Fort Worth FCI Arlington, Texas Horton Road Fort Worth, Texas Property D is contraband and is subject to forfeiture under Chapter 59 of the Texas Code of Criminal Procedure for the reason that the same was used or intended to be used in the commission of a felony under Chapter 481, Health and Safety Code (Texas Controlled Substances Act). Property D is contraband and is Notice of Seizure and Intended Forfeiture Page 8
9 0396-S Chapter 4 81, Health and Safety Code (Texas Controlled Substances Act ). Property D is contraband and is acquired with Chapter 481 of the Health and Safety Code (Texas Controlled Substances Act ) Property D is contraband and is used or intended to be used in the commission of a Chapter 34, Texas Penal Code. Property D is contraband and is Chapter 34, Texas Penal Code. Property D is contraband and is Notice of Seizure and Intended Forfeiture Page 9
10 0396-S acquired with Chapter 34, Texas Penal Code. Property E: Date of Seizure : October 27, 2015 Location : Description : 4700 IH 30, Fort Worth, Tarrant County, Texas. One (1 ) 2002 Lincoln LS bearing VIN 1LNHM87A42Y and contents therein Seizing Officer (s ) : C. Drew, No Potential Owners, Lienholders, Others With Interest : REYNA RENAY RANEY JADE ANN KUHN (Fed Reg# ) 3107 Mimosa Park Federal Detainee Richland Hills, Texas C/O Parker County Jail 129 Hogle Street Weatherford, Texas Property E is contraband and is subject to forfeiture under Chapter 59 of the Texas Code of Criminal Procedure for the reason that the same was used or intended to be used in the commission of a felony under Chapter 481, Health and Safety Code (Texas Controlled Substances Act ). Notice of Seizure and Intended Forfeiture Page 10
11 0396-S Property E is contraband and is Chapter 481, Health and Safety Code (Texas Controlled Substances Act). Property E is contraband and is acquired with Chapter 481 of the Health and Safety Code (Texas Controlled Substances Act ) Property E is contraband and is used or intended to be used in the commission of a Chapter 34, Texas Penal Code. Property E is contraband and is Noti ce of Seizure and Intended Forfeiture Page 11
12 0396-S Chapter 34, Texas Penal Code. Property E is contraband and is acquired with Chapter 34, Texas Penal Code. Property F: Date of Seizure : October 27, 2015 Location : Description : 1811 Mossy Oak Street, Tarrant County, Texas. One (1 ) 1998 Nissan bearing VIN JN1CA21D6WT and contents therein Seizing Officer (s) : C. Drew, No Potential Owners, Lienholders, Others With Interest : JESSE DON COLEMAN JOSE FRANCISCO AGUILAR (Fed Reg# ) 2704 Catalina Way C/O Fort Worth FCI Irving, Texas Horton Road Fort Worth, Texas Property F ls contraband and is subject to forfeiture under Chapter 59 of the Texas Code of Criminal Procedure for the reason that the same was used Notice of Seizure and Intended Forfeiture Page 12
13 or intended to be used in the commission of a felony under Chapter 481, Health and Safety Code (Texas Controlled Substances Act ). Property F is contraband and is Chapter 481, Health and Safety Code (Texas Controlled Substances Act ). Property F is contraband and is acquired with Chapter 481 of the Health and Safety Code (Texas Controlled Substances Act ) Property F is contraband and is used or intended to be used in the commission of a Chapter 34, Texas Penal Code. Notice of Seizure and Intended Forfeiture Page 13
14 Property F is contraband and is Chapter 34, Texas Penal Code. Property F is contraband and is acquired with Chapter 34, Texas Penal Code. Property G: Date of Seizure : October 27, 2015 Location : Description : 4700 IH 30, Fort Worth, Tarrant County, Texas. One (1 ) Glock Pistol with magazine containing seventeen (17 ) rounds, Serial# ASP338US ; one (1 ) Black Beretta Pistol loaded with magazine containing seven (7 ) rounds, Serial# DAA1907 ; one (1 ) Lorcin Pistol with magazine containing four (4 ) rounds, Serial# ; one (1 ) AST Pistol with magazine containing nine (9 ) rounds, Serial# ; and one KTC Pistol with magazine containing three (3 ) rounds, Serial# Notice of Seizure and Intended Forfeiture Page 14
15 0396-S Seizing Officer (s ) : C. Drew, No Potential Owners, Lienholders, Others With Interest : WILLIAM NIXON HOLLEY 4220 Kay Lynn Lane Arlington, Texas Property G is contraband and is subject to forfeiture under Chapter 59 of the Texas Code of Criminal Procedure for the reason that the same was used or intended to be used in the commission of a felony under Chapter 481, Health and Safety Code (Texas Controlled Substances Act ). Property G is contraband and is Chapter 481, Health and Safety Code (Texas Controlled Substances Act ). Property G is contraband and is acquired with Notice of Seizure and Intended Forfeiture Page 15
16 0396-S Chapter 481 of the Health and Safety Code (Texas Controlled Substances Act ) Property G is contraband and is used or intended to be used in the commission of a Chapter 34, Texas Penal Code. Property G is contraband and is Chapter 34, Texas Penal Code. Property G is contraband and is acquired with Chapter 34, Texas Penal Code. Property H: Date of Seizure : October 27, 2015 Location : 3008 W. Division Street, Arlington, Tarrant County, Texas. Notice of Seizure and Intended Forfeiture Page 16
17 Description : One (1 ) Mossberg. 270 rifle, Serial# BA Seizing Officer (s ) : C. Drew, No Potential Owners, Lienholders, Others With Interest : DOUGLAS WAYNE FAULK (Fed Reg# ) C/O Fort Worth FCI 3150 Horton Road Fort Worth, Texas Property H is contraband and is subject to forfeiture under Chapter 59 of the Texas Code of Criminal Procedure for the reason that the same was used or intended to be used in the commission of a felony under Chapter 481, Health and Safety Code (Texas Controlled Substances Act ). Property H is contraband and is of Criminal Procedure for the reason that the same is felon y unde r Chapter 481, Health and Safety Code (Texas Controlled Substances Act ). Property H is contraband and is Notice of Seizure and Intended Forfeiture Page 17
18 acquired with Chapter 481 of the Health and Safety Code (Texas Controlled Substances Act ) Property H is contraband and is used or intended to be used in the commission of a Chapter 34, Texas Penal Code. Property H is contraband and is Chapter 34, Texas Penal Code. Property H is contraband and is acquired with Chapter 34, Texas Penal Code. Notice of Seizure and Intended Forfeiture Page 18
19 IV. The property described hereinabove was seized by peace officers of the State of Texas. The State of Texas is entitled to have such property forfeited and title rendered to the State of Texas or an agency of the State or a political subdivision authorized to employ peace officers. WHEREFORE, PREMISES CONSIDERED, Petitioner respectfully prays that the persons and entities entitled to service named herein be cited to appear and answer, that upon hearing this court enter a judgment of Forfeiture of the described property to Petitioner, that this court award possession and title to such property to the Petitioner to be administered pursuant to Chapter 5 9 of the Texas Code of Criminal Procedure, for interest, if any, from the date of deposit in an interest bearing account, for cost of court and for such other and further relief as the Petitioner may show itself to be entitled. Respectfully submitted, Notice of Seizure and Intended Forfeiture Page 19
20 SHAREN WILSON CRIMINAL DISTRICT ATTORNEY TARRANT COUNTY, TEXAS By : /S/ VALERIE BASTON VALERIE BASTON Assistant Tarrant County Criminal District Attorney Civil Division 401 W. Belknap Street Fort Worth, Texas Ph. (81 7 ) Fax (817 ) State Bar No VBaston@tarrantcountytx. gov Notice of Seizure and Intended Forfeiture Page 20
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