Case :15-cr-196-FLW Documt 54-4 Filed 5/4/17 Page 1 of 2 PageD: 1667 ANTHONY L. VELASQUEZ, ESQ. 575 Rt. 7, 2nct Floor P.. Box 1 Brick, New Jersey 872 (t) 72-9-1966; (f) 72-416-7861 avelasquez@tryko.com Attorney for Public Tax nvestmts, LLC THE UNTED STATES DSTRCT COURT FOR THE DSTRCT OF NEW JERSEY UNTED STATES OF AMERCA, v. BOBBY BOYE, aka Bobby Ajiboye, aka Bobby Aji-Boye, Defdant. Case No. 15-196 (FLW) PROOF OF SERVCE Return date: June 5, 217, Anthony L. Velasquez, Esq., hereby certify and declare as follows: 1. am an attorney-at-law admitted to practice before the Courts of the State of New Jersey, the U.S. District Court for the District of New Jersey, and the United States Court of Appeals for the Third Circuit. am counsel for the Petitioner Public Tax nvestmts, LLC, and have personal knowledge of the following facts to which certify under palty of perjury. 2. On May 2, 217, filed the Clerk, United States District Court, by U.S. Priority Mail, Clarkson S. Fisher Bldg. and U.S. Courthouse, 42 E. State Street, Trton, NJ, 868, the following: (a) Notice of Petition; (b) Certification of Anthony L. Velasquez, Esq.; (c) Memorandum of Law; ( d) Proposed form of Order; and ( e) this Proof of Service.. On this same date, caused to be deposited via U.S. Priority Mail a copy of the above papers to the following:
Case :15-cr-196-FLW Documt 54-4 Filed 5/4/17 Page 2 of 2 PageD: 1668 Hon. Freda L. Wolfson, U.S.D.J. (courtesy copy as per judge preferce) United States District Court - District of NJ Clarkson S. Fisher Bldg. and U.S. Courthouse 42 E. State Street Trton, NJ, 868 and U.S. Departmt of Justice United States Attorney- District ofnj Atttion: Jafer Aftab, Esq., Assistant U.S. Attorney 97 Broad Street, 7th Floor Newark, NJ 712 hereby certify and declare under palty of perjury that the above-statemts made by me are true. am aware that if any such statemts are willfully false, am subject to punishmt sl Anthony L. Velasquez, Esq. Anthony L. Velasquez, Esq. May2, 217
' Case :15-cr-196-FLW Documt 54-5 Filed 5/4/17 Page 1 of 2 PageD: 1669 ANTHONY L. VELASQUEZ, ESQURE 575 Route 7, 2nd Floor P.O. Box 1 Brick, NJ 872 72 9 1966 PHONE, 72-416-7861 FAX AVelasquez@tryko.com RECEVED MAY 4 217 AT 8: M WLLAM T. WALSH CLERK VA U.S. PRORTY MAL Clerk, United States District CQurt - District of NJ Clarkson S. Fisher Bldg. and U.S. Courthouse 42 E. State Street Trton, NJ, 868 May 2, 217 Re: United States v. Boye, Criminal No. 15-196 Dear Clerk: As per my telephone conversation with yoµr office today, am in-house corporate counsel for a third party tax li company that holds tax sale certificates against real estate throughout NJ. The criminal defdant in this matter (Boye) owned property in NJ that was subject to forfeiture. The U.S. Attorney has now provided notice of this forfeiture (letter dated 4/26/217 attached), and has said that any third party claiming an interest in the property must in accordance with 21 US. C. 85(n) file a "petition for a hearing to adjudicate the validity" of such property interest. My company was the winning bidder at a public auction held by the municipal tax collector 2 years ago and therefore holds the tax li against this property and has paid the taxes on this property. My clit therefore has a recorded tax li against the defdant and all others who hold any property interests. Since the tax li laws place my clit in first position over any owners, mortgage holders, federal li holders, or any others, my clit asserts this limited right against the forfeiture, as set forth in my petition papers. attempted through ECF to file a Notice of Appearance on behalf of Public Tax nvestmts, LLC, but wh wt to file the petition papers as an "Application/ Petition" there is no option to add Public Tax nvestmts, LLC, as a party. Therefore, as per my conversation with your office, am submitting the papers by mail - an original plus a second copy (with a third copy marked as "courtesy copy" for Judge Wolfson since the website notes Judge Wolfson's preferce for courtesy copies). hereby close the following: (a) Notice of Petition; (b) Certification of Corporate Counsel Anthony L. Velasquez, Esq., in Support of Petition; (c) Legal Brief; (d) Proposed forin of Order; and ( e) Proof of Service. t is my understanding that there is no fee for this petition for property interest subject to forfeiture. f this is incorrect, you had said you would contact my office. Thank you. /ds. cc. Jafer Aftab, Assist. U.S. Attorney U
"' Case :15-cr-196-FLW Documt 54-5 Filed 5/4/17 Page 2 of 2 PageD: 167 U.S. Departmt of Justice United States Attorney District of New Jersey 97 Broad Street, 7'h floor Newark, New Jersey 712 97-645-27 April26,217 Via Certified Mail Public Tax nvestmts, LLC P.O. Box 1 Brick, New Jersey 872 Re: Notice of Third Party Claimant Procedure for Forfeited Property United States v. Bobby Boye, Criminal No. 15-196 (FLW) To Whom t May Concern: The United States District Court for the District of New Jersey has ordered that certain property be forfeited to the United States in connection with the abovecaptioned criminal case. The closed Corrected Const Judgmt of Forfeiture (Money Judgmt) and Preliminary Order of Forfeiture as to Specific Property (Final as to the Defdant) describes the property subject to forfeiture and the procedure for filing a claim to any of the property in which you may have a legal right, title, or interest. f you wish to assert a legal interest in the forfeited property, you must file a petition for a hearing to adjudicate the validity of your alleged interest within 5 days of the date of this letter- that is. May 1, 217. The procedure for filing a petition is set forth more fully in 21 U.S.C. 85(n), which provides the exclusive means by which a third party may lay claim to forfeited assets, and is described in the Notice of Forfeiture that is also closed with this letter. Your failure to file a petition within the time period set forth above will title the United States to seek try of a Final Order of Forfeiture as to the property, and any claim you might have to such property would thereafter be precluded. Sincerely, WLLAM E. FTZPATRCK ACTNG UNTED STATES ATTORNEY By:J Assistant United States Attorney Enclosures: Notice of Forfeiture Corrected Const Judgmt of Forfeiture (Money Judgmt) and Preliminary Order of Forfeiture as to Specific Property (Final as to the Defdant}
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