In March 1986, petitioner and Mr. DiMichele purchased
a one-third interest in property at 1441 Shunk Street for
$8,500. The other owners of the property were Tito
Vespasiano and Angel Giancoma, petitioner's cousin.
Petitioners' interest in the property was forfeited to the
U.S. Government in 1990 in connection with Mr. DiMichele's
conviction on drug charges, as discussed below.
At the time of the Government's investigation into
Mr. DiMichele's affairs, petitioner and her husband owned
two cars. Petitioner owned a 1981 Lincoln Continental that
she and her husband had purchased in March of 1981 for
$16,200. In purchasing this car, they had made a down-
payment of $6,200 and had financed the balance of $10,000
through the Fidelity Bank & Trust Co. of New Jersey over 4
years with monthly installments of $280.84. The Credit
Application and the Purchase Money Motor Vehicle Security
Agreement that were signed by petitioner and her husband
and submitted to Fidelity Bank & Trust Co. of New Jersey
list petitioner's address as "406 Orchard Ave Somerdale, NJ
08083." Similarly, the Certificate of Ownership of a Motor
Vehicle issued in petitioner's name by the New Jersey
Division of Motor Vehicles lists the same address.
The second car was a 1984 Cadillac Eldorado that
Mr. DiMichele had purchased in December 1983 for
$25,678.57. In purchasing that car, Mr. DiMichele had made
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