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amounts on or about the dates cited:
Date Amount Financial Institution
4/12/91 $5,000 National Security Bank
4/16/91 10,000 New Milwaukee-Ogden Currency Exchange
4/19/91 10,000 New Milwaukee-Ogden Currency Exchange;
In violation of Title 31, United States Code,
Sections 5324(3) and 5322(a).
3. From on or about April 8, 1991 to on or about
April 19, 1991, defendant JAMES E. WELLS engaged in the
above-described conduct in violation of Title 31,
United States Code, Section 5324(3), thereby subjecting
to forfeiture to the United States, pursuant to Title
18, United States Code, Section 982(a)(1) and Title 21,
United States Code, Section 853(a)(2) and (p)(5), the
following property and interests:
All of the defendant’s property used and intended
to be used in any manner or part to commit or to
facilitate the commission of defendant’s violations of
Title 31, United States Code, Section 5324(3).
Specifically, this includes the following:
$65,000 of the approximately $105,145 in cash recovered
from personal belongings of defendant JAMES E. WELLS
at the time of his arrest by officers of the Sarasota
Police Department on or about November 16, 1991.
In violation of Title 21, United States Code,
Section 853(a)(2) and (p)(5).
On April 22, 1993, petitioner and petitioner’s attorney
James I. Marcus (Mr. Marcus) entered into a plea agreement
(petitioner’s plea agreement) with the U.S. Attorney. Peti-
tioner’s plea agreement stated in pertinent part:
This Plea Agreement is entirely voluntary and
represents the entire agreement between the United
States Attorney and defendant regarding defendant’s
criminal liability in * * * [petitioner’s criminal
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