FEAR's Brief Bank II: indexed by issue

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Traceable proceeds [ 426 ]

NOTICE OF MOTION AND MOTION FOR SUMMARY JUDGMENT, OR PARTIAL

SUMMARY JUDGMENT, BASED ON LACK OF PROBABLE CAUSE FOR FORFEITURE

WHEN COMPLAINT WAS FILED; DECLARATIONS; EXHIBITS

A. Summary judgment should be granted when there is no

genuine issue of material fact for trial and the moving party

is entitled to judgment as a matter of law… .

B. Forfeiture statutes are strictly construed against the

government..

C. The government has the burden of proving that it had probable

cause for forfeiture at the time it filed the complaint..

D. The government has the burden of showing probable cause that

the defendant properties were purchased with the proceeds of

violations of 18 U.S.C. §2342… .

E. There is no genuine issue of material fact that the government

cannot meet its probable cause burden that the defendant

properties are traceable to a violation of 18 U.S.C. §2342(a).

by Honig, Eric

U.S. v. $19,985 C.D.Cal cv 07-3622- ( 2011 )

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