Final Motion for Forfeiture of Property as to Adiana Pierre by USA — USA v. Pierre et al. (Dkt. 111, D. Mass. No. 1:23-mj-05013)

Record facts

U.S. District Court for the District of Massachusetts · No. 1:24-cr-10007-MJJ · Doc. 111 · 2025-11-21 · Docket on CourtListener

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UNITED STATES DISTRICT COURT 
 
DISTRICT OF MASSACHUSETTS 
 
UNITED STATES OF AMERICA 
) 
) 
 
 
v. 
 
 
 
)  
Criminal No. 24-10007-MJJ 
) 
ADIANA PIERRE, 
) 
 
) 
 
 
 
Defendant. 
 
 
) 
____________________________________) 
 
 
 
 
 
 
) 
 
FIRST CITIZENS NATIONAL BANK, 
) 
 
 
 
 
 
 
) 
 
 
Petitioner. 
 
 
) 
____________________________________) 
 
UNITED STATES’ MOTION FOR FINAL ORDER OF FORFEITURE 
(2018 PORSCHE MACAN WITH VIN WP1AA2A52JLB08044) 
The United States of America, by its attorney, Leah B. Foley, United States Attorney for 
the District of Massachusetts, respectfully moves this Court for the issuance of a Final Order of 
Forfeiture in the above-captioned case pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. 
§ 2461(c), 18 U.S.C. § 982(a)(1), and Rule 32.2(c) of the Federal Rules of Criminal Procedure.  
A proposed Final Order of Forfeiture is submitted herewith.  In support thereof, the United 
States sets forth the following: 
1. 
On June 7, 2024, in connection with the charges against Adiana Pierre (the 
“Defendant”), this Court issued a Preliminary Order of Forfeiture against the following property, 
pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c), 18 U.S.C. § 982(a)(1), and Rule 
32.2(b)(2) of the Federal Rules of Criminal Procedure: 
(a) 
A Porsche Macan with VIN WP 1AA2A52JLB08044, registered to ADIANA 
PIERRE and seized on January 25, 2023, from Lookout Mountain, TN; 
(the “Porsche”).  See Docket No. 80. 
2. 
Notice of the Preliminary Order of Forfeiture was sent to all interested parties 
Case 1:24-cr-10007-MJJ     Document 111     Filed 11/21/25     Page 1 of 3

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and published on the government website www.forfeiture.gov for thirty (30) consecutive 
calendar days, beginning on March 6, 2025 and ending on April 4, 2025.  See Docket Nos. 
109 and 110. 
3. 
Subsequently, petitioner First Citizens National Bank (the “Petitioner”), through 
its Vice President of Special Assets, contacted the United States and asserted its interest in the 
Porsche, as a result of a Certificate of Title, a Noting of Lien for the Vehicle, a Promissory Note, 
and a Commercial Security Agreement.  In the submission, the Petitioner stated that it was “not 
aware of any wrong-doing by [the Defendant] when this loan was made,” that the amount 
financed was $40,621.00, and that the unpaid principal due at the time of seizure was 
$33,449.22.  The United States construes this submission as a request for a hearing to adjudicate 
the validity of its alleged interest in the property under 21 U.S.C. § 853(n)(2) and (3).    
4. 
The United States and the Petitioner (the “Parties”) now desire to reach a full and 
final settlement of this matter as to the Porsche. 
5. 
Pursuant to the terms of the Settlement Agreement, attached here to as Exhibit A 
and incorporated herein, the Parties agree that upon the sale of the Porsche by the United States, 
and pursuant to the Final Order of Forfeiture, the United States shall pay to the Petitioner, via its 
attorney or as otherwise directed by the Petitioner, from the net proceeds of the sale, after 
payment of the reasonable expenses incurred by the United States in connection with its custody 
and sale of the Porsche, after payment of any taxes owed as a result of such custody or sale,1 
after payment of any outstanding expenses necessary to sell the Porsche, and less any debt that 
the Petitioner owes to the United States, or any agency of the United States, or any debt that the 
 
1 Tax liability accrues until the United States takes title through a Final Order of Forfeiture. 
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United States is authorized to collect from the Petitioner, the following: 
a. 
unpaid principal due and owing under the Promissory Note and Commercial 
Security Agreement; 
b. 
accrued interest at the base contractual rate (not the default rate), to the date of 
payment; and 
c. 
any escrow advances and/or other fees and costs properly chargeable to the 
Promissory Note and Commercial Security Agreement. 
6. 
No other claims of interest in the Porsche have been filed with the Court or served 
on the United States Attorney’s Office, and the time within which to do so has expired. 
7. 
WHEREFORE, the United States requests that this Court enter a Final Order of 
Forfeiture against the Porsche in the form submitted herewith. 
Respectfully submitted, 
LEAH B. FOLEY 
United States Attorney, 
 
 
By: 
/s/ Annapurna Balakrishna                    
DAVID M. HOLCOMB 
ANNAPURNA BALAKRISHNA  
Assistant United States Attorneys 
United States Attorney’s Office 
1 Courthouse Way, Suite 9200 
Boston, MA 02210 
 
(617) 748-3100 
Dated:  November 21, 2025 
annapurna.balakrishna@usdoj.gov 
 
 
 
Case 1:24-cr-10007-MJJ     Document 111     Filed 11/21/25     Page 3 of 3

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