Answer to Writ of Continuing Garnishment, as to Andre Lee Gaines filed by Morgan & Morgan PLLC — USA v. Gaines (Dkt. 22, N.D. Ga.)

Summary

Morgan & Morgan Atlanta, PLLC answered the writ of garnishment in United States v. Andre Lee Gaines (N.D. Ga., Criminal Action No. 1:21-CR-206-01-JPB), filed 07/14/23. Gregory Keith Johnson, signing as the firm's representative, states that it was served with the writ on the 6th day of July 2023. It holds settlement funds of approximately 12,812.14 in which the defendant has a 100% interest, and lists no objections or set-offs.

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Case 1:21-cr-00206-JPB     Document 22     Filed 07/14/23     Page 1 of 6
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA

ATLANTA DIVISION
UNITED STATES OF AMERICA,
: CRIMINAL ACTION __,
Vv. : NO: 1:21-CR-206-01-JPB
ANDRE LEE GAINES,
Defendant,
and
MORGAN & MORGAN PLLC,
Garnishee.
ANSWER OF THE GARNISHEE
I, Gregory Keith Johnson (Declarant), as the _representative __ (Title

of Declarant) of Garnishee, Morgan & Morgan Atlanta, PIC (Garnishee's official
name).
BEING DULY SWORN DEPOSE AND SAY:

1. Choose one as applicable:

GARNISHEE IS AN INDIVIDUAL

Garnishee is or was doing business in name of

. The Garnishee is or was doing business under a DBA and the name

of DBA is . The official address where mail should be sent
Case 1:21-cr-00206-JPB     Document 22     Filed 07/14/23     Page 2 of 6
| GARNISHEE IS A PARTNERSHIP OR TRUST:

The names of the partners in the partnership, or members of the trust are

. Declarant is the

(Title) of a partnership or trust known as | which
is registered in the State of . The official title of the person
completing this Answer is . The mailing address for the

person or authorized agent for this partnership oor trust

[_] GARNISHEE IS A GOVERNMENTAL ENTITY.

The official title of the Declarant completing this answer is

(title of declarant). The Garnishee is an

(Agency, Department, etc.) of the

(official mame of government entity) with a principal office located at

[x] GARNISHEE IS A CORPORATION.

1. = Declarant is the _ representative (title of declarant) of

the Morgan & Morgan Atlanta PLL@corporation name), which is organized under the

laws of the State of _ Georgia
Case 1:21-cr-00206-JPB     Document 22     Filed 07/14/23     Page 3 of 6
2. The Garnishee may be contacted through the following individual, at
the following telephone number(s), and with the following identifying
information:

Gregory Keith Johnson

3. Onthe 6th _ day of __July ,20_23 , Garnishee was served
with the Writ of Garnishment.

4. Garnishee has custody, control or possession of the following
property owned by the Defendant, including the following checking accounts,
savings accounts, retirement accounts (IRA and 401k), and/or investment
accounts, any safety deposit boxes which are held in Defendant’s name or over
which Defendant holds signature authority:

4a. Description of Property Interest:

4b. Approximate Value:

4c. Estimation of Defendant's Interest in Property:
Case 1:21-cr-00206-JPB     Document 22     Filed 07/14/23     Page 4 of 6
5. Garnishee has custody, contro! or possession of the following other
property or funds (non-earnings), in which the Defendant maintains an interest,
as described below:

5a. Description of Property Interest: _Settlement Funds

5b. Approximate Value: _ 12,812.14
5c. Estimation of Defendant's Interest in Property:

100%

(Complete items 6-7 below if applicable)

6. Garnishee makes the following objections, defenses, or set-offs to the

United States’ right to the Defendant's property:

7. Garnishee was not and is not indebted or under liability to the
Defendant, and Garnishee did not or does not have possession or control of any
property belonging to the Defendant, or in which the Defendant has an interest;

and is not liable as Garnishee in the action for the following reason(s):

The Garnishee delivered or mailed an Answer by first class mail to the Clerk

of the United States District Court for the Northern District of Georgia, 2211 U.S.
Case 1:21-cr-00206-JPB     Document 22     Filed 07/14/23     Page 5 of 6
Courthouse, 75 Ted Turner Drive, Atlanta, Georgia 30303 and referenced Criminal
Action No.1:21-CR-206-01-JPB. The Garnishee delivered or mailed a copy of the
Answer by first-class mail to the Defendant, Andre Lee Gaines, 1199 Olde Bridge
Dr 1199 Olde Bridge Dr, Dallas, GA 30157. The Garnishee delivered or mailed a
copy of the Answer by first class mail to Vivieon K. Jones, Assistant United States

Attorney, 600 U.S. Courthouse, 75 Ted Turner Drive, S.W., Atlanta, GA 30303.

day of __July , 2023.

Signature of Representative of Garnishee

Dated this

Gregory Keith Johnson
Printed Name

Attorney/Representative

Title

Morgan & Morgan Atlanta, PLLC
408 12th Street, Suite 200

Columbus, GA 31901
gkjohnson@forthepeople.com

Address of Garnishee -

Telephone Number of Garnishee
Case 1:21-cr-00206-JPB     Document 22     Filed 07/14/23     Page 6 of 6
Subscribed to and sworn before me this

iY day of _July __, 20 23

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