Exhibit A - Affidavit of Angelina Banks ISO of Petition — USA v. Thomas et al. (Dkt. 967-1, N.D. Ga.)

Summary

Exhibit A to Document 967 in United States v. Dixon et al. (N.D. Ga., Case No. 1:20-CR-296-JPB-CMS), filed 04/15/24, is the affidavit of Angelina Banks, Principal of New Horizon Real Estate, LLC, supporting its petition to contest the forfeiture of a Fulton County, Georgia property. New Horizon bought the then-vacant land from The Atlanta 10 Group, LLC on October 14, 2021 for $62,500.00, which Banks calls its fair market value, and spent almost $400,000 building a house on it. Banks states that no one told New Horizon or Banks of the lis pendens or the Consent Preliminary Order of Forfeiture, that Banks does not know Charles Hill or any of the defendants, and that neither Banks nor the company has any connection to All Legal Hustles, LLC.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Record facts

Full text

Case 1:20-cr-00296-JPB-CMS     Document 967-1     Filed 04/15/24     Page 1 of 5
EXHIBIT A
Case 1:20-cr-00296-JPB-CMS     Document 967-1     Filed 04/15/24     Page 2 of 5
IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

UNITED STATES OF
AMERICA,

VS.

RICKY DIXON,

MEGHAN THOMAS,

JESIKA BLAKELY,

AMANDA CHRISTIAN,
DWAN ASHONG A/K/A DWAN
GILPIN,

JOHN GAINES A/K/A MARTY
GAINES,

CHARLES PETTY A/K/A
CHARLES KNIGHT,

JERRY BAPTISTE,

CARLA JACKSON,

DEREK PARKER,

DAVID BELGRAVE II,
CHARLES HILL IV,

RYAN WHITTLEY,

EL HADJ SALL, AND

RICK MCDUFFIE

Criminal Action No.
Case No. 1:20-CR-296-JPB-CMS

ee ee

AFFIDAVIT OF ANGELINA BANKS IN SUPPORT OF
PETITION TO CONTEST THE FORFEITURE OF PROPERTY

Personally appeared before me the undersigned officer duly authorized by law
to administer oaths, Angelina Banks who after being duly sworn, deposes and states

under oath as follows:
Case 1:20-cr-00296-JPB-CMS     Document 967-1     Filed 04/15/24     Page 3 of 5
My name is Angelina Banks. I am an adult, female citizen of the United States
of America and the State of Georgia, suffer no known disabilities, and testify herein
to facts which are personally known to be true and correct.

1 am the Principal of New Horizon Real Estate, LLC (“New Horizon”).

New Horizon purchased the property located at 503-505 Rockwell Street,

Fulton County, Georgia (the “Property”) in an arms-length transaction on October

I saw the Property’s listing on Zillow and worked with an agent to purchase
the Property New Horizon purchased the Property.
I am real estate investor by trade.
New Horizon paid $62,500.00 for the Property.
Based on my experience, $62,500.00 was the fair market valuation of the

Property at the time New Horizon purchased it.
Case 1:20-cr-00296-JPB-CMS     Document 967-1     Filed 04/15/24     Page 4 of 5
At the time New Horizon purchased the Property, it was vacant land.

I regularly purchase property, invest in renovations of or additional buildings

on said property, and then sell the property for profit.

After New Horizon purchased the Property, it spent almost $400,000 to build

a house on the Property and is now under contract to sell the Property.

No one informed New Horizon or me of the lis pendens on the Property or the
Consent Preliminary Order of Forfeiture as part of the purchase or closing of the sale
of the Property.

Had they done so, New Horizon would not have purchased and invested

hundreds of thousands of dollars in improving the Property.
New Horizon first became aware that the United States claimed an interest in

the Property as part of New Horizon’s efforts to sell the Property to a third party.
Case 1:20-cr-00296-JPB-CMS     Document 967-1     Filed 04/15/24     Page 5 of 5
New Horizon purchased the Property in fee simple from The Atlanta 10

Group, LLC on October 14, 2021, and is the current title holder of the Property.

I do not know Charles Hill or any of the defendants in the above-captioned
proceeding.

Neither New Horizon nor I has any relation or connection to All Legal
Hustles, LLC.

New Horizon purchased the Property for value in an arms-length transaction
without actual notice of the lis pendens on the Property or the subsequent Consent
Preliminary Order of Forfeiture.

AFFIANT FURTHER SAITH NOT.

Angelirfa Banks E
Principal
New Horizon Real Estate, LLC

7 (ST day of April 7 Ze

Notary Public
My Commission Expire


File and source

File

gov.uscourts.gand.292225.967.1.pdf

Size

93,711 bytes

SHA-256

b090d9dcd591df677bc51aaf024adacec79b3726d54bb199c7bbc23b21dc06bc

Our copy

gov.uscourts.gand.292225.967.1.pdf

Original

PACER (login required)