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Home Court filings United States v. Felicia Stanley Government's Motion for Preliminary Order of Forfeiture — United States v. Felicia Stanley (N.D. Fla.)

Court filing

Government's Motion for Preliminary Order of Forfeiture — United States v. Felicia Stanley (N.D. Fla.)

Filed November 28, 2022 in U.S. v. Felicia Stanley; one of 15 filings from this case.

Record facts

CourtU.S. District Court, Northern District of Florida, Tallahassee Division
Filed2022-11-28

U.S. District Court, Northern District of Florida, Tallahassee Division · No. 4:22-cr-00032-MW-MAF · Doc. 40 · 2022-11-28 · Docket on CourtListener

Full text

IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF FLORIDA 
TALLAHASSEE DIVISION 
 
UNITED STATES OF AMERICA 
  
v. 
 
 
 
 
 
 
CASE NO. 4:22-cr-32-MW/MAF 
 
FELICIA TIFFANY JACKSON-STANLEY 
 
AND 
WILBERT J. STANLEY III 
______________________________/ 
 
GOVERNMENT'S MOTION FOR  
PRELIMINARY ORDER OF FORFEITURE 
 
The United States of America, by and through the United States Attorney for 
the Northern District of Florida, respectfully moves this Court pursuant to Federal 
Rules of Criminal Procedure, Rule 32.2(b) for the issuance of a Preliminary Order 
of Forfeiture in the above-styled criminal matter against the following property: 
A. Real property located and situated in Leon County, Florida, located 
at 1660 Kay Avenue, Units 1,2,3,4,5,6,7,and 8, Tallahassee, FL 32301, 
and all areas designated as common elements of Greenside 
Condominiums, further described in Leon County Official Records 
Book 5470 and Page 79, and known to the Leon County Property 
Appraiser as Parcel Identification #s 3108360000010, 3108360000020, 
3108360000030, 3108360000040, 3108360000050, 3108360000060, 
3108360000070, 3108360000080, respectively. 
  
B. Real property located and situated in Leon County, Florida: Lot 10, 
Block C, Tallahassee Ranch Club, according to the plat thereof, 
recorded in Plat Book 18, Page(s) 1 through 35, of the inclusive, Public 
Records of Leon County, Florida, and further described in Leon 
County Official Records Book 5496 and Page 1308, and known to the 
Leon County Property Appraiser as Parcel Identification # 332525 
Case 4:22-cr-00032-MW-MAF     Document 40     Filed 11/28/22     Page 1 of 6

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C0100. 
 
C. Real property located and situated in Leon County, Florida, located 
at 3770 Laurel Trace Way, Tallahassee, FL 32303, described as: Lot 
6, Block D of Laurel Trace, According to the Plat thereof as Recorded 
in Plat Book 16, Page 75, of The Public Records of Leon County, 
Florida, and further described in Leon County Official Records Book 
5510 and Page 39, and known to the Leon County Property Appraiser 
as Parcel Identification #210929D0060. 
 
D. The Coinbase account with user identification number ending in 
9b775ae, held in the name of WILBERT STANLEY and/or associated 
with email address yepwekan@gmail.com. 
 
E. The Coinbase account with user identification number ending in 
8d710141, held in the name of FELICIA STANLEY and/or associated 
with email address liciapooh01@hotmail.com. 
 
F. The Robinhood account ending in 2819, held in the name of FELICIA 
STANLEY. 
 
G. The Robinhood account ending in 1939, held in the name of 
WILBERT STANLEY. 
 
H. The TD Ameritrade account ending in 1466, held in the name of 
FELICIA JACKSON-STANLEY. 
 
1. 
On June 17, 2022, an Information was filed against the Defendants, 
charging them both in Count One with conspiracy to commit wire fraud, in violation 
of Title 18, United States Code, Section 1343; in Count Two with money laundering 
conspiracy, in violation of Title 18, United States Code, Section 1956(h); and in 
Case 4:22-cr-00032-MW-MAF     Document 40     Filed 11/28/22     Page 2 of 6

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Count Three1 or Count Four2 with making false statements, in violation of Title 18, 
United States Code, Section 1001. (ECF Doc. 1) 
2. 
The Information included a criminal forfeiture provision pursuant to 
Title 18, United States Code, Sections 982(a)(1) and 982(a)(2), and Title 28, 
United States Code, Section 2461(c), that put the Defendants on notice that the 
United States would seek to forfeit the above-described property as property 
constituting and derived from proceeds traceable to offenses described in Counts 
One, Three, and Four, or as property involved in the offense alleged in Count Two, 
of the Information. (Id.) 
3. 
On July 29, 2022, the Defendants pled guilty to all four counts of the 
Information.  As part of their guilty pleas, the Defendants agreed that their 
sentences included the forfeiture of all forfeitable assets which included the above-
described property.3 (ECF Docs. 24-25 at pgs. 2-3) 
4.   For the reasons stated above, the United States requests that the Court 
forfeit to the United States the above-described property and further requests that, 
 
1 Defendant Felicia Jackson-Stanley was charged in Count Three. 
2 Defendant Wilbert Stanley III was charged in Count Four. 
3 The Government has agreed that it will not proceed with forfeiture of the assets listed in 
the Plea Agreements if the Defendants pay restitution described in the Plea Agreement in full 
prior to sentencing in this case. To date, no known restitution has been paid by the Defendants.  
Prior to seeking a Final Order of Forfeiture, the undersigned with consult with defense counsel to 
confirm that no restitution has been paid by the Defendants; if at that time restitution has been 
paid in full, then the Government will move to vacate the Preliminary Order of Forfeiture it 
seeks herein. 
Case 4:22-cr-00032-MW-MAF     Document 40     Filed 11/28/22     Page 3 of 6

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the order of forfeiture become final as to the Defendants at sentencing. 
5.    Upon issuance of a Preliminary Order of Forfeiture, the United States 
will publish notice of this Order on the Government’s official Internet website, 
www.forfeiture.gov, and will send direct notice to any person, other than the 
defendants, having or claiming a legal interest in the property, advising such person 
of his or her right to file a petition contesting the forfeiture in accordance with Title 
21, United States Code, Section 853(n) and Rule 32.2(c).  This notice will state that 
the petition shall be for a hearing to adjudicate the validity of the petitioner’s alleged 
interest in the property, shall be signed by the petitioner under penalty of perjury and 
shall set forth the nature and extent of the petitioner’s right, title or interest in the 
forfeited property and any additional facts supporting the petitioner’s claim and the 
relief sought. 
6. 
In accordance with the Title 18, United States Code, Sections 
982(a)(1) and 982(a)(2), and Title 28, United States Code, Section 2461(c), and 
Rule 32.2(b)(3) of the Federal Rules of Criminal Procedure, the United States 
requests that it be permitted to seize the specific property subject to forfeiture 
whether held by the defendants or a third party, and to undertake whatever 
discovery is necessary to identify, locate or dispose of the property subject to 
forfeiture, or substitute assets for such property. 
7. 
 As required by Federal Rule of Criminal Procedure 32.2(b)(4), the 
Case 4:22-cr-00032-MW-MAF     Document 40     Filed 11/28/22     Page 4 of 6

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United States requests that the Court include the forfeiture when orally pronouncing 
the sentences and in the judgments. 
8. 
The United States further requests that the Court retain jurisdiction to 
address any third-party claim that may be asserted in these proceedings, and to enter 
any further order necessary for the forfeiture and disposition of such property. 
9. 
A proposed Preliminary Order of Forfeiture will be submitted for the 
Court’s consideration. 
WHEREFORE, the United States respectfully requests entry of a Preliminary 
Order of Forfeiture for the above-described property. 
Dated this 28th day of November, 2022. 
                                    Respectfully submitted, 
 
JASON R. COODY 
United States Attorney 
 
/s/ Justin M. Keen            
JUSTIN M. KEEN 
Assistant United States Attorney 
Florida Bar Number: 021034 
111 North Adams Street, Fourth Floor 
Tallahassee, FL 32301 
Justin.Keen@usdoj.gov 
(850) 942-8430 
 
 
 
Case 4:22-cr-00032-MW-MAF     Document 40     Filed 11/28/22     Page 5 of 6

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CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1(F) 
I hereby certify, pursuant to N.D. Fla. Loc. R. 7.1(f), that this filing complies 
with the word limit and contains 1,095 words. This response was prepared using 
Microsoft Word 2016 software. In making this certification, I have relied upon the 
word-count feature of Microsoft Word 2016.  
/s/ Justin M. Keen            
JUSTIN M. KEEN 
Assistant United States Attorney 
 
 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that a true and correct copy of the foregoing has been 
filed via the Court’s CM/ECF system on this 28th day of November, 2022, which 
will send notification of such filing to all counsel of record.  
/s/ Justin M. Keen            
JUSTIN M. KEEN 
Assistant United States Attorney 
 
 
Case 4:22-cr-00032-MW-MAF     Document 40     Filed 11/28/22     Page 6 of 6

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  1. Preliminary Order of Forfeiture — United States v. Felicia Stanley (N.D. Fla.)same docket · 2022-11-29
  2. Order Granting 35 & 36 Motions — USA v. Stanley et al. (Dkt. 37, N.D. Fla.)same docket · 2022-09-29
  3. Motion to Continue Sentencing by Wilbert Jean Stanley — USA v. Stanley et al. (Dkt. 48, N.D. Fla.)same docket · 2023-01-19
  4. Consent Motion to Continue Sentencing — USA v. Stanley et al. (Dkt. 36, N.D. Fla.)same docket · 2022-09-28
  5. Motion to Continue Sentencing — USA v. Stanley et al. (Dkt. 49, N.D. Fla.)same docket · 2023-01-19
  6. Consent Motion to Continue Sentencing — USA v. Stanley et al. (Dkt. 35, N.D. Fla.)same docket · 2022-09-28
  7. Order Granting 48 & 49 Motions — USA v. Stanley et al. (Dkt. 50, N.D. Fla.)same docket · 2023-01-19
  8. NOTICE of Lis Pendens by USA as to FELICIA JACKSON STANLEY,… — USA v. STANLEY et al - FELICIA JACKSON STANLEY (Dkt. 34)same docket · 2022-09-02
  9. Criminal Information — United States v. Felicia Stanleysame case · 2022-06-17
  10. Joint Motion Authorizing Interlocutory Sale of Real Property Subject to Forfeiture — United States v. Felicia Stanleysame case · 2023-02-02
  11. Order Granting Joint Motion Authorizing Interlocutory Sale of Real Property — United States v. Felicia Stanleysame case · 2023-02-03
  12. Petition of American Commerce Bank, N.A. for Adjudication of Interest in Property — United States v. Felicia Stanley (N.D. Fla.)same case · 2023-03-28
  13. Government's Response to Petition of American Commerce Bank, N.A. — United States v. Felicia Stanley (N.D. Fla.)same case · 2023-04-04
  14. Order on American Commerce Bank, N.A.'s Petition for Adjudication of Interest in Property — United States v. Felicia Stanley (N.D. Fla.)same case · 2023-04-05
  15. Felicia Jackson-Stanley's Sentencing Memorandum — United States v. Felicia Stanleysame case · 2023-05-01
  16. Criminal Minutes - Sentencing — United States v. Felicia Stanleysame case · 2023-05-02
  17. Exhibit A — USA v. Stanley et al. (Dkt. 53-1, N.D. Fla.)same docket · 2023-02-02
  18. NOTICE of Lis Pendens by USA as to FELICIA JACKSON STANLEY,… — USA v. STANLEY et al - FELICIA JACKSON STANLEY (Dkt. 33)same docket · 2022-09-02
  19. NOTICE of Lis Pendens by USA as to FELICIA JACKSON STANLEY,… — USA v. STANLEY et al - FELICIA JACKSON STANLEY (Dkt. 32)same docket · 2022-09-02
  20. Motion to Extend Time to File Petition — USA v. Stanley et al. (Dkt. 55, N.D. Fla.)same docket · 2023-02-03

Part of: United States v. Felicia Jackson Stanley · U.S. District Court for the Northern District of Florida · Other pandemic litigation · Criminal prosecutions · Orders and opinions · 2022 · Court filings

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