Government's Response to Petition of American Commerce Bank, N.A. — United States v. Felicia Stanley (N.D. Fla.)

Record facts

U.S. District Court, Northern District of Florida, Tallahassee Division · No. 4:22-cr-00032-MW-MAF · Doc. 65 · 2023-04-04 · Docket on CourtListener

Full text

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IN THE UNITED STATES DISTRICT COURT 
FOR THE NORTHERN DISTRICT OF FLORIDA 
TALLAHASSEE DIVISION 
 
UNITED STATES OF AMERICA 
          
v. 
 
 
 
 
  
 
 
Case No.: 4:22cr32-MW 
  
FELICIA TIFFANY JACKSON-STANLEY 
and 
WILBUR JEAN STANLEY, III 
 
 
Defendant. 
__________________________________ / 
 
GOVERNMENT’S RESPONSE TO PETITION OF  
AMERICAN COMMERCE BANK, N.A. 
 
 
 COMES NOW, the United States of America, by and through the 
undersigned Assistant United States Attorney, and responds to the petition filed by 
American Commerce Bank, N.A. regarding their interest in Lot 10C on Painted Post 
Lane in Tallahassee, Florida. (ECF No. 63).  
Even though the petition is untimely pursuant to 21 U.S.C. § 853(n)(2), the 
government does not oppose waiving the defect based on the explanation of the 
Claimant contained in the petition. (ECF No. 63). The government recognizes the 
claim of American Commerce Bank for the balance of the note and interest as 
reflected in Exhibit C of the petition. (ECF No. 63-3).  
The Petitioner also requests an unspecified amount of attorney’s fees. (ECF 
No. 63). The government has reviewed the mortgage documents contained in the 
Case 4:22-cr-00032-MW-MAF     Document 65     Filed 04/04/23     Page 1 of 3

 
 
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Petitioner’s filing and acknowledges the provisions for attorney’s fees. (ECF No. 
63-1, 63-2). The government has requested the specific amount of attorney’s fees 
which Petitioner is seeking, and has received an estimate of fees, but has not received 
a final figure yet.  Given the lack of specificity regarding attorney’s fees, the 
government reserves the right to object to attorney’s fees should the requested fees 
be unreasonable.  
 
Respectfully submitted, 
 
JASON R. COODY 
United States Attorney 
 
/s/ Kaitlin Weiss  
  
KAITLIN WEISS 
Assistant United States Attorney  
Florida Bar No. 106130  
111 North Adams Street, Suite 400  
Tallahassee, FL 32301  
(850) 942-8430  
Kaitlin.Weiss@usdoj.gov 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Case 4:22-cr-00032-MW-MAF     Document 65     Filed 04/04/23     Page 2 of 3

 
 
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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 383 words.  In making this certification, I have 
relied upon the word-count feature of Microsoft Word.  
/s/ Kaitlin Weiss 
 
KAITLIN WEISS 
Assistant United States Attorney 
 
CERTIFICATE OF SERVICE 
 
I HEREBY CERTIFY that I electronically filed the foregoing 
document with the Clerk of the Court using CM/ECF on April 4, 2023, for 
service on all parties herein, and emailed to counsel for the Petitioner 
Christopher Thompson, Esq. at crthompson@burr.com and mlucca-
cruz@burr.com, and Adam Smart, Esq. at asmart@burr.com and 
jmlewis@burr.com.  
/s/ Kaitlin Weiss  
 
KAITLIN WEISS 
Assistant United States Attorney 
 
 
Case 4:22-cr-00032-MW-MAF     Document 65     Filed 04/04/23     Page 3 of 3

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