Government's Motion for Entry of Final Order of Forfeiture — 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. 82 · 2023-09-14 · Docket on CourtListener

Full text

1 
 
IN THE UNITED STATES DISTRICT COURT FOR THE 
NORTHERN DISTRICT OF FLORIDA 
TALLAHASSEE DIVISION 
 
UNITED STATES OF AMERICA, 
 
v. 
Case No.  4:22cr32-MW-MAF 
 
FELICIA TIFFANY JACKSON-STANLEY  
AND  
WILBERT J. STANLEY III,  
Defendants.  
                              / 
 
GOVERNMENT'S MOTION FOR ENTRY OF 
FINAL ORDER OF FORFEITURE 
 
The United States of America, by and through the undersigned Assistant 
United States Attorney, respectfully requests that this Court enter a Final Order of 
Forfeiture in the above-captioned criminal forfeiture matter against the following: 
A. $385,412.00 as substitute res in lieu of 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. 1 
 
1 As outlined below, on February 3, 2023, this Court authorized the interlocutory sale of The Kay 
Avenue apartment building.  The net proceeds from the sale were deposited with the United 
States Internal Revenue Service in the Treasury Suspense Account. The Government now 
requests the forfeiture of the net proceeds of the sale—$385,412.00—as a direct asset in lieu of 
the Kay Avenue property.  
Case 4:22-cr-00032-MW-MAF     Document 82     Filed 09/14/23     Page 1 of 8

 
 
2 
 
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 C0100.2  
 
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  
 
 
2 Hereinafter referred to as the “Painted Post property.” 
Case 4:22-cr-00032-MW-MAF     Document 82     Filed 09/14/23     Page 2 of 8

 
 
3 
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 
Counts Three and Four with making false statements, in violation of Title 18, United 
States Code, Section 1001. (Doc. 1). 
2. 
The Information included a criminal forfeiture allegation, pursuant to 
Title 18, United States Code, Sections 982(a)(1) and 982(a)(2), and Title 28, United 
States Code, Section 2461(c). Id. 
3. 
On July 29, 2022, the Defendants pled guilty to all four Counts of the 
Information. (Docs. 24-25). By pleading guilty to Counts One through Four, as 
stated in the Plea Agreement documents, the Defendants agreed to forfeit all 
forfeitable assets, pursuant to Title 18, United States Code, Section982(a)(2)(A).  
(Docs. 24-25).  
4. 
On November 29, 2022, this Court entered a Preliminary Order of 
Forfeiture against the property described above. (Doc. 41).  
Case 4:22-cr-00032-MW-MAF     Document 82     Filed 09/14/23     Page 3 of 8

 
 
4 
5. 
The Preliminary Order of Forfeiture and the Defendant’s plea 
agreement stated that the Government would terminate the forfeiture had restitution 
been paid in full by the time of sentencing. (Docs. 24, 25, 41). The Government has 
confirmed that, as of September 12, 2023, Felicia Jackson-Stanley has paid 
$1,000.00 in restitution, and Wilbert Stanley has paid $4,000.00 in restitution. The 
outstanding restitution balance is $2,798,990.76. Because restitution has not been 
satisfied, the Government is proceeding with the forfeiture of these assets.  
6. 
Pursuant to Rule 32.2 (b)(4)(A) of the Federal Rules of Criminal 
Procedure, the Preliminary Order of Forfeiture became final as to the defendants 
Felicia Tiffany Jackson-Stanley and Wilbert J. Stanley III, at the time of their 
sentencing on May 2, 2023.  On May 11, 2023, a judgment was entered with the 
court forfeiting the defendant’s interest in the above-listed property. (Docs. 75, 77). 
7. 
Pursuant to Rule 32.2(b)(6)(C), publication must take place as 
described in Supplemental Rule G(4)(a)(iii) of the Federal Rules of Civil Procedure 
by any means described in Rule G(4)(a)(iv), which authorizes publication by 
internet. As such, notice of this forfeiture action and the intent of the United States 
of America to dispose of the property was published on an official Internet 
government forfeiture site, www.forfeiture.gov, for at least 30 consecutive days, 
beginning January 6, 2023. (Doc. 81). 
Case 4:22-cr-00032-MW-MAF     Document 82     Filed 09/14/23     Page 4 of 8

 
 
5 
8. 
The Internet publication notified all who might have an interest in the 
real property of the United States’ intent to dispose of such property and provided 
instructions on filing a petition to adjudicate an interest in the property.  In 
accordance with the above-referenced provisions, a person or entity had 60 days 
from the first date of publication to file a petition with the District Court. Thus, the 
time for filing such petitions has expired. 
9. 
On February 2, 2023, the Government filed a joint motion for 
interlocutory sale as to the Kay Avenue property. (Doc. 53). The motion was granted 
on February 3, 2023. (Doc. 56). The Kay Avenue property was sold, and the net sale 
proceeds totaled $385,412.00. This amount was deposited in the Treasury Suspense 
Account.  
10. 
American Commerce Bank held the mortgages for the Kay Avenue and 
the Painted Post properties (Items A and B in the list of property, above). American 
Commerce Bank was noticed as to the forfeiture proceedings against both properties. 
As to the Kay Avenue property, American Commerce Bank agreed to the 
interlocutory sale of the Kay Avenue property, and their interest in that property has 
been satisfied. (Doc. 63, ¶ 10).  
11. 
As to the Painted Post property, American Commerce Bank filed a 
belated Petition establishing their interest, which the Government and the Court 
Case 4:22-cr-00032-MW-MAF     Document 82     Filed 09/14/23     Page 5 of 8

 
 
6 
recognized. (Docs. 63, 65-66). As noted in the Court’s order, the Government agrees 
that from the proceeds of the sale of the Painted Post property, the United States will 
pay American Commerce Bank the unpaid balance of the note, interest, and 
reasonable attorney’s fees due under the mortgage. (Doc. 66). 
12. 
 Cross Country Mortgage held the mortgage to the Laurel Trace 
Property (Item C in the list of property, above). Cross Country Mortgage was noticed 
regarding the forfeiture of the property, and the United States and Cross Country 
Mortgage have entered into a Stipulated Settlement Agreement. Exhibit 1. The 
parties agree that from the proceeds of the sale of the Laurel Trace property, the 
United States will pay Cross Country Mortgage the unpaid principal, interest, taxes, 
and casualty insurance premiums due under the mortgage.   
13. 
The government has no knowledge of any third-party interest in the 
above-mentioned property, and no person or entity beyond the previously-described 
mortgage holders have filed a claim. 
14. 
A proposed Final Order of Forfeiture will be submitted for the Court’s 
consideration. 
Applicable Law 
15. 
When all third-party petitions have been adjudicated, or if no petitions 
are filed, it is appropriate to enter a final order of forfeiture in accordance with Rule 
Case 4:22-cr-00032-MW-MAF     Document 82     Filed 09/14/23     Page 6 of 8

 
 
7 
32.2(c)(2) of the Federal Rules of Criminal Procedure.  In addition, 21 U.S.C. § 
853(n)(7) provides that following the disposition of all petitions, or if no petitions 
are timely filed in accordance with 21 U.S.C. § 853(n)(2), “the United States shall 
have clear title to property that is the subject of the order of forfeiture and may 
warrant good title to any subsequent purchaser or transferee.”  21 U.S.C. § 
853(n)(7). 
16. 
 As discussed above, other than American Commerce Bank and Cross 
Country Mortgage—whose interests have been addressed herein—no other party has 
have filed a petition or claimed an interest in the real property, and the time for filing 
such petition has expired. 
Conclusion 
17. 
Publication having been effected, and all claims or petitions to 
adjudicate an interest having been addressed, it is now appropriate to enter a final 
order of forfeiture for the property.   
18. 
WHEREFORE, the United States respectfully requests that, pursuant 
to 21 U.S.C. § 853(n)(7), Rule 32.2(c)(2) of the Federal Rules of Criminal 
Procedure, this Court enter a final order, forfeiting to the United States all right, title 
and interest in the real property, for disposition according to law, and vesting clear 
title to said property in the United States of America, subject to the terms of the 
Case 4:22-cr-00032-MW-MAF     Document 82     Filed 09/14/23     Page 7 of 8

 
 
8 
Stipulated Settlement Agreement between the United States and Cross Country 
Mortgage, and the previous order of the Court regarding the interests of American 
Commerce Bank (Doc. 66). 
Dated this 14th of September 2023. 
Respectfully submitted, 
 
JASON 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 82     Filed 09/14/23     Page 8 of 8

File and source

File

gov.uscourts.flnd.433859.82.0.pdf

Size

140,459 bytes

SHA-256

c05ea75c32aa4d8069415c0e6f41a8e56dd2583b3c14c970386ecd653c14edd3

Our copy

gov.uscourts.flnd.433859.82.0.pdf

Original

PACER (login required)