Verified Claim of Ownership by International Aviation, LLC — One 1990 Beechcraft 1900C (S.D. Fla., Dkt. 8)

Summary

Verified Claim of Ownership by International Aviation, LLC, filed as Document 8, entered on the docket October 24, 2008, in United States of America v. One 1990 Beechcraft 1900C Twin Engine Twin-Turbo Prop Aircraft, Case No. 08-61603-CIV-ALTONAGA/Brown, in the U.S. District Court for the Southern District of Florida. The claimant states that it has an interest in the aircraft superior to that of the United States, by virtue of its legal purchase, and states that the aircraft was not used in violation of any federal, state or local law or, if so used, without its knowledge or consent. It requests the immediate return of the aircraft under 18 U.S.C. § 983(f), stating that continued seizure is an extreme hardship. The claim is signed s/s Percy Martinez and a notarized declaration is by Carlos Enriquez Gonzalez.

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Case 0:08-cv-61603-CMA Document 8 Entered on FLSD Docket 10/24/2008 Page 1 of 3

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
MIAMI DIVISION

Case No.: 08-61603-CIV-ALTONAGA/Brown

UNITED STATES OF AMERICA
Plaintiff,

ONE 1990 Beechcraft 1900C TWIN
ENGINE Twin-Turbo Prop Aircraft,

Serial UC118, Venezuelan Registration
No. YV219T

Defendant.

VERIFIED CLAIM OF OWNERSHIP BY INTERNATIONAL AVIATION, LLC

COMES NOW the Claimant, International Aviation, LLC, by and through his
undersigned counsel and files this his Claim pursuant to Rule G(5), of the Supplemental Rules
for Certain Admiralty or Maritime and Asset Forfeiture Claims, for the immediate return of the
subject aircraft, and as grounds therefore would show:

1. The Claimant has an interest in the subject property superior to that of the United
States of America. The aircraft of the present action represents the Claimants’ property by
virtue of its legal purchase of the same.

2. The Claimant’s interests constitutes a lien and valid claim on the subject property
which must be satisfied in any subsequent disposition of the subject property.

3. The Claimant asserts that the subject aircraft was not used in manner violating any
federal, state or local law, and, if the aircraft was so used in this manner, it was without its

actual or constructive knowledge or consent of the same. Moreover, if the aircraft was used to
Case 0:08-cv-61603-CMA Document 8 Entered on FLSD Docket 10/24/2008 Page 2 of 3

commit a crime, it had no reason to believe that it would be used in such a manner.

4, The Claimant request the immediate return of the aircraft pursuant to 18 U.S.C. §
983(f) as the continued seizure of the aircraft during the pendency of the forfeiture represents an
extreme hardship to the Claimant.

WHEREFORE the Claimant pray this Honorable Court will award the immediate
return of the aircraft and inventory therein illegally seized by U.S. Customs and Border

Protection and Drug Enforcement Administration.

Respectfully submitted,

PERCY MARTINEZ, P. A.
Attorneys for Claimants

2 Alhambra Plaza

Suite 112

Coral Gables, Florida 33134
Telephone:(305) 529-0001
Fax: (305) 448-0554

By: s/s Percy Martinez
Percy Martinez, Es.

I HEREBY DECLARE, CERTIFY, VERIFY AND STATE, UNDER PENALTY

EXECUTED ON LY OCTOBER 2008 BY CARLOS ENRIQUEZ GONZALEZ.

STATE OF FLORIDA)
) SS:
COUNTY OF DADE )

BE IT KNOWN, that on this Val day of October 2008, before me, the
undersigned authority, personally appeared, Carlos Enriquez Gonzalez who executed the
Case 0:08-cv-61603-CMA Document 8 Entered on FLSD Docket 10/24/2008 Page 3 of 3

within Verified Claim, and they acknowledged it to be true accupe

—

NOTARY PUBLIC, State of Florida at Large

Expires October 25 2008

My Commission Expires:


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