Notice Re: Forfeiture Proceeding — United States v. Dennis Nobbe (S.D. Fla., Dkt. 42)

Summary

Document 42, entered December 7, 2020, in Case 1:20-mj-03236-JB, United States of America v. Dennis Nobbe, in the U.S. District Court for the Southern District of Florida. In a Notice Re: Forfeiture Proceeding, attorney H. Dohn Williams Jr. tells the Court and the Government that he does not represent the Estate of the Defendant, saying his representation ceased with Mr. Nobbe's passing and the dismissal of the case. Attached are FBI Notices of Seizure of Property and Initiation of Administrative Forfeiture Proceedings, addressed to the estate. Their asset lists show funds of $2,326.67 and $81,382.00 seized on July 23, 2020, from accounts in the names of Dynamic Medical Services, Inc. and Creative Chiropractic, 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

Cite this document

“Notice Re: Forfeiture Proceeding — United States v. Dennis Nobbe (S.D. Fla., Dkt. 42).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-1-20-mj-03236-dkt-42-s-d-fla-d580da70d5/, SHA-256 02f3d40f156ceab4dfbe277cf737aa8150140d02d48b2e4aa51a63b0121c0a9e.

Full text

Case 1:20-mj-03236-JB Document 42 Entered on FLSD Docket 12/07/2020 Page 1 of 9

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

Case No. 1:20- MJ-03236

UNITED STATES OF AMERICA,

DENNIS NOBBE,

Defendant.
_______________________________/

NOTICE RE: FORTEITURE PROCEEEDING
The undersigned attorney notifies the Court and the Government that the undersigned does
not represent the Estate of the Defendant, Dennis Nobbe. Twice recently, with the most recent
being December 7, 2020, the undersigned received notices to the Estate of Dennis Nobbe. (see
the attached). The undersigned does not represent his estate. The undersigned’s representation
ceased with Mr. Nobbe’s passing and the dismissal of his case. The Government should contact
his daughters, Ashley Winkler (ashwinkler3@gmail.com), and Callen Nobbe
(callenmnobbe@gmail.com), as they may have information regarding his estate
Certificate of Service
I HEREBY CERTIFY that the government’s counsel was sent a copy of this document via
the e-filing portal as well as via email on December 7, 2020.
H. DOHN WILLIAMS JR.
Attorney for Defendant
633 SE 3rd Avenue #202
Fort Lauderdale, FL 33301
444 W. Palmetto Park Road #D201
Boca Raton, FL 33432
Tel. (561) 929-5432 Main Number
e-file pleadings - hdohn@outlook.com
e-mail gen. correspondence – hdohn@outlook.com

By: /s/: Harry Dohn Williams Jr.
Harry Dohn Williams Jr.
Fla. Bar # 0166087
Case 1:20-mj-03236-JB Document 42 Entered on FLSD Docket 12/07/2020 Page 2 of 9

U.S. Department ofJustice

Federal Bureau of Investigation

Washington, D6' 20535

The kstate of Dennis Nobbe
c/oHarry Dohn Williams Jr. Esq.
990N W 5th Street
Boca Raton, PL 33486

NOTICE OF SEIZURE OF PROPERTY AND INITIATION OF
ADMINISTRATIVE FORFEiTURE PROCEEDINGS
SEIZED PROPERTY IDENTIFYING INFORMATION
Notice Date: November 25,2020 Asset ID Number: Multiple Assets
Notice Letter ID: 218816 (use ID when searching forassets during online filing)
Description of Seized Property: See Attached List

Seizure Date and Location: See Attached List
Forfeiture Authority: See Attached List

1. THE GOVERNMENT MAY CONSIDER GRANTING PETITIONS FOR REMISSION OR MITIGATION, WHICH PARDONS ALL
OR PART OF THE PROPERTY FROM THEFORFEITURE.

TO REQUESTA PARDON OF THE PROPERTY YOU MUST FILEA PETITION FOR REMISSION OR MITIGATION

A. What toFile: You may file botha claim (see section II below) anda Petition for Remission or Mitigation (Petition). If you
file onlya petition and no one else filesa claim, your petition will be decided by the seizing agency.
B. To Filea Petition: A petition should be filed online or by mailing it via the U.S. Postal Service ora Commercial Delivery
Service to the Federal Bureau of Investigation (FBI), Attn: Forfeiture Paralegal Specialist, 2030 SW 145th Avenue, Miramar,
FL 33027, It must be received no later than 11:59 PM EST thirty (30) days ofyour receipt of this Notice. See 28 C.F.R.
PartsI and 9.
Requirements forPetition: The petition must includea description of your interest in the property supported by
documentation and any facts you believe justify the return of thep roperty and be signed under oath, subject to the penalty
of perjury or meet therequirements of an unsworn statement under penalty of pequry. See 28 U.S.C.§ 1746.

Petition Forms: A petition need notbe made inanyparticular form but a standard petition form and the link to file the
petition online are available at https //www *orIeiture.gov/I- ilinqPetition htm If you wish tofilea petition online forthe assets
referenced in the asset list of this letter, please use the Notice Letter ID referenced above.
E. Supporting Evidence: Although not required, you may submit supporting evidence (for example, title paperwork or bank
records showing your interest in the seized property) to substantiate your petition.
F. No Attorney Required: You do not need an attorney to filea petition. You may, however, hire an attorney to represent you
in filinga petition.
Petition Granting Authority: The ruling official in administrative forfeiture cases is the Unit Chief, Legal Forfeiture Unit,
O9ice ofthe General Counsel. The ruling official in judicial forfeiture cases is the Chief, Money Laundering and Asset
Recovery Section, Criminal Division, Department ofJustice. See 28 C. F.R,§ 9.1.
H. Regulations for Petition: The RegulationS9 overning the petition process are set forth in 28 C.F.R. Part 9, and are
available at www forfeiture gov.
I. Penalties for Filing False or Frivolous Petitions: A petition containing false information may subject the petitioner to
criminal prosecution under 18 U.S.C.§ 1001 and 18 U.S.C.§ 1821.
Case 1:20-mj-03236-JB Document 42 Entered on FLSD Docket 12/07/2020 Page 3 of 9

Tne Estate of Dennis Nobbe Notre ofSe‹zure

J Online Petition Exclusions: If you cannot find the des red assets online, you must file your petition in writing at the
address listed above. For more details regarding what assets can be Detitioned online. please see the Frequently Asked
Ouestions at https //www forfeiture qov/F›IinqPetitionFAOs htm

II. TO CONTEST THE FORFEITURE OF THIS PROPERTY INUNITED STATES DISTRICT COURT YOU MUST FILEA CLAIM.
If you cIo not filea c/‹u/rr/, you will wnive yn //r nghl to contest the forfeimre of the as el. A‹!dihoi holly, if rio o//›er C/a/rrix are /i/ed, you may
I ‹›t de ‹h›/e fc ron/e.sf the fo/Ye/t‹//”e of //›/ asset /m and offerg ocee‹//r/g. c°/r/J/cal or c/all

A To Filea Claim: A claim must be *ited to contest the forfeiture A claim should be filed online or by mailing it via the U S
Portal Service ora Commercial Delivery Service :o the FBI Attn F orfeitu^e Paralegal Specialist. 2030 SW 145th Avenue
Mirama, FL 33027
B Time Limits A claim must be filed within 35 oays ofthe date o* this letter the efore. you must file your claim by 11: 59 PM
EST on December 30,2020. S 18 U S.C § 983(a)(2). A claim is deemed filed on tne date received by tne agency atthe
address listed above
C Requirements forClaim. A claim must be filed online or in writing, describe the seized prupeity, state youl- ownership or
other interest in the propeJy and be made under oath subject to penalty of pe^jury or meet therequirements of an unsworn
statement under penalty of perjury See 18U S G § 983(a)(2)(C) and 28 U S C § 1746
D Claim Forms. A claim need notbe made in any panicular form buta standard claim form and the link to file the claim online
are avaiIaD!e at httgs //www.forfeiture gov/FilinqClaim htm See 18U S C.§ 983(a)(2)(D) I you wish to filea claim on line
far the assets referenced in the asset list of this letter please use the Notice Letter ID referenced above

Supporting Evidence Although not required, you may submit supporting evidence (for example, title paperwork or bank
records showing your interest in the se›Zed prg perty) to substantiate your claim
F No Attorney Required: You do not need an attorney to filea claim. You may however. hire an attorney to represent you in
filinga claim
G When You Filea Claim A timely claim stops the administrative forfeiture proceeding. The seizing agency forwards the
timely claim to the U.S Attorneys Office *or furtherD oceedings You may also filea petition for remission or mitigation

H Penalties for Filing False or Frivolous Claims: I* you intentionally filea frivolous claim you may be subject toa civI fine
s 1g u s c \ 983(h). If you intentionally *ilea claim containing false information. you may be subject to criminal
prosecution. 3ee 18U S C § 1001
If No Claim is Filed Failure to filea claim by 11 :59 PM EST on December 30,2020 may result in tne property being
*orfe›ted to the United States.
Online Claim Exclus ions: If you cannot find the desired assets online you must *ice your claim in writing and send tothe
address listed above For more details regarding what assets can be claimed online. please see the Frequently Asked
Questions at https //www forfeiture qov/* ilinqñIa›ml-Ads htm

111. TO REQUEST RELEASE OF PROPERTY BASED ON HARDSHIP
A Hardship Release: Upon thefiling ofa proper claim,a claimant may request release of the seized property during the
pendency oftheforfeiture proceed Engdue to nardship if the claimant is able to meet speci*ic conditions See 18 U S C §
983(I), 28 C F.R.§ 8.15.
B To File Hardship Release: The hardship request cannot we fled online and must be ›n writing The claimant must
establish the following
• Claimant hasa possessory inte est in the property
• Claimant has suff›c‹ent ties to the commun›\y toassure that the property well be av ai/abIe at the tame of trial
and
• Governments continued possession will causea substantial hardship to the claimant
C. Regulations for Hardship: A complete list of the hardship provisions can be reviewed at 18U S C § 9B3(I) and 28 C.F R.§
8 15 Some assets are not eligible for release
Case 1:20-mj-03236-JB Document 42 Entered on FLSD Docket 12/07/2020 Page 4 of 9

The Estate of Dennis Nobbe Notice of Seizure

Asset List

Seizure Date and Location: The asset(s) referenced inthis notice letter were seized on July 23, 2020 by theFBI atMiami,
Florida

Forfeiture Authority: The forfeiture of this property has been initiated pursuant to 18 USC 981(a)(1)(C) and the following
additional federal laws. 19 U.S.C. §§ 1602-1619, 18 U.S C.§ 983 and 28 C.F R. Parts8 and 9

ASSET ID ASSET DESCRIPTION ASSET VALUE ACCT/VIN/SERIAL NO
20-FBI -004819 $2,326.67 infunds from account number 0000241730239, $2,326 67 241730239
held in the name ofDynamic Medical Services, Inc., at BB&T
Bank, now TruistF inancial, in Miami, FL
20-FBI-004820 $81,382.00 infunds from account number 00002423927 01, $81.382.00 242392701
held in the name ofCreative Chiropractic, LLC. at BB&T
Bank, now TruistF inancial, in Miami, FL
Case 1:20-mj-03236-JB Document 42 Entered on FLSD Docket 12/07/2020 Page 5 of 9

9414 7266 9904 2965 05BB 5#
Return Receipt Requested
Case 1:20-mj-03236-JB Document 42 Entered on FLSD Docket 12/07/2020 Page 6 of 9

“
,
Case 1:20-mj-03236-JB Document 42 Entered on FLSD Docket 12/07/2020 Page 7 of 9

U.S. Department ofJustice

b ederal Bureau of Investigation

Washington, DC 2fl535

"l’he kstate of Dennis Nobbe
c/oHarry Dohn Wllliams Jr. Esq.
444 W Palmetto Park Road
# D20l
Boca Raton, FL 33432

NOTICE OF SEIZURE OF PROPERTY AND INITIATION OF
ADMINISTRATIVE FORFEITURE PROCEEDINGS
SEIZED PROPERTY IDENTIFYING INFORMATION
Notice Date: November 25,2020 Asset ID Number: Multiple Assets
Notice Letter ID: 218818 (use ID when searching forassets during online filing)
Description of Seized Property: See Attached List

Seizure Date and Location: See Attached List
Forfeiture Authority: See Attached List

I. THE GOVERNMENT MAY CONSIDER GRANTING PETITIONS FOR REMISSION OR MITIGATION, WHICH PARDONS ALL
OR PART OF THE PROPERTY FROM THEFORFEITURE.

TO REQUESTA PARDON OF THE PROPERTY YOU MUST FILEA PETITION FOR REMISSION OR MITIGATION

A What toFile: You may file botha claim (see section II below) anda Petition for Remission or Mitigation (Petition). If you
file onlya petition and no one else filesa claim, your petition will be decided by the seizing agency.
B. To Filea Petition: A petition should be filed online or by mailing it via the U.S. Postal Service ora Commercial Delivery
Service to the Federal Bureau ofInvestigation (FBI), Attn: Forfeiture Paralegal Specialist, 2030 SW 145th Avenue, Miramar,
FL 33027. It must be received no later than 11:59 PM EST thirty (30) days ofyour receipt of this Notice. See 28 C.F.R.
Parts8 and 9.
c Requirements forPetition: The petition must includea description of your interest in the property supported by
documentation and any facts you believe justify the return of the property and be signed under oath, subject to the penalty
of pequry or meet therequirements of an unsworn statement under penalty of perjury. See 28 U.S.C.§ 1746.

Petition Forms: A petition need notbe made in any particular form buta standard petition form and the link to file the
petition online are available at https://www *orteiture qov/F iIinq*etition htm. If you wish tofilea petition online for the assets
referenced in the asset list of this letter, please use the Notice Letter ID referenced above.
E. Supporting Evidence: Although not required, you may submit supporting evidence (for example, title paperwork or bank
records showing your interest in the seized property) to substantiate your petition.
F. No Attorney Required: You do not need an attorney to filea petition. You may, however, hire an attorney to represent you
in filinga petition.
Petition Granting Authority: The ruling official in administrative forfeiture cases is the Unit Chief, Legal Forfeiture Unit,
Office of the General Counsel. The ruling official in judicial forfeiture cases is the Chief, Money Laundering and Asset
Recovery Section, Criminal Division, Department ofJustice. See 28 C.F R.§ 9.1.
H. Regulations for Petition: The Regulations governing the petition process are setforth in 28 C.F.R. Part 9, and are
available at www *orteiture gov.
I. Penalties for Filing False or Frivolous Petitions: A petition containing false information may subject the petitioner to
criminal prosecution under 18 U.S C.§ 1001 and 18 U.S.C.§ 1621.
Case 1:20-mj-03236-JB Document 42 Entered on FLSD Docket 12/07/2020 Page 8 of 9

The Estate of Dennis Nobbe Notice of Seizure

J. Online Petition Exclusions: If you cannot find the desired assets online, you must file your petition in writing at the
address listed above. For more details regarding what assets can be petitioned online, please see the Frequently Asked
Questions at https.//www forfeiture qDv/F iIinqF'etition FAUs htm.

II. TO CONTEST THE FORFEITURE OF THIS PROPERTY INUNITED STATES DISTRICT COURT YOU MUST FILEA CLAIM.
Ifyou do not filea claim. y •u will waive yourright to contest the fodeifure of the asset. Additionally, if no other claims are filed, you may
not be able to contest the fodeiture of this asset in any otherproceeding, criminal or civil.

A. To Filea Claim: A claim must be filed to contest the forfeiture. A claim should be filed online or by mailing it via the U.S.
Postal Service ora Commercial Delivery Service to the FBI, Attn: Forfeiture Paralegal Specialist, 2030 SW 145th Avenue,
Miramar, FL 33027.
B. Time Limits: A claim must be filed within 35 days ofthedate of this letter; therefore, you must file your claim by 11:59 PM
EST on December 30,2020. See 18 U.S.C.§ 983(a)(2). A claim is deemed filed on the date received by the agency atthe
address listed above.
Requirements forClaim: A claim must be filed online or in writing, describe the seized property, state your ownership or
other interest in the property and be made under oath, subject to penalty of perjury or meet therequirements of an unsworn
statement under penalty of perjury. See 18 U.S.C.§ 983(a)(2)(C) and 28 U.S.C.§ 1746.
D. Claim Forms: A claim need notbe made in any particular form, buta standard claim form and the link to file the claim online
are available at https //www.forfeiture gov/FilinqClaim htm. See 18 U.S.C.§ 983(a)(2)(D). If you wish tofilea claim online
for the assets referenced in the asset list of this letter, please use the Notice Letter ID referenced above.

E. Supporting Evidence: Although not required, you may submit supporting evidence (for example, title paperwork or bank
records showing your interest in the seized property) to substantiate your claim.
No Attorney Required: You do not need an attorney to filea claim You may, however, hire an attorney to represent you in
filinga claim.
When YouFilea Claim: A timely claim stops the administrative forfeiture proceeding. The seizing agency forwards the
timely claim to the U. S. Attorney’s Office for further proceedings. You may also filea petition for remission or mitigation,

Penalties for Filing False or Frivolous Claims: If you intentionally filea frivolous claim you may be subject toa civil fine.
See \ 8 U.S.C.§ 983(h). If you intentionally filea claim containing false information, you may be subject to criminal
prosecution. See 18 U.S.C.§ 1001.
1. If No Claim IsFiled: Failure to filea claim by 11:59 PM EST on December 30,2020 may result in the property being
forfeited to the United States.
J. Online Claim Exclusions: If you cannot find the desired assets online, you must file your claim in writing and send tothe
address listed above. For more details regarding what assets can be claimed online, please see the Frequently Asked
Questions at https.//www.›orteiture gov/F IingñlaimFAUs htm.

III. TO REQUEST RELEASE OF PROPERTY BASED ON HARDSHIP
A. Hardship Release: Upon thefiling ofa proper claim,a claimant may request release of the seized property during the
pendency oftheforfeiture proceeding due to hardship if the claimant is able to meet specific conditions. See 18 U.S.C.§
983(I); 28 C.F.R.§ 8.15.
B. To File Hardship Release: The hardship request cannot be filed online and must be in writing. The claimant must
establish the following:
• Claimant hasa possessory interest in the property;
• Claimant has sufficient ties to the community toassure that the property will be available at the time of trial;
and
• Government's continued possession will causea substantial hardship to the claimant.
C. Regulations for Hardship: A complete list of the hardship provisions can be reviewed at 18 U.S.C.§ 983(I) and 28 C.F.R.§
8.15. Some assets are not eligible for release.
Case 1:20-mj-03236-JB Document 42 Entered on FLSD Docket 12/07/2020 Page 9 of 9

Fhe Estate of Dennis Nobbe Notice of Seizure

Asset List

Seizure Date and Location: The asset(s) referenced in this notice letter were seized on July 23, 2020 by theFBI atMiami,
°lorida.

"orfeiture Authority: The forfeiture of this property has been initiated pursuant to 18 USC 981 (a)(1 )(C) and the following
additional federal laws: 19 U.S.C. §§ 1602-1619, 18 U.S.C.§ 983 and 28C F.R. Parts8 and 9.

ASSET ID ASSET DESCRIPTION ASSET VALUE ACCT/VIN/SERIAL NO
?0-FBI-004819 $2,326.67 in funds from account number 0000241730239, $2,326 67 241730239
held in the name ofDynamic Medical Services, Inc., at BB&T
Bank, now Truist Financial, in Miami, FL
?0-FBI-004820 $81,382.00 in funds from account number 0000242392701, $81,382 00 242392701
held in the name ofCreativeC hiropractic, LLC, at BB&T
Bank, now Truist Financial, in Miami, FL

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