Stipulated Preliminary Order of Forfeiture — United States v. Maurice Brown-Portwood (E.D. Mich., ECF No. 175)
Summary
A Stipulated Preliminary Order of Forfeiture in United States v. D-8 Maurice Brown-Portwood, Case No. 23-cr-20253, in the U.S. District Court for the Eastern District of Michigan, Southern Division, filed March 11, 2025 as ECF No. 175. It rests on the defendant's Rule 11 Plea Agreement (ECF No. 123) and guilty plea to Count One of the Indictment, a violation of 18 U.S.C. § 1349, and on 18 U.S.C. § 981(a)(1)(C) with 28 U.S.C. § 2461(c). The listed property includes $3,200.00 in U.S. currency from a 2017 Tesla Model X, $1,730.00 in currency from a Detroit residence, and funds from Bank of America demand deposit accounts in the names of individuals. The order provides for third-party petitions under Fed. R. Crim. P. 32.2(c)(2). It is signed by Assistant United States Attorney Kelly Fasbinder, defense counsel John M. McManus and United States District Judge Judith E. Levy.
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“Stipulated Preliminary Order of Forfeiture — United States v. Maurice Brown-Portwood (E.D. Mich., ECF No. 175).”
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Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1057 Filed 03/11/25 Page 1 of 18
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
United States of America,
Plaintiff, Case No. 23-cr-20253
Honorable Judith E. Levy
vs.
D-8 Maurice Brown-Portwood,
Defendant.
Stipulated Preliminary Order of Forfeiture
The United States of America, by and through its attorney, Jessica A. Nathan,
Assistant United States Attorney, and Defendant Deangelo Jackson-Portwood, by
and through his attorney, John M. McManus, submit this Stipulated Preliminary
Order of Forfeiture for immediate entry, and agree to the following:
Based on the contents of Brown-Portwood’s Rule 11 Plea Agreement (ECF
No. 123), Brown-Portwood’s guilty plea to Count One of the Indictment, a violation
of 18 U.S.C. § 1349, this Stipulation, and other information in the record, and
pursuant to Fed. R. Crim. P. 32.2, 18 U.S.C. § 981(a)(1)(C) together with 28 U.S.C.
§ 2461(c), IT IS HEREBY ORDERED, ADJUDGED, AND DECREED THAT:
1. Defendant shall forfeit to the United States all right, title and interest he
may possess in any and all property, real or personal, which constitutes or is
Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1058 Filed 03/11/25 Page 2 of 18
derived from proceeds traceable to, and which he acquired as a result of, his
participation in his offense including, but not limited to:
$3,200.00 U.S. Currency from a 2017 Tesla Model X,
VIN: 5YJXCDE23HF059189, registered to and in the
possession of Deangelo Jackson-Portwood at 22028
Malden Street, Farmington Hills, Michigan;
$1,730.00 U.S. Currency from the residence at 17303
Griggs Street, Detroit, Michigan;
$3,900.00 in funds from Demand Deposit Account
#XXXXXXXXX0695 in the name of Alexander Enriquez
at Bank of America, Grosse Pointe Woods, Michigan;
$22,800.00 in funds from Demand Deposit Account
#XXXXXXXXX6046 in the name of Alisa Hughes at
Bank of America, Grosse Pointe Woods, Michigan;
$600.00 in funds from Demand Deposit Account
#XXXXXXXXX2589 in the name of Alishia Pempleton
at Bank of America, Grosse Pointe Woods, Michigan;
$15,000.00 in funds from Demand Deposit Account
#XXXXXXXXX1825 in the name of Amy Spence at
Bank of America, Grosse Pointe Woods, Michigan;
$3.00 in funds from Demand Deposit Account
#XXXXXXXXX7595 in the name of Andrew Daniels at
Bank of America, Grosse Pointe Woods, Michigan;
$8,000.00 in funds from Demand Deposit Account
#XXXXXXXXX3060 in the name of Andrew George at
Bank of America, Grosse Pointe Woods, Michigan;
$13,700.00 in funds from Demand Deposit Account
#XXXXXXXXX6899 in the name of Anissa Forbes at
Bank of America, Grosse Pointe Woods, Michigan;
2
Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1059 Filed 03/11/25 Page 3 of 18
$18,450.00 in funds from Demand Deposit Account
#XXXXXXXXX6541 in the name of Anne Russo at Bank
of America, Grosse Pointe Woods, Michigan;
$13.00 in funds from Demand Deposit Account
#XXXXXXXXX9897 in the name of Araceli Thiele at
Bank of America, Grosse Pointe Woods, Michigan;
$21.32 in funds from Demand Deposit Account
#XXXXXXXXX4661 in the name of Ariana Paulson at
Bank of America, Grosse Pointe Woods, Michigan;
$5,900.00 in funds from Demand Deposit Account
#XXXXXXXXX7619 in the name of Ashli Ceraolo at
Bank of America, Grosse Pointe Woods, Michigan;
$0.85 in funds from Demand Deposit Account
#XXXXXXXXX0097 in the name of Atoe M Jackson at
Bank of America, Grosse Pointe Woods, Michigan;
$15,900.00 in funds from Demand Deposit Account
#XXXXXXXXX3038 in the name of Brandon Ogbodu at
Bank of America, Grosse Pointe Woods, Michigan;
$15,500.00 in funds from Demand Deposit Account
#XXXXXXXXX8262 in the name of Brent Stoll at Bank
of America, Grosse Pointe Woods, Michigan;
$21,900.00 in funds from Demand Deposit Account
#XXXXXXXXX7730 in the name of Brittany Bertheat at
Bank of America, Grosse Pointe Woods, Michigan;
$9,900.00 in funds from Demand Deposit Account
#XXXXXXXXX6384 in the name of Carlie Cantrell at
Bank of America, Grosse Pointe Woods, Michigan;
$5,500.00 in funds from Demand Deposit Account
#XXXXXXXXX7082 in the name of Casie Mahaley at
Bank of America, Grosse Pointe Woods, Michigan;
3
Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1060 Filed 03/11/25 Page 4 of 18
$5,300.00 in funds from Demand Deposit Account
#XXXXXXXXX0102 in the name of Catherine Wei at
Bank of America, Grosse Pointe Woods, Michigan;
$14,900.00 in funds from Demand Deposit Account
#XXXXXXXXX3963 in the name of Cherina Overton at
Bank of America, Grosse Pointe Woods, Michigan;
$15,500.00 in funds from Demand Deposit Account
#XXXXXXXXX6684 in the name of Claire Mintich at
Bank of America, Grosse Pointe Woods, Michigan;
$14,300.00 in funds from Demand Deposit Account
#XXXXXXXXX4726 in the name of Clint Brandon at
Bank of America, Grosse Pointe Woods, Michigan;
$15,500.00 in funds from Demand Deposit Account
#XXXXXXXXX0640 in the name of Cristina Urbina at
Bank of America, Grosse Pointe Woods, Michigan;
$18,600.00 in funds from Demand Deposit Account
#XXXXXXXXX4923 in the name of Curtis Bowen at
Bank of America, Grosse Pointe Woods, Michigan;
$10,700.00 in funds from Demand Deposit Account
#XXXXXXXXX3658 in the name of Dan Tatum at Bank
of America, Grosse Pointe Woods, Michigan;
$14,300.00 in funds from Demand Deposit Account
#XXXXXXXXX8776 in the name of Dana Green at Bank
of America, Grosse Pointe Woods, Michigan;
$14,900.00 in funds from Demand Deposit Account
#XXXXXXXXX1347 in the name of David Caplan at
Bank of America, Grosse Pointe Woods, Michigan;
$5,100.00 in funds from Demand Deposit Account
#XXXXXXXXX9040 in the name of David F Gorgie at
Bank of America, Grosse Pointe Woods, Michigan;
4
Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1061 Filed 03/11/25 Page 5 of 18
$13,055.76 in funds from Demand Deposit Account
#XXXXXXXXX6213 in the name of David Gray at Bank
of America, Grosse Pointe Woods, Michigan;
$22,800.00 in funds from Demand Deposit Account
#XXXXXXXXX9673 in the name of David M Reppond
at Bank of America, Grosse Pointe Woods, Michigan;
$600.00 in funds from Demand Deposit Account
#XXXXXXXXX7097 in the name of Delia Rodriguez at
Bank of America, Grosse Pointe Woods, Michigan;
$900.00 in funds from Demand Deposit Account
#XXXXXXXXX4990 in the name of Denise Bozzuto at
Bank of America, Grosse Pointe Woods, Michigan;
$6.50 in funds from Demand Deposit Account
#XXXXXXXXX9682 in the name of Derrick Brown at
Bank of America, Grosse Pointe Woods, Michigan;
$6.50 in funds from Demand Deposit Account
#XXXXXXXXX2482 in the name of Diane McCall at
Bank of America, Grosse Pointe Woods, Michigan;
$3.00 in funds from Demand Deposit Account
#XXXXXXXXX7282 in the name of Donna Kelley at
Bank of America, Grosse Pointe Woods, Michigan;
$22,800.00 in funds from Demand Deposit Account
#XXXXXXXXX4300 in the name of Donna Mayfield at
Bank of America, Grosse Pointe Woods, Michigan;
$10,100.00 in funds from Demand Deposit Account
#XXXXXXXXX8919 in the name of Doran Braun at
Bank of America, Grosse Pointe Woods, Michigan;
$7,100.00 in funds from Demand Deposit Account
#XXXXXXXXX5903 in the name of Edanette Marquez
at Bank of America, Grosse Pointe Woods, Michigan;
5
Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1062 Filed 03/11/25 Page 6 of 18
$16,800.00 in funds from Demand Deposit Account
#XXXXXXXXX4709 in the name of Elisa Gary at Bank
of America, Grosse Pointe Woods, Michigan;
$45.00 in funds from Demand Deposit Account
#XXXXXXXXX3905 in the name of Eugen Ratiu at Bank
of America, Grosse Pointe Woods, Michigan;
$21,900.00 in funds from Demand Deposit Account
#XXXXXXXXX4465 in the name of Frank Fleming at
Bank of America, Grosse Pointe Woods, Michigan;
$13,700.00 in funds from Demand Deposit Account
#XXXXXXXXX7248 in the name of George Coffey at
Bank of America, Grosse Pointe Woods, Michigan;
$21,900.00 in funds from Demand Deposit Account
#XXXXXXXXX4386 in the name of Hamilton Johnson
at Bank of America, Grosse Pointe Woods, Michigan;
$13.00 in funds from Demand Deposit Account
#XXXXXXXXX5775 in the name of Harriet Landree at
Bank of America, Grosse Pointe Woods, Michigan;
$3,900.00 in funds from Demand Deposit Account
#XXXXXXXXX7559 in the name of Heather Wiley at
Bank of America, Grosse Pointe Woods, Michigan;
$10,700.00 in funds from Demand Deposit Account
#XXXXXXXXX0682 in the name of James Williams at
Bank of America, Grosse Pointe Woods, Michigan;
$600.00 in funds from Demand Deposit Account
#XXXXXXXXX8413 in the name of Jason Baril at Bank
of America, Grosse Pointe Woods, Michigan;
$16,500.00 in funds from Demand Deposit Account
#XXXXXXXXX8747 in the name of Jayme Williams at
Bank of America, Grosse Pointe Woods, Michigan;
6
Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1063 Filed 03/11/25 Page 7 of 18
$3.00 in funds from Demand Deposit Account
#XXXXXXXXX3604 in the name of Jessica Williams at
Bank of America, Grosse Pointe Woods, Michigan;
$14,300.00 in funds from Demand Deposit Account
#XXXXXXXXX9590 in the name of Jessie McClay at
Bank of America, Grosse Pointe Woods, Michigan;
$22,800.00 in funds from Demand Deposit Account
#XXXXXXXXX9500 in the name of Jessie Wock at Bank
of America, Grosse Pointe Woods, Michigan;
$11,500.00 in funds from Demand Deposit Account
#XXXXXXXXX7967 in the name of Joan Gruczkowski
at Bank of America, Grosse Pointe Woods, Michigan;
$8,500.00 in funds from Demand Deposit Account
#XXXXXXXXX7397 in the name of Joann Estrada at
Bank of America, Grosse Pointe Woods, Michigan;
$13,700.00 in funds from Demand Deposit Account
#XXXXXXXXX7171 in the name of Joanne Rhiger at
Bank of America, Grosse Pointe Woods, Michigan;
$22,800.00 in funds from Demand Deposit Account
#XXXXXXXXX6441 in the name of John Davis at Bank
of America, Grosse Pointe Woods, Michigan;
$900.00 in funds from Demand Deposit Account
#XXXXXXXXX5880 in the name of John Hild at Bank
of America, Grosse Pointe Woods, Michigan;
$14,900.00 in funds from Demand Deposit Account
#XXXXXXXXX0214 in the name of Jolene Smyers at
Bank of America, Grosse Pointe Woods, Michigan;
$10.00 in funds from Demand Deposit Account
#XXXXXXXXX6750 in the name of Jonathan D Pacheco
at Bank of America, Grosse Pointe Woods, Michigan;
7
Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1064 Filed 03/11/25 Page 8 of 18
$18,600.00 in funds from Demand Deposit Account
#XXXXXXXXX7689 in the name of Joseph Barry-Austin
at Bank of America, Grosse Pointe Woods, Michigan;
$15,500.00 in funds from Demand Deposit Account
#XXXXXXXXX8413 in the name of Joy M Copeland at
Bank of America, Grosse Pointe Woods, Michigan;
$11,000.00 in funds from Demand Deposit Account
#XXXXXXXXX3041 in the name of Jurdy Sealey at
Bank of America, Grosse Pointe Woods, Michigan;
$16,500.00 in funds from Demand Deposit Account
#XXXXXXXXX4730 in the name of Kerry Goforth at
Bank of America, Grosse Pointe Woods, Michigan;
$3.00 in funds from Demand Deposit Account
#XXXXXXXXX5856 in the name of Kristy Hodges at
Bank of America, Grosse Pointe Woods, Michigan;
$5,500.00 in funds from Demand Deposit Account
#XXXXXXXXX8397 in the name of Kyal Manzini at
Bank of America, Grosse Pointe Woods, Michigan;
$16,800.00 in funds from Demand Deposit Account
#XXXXXXXXX4232 in the name of Laurent Michel at
Bank of America, Grosse Pointe Woods, Michigan;
$11,700.00 in funds from Demand Deposit Account
#XXXXXXXXX6732 in the name of Layton Brush at
Bank of America, Grosse Pointe Woods, Michigan;
$600.00 in funds from Demand Deposit Account
#XXXXXXXXX6337 in the name of Lee Mickus at Bank
of America, Grosse Pointe Woods, Michigan;
$15,500.00 in funds from Demand Deposit Account
#XXXXXXXXX0088 in the name of Lindsay Spencer at
Bank of America, Grosse Pointe Woods, Michigan;
8
Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1065 Filed 03/11/25 Page 9 of 18
$2,900.00 in funds from Demand Deposit Account
#XXXXXXXXX7862 in the name of Mario Reyes at
Bank of America, Grosse Pointe Woods, Michigan;
$7,450.00 in funds from Demand Deposit Account
#XXXXXXXXX2727 in the name of Marva Morris at
Bank of America, Grosse Pointe Woods, Michigan;
$5,800.00 in funds from Demand Deposit Account
#XXXXXXXXX2309 in the name of Mary Harris at Bank
of America, Grosse Pointe Woods, Michigan;
$17,700.00 in funds from Demand Deposit Account
#XXXXXXXXX8784 in the name of Matt Merrihew at
Bank of America, Grosse Pointe Woods, Michigan;
$18,600.00 in funds from Demand Deposit Account
#XXXXXXXXX1927 in the name of Matthew Polk at
Bank of America, Grosse Pointe Woods, Michigan;
$15,511.62 in funds from Demand Deposit Account
#XXXXXXXXX8853 in the name of Maxie Rowell at
Bank of America, Grosse Pointe Woods, Michigan;
$22.36 in funds from Demand Deposit Account
#XXXXXXXXX3413 in the name of Melinda Greenberg
at Bank of America, Grosse Pointe Woods, Michigan;
$20,741.02 in funds from Demand Deposit Account
#XXXXXXXXX1455 in the name of Michael Leckron at
Bank of America, Grosse Pointe Woods, Michigan;
$15,800.00 in funds from Demand Deposit Account
#XXXXXXXXX4655 in the name of Michelle Levy at
Bank of America, Grosse Pointe Woods, Michigan;
$3.00 in funds from Demand Deposit Account
#XXXXXXXXX0559 in the name of Monica Henriksen
at Bank of America, Grosse Pointe Woods, Michigan;
9
Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1066 Filed 03/11/25 Page 10 of 18
$16,500.00 in funds from Demand Deposit Account
#XXXXXXXXX1190 in the name of Nathaniel Everett at
Bank of America, Grosse Pointe Woods, Michigan;
$24,000.00 in funds from Demand Deposit Account
#XXXXXXXXX6945 in the name of Nicholas Goldberg
at Bank of America, Grosse Pointe Woods, Michigan;
$15,600.00 in funds from Demand Deposit Account
#XXXXXXXXX2371 in the name of Nick Jody at Bank
of America, Grosse Pointe Woods, Michigan;
$16,800.00 in funds from Demand Deposit Account
#XXXXXXXXX3419 in the name of Nicole Parry at
Bank of America, Grosse Pointe Woods, Michigan;
$21,000.00 in funds from Demand Deposit Account
#XXXXXXXXX9837 in the name of Nikki Harvey at
Bank of America, Grosse Pointe Woods, Michigan;
$8,970.45 in funds from Demand Deposit Account
#XXXXXXXXX8537 in the name of Noe Garcia at Bank
of America, Grosse Pointe Woods, Michigan;
$17,221.10 in funds from Demand Deposit Account
#XXXXXXXXX2771 in the name of Nunicka Epps at
Bank of America, Grosse Pointe Woods, Michigan;
$19,800.00 in funds from Demand Deposit Account
#XXXXXXXXX5282 in the name of Patricia Epperson at
Bank of America, Grosse Pointe Woods, Michigan;
$7,900.00 in funds from Demand Deposit Account
#XXXXXXXXX7932 in the name of Rebekah Anderson
at Bank of America, Grosse Pointe Woods, Michigan;
$15,500.00 in funds from Demand Deposit Account
#XXXXXXXXX4284 in the name of Robyn Mendez at
Bank of America, Grosse Pointe Woods, Michigan;
10
Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1067 Filed 03/11/25 Page 11 of 18
$8,554.67 in funds from Demand Deposit Account
#XXXXXXXXX9081 in the name of Ronald Cockerill at
Bank of America, Grosse Pointe Woods, Michigan;
$10,700.00 in funds from Demand Deposit Account
#XXXXXXXXX2602 in the name of Ronald Schoelkopf
at Bank of America, Grosse Pointe Woods, Michigan;
$14,900.00 in funds from Demand Deposit Account
#XXXXXXXXX6683 in the name of Sabrina Irvin at
Bank of America, Grosse Pointe Woods, Michigan;
$13.00 in funds from Demand Deposit Account
#XXXXXXXXX5624 in the name of Sean Menza at Bank
of America, Grosse Pointe Woods, Michigan;
$18,900.00 in funds from Demand Deposit Account
#XXXXXXXXX3329 in the name of Shannon Amerson
at Bank of America, Grosse Pointe Woods, Michigan;
$34.00 in funds from Demand Deposit Account
#XXXXXXXXX5178 in the name of Shannon E Hill at
Bank of America, Grosse Pointe Woods, Michigan;
$18,450.00 in funds from Demand Deposit Account
#XXXXXXXXX4171 in the name of Shannon Hughes at
Bank of America, Grosse Pointe Woods, Michigan;
$7,100.00 in funds from Demand Deposit Account
#XXXXXXXXX2487 in the name of Shonda Walker at
Bank of America, Grosse Pointe Woods, Michigan;
$21,900.00 in funds from Demand Deposit Account
#XXXXXXXXX2678 in the name of Stephen Black at
Bank of America, Grosse Pointe Woods, Michigan;
$11,061.77 in funds from Demand Deposit Account
#XXXXXXXXX2745 in the name of Steven Nichols at
Bank of America, Grosse Pointe Woods, Michigan;
11
Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1068 Filed 03/11/25 Page 12 of 18
$16,500.00 in funds from Demand Deposit Account
#XXXXXXXXX5328 in the name of Tameika McLean at
Bank of America, Grosse Pointe Woods, Michigan;
$15,500.00 in funds from Demand Deposit Account
#XXXXXXXXX8870 in the name of Tamika A Williams
at Bank of America, Grosse Pointe Woods, Michigan;
$18,000.00 in funds from Demand Deposit Account
#XXXXXXXXX7028 in the name of Tatyanna Philips at
Bank of America, Grosse Pointe Woods, Michigan;
$7,100.00 in funds from Demand Deposit Account
#XXXXXXXXX5719 in the name of Tayler Briggs at
Bank of America, Grosse Pointe Woods, Michigan;
$2,850.97 in funds from Demand Deposit Account
#XXXXXXXXX4395 in the name of Terra Stock at Bank
of America, Grosse Pointe Woods, Michigan;
$16,800.00 in funds from Demand Deposit Account
#XXXXXXXXX1820 in the name of Thomas Straus at
Bank of America, Grosse Pointe Woods, Michigan;
$13.00 in funds from Demand Deposit Account
#XXXXXXXXX8067 in the name of Tiffany Jaquez at
Bank of America, Grosse Pointe Woods, Michigan;
$3.00 in funds from Demand Deposit Account
#XXXXXXXXX1919 in the name of Todd Daviso at
Bank of America, Grosse Pointe Woods, Michigan;
$16,800.00 in funds from Demand Deposit Account
#XXXXXXXXX1899 in the name of Tracey Shipman at
Bank of America, Grosse Pointe Woods, Michigan;
$5,900.00 in funds from Demand Deposit Account
#XXXXXXXXX4699 in the name of Tracy Silvestri at
Bank of America, Grosse Pointe Woods, Michigan;
12
Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1069 Filed 03/11/25 Page 13 of 18
$10,100.00 in funds from Demand Deposit Account
#XXXXXXXXX2986 in the name of Travis Fagala at
Bank of America, Grosse Pointe Woods, Michigan;
$600.00 in funds from Demand Deposit Account
#XXXXXXXXX8101 in the name of Trey Ormond at
Bank of America, Grosse Pointe Woods, Michigan;
$15,500.00 in funds from Demand Deposit Account
#XXXXXXXXX8942 in the name of Tyler Tipps at Bank
of America, Grosse Pointe Woods, Michigan;
$1,050.00 in funds from Demand Deposit Account
#XXXXXXXXX9627 in the name of Victor A Soto at
Bank of America, Grosse Pointe Woods, Michigan;
$3.00 in funds from Demand Deposit Account
#XXXXXXXXX2419 in the name of Walter Jahn at Bank
of America, Grosse Pointe Woods, Michigan;
$3.14 in funds from Demand Deposit Account
#XXXXXXXXX7332 in the name of William Roper at
Bank of America, Grosse Pointe Woods, Michigan;
$14,300.00 in funds from Demand Deposit Account
#XXXXXXXXX8264 in the name of William Turner at
Bank of America, Grosse Pointe Woods, Michigan; and
$9,857.60 in funds from Demand Deposit Account
#XXXXXXXXX3214 in the name of Yabdiel Martinez at
Bank of America, Grosse Pointe Woods, Michigan
(collectively referred to hereinafter as the “Subject Property”), as proceeds of
his violation of 18 U.S.C. § 1349. As proceeds of the Defendant’s violation
of 18 U.S.C. § 1349, the Subject Property is subject to forfeiture under 18
13
Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1070 Filed 03/11/25 Page 14 of 18
U.S.C. § 981(a)(1)(C) together with 28 U.S.C. § 2461(c), and the requisite
nexus exists between the Subject Property and the offense of conviction.
2. The Subject Property IS HEREBY FORFEITED to the United States
under 18 U.S.C. § 981(a)(1)(C) together with 28 U.S.C. § 2461(c) for
disposition according to law, and any right, title, and interest of the Defendant,
and any right, title, and interest that his heirs, successors, or assigns have, or
may have, in the Subject Property is HEREBY AND FOREVER
EXTINGUISHED.
3. The Court ENTERS a forfeiture money judgment in the amount of Six
Hundred Thirty-Nine Thousand Three Hundred and Sixty Dollars and
00/100 ($639,360.00) against the Defendant in favor of the United States
which represents the total amount of proceeds that the Defendant personally
obtained as described in the factual basis of the Rule 11 Plea Agreement. See
ECF No. 123. The Parties have agreed the forfeiture money judgment shall be
reduced by the net proceeds forfeited to the United States from the Subject
Property.
4. If the Defendant does not pay the forfeiture money judgment, the
United States may move to satisfy the forfeiture money judgment with any
assets the Defendant has now or may later acquire. The Defendant’s assets
may be forfeited as substitute assets under 21 U.S.C. § 853(p)(2). The United
14
Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1071 Filed 03/11/25 Page 15 of 18
States is permitted to undertake whatever discovery is necessary to identify,
locate, or dispose of substitute assets under Fed. R. Crim. P. 32.2(b) and to
otherwise collect on and enforce the money judgment under the Federal Rules
of Civil Procedure.
5. Pursuant to Fed. R. Crim. P. 32.2(b)(4)(A), this Stipulated Preliminary
Order of Forfeiture shall become final and effective as to the Defendant at the
time it is entered by the Court and shall be made a part of the Defendant’s
sentence and included in his Judgment, but remains preliminary as to third
parties until the ancillary proceedings, if any, are concluded under Rule
32.2(c).
6. The forfeiture of the Subject Property shall also be made part of the
Defendant’s sentence and included in his Judgment.
7. Upon entry of this Order, the United States is authorized to begin
proceedings consistent with the applicable statutory requirements pertaining
to ancillary hearings and the rights of any third parties.
8. Pursuant to 21 U.S.C. § 853(n), Fed. R. Crim. P. 32.2, and other
applicable rules, the United States shall publish notice of this Stipulated
Preliminary Order of Forfeiture and of its intent to dispose of the Subject
Property on www.forfeiture.gov, for at least thirty (30) consecutive days. The
United States may also, to the extent practicable, provide direct written notice
15
Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1072 Filed 03/11/25 Page 16 of 18
to any person or entity known to have an alleged interest in the Subject
Property. The aforementioned notice shall direct that any person, other than
Defendant, asserting a legal interest in the Subject Property must file a petition
with the Court within thirty (30) days of the final date of publication of notice
or within thirty (30) days of receipt of actual notice, whichever is earlier. The
petition shall be for a hearing before the Court alone, without a jury and in
accordance with 21 U.S.C. § 853(n), to adjudicate the validity of the
petitioner's alleged interest in the Subject Property. Any petition filed by a
third party asserting an interest in the Subject Property must be signed by the
petitioner under penalty of perjury and must set forth the nature and extent of
the petitioner's alleged right, title or interest in the Subject Property, the time
and circumstances of the petitioner’s acquisition of the right, title, or interest
in the Subject Property, any additional facts supporting the petitioner's claim,
and the relief sought.
9. After the disposition of any motion filed under Fed. R. Crim. P.
32.2(c)(1)(A) and before a hearing on any ancillary petition, the United States
may conduct discovery in accordance with the Federal Rules of Civil
Procedure upon a showing that such discovery is necessary or desirable to
resolve factual issues in the ancillary proceeding of one or more orders of
16
Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1073 Filed 03/11/25 Page 17 of 18
forfeiture and agrees to sign such order, indicating that he consents to its entry
if requested to do by the Government.
10. If no third party files a timely petition before the expiration of the period
provided in 21 U.S.C. § 853(n)(2), then this Stipulated Preliminary Order of
Forfeiture shall become the Final Order of Forfeiture and the United States
shall have clear title to the Subject Property as provided in 21 U.S.C. §
853(n)(7) and Fed. R. Crim. P. 32.2(c)(2); further, the United States shall be
authorized to dispose of the Subject Property as prescribed by law.
11. If a third party files a petition for ancillary hearing for the Subject
Property, the Court shall enter an Amended and/or Final Order of Forfeiture
that addresses the disposition of the third-party petition as provided under Fed.
R. Crim. P. 32.2(c)(2).
12. The provisions of this Order will survive the Defendant,
notwithstanding the abatement of any underlying criminal conviction after the
entry of this Order. The forfeitability of any particular property pursuant to
this Order shall be determined as if the Defendant had survived, and that
determination shall be binding upon the Defendant’s heirs, successors, and
assigns until the forfeiture money judgment amount is collected in full.
13. This Court shall retain jurisdiction to enforce this Order, and to amend
it as necessary, pursuant to Fed. R. Crim. P. 32.2.
17
Case 5:23-cr-20253-JEL-DRG ECF No. 175, PageID.1074 Filed 03/11/25 Page 18 of 18
Approved as to form and substance:
Julie A. Beck
Acting United States Attorney
s/Kelly Fasbinder s/ John McManus (with consent)
KELLY FASBINDER John M. McManus (P44102)
(P80109) Attorney for Maurice Brown-Portwood
Assistant United States Attorney McManus Law
211 W. Fort Street, Ste. 2001 17 W. Fourth St., Ste. 201
Detroit, MI 48226 Royal Oak, MI 48067
(313) 226-6397 (248) 268-8989
Kelly.Fasbinder@usdoj.gov jmcmanus@vgpclaw.com
Dated: March 11, 2025 Dated: March 11, 2025
*******************************
IT IS SO ORDERED.
Date: March 11, 2025 s/Judith E. Levy
Honorable Judith E. Levy
United States District Judge
18
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