Declaration of Publication, Notice of Forfeiture and Advertisement Certification Report (Document 60)
Summary
Document 60, filed 06/02/25 in United States v. Cassie Will-Darnall, is a Declaration of Publication by an asset forfeiture paralegal, executed June 02, 2025. It states that notice of the forfeiture was posted on www.forfeiture.gov for at least 30 consecutive days. Attachment 1 is the notice, reciting the April 30, 2025 order forfeiting funds up to $625,952.60 in a Vanguard account in the name of Alternative Health Services Inc and two parcels of real property in Los Gatos. It sets an ancillary petition deadline of 60 days from first publication. The final page is an Advertisement Certification Report for May 2, 2025 to May 31, 2025.
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“Declaration of Publication, Notice of Forfeiture and Advertisement Certification Report (Document 60).”
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Case 5:24-cr-00292-PCP Document 60 Filed 06/02/25 Page 1 of 4
1 CRAIG H. MISSAKIAN (CABN 125202)
United States Attorney
2
MARTHA BOERSCH (CABN 126569)
3 Chief, Criminal Division
4 GALEN A. PHILLIPS (CABN 307644)
Assistant United States Attorney
5
450 Golden Gate Avenue, Box 36055
6 San Francisco, California 94102-3495
Telephone: (415) 436-7110
7 Facsimile: (415) 436-7234
Email: galen.phillips@usdoj.gov
8
Attorneys for United States of America
9
UNITED STATES DISTRICT COURT
10
NORTHERN DISTRICT OF CALIFORNIA
11
SAN JOSE DIVISION
12
UNITED STATES OF AMERICA, ) CASE NO.: CR-24-00292-PCP
13 )
Plaintiff, )
14 ) DECLARATION OF PUBLICATION
v. )
15 )
CASSIE WILL-DARNALL, )
16 )
Defendant. )
17 )
18 In accordance with 21 U.S.C. § 853(n)(1) and Rule 32.2(b)(6)(C) of the Federal Rules of
19 Criminal Procedure, notice of the forfeiture was posted on an official government internet site
20 (www.forfeiture.gov) for at least 30 consecutive days, beginning on May 02, 2025 and ending on May
21 31, 2025. (See, Attachment 1).
22 I declare under penalty of perjury that the forgoing is true and correct.
23 Executed on June 02, 2025, at San Francisco, California.
24
__________/S/__________________
25 YAQIONG(VICKY)FAN
FSA Paralegal/Asset Forfeiture Unit
26
27
28
DECLARATION OF PUBLICATION
CR-24-00292-PCP 1
Case 5:24-cr-00292-PCP Document 60 Filed 06/02/25 Page 2 of 4
Attachment 1
UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
COURT CASE NUMBER: 24-CR-00292 PCP; NOTICE OF FORFEITURE
Notice is hereby given that on April 30, 2025, in the case of U.S. v. Will-Darnall,
Cassie, Court Case Number 24-CR-00292 PCP, the United States District Court for the
Northern District of California entered an Order condemning and forfeiting the following
property to the United States of America:
All funds up to $625,952.60 on deposit in a Vanguard account ending in -6846, held
in the name of Alternative Health Services Inc, and all interest since seizure of those
funds(23-FBI-006061) which was seized from Alternative Health Services, Inc. on
June 29, 2023 at 100 Vanguard Blvd., M/S 35, located in Malvern, PA
Real property located at 111 Belwood Gateway, Los Gatos, CA 95032
(24-FBI-004702) Parcel # 527-31-019
Real property located at 306 Los Gatos Almaden Road, Los Gatos, CA, 95032
(24-FBI-004703) Parcel # 527-46-002
The United States hereby gives notice of its intent to dispose of the forfeited
property in such manner as the United States Attorney General may direct. Any person,
other than the defendant(s) in this case, claiming interest in the forfeited property must file
an ancillary petition within 60 days of the first date of publication (May 02, 2025) of this
Notice on this official government internet web site, pursuant to Rule 32.2 of the Federal
Rules of Criminal Procedure and 21 U.S.C. § 853(n)(1). The ancillary petition must be
filed with the Clerk of the Court, 280 South First Street, Room 2112, San Jose, CA 95113,
and a copy served upon Assistant United States Attorney Galen Phillips, 450 Golden Gate
Avenue, 9th Floor, San Francisco, CA 94102. The ancillary petition shall be signed by the
petitioner under penalty of perjury and shall set forth the nature and extent of the
petitioner's right, title or interest in the forfeited property, the time and circumstances of the
petitioner's acquisition of the right, title and interest in the forfeited property and any
additional facts supporting the petitioner's claim and the relief sought, pursuant to 21
U.S.C. § 853(n).
Following the Court’s disposition of all ancillary petitions filed, or if no such petitions
are filed, following the expiration of the period specified above for the filing of such
ancillary petitions, the United States shall have clear title to the property and may warrant
good title to any subsequent purchaser or transferee.
The government may also consider granting petitions for remission or mitigation,
which pardon all or part of the property from the forfeiture. A petition must include a
description of your interest in the property supported by documentation; include any facts
you believe justify the return of the property; and be signed under oath, subject to the
penalty of perjury, or meet the requirements of an unsworn statement under penalty of
Case 5:24-cr-00292-PCP Document 60 Filed 06/02/25 Page 3 of 4
perjury. See 28 U.S.C. Section 1746. For the regulations pertaining to remission or
mitigation of the forfeiture, see 28 C.F.R. Sections 9.1 - 9.9. The criteria for remission of
the forfeiture are found at 28 C.F.R. Section 9.5(a). The criteria for mitigation of the
forfeiture are found at 28 C.F.R. Section 9.5(b). The petition for remission need not be
made in any particular form and may be filed online or in writing. You should file a petition
for remission not later than 11:59 PM EST 30 days after the date of final publication of this
notice. See 28 C.F.R. Section 9.3(a). The https://www.forfeiture.gov/FilingPetition.htm
website provides access to a standard petition for remission form that may be mailed and
the link to file a petition for remission online. If you cannot find the desired assets online,
you must file your petition for remission in writing by sending it to Assistant United States
Attorney Galen Phillips, 450 Golden Gate Avenue, 9th Floor, San Francisco, CA 94102.
This website provides answers to frequently asked questions (FAQs) about filing a petition
for remission. You may file both an ancillary petition with the court and a petition for
remission or mitigation.
Case 5:24-cr-00292-PCP Document 60 Filed 06/02/25 Page 4 of 4
Advertisement Certification Report
The Notice of Publication was available on the www.forfeiture.gov web site for at least 18 hours per day
between May 2, 2025 and May 31, 2025. Below is a summary report that identifies the uptime for each
day within the publication period and reports the results of the web monitoring system’s daily check that
verifies that the advertisement was available each day.
U.S. v. Will-Darnall, Cassie
Court Case No: 24-CR-00292 PCP
For Asset ID(s): See Attached Advertisement Copy
Consecutive Date Advertisement Total Hours Web Site Verification that
Calendar Day Appeared on the was Available during Advertisement
Count Web Site Calendar Day existed on Web Site
1 05/02/2025 23.9 Verified
2 05/03/2025 23.9 Verified
3 05/04/2025 23.9 Verified
4 05/05/2025 23.9 Verified
5 05/06/2025 23.9 Verified
6 05/07/2025 23.8 Verified
7 05/08/2025 23.8 Verified
8 05/09/2025 23.9 Verified
9 05/10/2025 23.9 Verified
10 05/11/2025 23.8 Verified
11 05/12/2025 23.9 Verified
12 05/13/2025 23.8 Verified
13 05/14/2025 23.9 Verified
14 05/15/2025 23.9 Verified
15 05/16/2025 23.8 Verified
16 05/17/2025 24.0 Verified
17 05/18/2025 23.9 Verified
18 05/19/2025 23.9 Verified
19 05/20/2025 23.9 Verified
20 05/21/2025 23.9 Verified
21 05/22/2025 24.0 Verified
22 05/23/2025 24.0 Verified
23 05/24/2025 24.0 Verified
24 05/25/2025 24.0 Verified
25 05/26/2025 23.8 Verified
26 05/27/2025 23.9 Verified
27 05/28/2025 23.9 Verified
28 05/29/2025 23.9 Verified
29 05/30/2025 23.8 Verified
30 05/31/2025 22.8 Verified
Additional log information is available and kept in the archives for 15 years after the asset has been disposed.
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