Case 1:12-cv-00171-RC-KFG Document 11

Filed 09/04/12 Page 1 of 3 PageID #: 47

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS BEAUMONT DIVISION UNITED STATES OF AMERICA V. (1) TRACT 31A, LOTS 31 & 32 LAFITTES LANDING PHASE TWO PORT ARTHUR, JEFFERSON COUNTY TEXAS, INCLUDING ALL BUILDINGS APPURTENANCES, AND IMPROVEMENTS THEREON; (2) 2010 MERCEDES S550V, VIN: WDDNG7BB0AA288631 WITH ALL ACCESSORIES AND MODIFICATIONS THERETO; (3) ING/TRANSAMERICA, PREFERRED CHOICE FIXED ANNUITY CONTRACT 02TPC047479 IN THE AMOUNT OF $1,600,000.00, WITH ALL ACCUMULATED INTEREST THEREON; and (4) ING/TRANSAMERICA, PERFERRED CHOICE FIXED ANNUITY CONTRACT 02TPC080685 IN THE AMOUNT OF $1,800,000.00, WITH ALL ACCUMULATED INTEREST THEREON

CIVIL ACTION NO.: 1:12-CV-171

NOTICE OF VERIFIED CLAIM COMES NOW Beaumont Independent School District (Beaumont ISD) and makes this potential claim in the above-referenced matter. On April 10, 2012, the United States of America filed a civil complaint seeking forfeiture, pursuant to 18 U.S.C. 981, in the United States District Court for the Eastern District of Texas against the following property:

Case 1:12-cv-00171-RC-KFG Document 11

Filed 09/04/12 Page 2 of 3 PageID #: 48

a.

Real property located at Tract 31A, Lots 31 & 32, Lafittes Landing Phase Two, Port Arthur, Texas, with all appurtenances, improvements, and attachments thereon, more particularly described as: Tract 31A of a Replat of Lots Numbered Thirty-one and Thirty-two (31 & 32) of LAFITTES LANDING PHASE TWO, a 106.97 acre subdivision out of and part of the N. Coleman Survey A-12 and the Dennis Gahagan League, Abstract No. 123, in the City of Port Arthur, Jefferson County, Texas, as the same appears upon the map or plat thereof, on file and of record in Vol. 16 page 309, Map Records of Jefferson County, Texas;

b.

2010 Mercedes S550V, WDDNG7BB0AA288631 with modification thereto;

4 all

door, VIN: accessories and

c.

ING/Transamerica, a Preferred Choice Fixed Annuity Contract 02TPC047479 in the amount of $1,600,000 purchased on September 21, 2009, using funds from the JP Morgan savings account number xxxxxx7080 of Calvin Walter [sic] and Stacy Walker; ING/Transamerica, a Preferred Choice Fixed Annuity Contract 02TPC080685 in the amount of $1,800,000 purchased on October 28, 2009, using funds from the JP Morgan savings account number xxxxxx7080 of Calvin Walter [sic] and Stacy Walker.

d.

Beaumont ISD through its counsel received the Notice of Complaint for Forfeiture on August 2, 2012. Beaumont ISD assisted the United States Attorneys office in gathering information, witnesses for prosecution of this matter. Beaumont ISD seeks to obtain payment for attorney fees and costs associated with the attempted prosecution of Calvin Walker. Beaumont ISD has incurred costs which can be calculated and proven.

Case 1:12-cv-00171-RC-KFG Document 11

Filed 09/04/12 Page 3 of 3 PageID #: 49

Respectfully submitted, By: /s/Melody G. Chappell_________ Melody G. Chappell Texas State Bar No. 00785096 Attorney for Beaumont Independent School District

WELLS, PEYTON, GREENBERG & HUNT, L.L.P. P.O. Box 3708 Beaumont, Texas 77704-3708 Telephone (409) 838-2644 Facsimile (409) 838-0416

CERTIFICATE OF SERVICE I certify that a true and correct copy of the above and foregoing document was served as follows: VIA HAND DELIVERY Michael W. Lockhart Assistant United States Attorney U.S. Department of Justice 350 Magnolia Avenue, Suite 150 Beaumont, Texas 77701 September 4, 2012 /s/__Melody G. Chappell Melody G. Chappell Attorney for Beaumont Independent School District

Case 1:12-cv-00171-RC-KFG Document 11-1

Filed 09/04/12 Page 1 of 2 PageID #: 50

Case 1:12-cv-00171-RC-KFG Document 11-1

Filed 09/04/12 Page 2 of 2 PageID #: 51