Free Stipulation - District Court of Connecticut - Connecticut

Case 3:03-cv-01033-SRU

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA, : : Plaintiff, : : v. : : ONE PARCEL OF PROPERTY : LOCATED AT 171 LINCOLN AVENUE, : NEW LONDON, CONNECTICUT, : WITH ALL APPURTENANCES AND : IMPROVEMENTS THEREON, AND : : Defendant. : : [CLAIMANTS: ROBERT A. VENTURINI, : JR., ESTATE OF EDWIN C. JACKSON, : CITY OF NEW LONDON, LAWRENCE : AND MEMORIAL HOSPITAL, AND : STATE OF CONNECTICUT] :

Civil No. 3:03CV1033 (SRU)

STIPULATION FOR COMPROMISE SETTLEMENT It is hereby stipulated by and between the PLAINTIFF, UNITED STATES OF AMERICA ("UNITED STATES"), on the one hand, and the CLAIMANT, ROBERT A. VENTURINI, JR. ("CLAIMANT"), on the other, by and through counsel for the UNITED STATES and the pro se CLAIMANT, as follows: 1. That the parties do hereby agree to settle and compromise the above-entitled action,

and a related civil forfeiture action entitled United States v. 62 Cutler Street, New London, Connecticut, Civil No. 3:03CV1033 (SRU), upon the terms indicated below. 2. That the CLAIMANT agrees to the entry of a Decree of Forfeiture thereby forfeiting

the real property in the related civil forfeiture action entitled United States v. 62 Cutler Street,

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New London, Connecticut, Civil No. 3:03CV1033 (SRU), to the UNITED STATES, pursuant to 21 U.S.C. § 881(a)(7), for disposition according to law. 3. That the UNITED STATES agrees to dismiss this civil forfeiture action upon the

entry of a Decree of Forfeiture in the related civil forfeiture action in the related case against 62 Cutler Street, New London, Connecticut. 4. That the UNITED STATES agrees to record a Release of Lis Pendens on the New

London land records for the real property located at 171 Lincoln Avenue, New London, Connecticut, upon the entry of a Decree of Forfeiture in the related case against 62 Cutler Street, New London, Connecticut. 5. That the CLAIMANT hereby releases and forever discharges the United States of

America, the Drug Enforcement Administration, the United States Marshals Service, and the New London Police Department, their officers, agents, servants, and employees, their heirs, successors, or assigns, from any and all actions, causes of action, suits, proceedings, debts, dues, contracts, judgments, damages, claims, and/or demands whatsoever in law or equity which claimants, their heirs, successors, or assigns ever had, now have, or may have in the future in connection with this forfeiture action against the Defendant, one parcel of property located at 171 Lincoln Avenue, New London, Connecticut, and the seizure, detention, and forfeiture of the related case against one parcel of property located at 62 Cutler Street, New London, Connecticut, with all appurtenances and improvements thereon. 7. That the CLAIMANT further agrees to hold and save the United States of America,

the Drug Enforcement Administration, the United States Marshals Service, and the New London Police Department, their servants, employees, heirs, successors, or assigns harmless from any 2

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claims by any others, including costs and expenses for or on account of any and all lawsuits or claims of any character whatsoever, in connection with this forfeiture action against the Defendant, one parcel of property located at 171 Lincoln Avenue, New London, Connecticut, and the seizure, detention, and forfeiture of the related case against one parcel of property located at 62 Cutler Street, New London, Connecticut, with all appurtenances and improvements thereon. 8. This Stipulation for Compromise Settlement shall not constitute an admission of

liability or fault on the part of the UNITED STATES, its officers, agents, servants, or employees, or on the part of the CLAIMANT, and is entered into by all parties for the purpose of compromising disputed claims and avoiding the expenses and risks of litigation. 9. The UNITED STATES and the CLAIMANT agree to bear their own costs and

attorneys' fees, and to execute and/or consent to, any additional documents necessary to implement the terms of this stipulated agreement and in the related forfeiture action. UNITED STATES OF AMERICA KEVIN J. O'CONNOR UNITED STATES ATTORNEY

Dated: JULIE G. TURBERT ASSISTANT U.S. ATTORNEY P.O. BOX 1824 NEW HAVEN, CT 06508 (203) 821-3700 FEDERAL BAR # ct23398 ATTORNEY FOR THE PLAINTIFF UNITED STATES OF AMERICA

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Dated: ANTHONY BASILICA, ESQ. 37 GRANITE STREET NEW LONDON, CT 06320 FEDERAL BAR # ct ATTORNEY FOR THE CLAIMANT

Dated: ROBERT A. VENTURINI, JR. REG. NO. 250620 MACDOUGALL-WALKER OSBORN CORRECTIONAL INSTITUTION 100 BILTON ROAD, POB 100 SOMERS, CT 06071 CLAIMANT

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CERTIFICATE OF SERVICE This is to certify that a copy of the within and foregoing Stipulation for Compromise Settlement has been mailed, postage prepaid, on this Robert Venturini, Jr., pro se Reg. No. 250620 Osborn Correctional Institution 100 Bilton Road, POB 100 Somers, CT 06071 Mark Solak, Esq. Devine & Associates One Exchange Place, 6th Floor Waterbury, CT 06702 Gary G. Williams Assistant Attorney General P.O. Box 120 Hartford, CT 06141 (Counsel for State of Connecticut) day of , 2004, to:

Brian K. Estep, Esq. Conway & Londregan, P.C. 38 Huntington Street New London, CT 06320 (Counsel for City of New London) Patricia H. Modzelewski, Esq. Peck & Tuneski, P.C. 10 Pearl Street P.O. Box 37 New London, CT 06320 (Counsel for the Estate of E. Barbara Jackson) Lawrence & Memorial Hospital Legal Department 365 Montauk Avenue New London, CT 06320

JULIE G. TURBERT ASSISTANT U.S. ATTORNEY P.O. BOX 1824 NEW HAVEN, CT 06508 (203) 821-3700 FEDERAL BAR # ct23398