Case: 3:12-cr-50027 Document #: 197 Filed: 12/10/14 Page 1 of 5 PageID #:1181

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS
WESTERN DIVISION
UNITED STATES OF AMERICA

v.
RITA CRUNDWELL,
Defendant,
and
THE FIRST NATIONAL BANK IN
AMBOY,

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No. 12 CR 50027
Judge Philip G. Reinhard

Third Party Citation Respondent.

MOTION FOR TURNOVER ORDER
The United States, by Zachary T. Fardon, United States Attorney for the Northern
District of Illinois, moves this court for a turnover order, and in support states as follows:
1.

Judgment in the captioned matter was entered in favor of the United States and

against the defendant on February 14, 2013. As of December 10, 2014, the defendant has an
outstanding balance of $44,452,107.96.
2.

The United States may use any federal or state procedure to enforce the judgment.

18 U.S.C. 3613(a) and (f). A citation to discover assets directed to the respondent was issued
on the judgment on April 5, 2013 and served on the respondent on April 8, 2013. The defendant
was served on April 8, 2013 with statutory notice.
3.

Pursuant to the citation to discover assets, the respondent answered on April 8,

2013. A copy of the answer is attached as Exhibit A. In its answer, the respondent stated that at
the time the citation was served, the respondent had in its possession or under its control,

Case: 3:12-cr-50027 Document #: 197 Filed: 12/10/14 Page 2 of 5 PageID #:1182

property belonging to the defendant, Rita Crundwell. Based upon the respondents answer, the
United States is entitled to $1,549.95, which represents the defendants nonexempt interest in
demand deposit account being held by the respondent. 18 U.S.C. 3613(a) and 26 U.S.C.
6334.
4.

The Clerk of the Court collects all payments on monetary penalties imposed in

criminal cases; accordingly, all payments should have 12 CR 50027 written in the lower left
corner of the check and be submitted to:
Clerk of the Court
U.S. District Court, Northern District of Illinois

5.

The United States has provided all notices required by law.

WHEREFORE, the United States moves for entry of a turnover order directing the
respondent, The First National Bank In Amboy, to submit to the Clerk of the Court $1,549.95,
which represents the defendants nonexempt interest in demand deposit account, to be applied to
the defendants outstanding judgment.
Respectfully submitted,
ZACHARY T. FARDON
United States Attorney
By: s/ Joseph A. Stewart
JOSEPH A. STEWART
Assistant United States Attorney

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