On December 26, 2023 a
Complaint-Civil Index #1
was filed
involving a dispute between
Wright County Attorney,
and
for Forfeiture
in the District Court of Wright County.
Preview
86-CV-23-6442
Filed in District Court
State of Minnesota
12/26/2023 12:26 PM
STATE OF MINNESOTA IN DISTRICT COURT
COUNTY OF WRIGHT TENTH JUDICIAL DISTRICT
Brian A. Lutes, Ct. File No.:
WRIGHT COUNTY ATTORNEY Case Type: 14 – Other Civil
Plaintiff,
vs.
COMPLAINT
2018 Chevrolet Silverado
MN license plate: YBV5917 (expires 2019)
VIN: 1GC4KYCYXJF151695
(Owner: Maxwell Kenneth Moonen),
Defendant.
THE STATE OF MINNESOTA TO THE ABOVE-NAMED DEFENDANT, Maxwell Kenneth Moonen:
The Plaintiff, for his Separate Complaint for Forfeiture, states and alleges as follows:
1. Defendant property is: property that was used or intended for use to commit or facilitate
the commission of a designated offense, to-wit, Fleeing a Peace Officer, in violation of Minn. Stat. §
609.487 and endangered life or property.
2. Defendant property is subject to forfeiture pursuant to Minn. Stat. § 609.5312.
3. On or about November 5, 2023, and on all other dates material herein, defendant property
was owned and possessed by Maxwell Kenneth Moonen in Wright County, Minnesota.
4. J and J Glass and Glazing, Inc., (300 Railroad Avenue, Delano, MN 55328) is listed as the
registered owner of the defendant vehicle with the Department of Public Safety.
5. On or about December 24, 2023, defendant property was seized in Wright County by the
Wright County Sheriff’s Office and remains in the custody of that law enforcement agency subject to the
criminal complaint and to these said proceedings.
6. The Plaintiff will charge Maxwell Kenneth Moonen with Fleeing in violation of Minn. Stat. §
609.487.
WHEREFORE, Plaintiff prays that the Court:
86-CV-23-6442
Filed in District Court
State of Minnesota
12/26/2023 12:26 PM
1. Order the forfeiture of defendant property to the Wright County Sheriff’s Office to be used
and/or disposed of as provided by law.
2. Grant such other relief as the Court deems appropriate.
The undersigned hereby acknowledges that the costs, disbursements and reasonable attorney and
witness fees may be awarded to the opposing party or parties pursuant to Minn. Stat. § 549.21.
Dated: December 26, 2023 By: /s/ Aaron Duis
Aaron Duis
Assistant County Attorney
Wright County Attorney's Office
3700 Braddock Avenue NE, Suite 2100
Buffalo, MN 55313
(763) 682-7400
Attorney I.D. #285213
2
Document Filed Date
December 26, 2023
Case Filing Date
December 26, 2023
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86-CV-23-6442 Filed in District Court State of Minnesota 12/26/2023 12:26 PM STATE OF MINNESOTA IN DISTRICT COURT COUNTY OF WRIGHT TENTH JUDICIAL DISTRICT Brian A. Lutes, Ct. File No.: WRIGHT COUNTY ATTORNEY Case Type: 14 – Other Civil Plaintiff, vs. COMPLAINT 2018 Chevrolet Silverado MN license plate: YBV5917 (expires 2019) VIN: 1GC4KYCYXJF151695 (Owner: Maxwell Kenneth Moonen), Defendant. THE STATE OF MINNESOTA TO THE ABOVE-NAMED DEFENDANT, Maxwell Kenneth Moonen: The Plaintiff, for his Separate Complaint for Forfeiture, states and alleges as follows: 1. Defendant property is: property that was used or intended for use to commit or facilitate the commission of a designated offense, to-wit, Fleeing a Peace Officer, in violation of Minn. Stat. § 609.487 and endangered life or property. 2. Defendant property is subject to forfeiture pursuant to Minn. Stat. § 609.5312. 3. On or about November 5, 2023, and on all other dates material herein, defendant property was owned and possessed by Maxwell Kenneth Moonen in Wright County, Minnesota. 4. J and J Glass and Glazing, Inc., (300 Railroad Avenue, Delano, MN 55328) is listed as the registered owner of the defendant vehicle with the Department of Public Safety. 5. On or about December 24, 2023, defendant property was seized in Wright County by the Wright County Sheriff’s Office and remains in the custody of that law enforcement agency subject to the criminal complaint and to these said proceedings. 6. The Plaintiff will charge Maxwell Kenneth Moonen with Fleeing in violation of Minn. Stat. § 609.487. WHEREFORE, Plaintiff prays that the Court: 86-CV-23-6442 Filed in District Court State of Minnesota 12/26/2023 12:26 PM 1. Order the forfeiture of defendant property to the Wright County Sheriff’s Office to be used and/or disposed of as provided by law. 2. Grant such other relief as the Court deems appropriate. The undersigned hereby acknowledges that the costs, disbursements and reasonable attorney and witness fees may be awarded to the opposing party or parties pursuant to Minn. Stat. § 549.21. Dated: December 26, 2023 By: /s/ Aaron Duis Aaron Duis Assistant County Attorney Wright County Attorney's Office 3700 Braddock Avenue NE, Suite 2100 Buffalo, MN 55313 (763) 682-7400 Attorney I.D. #285213 2