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ELECTRONICALLY FILED
JOHN SAVRNOCH Superior Court of California
DISTRICT ATTORNEY
County of Santa Barbara
BY: Anthony S. Davis
Senior Deputy District Attorney Darrel E. Parker, Executive Officer
1112 Santa Barbara Street 6/18/2024 4:32 PM
Santa Barbara, CA 93101 By: Norma Willoughby , Deputy
Telephone: (805) 568-2300
State Bar #220130
Attorneys for Plaintiff
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF SANTA BARBARA
SANTA MARIA DIVISION
10
THE PEOPLE OF THE STATE OF CALIFORNIA,
24CV03432
VW Case No.
12
13 Plaintiff, PETITION FOR FORFEITURE
(Health and Safety Code section
14 vs. 11488.4)
15
16 SIXTY-FIVE THOUSAND SIX-HUNDRED AND
17 SEVENTY-SIX DOLLARS ($65,676.00) U.S.
18 CURRENCY AND WHITE 2016 MERCEDES-BENZ
19 E350 LICENSE PLATE 9LSF338,
20 Defendants,
21
22
23
24 Plaintiff, by and through its counsel, Santa Barbara County District Attorney, hereby alleges:
25 I
26 This is an action for forfeiture of the defendant property pursuant to the provisions of Health and
27 Safety Code sections 11469, et seq. brought on behalf
of the People of the State of California.
28
Petition for Forfeiture
Il.
This court has jurisdiction over this action by virtue of Health and Safety Code section
11488.4(a).
Til.
The defendant property is described as SIXTY-FIVE THOUSAND SIX-HUNDRED AND
SEVENTY-SIX DOLLARS ($65,676.00) U.S. CURRENCY AND WHITE 2016 MERCEDES-BENZ
E350 LICENSE PLATE 9LSF338.
IV.
On May 22, 2024, agents of the Santa Barbara County Sheriff's Department seized the defendant
10 currency from Extra Space Storage, Space #F284, at 401 Farnel Road in the City of Santa Maria,
i California, and the defendant vehicle from the Santa Maria Probation Report and Resource Center
12 located at 124 Carmen Lane in the City of Santa Maria, California. The defendant property is currently
13 located at, or is under the control of, the Santa Barbara Sheriff's Office Special Investigations Bureau,
14 in Santa Maria, California, within the jurisdiction of this court.
15 Vv.
16 On or before May 22, 2024, the defendant property became subject to forfeiture pursuant to
17 Health and Safety Code section 11470 in that said property was used as an instrument to facilitate the
18 manufacture of, possession for sale or sale of a controlled substance or was exchanged or intended to be
19 exchanged for a controlled substance.
20 VI.
21 On or before May 22, 2024, the defendant property became subject to forfeiture pursuant to
22 Health and Safety Code section 11470 in that said property was a thing of value purchased with funds
23 from the sale of controlled substances, or was proceeds traceable to such an exchange and/or defendant
24 money was used or intended to be used to facilitate any violation of section of the Health and Safety
25 Code insofar as the offense involves sale, possession for sale, cultivation or conspiracy to commit at
26 least one of those offenses.
27
28
Petition for Forfeiture
Vil.
On May 22, 2024, a copy of the Notice of Seizure and Forfeiture Proceedings regarding
Defendant Property, SIXTY-FIVE THOUSAND SIX-HUNDRED AND SEVENTY-SIX DOLLARS
($65,676.00) U.S. CURRENCY AND WHITE 2016 MERCEDES-BENZ E350 LICENSE PLATE
9LSF338, was personally served on Luis Gil at the Santa Maria Probation Report and Resource Center,
124 Carmen Lane, Santa Maria, California.
WHEREFORE, Plaintiff prays:
1. For judgment and order declaring defendant property forfeited to the State of California and
10 for disposition pursuant to Health and Safety Code section 11489 [or 11473.2, 11473.3];
ll 2. For such further relief as the court deems proper.
12
13
14 DATED: June 17, 2024
15 Respectfully submitted,
16
JOHN SAVRNOCH,
17 DISTRICT ATTORNEY
18
19
By: =. i Rez
20 ANTHORY S. DAVIS
Senior Deputy District Attorney
21 Attorney for Plaintiff
22
23
24
25
26
27
28
Petition for Forfeiture
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ELECTRONICALLY FILED JOHN SAVRNOCH Superior Court of California DISTRICT ATTORNEY County of Santa Barbara BY: Anthony S. Davis Senior Deputy District Attorney Darrel E. Parker, Executive Officer 1112 Santa Barbara Street 6/18/2024 4:32 PM Santa Barbara, CA 93101 By: Norma Willoughby , Deputy Telephone: (805) 568-2300 State Bar #220130 Attorneys for Plaintiff SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF SANTA BARBARA SANTA MARIA DIVISION 10 THE PEOPLE OF THE STATE OF CALIFORNIA, 24CV03432 VW Case No. 12 13 Plaintiff, PETITION FOR FORFEITURE (Health and Safety Code section 14 vs. 11488.4) 15 16 SIXTY-FIVE THOUSAND SIX-HUNDRED AND 17 SEVENTY-SIX DOLLARS ($65,676.00) U.S. 18 CURRENCY AND WHITE 2016 MERCEDES-BENZ 19 E350 LICENSE PLATE 9LSF338, 20 Defendants, 21 22 23 24 Plaintiff, by and through its counsel, Santa Barbara County District Attorney, hereby alleges: 25 I 26 This is an action for forfeiture of the defendant property pursuant to the provisions of Health and 27 Safety Code sections 11469, et seq. brought on behalf of the People of the State of California. 28 Petition for Forfeiture Il. This court has jurisdiction over this action by virtue of Health and Safety Code section 11488.4(a). Til. The defendant property is described as SIXTY-FIVE THOUSAND SIX-HUNDRED AND SEVENTY-SIX DOLLARS ($65,676.00) U.S. CURRENCY AND WHITE 2016 MERCEDES-BENZ E350 LICENSE PLATE 9LSF338. IV. On May 22, 2024, agents of the Santa Barbara County Sheriff's Department seized the defendant 10 currency from Extra Space Storage, Space #F284, at 401 Farnel Road in the City of Santa Maria, i California, and the defendant vehicle from the Santa Maria Probation Report and Resource Center 12 located at 124 Carmen Lane in the City of Santa Maria, California. The defendant property is currently 13 located at, or is under the control of, the Santa Barbara Sheriff's Office Special Investigations Bureau, 14 in Santa Maria, California, within the jurisdiction of this court. 15 Vv. 16 On or before May 22, 2024, the defendant property became subject to forfeiture pursuant to 17 Health and Safety Code section 11470 in that said property was used as an instrument to facilitate the 18 manufacture of, possession for sale or sale of a controlled substance or was exchanged or intended to be 19 exchanged for a controlled substance. 20 VI. 21 On or before May 22, 2024, the defendant property became subject to forfeiture pursuant to 22 Health and Safety Code section 11470 in that said property was a thing of value purchased with funds 23 from the sale of controlled substances, or was proceeds traceable to such an exchange and/or defendant 24 money was used or intended to be used to facilitate any violation of section of the Health and Safety 25 Code insofar as the offense involves sale, possession for sale, cultivation or conspiracy to commit at 26 least one of those offenses. 27 28 Petition for Forfeiture Vil. On May 22, 2024, a copy of the Notice of Seizure and Forfeiture Proceedings regarding Defendant Property, SIXTY-FIVE THOUSAND SIX-HUNDRED AND SEVENTY-SIX DOLLARS ($65,676.00) U.S. CURRENCY AND WHITE 2016 MERCEDES-BENZ E350 LICENSE PLATE 9LSF338, was personally served on Luis Gil at the Santa Maria Probation Report and Resource Center, 124 Carmen Lane, Santa Maria, California. WHEREFORE, Plaintiff prays: 1. For judgment and order declaring defendant property forfeited to the State of California and 10 for disposition pursuant to Health and Safety Code section 11489 [or 11473.2, 11473.3]; ll 2. For such further relief as the court deems proper. 12 13 14 DATED: June 17, 2024 15 Respectfully submitted, 16 JOHN SAVRNOCH, 17 DISTRICT ATTORNEY 18 19 By: =. i Rez 20 ANTHORY S. DAVIS Senior Deputy District Attorney 21 Attorney for Plaintiff 22 23 24 25 26 27 28 Petition for Forfeiture