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DocuSign Envelope ID: CSF3FFE9-3D77-4356-888C-C9E3A6C1D6D1
NO.
THE STATE OF TEXAS IN THE JUDICIAL
VS. DISTRICT COURT OF
$1309.00 U.S. Currency
TRAVIS COUNTY, TEXAS
ORIGINAL NOTICE OF SEIZURE AND INTENDED FORFEITURE
PURSUANT TO TEXAS CODE OF CRIM. PROC. CHAPTER 59
NOW COMES Sgt. J. Miller #1430, a peace officer of the Cedar Park Police Department, and in the
name of the State of Texas, files this, a Notice of Seizure and Intended Forfeiture of Contraband, to wit:
$1309.00 U.S. Currency as petition for relief alleges the following through his attorney of record, the
District Attorney of Travis County, Texas:
I
Petitioner seeks discovery to be conducted pursuant to Texas Rule of Civil procedure 190.2
(Discovery Control Plan Level 1).
I
This proceeding is brought pursuant to Chapter 59 of the Texas Code of Criminal Procedure.
Il
Plaintiff alleges that on or about the 6th day of October, 2020, Sgt, J. Miller , a peace officer with the
Cedar Park Police Department, whose office is located at 911 Quest Pkwy, Cedar Park, Williamson
County, Texas, acting in his capacity as such, and in the course of his duty, seized the above contraband,
pursuant to Articles 59.01 et seq. of the Texas Code of Criminal Procedure, located at 12820 N. Lamar
Blvd. #1414, in Austin, Travis County, Texas, which was used and intended to be used in the commission
of a felony enumerated under Art. 59.01, Manufacture/Delivery of a Controlled Substance PG3
(Alprazolam)- 1 Degree Felony and Manufacture/Delivery of a Controlled Substance PG1 (Cocaine)
-1 Degree Felony, in Travis County, Texas.
IV
In the alternative, Plaintiff alleges that the above described contraband was the proceeds gained from
the commission of said felony, or was acquired with proceeds gained from the commission of said felony.
DocuSign Envelope ID: CSF3FFE9-3D77-4356-888C-C9E3A6C1D6D1
Vv
Plaintiff alleges that Jacob Moore Padgett WM 10/10/1996, was in possession of the contraband at the
/time of its lawful seizure by the peace officer pursuant to Art. 59.03 of the Texas Code of Criminal
Procedure.
WHEREFORE, PREMISES CONSIDERED, the State of Texas prays that this be considered as a
Notice of Seizure and Intended Forfeiture and that upon hearing, as provided by statutes, this Court enter
its Order finding that said contraband was used and intended to be used in the commission of a felony
enumerated under Art. 59.01, Tex. Code of Criminal Procedure, or was the proceeds gained from the
commission of a felony enumerated under Art. 59.01, or was acquired with proceeds gained from the
commission of a felony enumerated under 59.01, and uphold said seizure and forfeiture, and forfeit to the
Travis County District Attorney as agent for the State pursuant to Art. 59.06 of the Tex. Code of Crim.
Procedure, the said contraband as provided by law, and order the same to be disposed of in accordance with
the provisions of Chapter 59 of the Texas Code of Criminal Procedure.
Plaintiff prays for such other relief, at law and in equity, as Plaintiff shall be entitled to receive.
Respectfully submitted,
Margaret Moore
District Attorney
Travis County, nas
Josh Reno
Assistant District Attorney
State Bar No. 24046702
P.O. Box 1748
Austin, TX 78767
512-854-5156
DocuSign Envelope ID: CSF3FFE9-3D77-4356-888C-C9E3A6C1D6D1
STATE OF TEXAS
§ AFFIDAVIT OF SEIZING OFFICER
COUNTY OF TRAVIS
THE UNDERSIGNED AFFIANT, WHO AFTER BEING DULY SWORN BY ME, ON OATH,
MAKES THE FOLLOWING STATEMENT:
Affiant is Sgt. J. Miller, and is a peace officer with the Cedar Park Police Department, whose address is
911 Quest Pkwy, Cedar Park, Williamson County, Texas, 78613. On the 6" day of October, 2020, Cedar
Park Police Sergeant Miller, in the course of his duty, seized certain property described as follows:
$1309.00 in U.S. Currency. Said seizure was made by Sergeant Miller at 12820 N. Lamar Blvd. # 1414
Austin, Travis County, Texas.
Sergeant Miller’s reasons for the seizure of the above described property are as follows:
On October 6", 2020, members of the Cedar Park Police Organized Crime Unit (OCU) executed a search
warrant at 12820 N. Lamar Blvd. #1414. The search warrant was for the body of Jacob Padgett WM
10/10/1996, who was wanted on outstanding warrant (Possession of a Controlled Substance PG1 — F3)
from Williamson County.
OCU Detectives knocked at the front door of Padgett’s apartment, 12820 N. Lamar Blvd. #1414 and had
good reason to believe he was inside the apartment. After continued knocking at the front door, Detective
Alejandro advised that he saw Padgett, through the first floor window, run from the living room and into
the bathroom of the apartment.
Entry was forced into the apartment and Padgett was found in the bathroom flushing pills down the toilet.
It was estimated that Padgett flushed and destroyed approximately 900 pills. The pills appeared to be 2
MG Alprazolam based on the markings found on other blue pills packaged similarly (B707).
Padgett granted consent to search his residence. As a result of the search, approximately 1664 additional
2MG Alprazolam pills, 13 grams of cocaine, and $1309 in US currency were located.
A digital scale and multiple clear plastic bags were found in the kitchen, where a large sum of US Currency
was found.
Digital scales and plastic bags are often used as implements in the distribution of illegal narcotics. This,
combined with the large number of drugs found inside the residence gives reason for affiant to believe that
Padgett was selling drugs for profit. Affiant knows that it is common for drug dealers to receive US
DocuSign Envelope ID: CSF3FFE9-3D77-4356-888C-C9E3A6C1D6D1
Currency in exchange for selling drugs.
Affiant contends that the $1309.00 in US Currency seized from Jacob Padgett is either the proceeds of
illegal narcotics trafficking or was being used to facilitate illegal narcotics trafficking.
\
wit
Affiant
SUBSCRIBED AND SWORN to before me by Justin Miller this 27th day of October, 2020.
*
i, DIANE LORAINE GLERUM
< Notary Public, State of Texas| Notary Public, State of Texas
33)
oy Comm. Expires 09-10-2022
“ur Notary ID 131716080
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DocuSign Envelope ID: CSF3FFE9-3D77-4356-888C-C9E3A6C1D6D1 NO. THE STATE OF TEXAS IN THE JUDICIAL VS. DISTRICT COURT OF $1309.00 U.S. Currency TRAVIS COUNTY, TEXAS ORIGINAL NOTICE OF SEIZURE AND INTENDED FORFEITURE PURSUANT TO TEXAS CODE OF CRIM. PROC. CHAPTER 59 NOW COMES Sgt. J. Miller #1430, a peace officer of the Cedar Park Police Department, and in the name of the State of Texas, files this, a Notice of Seizure and Intended Forfeiture of Contraband, to wit: $1309.00 U.S. Currency as petition for relief alleges the following through his attorney of record, the District Attorney of Travis County, Texas: I Petitioner seeks discovery to be conducted pursuant to Texas Rule of Civil procedure 190.2 (Discovery Control Plan Level 1). I This proceeding is brought pursuant to Chapter 59 of the Texas Code of Criminal Procedure. Il Plaintiff alleges that on or about the 6th day of October, 2020, Sgt, J. Miller , a peace officer with the Cedar Park Police Department, whose office is located at 911 Quest Pkwy, Cedar Park, Williamson County, Texas, acting in his capacity as such, and in the course of his duty, seized the above contraband, pursuant to Articles 59.01 et seq. of the Texas Code of Criminal Procedure, located at 12820 N. Lamar Blvd. #1414, in Austin, Travis County, Texas, which was used and intended to be used in the commission of a felony enumerated under Art. 59.01, Manufacture/Delivery of a Controlled Substance PG3 (Alprazolam)- 1 Degree Felony and Manufacture/Delivery of a Controlled Substance PG1 (Cocaine) -1 Degree Felony, in Travis County, Texas. IV In the alternative, Plaintiff alleges that the above described contraband was the proceeds gained from the commission of said felony, or was acquired with proceeds gained from the commission of said felony. DocuSign Envelope ID: CSF3FFE9-3D77-4356-888C-C9E3A6C1D6D1 Vv Plaintiff alleges that Jacob Moore Padgett WM 10/10/1996, was in possession of the contraband at the /time of its lawful seizure by the peace officer pursuant to Art. 59.03 of the Texas Code of Criminal Procedure. WHEREFORE, PREMISES CONSIDERED, the State of Texas prays that this be considered as a Notice of Seizure and Intended Forfeiture and that upon hearing, as provided by statutes, this Court enter its Order finding that said contraband was used and intended to be used in the commission of a felony enumerated under Art. 59.01, Tex. Code of Criminal Procedure, or was the proceeds gained from the commission of a felony enumerated under Art. 59.01, or was acquired with proceeds gained from the commission of a felony enumerated under 59.01, and uphold said seizure and forfeiture, and forfeit to the Travis County District Attorney as agent for the State pursuant to Art. 59.06 of the Tex. Code of Crim. Procedure, the said contraband as provided by law, and order the same to be disposed of in accordance with the provisions of Chapter 59 of the Texas Code of Criminal Procedure. Plaintiff prays for such other relief, at law and in equity, as Plaintiff shall be entitled to receive. Respectfully submitted, Margaret Moore District Attorney Travis County, nas Josh Reno Assistant District Attorney State Bar No. 24046702 P.O. Box 1748 Austin, TX 78767 512-854-5156 DocuSign Envelope ID: CSF3FFE9-3D77-4356-888C-C9E3A6C1D6D1 STATE OF TEXAS § AFFIDAVIT OF SEIZING OFFICER COUNTY OF TRAVIS THE UNDERSIGNED AFFIANT, WHO AFTER BEING DULY SWORN BY ME, ON OATH, MAKES THE FOLLOWING STATEMENT: Affiant is Sgt. J. Miller, and is a peace officer with the Cedar Park Police Department, whose address is 911 Quest Pkwy, Cedar Park, Williamson County, Texas, 78613. On the 6" day of October, 2020, Cedar Park Police Sergeant Miller, in the course of his duty, seized certain property described as follows: $1309.00 in U.S. Currency. Said seizure was made by Sergeant Miller at 12820 N. Lamar Blvd. # 1414 Austin, Travis County, Texas. Sergeant Miller’s reasons for the seizure of the above described property are as follows: On October 6", 2020, members of the Cedar Park Police Organized Crime Unit (OCU) executed a search warrant at 12820 N. Lamar Blvd. #1414. The search warrant was for the body of Jacob Padgett WM 10/10/1996, who was wanted on outstanding warrant (Possession of a Controlled Substance PG1 — F3) from Williamson County. OCU Detectives knocked at the front door of Padgett’s apartment, 12820 N. Lamar Blvd. #1414 and had good reason to believe he was inside the apartment. After continued knocking at the front door, Detective Alejandro advised that he saw Padgett, through the first floor window, run from the living room and into the bathroom of the apartment. Entry was forced into the apartment and Padgett was found in the bathroom flushing pills down the toilet. It was estimated that Padgett flushed and destroyed approximately 900 pills. The pills appeared to be 2 MG Alprazolam based on the markings found on other blue pills packaged similarly (B707). Padgett granted consent to search his residence. As a result of the search, approximately 1664 additional 2MG Alprazolam pills, 13 grams of cocaine, and $1309 in US currency were located. A digital scale and multiple clear plastic bags were found in the kitchen, where a large sum of US Currency was found. Digital scales and plastic bags are often used as implements in the distribution of illegal narcotics. This, combined with the large number of drugs found inside the residence gives reason for affiant to believe that Padgett was selling drugs for profit. Affiant knows that it is common for drug dealers to receive US DocuSign Envelope ID: CSF3FFE9-3D77-4356-888C-C9E3A6C1D6D1 Currency in exchange for selling drugs. Affiant contends that the $1309.00 in US Currency seized from Jacob Padgett is either the proceeds of illegal narcotics trafficking or was being used to facilitate illegal narcotics trafficking. \ wit Affiant SUBSCRIBED AND SWORN to before me by Justin Miller this 27th day of October, 2020. * i, DIANE LORAINE GLERUM < Notary Public, State of Texas| Notary Public, State of Texas 33) oy Comm. Expires 09-10-2022 “ur Notary ID 131716080