On December 17, 2020 a
Party Notice
was filed
involving a dispute between
The State Of Texas,
and
$30,000.00 In U.S. Currency,
Muehlberger, Linda,
for Criminal Matters - Seizure and Forfeiture
in the District Court of Galveston County.
Preview
Filed: 12/17/2020 11:06 AM
JOHN D. KINARD - District Clerk
Galveston County, Texas
Envelope No. 49041879
By: Shailja Dixit
20-CV-1923 12/17/2020 3:19 PM
CAUSE NO.
THE STATE OF TEXAS IN THE DISTRICT COURT OF
V. GALVESTON COUNTY, TEXAS
Galveston County - 10th District Court
$30,000.00 IN U.S. CURRENCY JUDICIAL DISTRICT
_______________________________________________________________________________
NOTICE OF SEIZURE AND INTENDED FORFEITURE
______________________________________________________________________________
Jack Roady, Criminal District Attorney of Galveston County, Texas, for the State of Texas,
files this Notice of Seizure and Intended Forfeiture of $30,000.00 IN U.S. CURRENCY.
I.
DISCOVERY LEVEL
Plaintiff intends to conduct discovery pursuant to the discovery control plan Level 2. Tex. R.
Civ. P. 190.3.
II.
DEFENDANT CONTRABAND
Defendant is the following property:
$30,000.00 IN U.S. CURRENCY
III.
RESPONDENTS
A certified copy of this Notice should be served on the following person or persons, who
may own, have an interest in, or claim to own or have an interest in the seized property, and who
may be served with process at the address indicated:
LINDA MUEHLBERGER
14 LEGAS DRIVE
GALVESTON, TX 77551
DOB: 8/24/1946
Status Conference - 03/18/2021
1
IV.
SEIZURE
In Galveston County, Texas, on 12/10/2020, J. COWARD, a Peace Officer employed by
the LEAGUE CITY POLICE DEPARTMENT, a political subdivision of the State authorized by
law to employ peace officers, seized the property described in Paragraph II.
V.
CRIMINAL ACTIVITY
The property listed in Paragraph II is contraband and is subject to forfeiture by authority of
Chapter 59 of the Texas Code of Criminal Procedure, as the property was used in the commission
of, intended to be used in the commission of, is proceeds gained from, or was acquired with proceeds
gained from, the commission of the following felony or felonies:
MONEY LAUNDERING IN TEXAS PENAL CODE 34.02
The sworn statement of the seizing officer which contains a schedule of the property seized,
an acknowledgment that the officer has seized the property, and a list of the officer's reasons for the
seizure is attached hereto as "APPENDIX A" and is incorporated herein.
VI.
REQUESTS FOR DISCLOSURE
Pursuant to Rule 194, each respondent is requested to disclose, within 50 days of service of
this request, the information or material described in Texas Rule of Civil Procedure 194.2 (a) – (f)
and (i) - (1).
VII.
PRAYER
The State of Texas prays that this Court find that the seized property is contraband and order
it forfeited to the State pursuant to Texas Code of Criminal Procedure Chapter 59, and for such other
relief at law or in equity to which the State of Texas may be entitled.
2
Respectfully submitted,
JACK ROADY
CRIMINAL DISTRICT ATTORNEY
GALVESTON COUNTY, TEXAS
/s/ Shawn Connally
SHAWN CONNALLY
ASST. CRIMINAL DISTRICT ATTORNEY
600 59TH Street, Suite 1001
Galveston, Texas 77551
shawn.connally@co.galveston.tx.us
Telephone (409) 766-2355
Fax (409) 765-3132
SBN: 24051899
3
APPENDIX “A”
4
Document Filed Date
December 17, 2020
Case Filing Date
December 17, 2020
Category
Criminal Matters - Seizure and Forfeiture
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Filed: 12/17/2020 11:06 AM JOHN D. KINARD - District Clerk Galveston County, Texas Envelope No. 49041879 By: Shailja Dixit 20-CV-1923 12/17/2020 3:19 PM CAUSE NO. THE STATE OF TEXAS IN THE DISTRICT COURT OF V. GALVESTON COUNTY, TEXAS Galveston County - 10th District Court $30,000.00 IN U.S. CURRENCY JUDICIAL DISTRICT _______________________________________________________________________________ NOTICE OF SEIZURE AND INTENDED FORFEITURE ______________________________________________________________________________ Jack Roady, Criminal District Attorney of Galveston County, Texas, for the State of Texas, files this Notice of Seizure and Intended Forfeiture of $30,000.00 IN U.S. CURRENCY. I. DISCOVERY LEVEL Plaintiff intends to conduct discovery pursuant to the discovery control plan Level 2. Tex. R. Civ. P. 190.3. II. DEFENDANT CONTRABAND Defendant is the following property: $30,000.00 IN U.S. CURRENCY III. RESPONDENTS A certified copy of this Notice should be served on the following person or persons, who may own, have an interest in, or claim to own or have an interest in the seized property, and who may be served with process at the address indicated: LINDA MUEHLBERGER 14 LEGAS DRIVE GALVESTON, TX 77551 DOB: 8/24/1946 Status Conference - 03/18/2021 1 IV. SEIZURE In Galveston County, Texas, on 12/10/2020, J. COWARD, a Peace Officer employed by the LEAGUE CITY POLICE DEPARTMENT, a political subdivision of the State authorized by law to employ peace officers, seized the property described in Paragraph II. V. CRIMINAL ACTIVITY The property listed in Paragraph II is contraband and is subject to forfeiture by authority of Chapter 59 of the Texas Code of Criminal Procedure, as the property was used in the commission of, intended to be used in the commission of, is proceeds gained from, or was acquired with proceeds gained from, the commission of the following felony or felonies: MONEY LAUNDERING IN TEXAS PENAL CODE 34.02 The sworn statement of the seizing officer which contains a schedule of the property seized, an acknowledgment that the officer has seized the property, and a list of the officer's reasons for the seizure is attached hereto as "APPENDIX A" and is incorporated herein. VI. REQUESTS FOR DISCLOSURE Pursuant to Rule 194, each respondent is requested to disclose, within 50 days of service of this request, the information or material described in Texas Rule of Civil Procedure 194.2 (a) – (f) and (i) - (1). VII. PRAYER The State of Texas prays that this Court find that the seized property is contraband and order it forfeited to the State pursuant to Texas Code of Criminal Procedure Chapter 59, and for such other relief at law or in equity to which the State of Texas may be entitled. 2 Respectfully submitted, JACK ROADY CRIMINAL DISTRICT ATTORNEY GALVESTON COUNTY, TEXAS /s/ Shawn Connally SHAWN CONNALLY ASST. CRIMINAL DISTRICT ATTORNEY 600 59TH Street, Suite 1001 Galveston, Texas 77551 shawn.connally@co.galveston.tx.us Telephone (409) 766-2355 Fax (409) 765-3132 SBN: 24051899 3 APPENDIX “A” 4