Case: 3:12-cr-50027 Document #: 196 Filed: 12/10/14 Page 1 of 4 PageID #:1177

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS
WESTERN DIVISION
UNITED STATES OF AMERICA

v.
RITA CRUNDWELL,
Defendant,
and
KAPLOW INSURANCE AGENCY,
Third Party Citation Respondent.

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No. 12 CR 50027
Judge Philip G. Reinhard

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 15, 2013 and served on the respondent on April 16, 2013. The
defendant was served on April 18, 2013 with statutory notice.
3.

Pursuant to the citation to discover assets, the respondent answered on April 19,

2013. The respondent responded to the citation in a letter dated April 17, 2013 wherein they
indicated they were holding $18,997.80 belonging to the defendant.

In its answer, the

respondent stated that at the time the citation was served, the respondent had in its possession or

Case: 3:12-cr-50027 Document #: 196 Filed: 12/10/14 Page 2 of 4 PageID #:1178

under its control, property belonging to the defendant, Rita Crundwell, in the form of insurance
premium refunds for cancelled insurance policies. Based upon the respondents answer, the
United States is entitled to $18,997.80, which represents the defendants nonexempt interest in
insurance policy premiums refunds 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, 219 South Dearborn Street, 20th Floor, Chicago, Illinois 60604.
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, Kaplow Insurance Agency, to submit to the Clerk of the Court $18,997.80, which
represents the defendants nonexempt interest in the insurance policy premium refunds, 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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