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Colorado civil forfeiture,
restraining orders & nuisance abatement - drugs, drug prosecutions,
prostitution
soliciting for prostitution, pimping, pandering,
gambling
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RIGHT
TO REMAIN SILENT
NO STATEMENTS
LAW ENFORCEMENT * PROSECUTORS
* THIRD PERSONS
IMPORTANT - PLEASE READ CAREFULLY |
My clients are advised not to discuss facts, law or trial strategy in any
offense of a sexual nature or civil nuisance abatement proceeding with anyone other than myself as legal counsel or a private investigator
retained as my agent, who is covered by the attorney - client privilege. Statements
to any third person may be grounds for additional criminal charges, even if
the other person is a trusted confidant. In cases alleging a sexual or
drug offense, it is quite common for others to be previously or subsequently
apprehended and offer information to law enforcement or prosecution in return
for reduced charges or immunity (transactional or use). Because offenses
of a sexual or drug nature may be perceived as going enterprises, VNI units of
law enforcement recruit confidential informants to gain information. It
would also not be uncommon for a person's confidant to be a confidential
informer, perhaps
wearing a
wire. Be very careful what you tell or say to other persons -
your statements may be used against you at hearing or trial, and the third person's testimony may be involuntarily compelled by
subpoena. Website visitors who are not my clients should consult with
your attorney before talking.
Colorado statutes classify
identify 4 classes of nuisances. The statutes are rather lengthy and not
included here. Below I have provided an abbreviated synopsis of assets
used in connection with criminal activity which are generally included as class 1 pubic
nuisances pursuant to CRS 16-13-303.
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public or private place of prostitution, place where the following
occurs - commission of soliciting for prostitution, pandering, keeping a place of prostitution, or
pimping
child prostitution, place where the commission of soliciting for child
prostitution, pandering of a child, keeping a place of child prostitution, pimping of a child, inducement of child prostitution, sexual exploitation of children
gambling
unlawful drugs - unlawful manufacture, cultivation, growth, production, processing, sale, or distribution or for storage or possession for any unlawful manufacture, sale, or distribution of any controlled
substance or any other drug the possession of which is an offense, except for possession of less than eight ounces of
marijuana
drug paraphernalia - unlawful manufacture, sale, or distribution
theft by receiving or transportation
of goods which are the subject of felony theft
commission of any felony not otherwise included in this
section
felony vehicular eluding
hit and run with serious bodily injury or death
drive-by crime
committing, attempting to commit, or conspiring to commit against an elderly person any felony.
For purposes of this forfeiture, an "elderly person" means a person sixty years of age or older.
All equipment, mechanical systems, or machinery, or parts thereof, shall be deemed to be a class 1 public nuisance at the location of the automatic dialing system when used for soliciting with an automatic dialing system containing a prerecorded message.
Judgment in an action to abate a public nuisance may include a permanent injunction to restrain, abate, and prevent the continuance or recurrence of the nuisance and an order directing the confiscation and forfeiture of property. The court may grant declaratory relief, mandatory orders, or any other relief deemed necessary to accomplish the purposes of the injunction or order and enforce the same, and the court may retain jurisdiction of the case for the purpose of enforcing its orders.
CRS 16-13-309
Pursuant to CRS 16-13-303
Forfeiture may include all fixtures and contents of any building, structure, vehicle, or real property which is a class 1 public nuisance
and all such property is are subject to seizure, confiscation, and forfeiture
In addition, the personal property of every kind and description, including currency and other negotiable instruments and vehicles, used in conducting, maintaining, aiding, or abetting any class 1 public nuisance is subject to seizure, confiscation, and
forfeiture. The following shall be deemed class 1 public nuisances and be subject to forfeiture and distributed as provided in section 16-13-311 (3), and no property rights shall exist in them:
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All currency, negotiable instruments, securities, or other things of value furnished or intended to be furnished by any person in exchange for any public nuisance act; or
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All proceeds traceable to any public nuisance act; or
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All currency, negotiable instruments, and securities used or intended to be used to facilitate any public nuisance act; or
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All equipment of any kind, including but not limited to computers and any type of computer hardware, software, or other equipment, used in committing sexual exploitation of a child, as described in
CRS 18-6-403, or computer crime, as described in section CRS 18-5.5-102
Additionally, the state may move
for forfeiture summary judgment if no dispute exists as to the facts.
Simply stated, when a person
commits crime, much of the person's physical wealth or possession may be subject
to forfeiture. Call it greed or deterrence, this significantly piques
interest of the State of Colorado.
The DA
Office may seek an injunction to abate a nuisance. Usually this
would take the form of a court order closing a business, but essentially an
injunction prohibits a given activity.
CRS 16-13-302 declares it is the policy of Colorado that every public nuisance shall be restrained, prevented, abated, and perpetually enjoined. It is the duty of the
See: People v. Perez, 192 Colo. 562 (Colo. 1977)
business closed permanently - prostitution
Steinberg v. People, 154 Colo.
264, 390 P.2d 811 (Colo. 1964)
business closed one year - center of
annoyances, vandalism and indecencies
Edelweiss v.
People, 154 Colo. 154, 389 P.2d 189 (Colo. 1964)
business closed permanently - prostitution
To abate a nuisance, a forfeiture
action may be commenced against property, real or personal. CRS 16-13-301,
et. seq. Forfeitures are disfavored as a
matter of public policy. People
v. One 1988 Mazda 323, 857 P.2d 569 (Colo. App. 1993)
ADMISSION OF OWNERSHIP INTEREST. Any person contesting an action for forfeiture
must establish his or her standing as a true owner of the property subject to
forfeiture. People v. Grell,
950 P.2d 660 (Colo. App. 1997)
The state must establish a nexus
or connection between the asset and the nuisance.
USE OF VEHICLES TO TRANSPORT
STOLEN ITEMS - INSUFFICIENT NEXUS. Defendant used a 1988 Mazda lawfully to
drive to and from her job in a department store. On two separate occasions
was observed removing merchandise from the store without paying for it, then
placed the items in her Mazda and drove away. Such thefts constituted
felonious conduct. The People, for the purposes of this proceeding, conceded
that the theft was completed before defendant placed the stolen merchandise in
her vehicle, but sought forfeiture under Colorado's Abatement of Public Nuisance
Act, § 16-13-301 on the theory the Mazda aided and abetted defendant's illegal
activity making it subject to forfeiture under CRS 16-13-303(2). The facts
and the evidence presented, when placed in context with concessions by the
People, were inadequate to prove that the Mazda was sufficiently connected to
the thefts to allow forfeiture under either § 16-13-303(1) or (2). People
v. One 1988 Mazda 323, 857 P.2d 569 (Colo. App. 1993)
USE OF VEHICLE FOR COMMUTE TO
MARIJUANA CULTIVATION - INSUFFICIENT NEXUS. Where there had been no activity,
other than the cultivation of marihuana, carried on at an office location, and 3
affidavit asserted that: "I observed the trucks . . . being driven . . . to
the dental office on several occasions." However, none of these affidavits
alleged that either of the two trucks were involved in carrying any item either
to or from the office where the marihuana was under cultivation, citing People
v. Cerrone, 780 P.2d 562 (Colo. App. 1989) the court ruled the evidence was
insufficient to establish a nexus. CRS 16-13-303(3)(b) which makes property
acquired by the proceeds from unlawful activities forfeitable, this court held,
as a matter of law, that the absence of proof that the property had a connection
with criminal activity made its forfeiture improper. People v. Cerrone,
780 P.2d 562 (Colo. App. 1989).
USE OF VEHICLE IN PROSTITUTION -
FORFEITURE APPROVED. Where defendant had telephoned an undercover police
officer and solicited prostitution, then drove in the Volkswagen to the motel
where the contract for prostitution was completed, the evidence established that
the vehicle was used by the defendant in completing the crime of solicitation by
driving to the motel for that purpose. A sufficient nexus had been established
linking the car to the criminal activity. People v. 1979 Volkswagen, 773
P.2d 619 (Colo. App. 1989) This case is similar to People v. Garner, 732
P.2d 1194 (Colo. 1987) in which the vehicle was used to transport marihuana.
FORFEITURE - INFERRED NEXUS. By
establishing that the items sought to be forfeited were used in the unlawful
activity, the items were subject to forfeiture pursuant to CRS 16-13-303(2).
Because the building in which the items were located was deemed a public
nuisance, the trial court could reasonably infer that the use of the items
seized was "connected or rationally related to" the unlawful activity.
People v. Lot 23, 735 P.2d 184 (Colo. 1987)
FORFEITURE - RELEVANT RULING. People
v. Cerrone, 780 P.2d 562 (Colo. App. 1989)
Defendants operated numerous
lingerie modeling and massage businesses for the purpose of promoting
prostitution. Trial court inferred that at least the items of personal
property were purchased with proceeds from <prostitution> because it
found no legitimate source of funds for these large cash purchases. No
evidence was presented, however, to trace any of the real or personal property
in question here to illegal proceeds.
FORFEITURE OF ASSETS PURCHASE
WITH PROCEEDS TRACEABLE TO NUISANCE All proceeds traceable to certain illegal
activities, including prostitution, are subject to a forfeiture. CRS
16-13-303(3)(b). If the property is not per se connected to the criminal
activity, the
People have the burden of
establishing a nexus between the property for which the forfeiture is sought
and the criminal activity. People v. McBeath, 709 P.2d 38 (Colo. App.
1985). The nexus required by the statute is that the items be proceeds
traceable to the illegal activity.
Defendants obtained the motor
home in exchange for a vehicle and an amount of cash. There is no evidence
in the record to connect this purchase to illegal proceeds accruing within
one year prior to the filing of the complaint or at any other time.
Traceability was not shown.
The family home was paid for
with other proceeds unrelated to the prostitution activities and was not
used for any illegal purpose. Ruling: the home could not be seized. In an
action to abate a public nuisance, only real property which has been used
for the illegal purpose which is the underlying subject matter of the action
is subject to forfeiture and seizure. CRS 16-13-314.
STATUTE OF LIMITATIONS. All
forfeiture actions must be commenced within one year after the cause of action
accrues. Section 13-80-103(1)(d). Consequently, the trial court was without
authority to order a seizure of items as proceeds traceable to illegal
activities conducted more than one year prior to the filing of the complaint. People
v. Steinberg, 672 P.2d 543 (Colo. App. 1983). As the automobile, pickup
truck, and boat with trailer were all purchased more than one year before the
filing of the complaint, the trial court was without authority to order a
seizure of those items.
TIME
FOR FILING. Where the prosecution failed to file a complaint within 60
days as required by CRS 16-13-307(3.5), the court ruled that failure to file a complaint
within the 60-day period provided in 16-13-307(3.5) is not a jurisdictional
defect that would divest a trial court of subject matter jurisdiction, but a
procedural defect that subjects the complaint to dismissal at the discretion of
the trial court. People v. Grell,
950 P.2d 660 (Colo. App. 1997)
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If the owner pays all costs, fees, and allowances which are declared by this section to be a lien on the building, place, or real property, and files a bond in the amount fixed by the court not to exceed the full value of said property, with sureties to be approved by the court, conditioned that he will immediately abate any such nuisance that exists at the building, place, or real property and prevent the same from being established or kept thereat within a period of one year thereafter,
and
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If the owner
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The property may be returned to the
owner
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CRS 16-13-310. Redelivery of Seized Premises
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This is essentially a means to return property
to a non-culpable owner
What does this all basically
mean? If a person engages in prostitution or one of the above defined
nuisances, buildings, fixtures, contents, motor vehicles, bank accounts or
practically any other asset which can be connected to the unlawful / prohibited activity is
subject to seizure and forfeiture in a civil lawsuit.
If a person has utilized an
expensive automobile to drive to prostitution engagements, or if a person has used his / her
home for engagements, telephone appointment setting center, or the bookkeeping
or other business end of any above identified criminal / prohibited activity, say good-bye to
the asset unless a defense exists. To pursue forfeitures, the local DA
Office employs a deputy district attorney who is autonomous from
prosecutors and offices in the
CSPD
Police Operations Center, Metro Vice & Narcotics Unit.
Forfeiture is what he / she does.
The primary defense would be that the
State's proof failed to establish the activity defined as a nuisance, or that
the State failed to establish a sufficient nexus (connection) between the asset
and the nuisance. If the state is seeking forfeiture based upon traceable
proceeds, defendant may attack the audit trail. If the state fails to file
within the statutory time, jurisdictional arguments would naturally be raised.
The requirement that defendant must establish his or her standing as a true owner of the property subject to
forfeiture
may be sufficient to cause acquiescence to forfeiture. If
criminal charges are pending or if the defendant is being investigated for
possible future criminal charges, and if ownership or possessory interest of the asset is a
fact detrimental to the defense, a person may be in a position where it is best
to default in the forfeiture action. Ownership claim under oath would be
admissible in any other lawsuit - civil or criminal.
In the course of a forfeiture action, a
defendant may or may not be able to negotiate re-purchase at a value less than
fair market value.
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INDEPENDENT SERVICE PROVIDERS |
Where relevant, I utilize
the services of independent professionals. Rates of independent
providers of professional services change periodically and billings are not
controlled by counsel.
If retained by counsel as an
agent of the attorney, such independent service providers are bound by the
attorney-client privilege. If retained privately by the client, no such
agency or confidentiality exists.
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Do I need an attorney? |
In determining whether
representation is economically justifiable or prudent, to a large extent
a prospective client's decision will likely be influenced by four major
factors.
1. If injunctive relief is sought,
is the activity income generating, and if so, the amount of income
derived from the activity.
2. If forfeiture relief is sought,
what is the value
of the assets subject to forfeiture action
3. If either injunctive or
forfeiture relief is sought, how much personal importance does defendant
assign to the activity or asset.
4. If the state is successful,
possibility of sealing of civil court records is nearly
non-existent. If defendant prevails on the merits, perhaps an
order to seal civil court records could be obtained. The civil
suit will allege an activity which defendant may find repugnant or
harmful to reputation or future business dealings, job opportunities or
other potential future consequence. The forth factor foreseen to
counsel is how much importance defendant assigns to sealing civil court
records.
If the prospective client finds one of
the above factors important, it's probably time to loosen the pocket book and
hire an attorney. If relevant, you need not retain my services, but hire counsel.
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At the time of your first
visit, you will be quoted attorney's fees and estimated costs. The quote will
be honored for a period of seven (7) days, after which it is subject to change
without notice if this office has not been retained.
I have included a
fees and costs
page devoted to clear definition and understanding of
first
consultation,
fees and costs, retainer agreement and terms of representation. Please
refer to the following links.
ELECTION. In most
circumstances, I initially make an option offer of 1.) billing to be upon hourly
fees, or in the alternative, 2.) quote of a hearing flat fee.
Offered fee options will be up to the client, however client's initial election will be
final. Attorney reserves the right to quote hourly fees only without a
hearing flat fee
offer. Attorney
reserves the right to decline any case.
POTENTIAL
FEE QUOTE
NUISANCE
ABATEMENT |
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HOURLY
FEE RATE
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I
generally offer hourly fees or a hearing flat fee. The hearing
flat fee would be dependent upon the facts and circumstances of the
case, however the above would be a common quote in a forfeiture case *if
the attorney has provided defense in the underlying alleged criminal
nuisance and is familiar with the facts and circumstances. Civil
injunction would be billed upon hourly fees.
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trust deposit request
regarding fees & costs |
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private investigation can
change the quote dramatically. |
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Absent
criminal defense representation, the attorney would need to know
more about the facts and circumstances surrounding the alleged
nuisance and identification of assets before making a final
offer of hearing flat fee or quoting a trust deposit request for
anticipated costs. This shall neither constitute an offer,
nor be construed as a binding estimate.
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Forfeiture action is frequently ancillary to representation in a prostitution or
drug case. Forfeiture cases may be negotiable and time
expended in negotiations may exceed time spent in hearing preparation. If
the case appears indefensible at hearing, negotiation may be the wisest
alternative.
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PAYMENT
Secure
On-Line Payment
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Prior to commencement of
representation, the attorney will quote the amount requested as a trust
deposit against which attorney's fees and costs may be billed. The
requested trust
deposit will be dependent upon the facts and
circumstances of your case.
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nuisance
abatement defense
*
this shall not constitute an offer, nor be construed as a binding
estimate |
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Client authorization
is obtained
for any large cost expense. Final expenditure may run less or
client
may periodically be asked for additional amounts to be deposited to trust if
fees and costs will exceed previous deposits. |
Client
will be provided with a trust accounting and itemized
billing statement when there has been activity on the account. At the end of
each case, a detailed accounting summary is provided and
remaining trust proceeds are refunded. |
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trust
deposit for anticipated fees & costs is due when
retained |
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attorney does not accept installment payments |
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regular billings are
scheduled on the 1st and 15th
if
fees and costs are not paid as agreed, representation is
withdrawn |
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MAJOR
CREDIT CARDS ACCEPTED
PAYPAL ACCEPTED |
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COSTS
Out of pocket expenses (costs) are the responsibility of the client. |
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Generic
costs relevant to any criminal action
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Generic
costs relevant to any litigation
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nuisance abatement defense out of
pocket expenses
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Price |
Client Background Search |
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Varies |
DMV
Out of
State Driving Record |
| 10.00 |
Accident
Report -
relevant only if traffic stop is also involved |
| 20.00 |
Offense
Report |
| 10.00 |
DA
Office
discovery packet -
estimate (actual may be more or less) |
| 10.00 |
Local
court archive
records search fee (actual may be more or less) |
| 10.00 |
Copy expense at
courthouse for prior offense files (estimate - may vary) |
| Varies |
Court transcripts or
certified documents |
| 500.00 |
Private Investigator
initial retainer - if relevant
variable based upon number of witnesses to interview |
| 200.00 |
Law enforcement 911 /
dispatch records, tapes & transcript - widely variable |
| 200.00 |
Subpoena
process service
expense - depends on number of subpoenas issued |
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Varies |
On-line
legal
research - dependent upon issues requiring legal research,
if any |
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Rates |
Travel
time and expenses if the case
is outside Colorado Springs |
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NOTE
It is generally prudent to procure DA criminal case discovery, law enforcement video or audio tapes and
to conduct police officer or witness interviews by a
private investigator prior to negotiations
these matters will likely have been accomplished in the defense of the
underlying criminal charge |
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CAVEAT:
Not all above costs will be relevant to any given case, and additional
expenses not identified may be incurred in any individual case. Costs
quoted are subject to change by independent providers; actual costs paid will
be billed. *limited
search
pricing* Absent knowledge of specific facts, no realistic cost estimation
can be made in a forfeiture or civil injunction case regarding court
transcripts of testimony or exhibits in related proceedings.
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Thank you for considering my
services; I appreciate your inquiry.
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ATTORNEY
REPRESENTATION
AND DECLINED MATTERS
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NOTICE: I NO LONGER ACCEPT CASES:
SEXUAL ASSAULT or SEXUAL ASSAULT ON A CHILD |
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I
welcome representation inquiries however please refer to
first
consultation - the purpose is not to provide free legal advice to the
general public. Unless seeking to retain counsel, please do not email or
call. I do not provide legal opinions, answers or information in response
to questions submitted from non-clients. Given the scope of internet
accessibility I can not be the free "Colorado answer man" and will
politely decline.
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ALTERNATIVES
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FIND
A LAWYER |
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if
you are seeking the below
please refer to above links for helpful information
sole practitioner
attorney does not accept these matters |
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a. a pro-bono (free) lawyer
b. an attorney who may take
lower fees - economic hardship
c. an attorney who may take installment payments |
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MID-LITIGATION
REPRESENTATION
alternatives and find a
lawyer links provided as a courtesy
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Attorney
Policies
Litigant Pro Se - Attempt to
Prepare Defense of Own Nuisance Abatement or Forfeiture Case |
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1.
Adequate Time. If sufficient time exists to adequately prepare your case and if prospective client approves this
attorney's fees and costs structure, attorney will
likely accept nuisance injunctive or forfeiture representation. This shall
not constitute an offer of representation; attorney and
prospective client retain discretion through
first
consultation. |
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2.
Insufficient Time. If you've waited until the eleventh hour and there is not
sufficient time to adequately prepare your case or defense before a contested
court proceeding, please do not call. I decline. |
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3.
Limited Assistance.
Please do not call requesting instruction, directions, legal theory,
forms completion or limited document drafting, partial representation, or an explanation of
applicable law to assist you in preparation or defense of your own case. I decline. |
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Attorney
Policies
Representation
by Previous Attorney
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1.
Current Attorney.
Until an order has entered withdrawing representation by an
attorney, an ethical rule violation exists if counsel
knowingly speaks to another attorney's client without current
attorney's consent. This ethical rule governs all
attorneys. Please do not call until after
you have terminated representation by a former attorney.
After
other counsel's withdrawal it may take significant effort for the the new attorney to "catch up."
Please be aware fees and costs will be associated with procuring the court
file and coming up to speed in the case. |
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2.
Adequate Time.
If prospective client terminates employment of the
former attorney, if sufficient time exists to adequately prepare your nuisance injunctive or forfeiture
case, and if prospective client approves this
attorney's fees and costs structure, attorney will
likely accept representation. This shall
not constitute an offer of representation; attorney and
prospective client retain discretion through
first
consultation. |
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3.
Insufficient Time.
If you've waited until the eleventh hour and there is
not sufficient time to adequately prepare your case or
defense before a contested court proceeding, please do
not call. I decline. |
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4.
Second Opinion.
I will not arm chair quarterback another
attorney's case preparation, trial tactics or theory of
the case. Please do not call for a second
opinion or an opinion regarding the competence
of preparation or defense in your current
nuisance injunction or forfeiture case. I decline. |
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UNDERLYING
CRIMINAL CASE - POST
SENTENCING MATTERS
PROBATION
REVOCATION * PAROLE VIOLATION
DEFERRED SENTENCE
REVOCATION * APPEALS |
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Post
Sentencing. I do not accept post sentencing
matters in any criminal, DUI or traffic case unless I provided
representation during the case in chief at the trial court level
and am familiar with the facts,
testimony and exhibits received into evidence, meritorious issues
& rulings. That's been my policy for years. Please do
not call or inquire regarding post sentencing matters if you are
not a former client.
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This
includes plea to
domestic
violence or other
criminal charge,
DUI,
DEAC
or DWAI charge or other
traffic
charge and probation,
deferred sentence,
parole or incarceration or
revocation proceedings based upon alleged failure to comply. |
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Exceptions.
If the underlying criminal case qualifies, refer to
sealing
criminal records. I accept meritorious sealing cases
regardless of whether or not you are a former client. NOTICE:
alcohol related traffic offenses, other traffic offenses or traffic
infractions are a specifically excluded in the
sealing
statute and can not be sealed. If relevant, I also accept
meritorious
collateral
attack cases.
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CASES
OUTSIDE EL PASO COUNTY
ECONOMIC CONSIDERATIONS
Geographic Distance - Travel
Time, Mileage and Expense
Colorado is a big
state. Ease of internet access, email and toll free phone doesn't change
that fact. |
Attorney
is very willing to travel outside the Colorado Springs area to present
or defend a case,
but please be aware
travel
time, mileage and expense would apply. If you are out of state or unfamiliar with Colorado
geography, refer to the map to determine where
Colorado Springs is
located in relation to the county of your court case or hearing.
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If
travel is necessary, a
trust
deposit
would be required to cover anticipated travel time, mileage & expenses. If it is not economically justifiable to retain my
services with travel,
please contact counsel in the locale of your case. |
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FIND
A LAWYER
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I welcome new cases.
Intent is not to be harsh or to discard potential new business, but to be
practical. |
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| ATTORNEY TRADE AREA |
| COUNTIES |
CITIES / TOWNS |
COUNTIES |
CITIES / TOWNS |
| El Paso County |
Colorado Springs / Fountain |
Pueblo County |
Pueblo |
| Teller County |
Cripple Creek |
Fremont County |
Canon City |
| Chaffee County |
Salida |
Custer County |
Westcliffe |
| Park County |
Fairplay |
Huerfano County |
Walsenburg |
| Douglas County |
Castle Rock |
Las Animas County |
Trinidad |
| Arapahoe County |
Littleton |
Crowley County |
Ordway |
| Arapahoe County - East |
Aurora |
Otero County |
La Junta |
| City and County of Denver |
Denver |
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