IN THE CIRCUIT COURT OF THE TENTH JUDICIAL CIRCUIT

IN AND FOR POLK COUNTY, FLORIDA

CIVIL DIVISION

CASE NO.:

SECTION:

IN RE: THE FORFEITURE OF:

TEN THOUSAND SEVEN HUNDRED

TWENTY-SEVEN AND 00/100 ($10,727.00)

UNITED STATES CURRENCY

CUBAN LINK GOLD CHECKLACEWITH CHARM

VERIFIED COMPLAINT FOR PROBABLE CAUSE

AND FOR FINAL ORDER OF FORFEITURE

TO: Paul Anthony Morgan

4749 Luce Road

Lakeland, Florida 33813

A'Cher Morgan

4749 Luce Road

Lakeland, Florida 33813

COMES NOW, Grady Judd as Sheriff of Polk County, Florida, by and through hisundersigned attorney and files this Verified Complaint for Probable Cause and for Final Order ofForfeiture and as grounds therefore would show as follows:

1. This is an action for forfeiture pursuant to Section 932.701-7062, Florida Statutes(2024), and jurisdiction is in this Court pursuant to Section 932.704(4), Florida Statutes (2024).

2. Venue is properly laid in Polk County, Florida, pursuant to Chapter 47, FloridaStatutes (2024).

3. The Polk County Sheriff's Office is a "law enforcement agency" as set forth inSections 932.701-7062, Florida Statutes (2024).

4. A description of the property that is the subject of this action is as follows:

TEN THOUSAND SEVEN HUNDRED

TWENTY-SEVEN AND 00/100 ($10,727.00)

UNITED STATES CURRENCY

CUBAN LINK GOLD CHECKLACE

WITH CHARM

5. On or about February 24, 2025, the property described in Paragraph Four (4) above,was used, attempted to be used, or was intended to be used in violation of Sections 932.701 -932.7062, and chapter 893 Florida Statutes, or the property is a "contraband article" as defined bySection 932.701(2)(a)(1)-(12), Florida Statutes (2024).

6. The facts and circumstances under which the "contraband article[s]" described inParagraph Four (4) above were seized is more particularly described in the Ex-Parte Post-SeizureApplication for an Order Finding Probable Cause Pursuant to the Florida Contraband ForfeitureAct of Detective Benjamin Brown, attached hereto as Exhibit "A" and incorporated herein.

7. The Polk County Sheriff's Office has conducted a diligent search and inquiry for allpersons or entities who may have an interest in this action and such search has revealed that thefollowing person may claim an interest in the property that is the subject of this action by virtueof ownership registration law, other claim of ownership known to the Polk County Sheriffs Office,or by virtue of a lien perfected in the manner described by law:

Paul Anthony Morgan

4749 Luce Road

Lakeland, Florida 33813

A'Cher Morgan

4749 Luce Road

Lakeland, Florida 33813

8. The Polk County Sheriff's Office has complied with or will comply with the noticerequirements of the Florida Contraband Forfeiture Act and will present proof of notices at the FinalHearing.

9. An order finding probable cause for the seizure of the above captioned property wasobtained within ten business days of the date of seizure pursuant to $932.703 Florida Statutes(2023) and is attached hereto as exhibit "?".

10. The Polk County Sheriff's Office shall also publish, in accordance with chapter 50, a noticeof forfeiture complaint once each week for 2 consecutive weeks in a newspaper of generalcirculation, as defined in section 163.031, in the county where the seizure occurred.

WHEREFORE, the Polk County Sheriff's Office respectfully requests this Court to entera Final Order of Forfeiture perfecting the Polk County Sheriff's Office right, title and interest inthe property for its use and benefit.

If no Claimant comes forth to claim an interest in the property after notice has been madepursuant to Statute, the Polk County Sheriff's Office requests that this Court enter a Final Orderof Forfeiture perfecting the Polk County Sheriff's Office right, title and interest in the property forits use and benefit.

DEMAND FOR JURY TRIAL

The Sheriff request that the issue of forfeiture be decided by a jury.

Respectfully submitted,

JASON A. REUTER, ESQUIRE

Florida Bar Number 0085317

Polk County Sheriff's Office

1891 Jim Keene Blvd

Winter Haven, Florida 33880

(863) 298-6600

Attorney for the Plaintiff

Primary email: jreuter@polksheriff.org

Secondary email: DBing@polksheriff.org

No.11379460 June 8, 15, 2025