UNITED STATES OF AMERICA v. 8 GILCREASE LANE, QUINCY, FLORIDA 32351 et al

Filing 23

NOTICE of Filing of Claimants' Proposed Compliance and Oversight Plan by ADSURFDAILY, INC. (Attachments: # 1 Proposed Compliance and Oversight Plan)(Fayad, Michael)

UNITED STATES OF AMERICA v. 8 GILCREASE LANE, QUINCY, FLORIDA 32351 et al

Doc. 2

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES OF AMERICA, Plaintiff, v. 8 GILCREASE LANE, QUINCY FLORIDA 32351, and ONE CONDO LOCATED ON NORTH OCEAN BOULEVARD IN MYRTLE BEACH, SOUTH CAROLINA, and ALL FUNDS, INCLUDING APPROXIMATELY $53 MILLION, HELD ON DEPOSIT AT BANK OF AMERICA ACCOUNTS IN THE NAMES OF (1) THOMAS A. BOWDOIN, JR., SOLE PROPRIETOR, DBA ADSURFDAILY, (2) CLARENCE BUSBY, JR. AND DAWN STOWERS, DBA GOLDEN PANDA AD BUILDER, AND (3) GOLDEN PANDA AD BUILDER, Defendants, and ADSURFDAILY, INC., THOMAS A. BOWDOIN, JR., AND BOWDOIN HARRIS ENTERPRISES, INC. , Claimants.

Case: 1:08-cv-01345 Hon. Rosemary M. Collyer

NOTICE OF FILING OF CLAIMANTS' PROPOSED COMPLIANCE AND OVERSIGHT PLAN Claimant, AdSurfDaily, Inc. ("ASD"), by counsel, hereby submits this Proposed Compliance and Oversight Plan ("Plan") in connection with its still{TY046601;1}

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pending Emergency Motion for Return of Seized Funds To Save Business and Jobs With Oversight and Monitoring And/Or For Evidentiary Hearing, and Motion to Dismiss ("Claimant ASD's Emergency Motion"). 1. On August 18, 2008, Claimant ASD's Emergency Motion was filed with this Court. Memoranda in Opposition of the United States ("Government Oppositions") were filed on August 25, 2008, and ASD's Reply to the Government's Oppositions ("Reply") was filed on August 29, 2008. 2. Claimant ASD's Emergency Motion and Reply request emergency relief as part of a Compliance and Oversight Plan. 3. ASD is still in need of the requested emergency relief and proposes the attached Plan for ASD's future operations for consideration by the Court at an evidentiary or other hearing as soon as possible. Dated: September 16, 2008 Respectfully submitted, AKERMAN SENTERFITT By: /s/ Michael L. Fayad Michael L. Fayad, Esq. D.C. Bar No. 91694 8100 Boone Boulevard, Suite 700 Vienna, VA 22182 Telephone: [phone] Fax: [phone] Jonathan Goodman, Esq.1 Florida Bar Number: 371912 One Southeast Third Avenue 25th Floor Miami, FL 33131-1714 Phone: [phone] Fax: [phone] Email: [e-mail] ATTORNEYS FOR CLAIMANTS

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Mr. Goodman has been permitted to Appear Pro Hac Vice.

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CERTIFICATE OF SERVICE I hereby certify that the foregoing Notice and Proposed Compliance and Oversight Plan was served this 16th day of September, 2008 via the Court's electronic filing system upon the following counsel: William Rakestraw Cowden, Esq. U.S. Attorney's Office 555 Fourth Street, NW Washington, DC 20530 /s/ Michael L. Fayad Michael L. Fayad, Esq.

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