STATE OF ALABAMA, EX REL IN THE CIRCUIT COURT OF

LYN HEAD, AS DISTRICT ATTORNEY

OF THE SIXTH JUDICIAL CIRCUIT TUSCALOOSA COUNTY, ALABAMA
OF ALABAMA,
CIVIL DIVISION
Plaintiff,

Vs.

FOUR THOUSAND SIX HUNDRED CIVIL ACTION NO. CV2014-________
SIXTY-ONE ($4,661.00) DOLLARS,
LAWFUL CASH, COIN OR CURRENCY
OF THE STATES OF AMERICA,

Defendant.

C O M P L A I N T

Comes now the Plaintiff, the State of Alabama, on the relation of LYN HEAD, as District Attorney of the
Sixth Judicial Circuit of Alabama, who relates and specifically shows and avers unto this Court the following facts:
(1) That the said LYN HEAD is the District Attorney of the Sixth Judicial Circuit of Alabama, and as
District Attorney, she is authorized to bring and file this Complaint for forfeiture on the property hereinafter
described.
(2) On October 7
th
, 2014, agents with the West Alabama Narcotics Task Force observed and recorded
a drug transaction outside Bryant Hall, Tuscaloosa, Alabama, involving Kurt Freitag. Agents were able to identify
Mr. Freitag through a confidential informant. Agents made contact with Mr. Freitag, read him Miranda in room
413 of Bryant Hall and was given permission to search. Approximately 112 grams of marijuana was seized from
Mr. Freitags room. Also seized from the room was Four Thousand Six Hundred Sixty-One ($4,661.00) Dollars,
lawful cash, coin or currency of the United States of America.
(3) That marijuana is a controlled substance and that the sale or possession of marijuana is a violation
of the laws of the state of Alabama.
(4) That the money seized was furnished or intended to be furnished by any person in exchange for a
controlled substance in violation of any law of this State, or is traceable to such an exchange, or was used or
intended to be used to facilitate any violation of any law of this State regarding controlled substances, and as such,
is subject to condemnation and forfeiture by the State of Alabama, pursuant to Section 20-2-93 Alabama Code,
1975 (as amended 1990).
ELECTRONICALLY FILED
10/13/2014 12:44 PM
63-CV-2014-901222.00
CIRCUIT COURT OF
TUSCALOOSA COUNTY, ALABAMA
MAGARIA HAMNER BOBO, CLERK
(5) That the money seized was constituted or derived from proceeds obtained from a violation of this
State concerning controlled substances.
(6) That said property was used or intended to be used to transport, or in any manner to facilitate the
transportation, sale, receipt, possession, or concealment of a controlled substance, and as such, is subject to
condemnation and forfeiture by the State of Alabama, pursuant to Section 20-2-93 Alabama Code, 1975 (as
amended 1990).
WHEREFORE, THE PREMISES CONSIDERED, Plaintiff prays that this Honorable Court will take
jurisdiction of this cause, allow all interested parties to assert any claims, they may have, and that upon final hearing
of this cause, the Court will issue an order finding the said property is contraband of the type described in Section
20-2-93 Alabama Code, 1975 (as amended 1990), condemning and forfeiting the said property to the State of
Alabama and/or the appropriate law enforcement agency involved for official use by that agency, or as otherwise
authorized by law.
WHEREFORE, Plaintiff further prays that this Honorable Court will make such other orders and decrees as
are necessary to implement the provisions of Section 20-2-93 Alabama Code, 1975 (as amended 1990).
Respectfully submitted, this the 13
th
day of October, 2014.
LYN HEAD
District Attorney
Sixth Judicial Circuit of Alabama


By: /s/Kimberly Bawgus______________
KIMBERLY BAWGUS (BAW 001)
Deputy District Attorney
Tuscaloosa County Courthouse
714 Greensboro Avenue, Suite 410
Tuscaloosa, Alabama 35401-1894