Case: 3:12-cr-50027 Document #: 280-2 Filed: 12/18/15 Page 1 of 19 PageID #:1528

SETTLEMENT AGREEMENT
This Settlement Agreement ("this Agreement") is made and entered into between the
United States of America and Humphrey Family Farms, an Illinois general partnership ("the
Partnership"), to resolve certain claims that regard, concern, or relate to the matters described
herein.

I.

Background and Definitions.

a.

The Partnership. Caroline W. Humphrey had six children, Ray A.

Humphrey, Jr. ("Ray"), Roger A. Humphrey ("Roger"), Richard A.
Humphrey ("Richard"), Carol Ann Beardin ("Carol"), Rita A. Crundwell
("Rita"), and Linda Humphrey Burkitt ("Linda"). Mrs. Humphrey died on
August 14, 1984. At the time of her death, Mrs. Humphrey owned various
assets, including farm real estate. Under Mrs. Humphrey's Last Will and
Testament dated April 20, 1977, she left her farm real estate in equal shares
to her children. Because Linda at the time was not yet 30 years of age, Mrs.
Humphrey's Last Will and Testament provided that Linda's interest be
subject to a testamentary trust, of which Dixon National Bank was Trustee.
Ray, Roger, Richard, Carol, Rita, and Dixon National Bank, as Trustee of
the Testamentary Trust for Linda, are collectively referred to in this
Agreement as "the Beneficiaries." On or about May 8, 1986, the
Beneficiaries formed the Partnership. On March 21, 1987, Linda turned 30
years of age. The testamentary trust created for her therefore terminated,
and she replaced Dixon National Bank as a partner in the Partnership. On
July 29, 1987, pursuant to a purchase and sale agreement, Richard ceased
being a partner in the Partnership. As of the date of this Agreement, the
Partnership has five partners - Ray, Roger, Carol, Rita, and Linda, each
owning a 20 percent interest in the Partnership.

b.

The Land Trust. On or about May 8, 1986, the Beneficiaries created the
land trust known as Trust Number 1651 (''the Land Trust") and named
Dixon National Bank Trustee of the Land Trust. On or about May 12, 1986,
the Beneficiaries assigned their beneficial interests in the Land Trust to the
Partnership, making the Partnership the sole beneficial owner of the Land
Trust. AMCORE Bank, N.A., Rock River Valley, then succeeded to the
business of Dixon National Bank and became Successor Trustee of the Land
Trust. BMO Harris Bank N.A. f/k/a Harris Bank then succeeded to the
business of AMCORE Bank N.A., Rock River Valley, and became
Successor Trustee of the Land Trust. Thereafter, Chicago Title Land Trust
Company ("Chicago Title") acquired the interest of BMO Harris Bank N .A.
f/k/a Harris Bank in the Larid Trust and became the Successor Trustee of
the Land Trust. Chicago Title is the current Successor Trustee of the Land
Trust.

Case: 3:12-cr-50027 Document #: 280-2 Filed: 12/18/15 Page 2 of 19 PageID #:1529

c.

The Real Estate. As of the date of this Agreement, Chicago Title, as

Successor Trustee of the Land Trust, is the sole owner of the real estate
legally described on the attached Exhibit A (collectively, "the Real Estate").

d.

The Criminal Case and Forfeiture Proceedings. On May 1, 2012, in the

proceeding styled United States of America v. Rita A. Crundwell, No. 12CR-50027, United States District Court for the Northern District of Illinois,
Western Division ("the Proceeding"), the Government charged Rita with
wire fraud under 18 U.S.C. 1343. On November 14, 2012, Rita pleaded
guilty to Count I of the Government's indictment in the Proceeding and
thereby made certain of her property subject to forfeiture under 18 U.S.C.
981(a)(l)(C). On February 14, 2013, the Court in the Proceeding entered
a Preliminary Order of Forfeiture through which, among other things, the
Court purported to forfeit Rita's interest in the Real Estate. On or about
March 27, 2013, Ray, Roger, Carol, and Linda (collectively, "Petitioners")
filed in the Proceeding a Petition to Adjudicate Interests in Land Trust and
Partnership ("the Petition"), through which they asked the Court to, among
other things, determine that Chicago Title is the sole title holder of the Real
Estate and that Rita has no direct beneficial interest in the Land Trust subject
to forfeiture. Petitioners further asked the Court to determine that each of
them and Rita is a partner in the Partnership, subject to the terms,
conditions, and obligations of the Partnership's partnership agreement and
of Illinois partnership law. On May 3, 2013, the Government and
Petitioners filed in the Proceeding an Agreed Motion to Withdraw Petition
("the Agreed Motion"), through which the parties agreed that Rita's interest
in the Partnership could more easily be resolved through supplementary
proceedings, that the Partnership would accept a citation to discover assets
of the Partnership, and the Government would accept the Petition as a
written answer to the citation to discover assets. On May 9, 2013, the Court
granted the Agreed Motion. On May 13, 2013, the Government in the
Proceeding issued a Third Party Citation to Discover Assets ("the Citation")
to the Partnership. Petitioners represent that none of their conduct gave rise
to the criminal indictment in the Proceeding or in the civil forfeiture action
of United States ofAmerica v. Have Faith in Money, a quarter horse, et al,
No. 12-CV-50153 (N.D. Ill.).

e.

The Distributions. Pursuant to the Agreed Motion, the Government

forfeited Rita's interest in a $5,000 distribution made by the Partnership and
delivered to the U.S. Marshals Service on or about March 29, 2013. In
2014, the Partnership made two $5,000 distributions to each of Petitioners.
Pursuant to the Citation, the Partnership on or about July 21, 2014, and
December 3, 2014, delivered to the Government the corresponding $5,000
distributions to which Rita was entitled. The three distributions delivered
to the Government, totaling $15,000, are collectively referred to in this
Agreement as "the Distributions."

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f.

The Assets and Liabilities. Petitioners represent that, as of November 20,

2015, the only assets of the Partnership are the Partnership's beneficial
interest in the Real Estate and its interest in Checking Account No.
at
The First National Bank in Amboy, which has a balance of $
("the
Cash"). Petitioners further represent that, as of November 20, 2015, the
only liability of the Partnership is its balance of Loan No.
payable to
The First National Bank in Amboy, which balance is $
and which
balance is secured by a mortgage on the Real Estate ("Mortgage Debt'').

g.

Rita's Interest in the Partnership. The parties to this Agreement ("the

Parties") have agreed that Rita's interest in the Partnership ("the Interest")
has a fair market value of $665,000.

h.

The Subject Real Estate. The Parties have agreed that the fair market value
of that certain parcel of real property, legally described in Exhibit B and
which is part of the Real Estate ("the Subject Real Estate"), is $665,000.

i.

Purpose of This Agreement. The parties enter into this Agreement to settle
the matters between them related to the Real Estate, the Partnership, the
Land Trust, the Proceeding, the Petition, the Citation, the Distributions, the
Cash, the Mortgage Debt, the Interest, and the Subject Real Estate.

2.
Court Approval. All of the Parties' rights and obligations under this Agreement are
contingent on the approval of this Agreement by the Court in the Proceeding. Within a reasonable
time of the full execution of this Agreement, the Government will move the Court in the
Proceeding for entry of a Turnover Order, ordering Petitioners to direct Chicago Title, as Successor
Trustee of the Land Trust and as owner of the Subject Real Estate, to turn over the Subject Real
Estate, granting the Government permission to fulfill its obligations under the Agreement and the
Contract for Purchase and Sale of Real Estate referred to in Paragraph 5 of this Agreement, and
discharging the Citation. If the Court grants the Government's motion for a Turnover Order, the
Agreement shall be deemed approved and the date it does so shall be deemed ''the Approval Date."
3.
Transfer of the Subject Real Estate. Within ten business days of the Approval Date,
Petitioners shall direct Chicago Title, as Successor Trustee of the Land Trust and as owner of the
Subject Real Estate, to convey the Subject Real Estate to the Government, by a recordable
Warranty Deed C'the Conveyance"). Petitioners shall pay the transfer tax and all other fees
associated with the Conveyance. The Conveyance shall be free and clear of all liens and
encumbrances.
4.
The Cash. the Mortgage Debt. and the Distributions. The Parties agree that, in
exchange for Petitioners' agreement not to seek to assess or charge the Government with any
portion of the Mortgage Debt, the Government hereby relinquishes all of its right, title, and interest
in the Cash to the Partnership and accepts the Distributions in full satisfaction of any rights the
Government has or has had to distributions from the Partnership.

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5.
Purchase of the Subject Real Estate. Simultaneously with the execution of this
Agreement, the Government and Petitioners shall execute the Contract for Purchase and Sale of
Farm Real Estate attached to this Agreement as Exhibit C ("the Real Estate Contract"). Petitioners
may subsequently transfer any or all of their interests and obligations in and under the Real Estate
Contract to a limited liability company to be formed and owned by them; provided, however, that
if such an assignment is made, each Petitioner shall remain personally liable to the Government
for the purchase price under the Real Estate Contract. Petitioners shall pay all fees and costs with
the execution of this transfer of the Subject Real Property including those fees customarily paid
by a seller. Final payment shall be made at Closing, as defined in the Real Estate Contract. The
Government expressly does not provide any position, representation, or advice as to any tax-related
or business-related matters the Partnership might encounter based on this Agreement and
associated Real Estate Contract. The Parties agree that the Closing of the Sale shall satisfy all of
the Partnership's obligations under the Citation.
Payment shall be made with certified funds in the following manner:
1. $2,000 payable to the United States Marshals Service as recovery of expenses
assoCiated with valuation of the Partnership and its assets, mailed to the
following address:
United States Marshals Service
Asset Forfeiture Unit
Everett McKinley Dirksen U.S. Courthouse
219 South Dearborn Street, Suite 2444
Chicago, Illinois 60604
Reference: USMS-D24-00000167
2. $663,000 payable to the Clerk of Court, mailed to the following address:
Clerk of Court
United States District Court
Northern District of Illinois
Everett McKinley Dirksen U.S. Courthouse
219 South Dearborn Street, 20th Floor
Chicago, Illinois 60604
Reference: 12 CR 50027
6.

Mutual General Releases.

a.
The Government's Releases. Except for a future breach of this Agreement
or the Real Estate Contract and except for any taxes properly chargeable, the Government, on its
behalf and on behalf of its agencies and assigns, hereby forever discharges and releases Petitioners,
and each of them, and each's agents, representatives, heirs, beneficiaries, successors, and assigns
from any and all non-tax, non-criminal: dam.~ges, liabilities, obligations, losses, costs, actions,

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claims, causes of action, judgments, controversies, rights, duties, and demands of any nature
whatsoever, whether known or unknown, suspected, or claimed, that exist on the date of this
Agreement arising out of, under, in connection with, or otherwise relating in any manner to the
Partnership, the Land Trust, the Real Estate, the Subject Real Estate, the Citation, and/or the
Proceedings. This release is limited to the terms of this paragraph and excludes any other potential
claim, cause of action, demand, charge, or allegation, whether past, present, or future, including,
but not limited to, tax or criminal liability and any claims arising under this Agreement.
b.
Petitioners' Releases. Except for a future breach of this Agreement or the
Real Estate Contract and except for any challenge or protest of taxes assessed by the Government
or any of its agencies, Petitioners, and each of them, on each' s behalf and on behalf of his or her
agents, representatives, heirs, beneficiaries, successors, and assigns, hereby forever discharges and
releases the Government and its agencies and assigns from any and all damages, liabilities,
obligations, losses, costs, actions, claims, causes of action, judgments, controversies, rights, duties,
and demands of any nature whatsoever, whether known or unknown, suspected, or claimed, that
exist on the date of this Agreement arising out of, under, in connection with, or otherwise relating
in any manner to the Partnership, the Land Trust, the Real Estate, the Subject Real Estate, the
Citation, and/or the Proceedings.
7.
Breach. If a party breaches this Agreement, the non-breaching party or parties shall
have the right either to terminate this Agreement and pursue all rights and remedies against the
breaching party or to seek specific performance of this Agreement. In the event that any party
institutes or defends any action or proceeding, including but not limited to litigation or arbitration,
to preserve, protect, or enforce any claim or right arising under this Agreement, each such party
shall bear its own costs and expenses of litigation, including attorney's fees.
8.
Further Actions. The Parties agree that they shall take all actions, including the
execution and delivery of other documents, to fully effectuate the provisions of this Agreement.
9.
No Assignment. Each party to this Agreement represents and warrants to all other
parties that he or it has not assigned any right or claim related to the Subject Real Estate to any
other person or entity.
I 0.
Counterparts. This Agreement may be executed simultaneously in one or more
counterparts, each one of which shall be deemed an original, but all of which together shall
constitute one and the same instrument.

11.
Entire Agreement. This document, in conjunction with the Real Estate Contract,
contains the entire agreement among the Parties concerning the subject matters set forth herein
and supersedes all prior and/or contemporaneous written or oral agreements relating to such
matters. Each party represents and warrants that no statement, promise, or representation has been
made by any of the other parties except to the extent set forth in this Agreement. This Agreement
may not be modified except by written document, signed by all parties.

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12.
Notices. Any notice, demand, or request that may be permitted, required, or desired
to be given under this Agreement shall be given in writing and directed to the Government and the
Partnership as follows:
If to the Government:

Julia Jarrett
Asset Forfeiture and Money Laundering Section
U.S. Department of Justice, Criminal Division
1400 New York Ave NW
Washington, D.C. 20053
Telephone: 202-514-5131
Email: julia.jarrett@usdoj.gov

with a copy to:

Jason Wojdylo
Asset Forfeiture Division
U.S. Marshals Service
333 Clay Street, Suite 3050
Houston, Texas 77002
Telephone: 713-718-3055
E-mail: Jason. Wojdylo@usdoj.gov

If to the Partnership:

Humphrey Family Farms

c/o Ray A. Humphrey, Jr.
Dixon, IL

with a copy to:

Douglas E. Lee
Ehrmann Gehlbach Badger Lee & Considine, LLC
215 E. First St., Suite 100
Dixon, IL 61021
Telephone: (815) 288-4949
Fax: (815) 288-3068
E-mail: lee@eglbc.com

Notices shall be deemed properly delivered and received when and if either (a) personally delivered;
(b) delivered by national overnight courier; (c) sent by facsimile with confirmation of receipt, so long
as sender follows facsimile transmission with the mailing of a copy of the notice via U.S. Mail, First
Class ("U.S. Mail") within one business day, (d) three business days after being deposited in the U.S.
Mail, by registered or certified mail, return receipt requested, postage prepaid; or (v) sent by e-mail
to notified party's attorney, if any, so long as sender follows the e-mail with the mailing of a copy of
the notice by U.S. Mail, within three days of receipt by the sender of a request to send by U.S. Mail.

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Crundwcll-Scttlcmcnt Agreement

Case: 3:12-cr-50027 Document #: 280-2 Filed: 12/18/15 Page 7 of 19 PageID #:1534

THE UNITED STATES OF AMERICA

Dated: December _ll_, 2015.

ated: December_!_], 2015.

By CJQ,:]~

Dated: December LJ_, 2015.

Caro l Ann Beardin

Dated: December 2._,1 .015.

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Crundwcll-Scttlcment Agreement

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EXHIBIT A

PARCEL NO. 1:
That part of the West Half of the Northeast Quarter of Section 10,
Township 21 North, Range 9 East of the Fourth Principal Meridian, North of Tollway right of
way, in LEE COUNTY, Illinois
PARCEL NO. 2: The Northeast Quarter (NE 1/4) of Section Seventeen (17), in Township
Twenty-one (21) North, Range Nine (9) East of the Fourth Principal Meridian, EXCEPT a tract
in the Northwest comer of said Quarter Section described as follows: Commencing at the
Northwest comer of said Quarter Section and running East 14.145 chains; thence South 17 1/2
chains; thence West 14.145 chains; thence North 17 1/2 chains to the place of beginning,
ALSO EXCEPTING that part taken by State Toll Highway Authority described as: That part of
the Northeast Quarter of Section 17, Township 21 North, Range 9 East of the Fourth Principal
Meridian, described as follows: Beginning at Station 2830+00.12 on the centerline of a highway
known as the East-West Tollway Extension, thence Northerly along a line 14.145 chains East of
the West line of the Northeast Quarter of Section 17 to a point 125 feet Northwesterly from said
centerline, thence Northeasterly to a point 125 feet Northwesterly from Station 2836+ 12.71 of
said centerline, thence Northeasterly along a line toward a point 130 feet Northwesterly from
Station 2840+00.0 of said Centerline to the North line of Section 17, which North line intersects
said centerline at Station 2840+78.0 of said centerline, thence Easterly along said North line to a
line between points 130 feet Southeasterly from Station 2840+00.0 and 140 feet Southeasterly
from Station 2844+00.0, both stations of said centerline, thence Southwesterly to said point 130
feet Southeasterly from Station 2840+00.0, thence Southwesterly and parallel to said centerline
to a point Southeasterly from Station 2830+00.0 of said centerline, thence Southwesterly to a
point 125 feet Southeasterly from Station 2829+00.0 of said centerline, thence Southwesterly and
parallel to said centerline to said line East of said West line, thence Northerly to the point of
beginning; distances referred to the highway centerline are normal to said centerline unless
otherwise stated. Said centerline was surveyed and staked by the Illinois State Toll Highway
Authority and recorded in Book G of Plats, pages 61 and 62 in the Recorder's Records of Lee
County,
ALSO EXCEPTING therefrom that part of the Northeast Quarter of Section 17, Township 21
North, Range 9 East of the Fourth Principal Meridian, described as follows: Beginning at Station
2817+02.28 on the centerline of a highway known as the East-West Tollway Extension, thence
Northerly along the West line of the Northeast Quarter of Section 17 to a line between points 150
feet Northwesterly from Station 2817+00.0 and 125 feet Northwesterly from Station 2819+00.0,
both stations of said centerline, thence Northeasterly to said point 125 feet Northwesterly from
Station 2819+00.0, thence Northeasterly and parallel to said centerline to a line 17.5 chains
South of the North line of Section 17, which line South of said North line intersects said
centerline at Station 2824+38.37 of said centerline, thence Easterly along said line South of said
North line to a point 125 feet Southeasterly from said centerline, thence Southwesterly to a point

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125 feet Southeasterly from Station 2817+00.0 of said centerline, thence Southwesterly to a
point 135 feet Southeasterly from Station 2816+00.0 of said centerline, thence Southwesterly and
parallel to said centerline to said West line, thence Northerly to the point of beginning, all in
LEE COUNTY, Illinois
PARCEL NO. 3: All of the Northwest Quarter (NW 1/4) of Section Ten (10), in Township
Twenty-one (21) North, Range Nine (9) East of the Fourth Principal Meridian,
EXCEPTING such part thereof as may be used for railways or highways, and Excepting a part of
the North Half (N 112) of said Northwest Quarter (NW 1/4) of said Section Ten (10), described
as follows, towit: Commencing at a point where the Southern boundary of the right of way of the
Chicago and NorthWestern Railroad Company intersects the West line of said Section Ten (10),
and running thence South upon the Section line 684 feet; thence Easterly parallel with the said
Southerly boundary of said Railroad Company, 1910 1/2 feet; thence North parallel with the
West line of said Section, 684 feet to the Southern boundary of said Railroad right way; and
thence Westerly along said Southern boundary of said right of way 1910 1/2 feet to the place of
beginning;
ALSO EXCEPTING a part of said Northwest Quarter (NW,) of said Section Ten (10), described
as follows: Commencing at the Southwest comer of the Northwest Quarter of Section 1O; thence
Northerly 0 degrees 19 minutes 43 seconds East along West line of said Section 10, 38.87 feet to
the point of beginning: thence North 0 degrees 19 minutes 43 seconds East along the West line
of Section, 400 feet to a point on said Section line; thence North 70 degrees 37 minutes 28
seconds East, 769.46 feet to a point; thence South 0 degrees 19 minutes 43 seconds West, 431.33
feet to a point; thence South 70 degrees 37 minutes 28 seconds West 650.0 feet to a point; thence
South 85 degrees 46 minutes 54 seconds West, 112.83 feet to the point of beginning;
ALSO EXCEPTING a tract described as follows: Commencing at the West Quarter comer of
Section Ten (10); thence North 0 degrees 19 minutes 43 seconds East along the West line of said
Section Ten (10), 438.87 feet to a point on said Section line; thence North 70 degrees 37 minutes
28 seconds East 769.46 feet to the point of beginning; thence North 0 degrees 19 minutes 43
seconds East, 22.74 feet to a point; thence North 46 degrees 04 minutes 02 seconds East, 145.81
feet to a point; thence South 33 degrees 20 minutes 39 seconds East, 193.80 feet to a point;
thence South 17 degrees 29 minutes 40 seconds West, 262.50 feet to a point; thence South 43
degrees 24 minutes 30 seconds West, 196.79 feet to a point; thence North 0 degrees 19 minutes
43 seconds East, 431.33 feet to the point of beginning;
ALSO EXCEPTING that part taken by the State Toll Highway Authority by Condemnation in
Case No. 71-8L-320, Circuit Court of Lee County;
ALSO EXCEPTING THEREFROM: Commencing at the Southwest comer of the Northwest
Quarter of Section 1O; thence Northerly along West line of said Northwest Quarter of Section I 0,
1,816.05 feet to centerline of U.S. Route 52; thence Southeasterly along centerline of U.S. Route
2

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52 at an angle of 44 degrees 13 minutes 29 seconds measured counterclockwise, 662.18 feet;

thence Southwesterly at a right angle of 40.6 feet to a point on right of way line of U.S. Route 52
also being the Point of Beginning for the following described tract of land; thence Southwesterly
at an angle of 169 degrees 20 minutes measured clockwise, 122.03 feet; thence Southeasterly at
an angle of 119 degrees 51 minutes measured clockwise, 108.98 feet; thence Northeasterly at an
angle of 84 degrees 52 minutes measured clockwise 44.95 feet; thence Southeasterly at an angle
of 259 degrees 38 minutes measured clockwise, 126.95 feet; thence Northeasterly at an angle of
97 degrees 56 minutes measured clockwise, 74.35 feet to right of way of U.S. Route 52; thence
Northwesterly along right of way line of U.S. Route 52 at an angle of 84 degrees 10 minutes 30
seconds measured clockwise, 78.51 feet; thence Northwesterly along said right of way line of
U.S. Route 52 at an angle of 185 degrees 23 minutes 30 seconds measured clockwise, 203.84
feet to Point of Beginning, containing 0.588 acres of land,
ALSO EXCEPTING THEREFROM: Commencing at the Southwest comer of the Northwest
Quarter of Section 1O; thence Northerly along West line of said Northwest Quarter of Section 10,
1,816.05 feet to centerline of U.S. Route 52; thence Southeasterly along centerline of U.S. Route
52 at an angle of 44 degrees 13 minutes 29 seconds measured counterclockwise, 662.18 feet;
thence Southwesterly at a right angle of 40.6 feet to a point on right of way line of U.S. Route
52; thence Southeasterly at an angle of 101 degrees 11 minutes measured clockwise along right
of way line of U.S. Route 52, 203.84 feet; thence Southeasterly at an angle of 185 degrees 23
minutes 30 seconds measured counterclockwise 78.51 feet for a Point of Beginning; thence
continuing along aforementioned line, 72.24 feet; thence Southeasterly along right of way line of
U.S. Route 52 at an angle of 186 degrees 07 minutes 30 seconds measured counterclockwise,
210.91 feet; thence Westerly at an angle of 45 degrees 58 minutes measured counterclockwise,
281.30 feet; thence Northwesterly at an angle of 117 degrees 04 minutes measured
counterclockwise, 258.61 feet; thence Northeasterly at an angle of 92 degrees 35 minutes
measured counterclockwise, 72.91 feet; thence Southeasterly at an angle of 100 degrees 22
minutes measured counterclockwise, 126.95 feet; thence Northeasterly at an angle of 262
degrees 04 minutes measured counterclockwise, 74.35 feet to Point of Beginning,
ALSO EXCEPTING: A part of the Northwest Quarter of Section 10, Township 21 North, Range
9 East of the Fourth Principal Meridian described as follows: Commencing at the Southwest
corner of the Northwest Quarter of Section 10; thence Northerly along West line of said
Northwest Quarter of Section 10, 1,816.05 feet to centerline of U.S. Route 52; thence
Southeasterly along centerline of U.S. Route 52 at an angle of 44 degrees 13 minutes 29 seconds
measured counterclockwise, 662.18 feet; thence Southwesterly at a right angle of 40.6 feet to a
point on right of way line of U.S. Route 52 also being the Point of Beginning for the following
described tract of land; thence Southwesterly at an angle of 169 degrees 20 minutes measured
clockwise 122.03 feet; thence Northwesterly at an angle of 79 degrees 20 minutes measured
counterclockwise 160.95 feet; thence Northeasterly at a right angle 119.92 feet to a point 40.6

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feet perpendicularly distant from the centerline of U.S. Route 52; thence Southeasterly at a right
angle 138.36 feet to the point of beginning,
ALSO EXCEPTING THEREFROM: Commencing at the Southwest Corner of the Northwest
Quarter of Section 10; thence Northerly on the West Line of said Section 10, said line having a
bearing of North 0 degrees 27 minutes 36 seconds East, a distance of 1813.29 feet (1816 feet
Plat) to point in the Center Line of a public highway designated as F.A. Route 694 (U.S. Route
52), said point being the Point of Beginning of the hereinafter described parcel of land; thence
continuing Northeasterly on said West Line, a distance of 40.04 feet to a point; thence Easterly
on a line having a bearing of North 89 degrees 55 minutes 02 seconds East, a distance of 44.35
feet to a point; thence Southeasterly on a line having a bearing of South 43 degrees 48 minutes
42 seconds East, a distance of 557.21 feet to a point; thence Southeasterly on a line having a
bearing of South 49 degrees 30 minutes 31 seconds East, a distance of 100.74 feet to a point;
thence Southeasterly on a line having a bearing of South 43 degrees 48 minutes 42 seconds East,
a distance of 300.00 feet to a point in the Northeasterly Right-of-Way line of said U.S. Route 52
(F.A. Route 694); thence Northwesterly on said Northeasterly Right-of-Way Line, said line
having a bearing of North 57 degrees 14 minutes 07 seconds West, a distance of 154.21 feet to a
point; thence Southwesterly on a line having a bearing of South 46 degrees 11 minutes 18
seconds West, a distance of 34.20 feet to a point in said Center Line of F.A. Route 694 (U.S.
Route 52); thence Northwesterly on said Center Line, said line having a bearing of North 43
degrees 48 minutes 42 seconds West, a distance of 150.00 feet to a point; thence Southwesterly
on a line having a bearing of South 46 degrees 11 minutes 15 seconds West, a distance of 40.60
feet to a point in the Southwesterly Right-of-Way Line of said U.S. Route 52 (F.A. Route 694)
said line also being the Northeasterly Line of said premises conveyed to Rita A. Crundwell from
Dixon National Bank, Trustee, Trust Number 1651 by Trustee's Deed recorded September 17,
1987 in Book 8709 at page 725 as Document Number 481161 in the Recorder's Office of Lee
County; thence Northwesterly on said Southwesterly Right-of-Way Line, said line being a curve
having a radius of 4257.18 feet and the center bears South 47 degrees 11 minutes 16 seconds
West, an arc length of 75.44 feet to a point; thence continuing Northwesterly on said
Southwesterly Right-of-Way Line, said line having a bearing of North 43 degrees 48 minutes 42
seconds West, a distance of 62.92 feet to the Northerly Property Corner of said premises so
conveyed; thence Southwesterly on the Northwesterly Line of said premises so conveyed, said
line having a bearing of South 46 degrees 11 minutes 18 seconds West, a distance of 25.00 feet
to a point; thence Northwesterly on a line having a bearing of North 43 degrees 48 minutes 42
seconds West, a distance of 361.88 feet to a point; thence Northwesterly on a line having a
bearing of North 46 degrees 40 minutes 27 seconds West, a distance of 88.12 feet to a point in
the West Line of said Section 10; thence Northerly on the West Line of said Section 10, said line
having a bearing of North 0 degrees 27 minutes 36 seconds East, a distance of 99.42 feet to the
Point of Beginning.

Case: 3:12-cr-50027 Document #: 280-2 Filed: 12/18/15 Page 12 of 19 PageID #:1539

EXCEPTING THEREFROM: Part of the Northwest Quarter of Section 10, Township 21 North,
Range 9 East of the 4th Principal Meridian, bounded and described as follows:
Beginning at the intersection of the west line of said Northwest Quarter and the southwesterly
Right of Way line of U.S. Route 52; thence Southeasterly, along said Right of Way line, 87.95
feet (88.12 feet platted); thence continuing along said Right of Way line, at an angle of
17708' 15", measured counterclockwise from the last described course, 365.32 feet (361.88 feet
platted); thence Southwesterly, perpendicular to the last described course, 95.52 feet; thence
Southeasterly, perpendicular to the last described course, 160.95 feet; thence Southeasterly at an
angle of 16051 '07'', measured counterclockwise from the last described course, 108.64 feet
(108.98 feet deeded); thence Northeasterly at an angle of 8500'30" (8452' deeded), measured
clockwise from the last described course, 44.95 feet; thence Southeasterly at an angle of 10022',
measured counterclockwise from the last described course, 126.95 feet; thence Northeasterly at
an angle of 9758'01" (9756' deeded), measured clockwise from the last described course,
74.44 feet (74.35 feet deeded) to the said Right of Way line of U.S. Route 52; thence
Southeasterly, along said Right of Way line, at an angle of 9546'53" (95049130" deeded),
measured counterclockwise from the last described course, 11. 78 feet; thence Southwesterly at
an angle of 8608'25", measured counterclockwise from the last described course, 30.19 feet;
thence Southwesterly at an angle of 16232'56", measured counterclockwise from the last
described course, 63.50 feet; thence Southwesterly at an angle of 18357'01 ", measured
counterclockwise from the last described course, 228.41 feet; thence Southwesterly at an angle
of 20513'38", measured counterclockwise from the last described course, 434.49 feet to the said
west line of the Northwest Quarter; thence Northerly, along said west line, at an angle of
43 53 '35", measured counterclockwise from the last described course, 1075.58 feet to point of
beginning, containing 6.099 acres more or less.
EXCEPTING THEREFROM: Part of the Northwest Quarter of Section 10, Township 21 North,
Range 9 East of the 4th Principal Meridian, bounded and described as follows:
Commencing at the intersection of the west line of said Northwest Quarter and the southwesterly
Right of Way line of U.S. Route 52; thence Southerly, along said west line, 1075.58 feet to the
point of beginning of the hereinafter described tract of land; thence Northeasterly at an angle of
4353'35", measured clockwise from the last described course, 434.49 feet; thence Northeasterly
at an angle of 20513'38", measured clockwise from the last described course, 228.41 feet;
thence Northeasterly at an angle of 18357'01 ", measured clockwise from the last described
course, 63.50 feet; thence Northeasterly at an angle of 16232'56", measured clockwise from the
last described course, 30.19 feet to the said Right of Way line of U.S. Route 52; thence
Southeasterly, along said Right of Way line at an angle of 9351 '35", measured
counterclockwise from the last described course, 60.46 feet; thence Southeasterly, along said
Right of Way line, at an angle of 18615'23" (18607'30" deeded), measured counterclockwise
from the last described course, 210.98 feet (210.91 feet deeded); thence Southeasterly, along said
Right of Way line, at an angle of 17555'02", measured counterclockwise from the last described
5

Case: 3:12-cr-50027 Document #: 280-2 Filed: 12/18/15 Page 13 of 19 PageID #:1540

course, 59.09 feet; thence Southwesterly at an angle of 9703 '22", measured counterclockwise
from the last described course, 145.81 feet; thence Southerly at an angle of 22259'56",
measured counterclockwise from the last described course, 22.74 feet; thence Southwesterly at
an angle of 10907'3 l ", measured counterclockwise from the last described course, 770.13 feet
(769.46 feet deeded) to the said west line of the Northwest Quarter; thence Northerly, along said
west line, 201.40 feet to the point of beginning, containing 6. 099 acres more or less.
EXCEPTING THEREFROM: The Southeast Quarter of Section 18, Township 21 North, Range
Ten East of the Fourth Principal Meridian, Nachusa Township, Lee County, Illinois.
EXCEPTING THEREFROM: Part of the Northwest Quarter of Section 10 in Township Twentyone North, Range Nine East of the Fourth Principal Meridian described as follows:
Commencing at the Southeast Corner of the Northwest Quarter of said Section Ten for a point of
beginning, thence North along the centerline of said Section Ten to the point where said
centerline intersects the Southerly line of the East-West Tollway Extension, then Southwesterly
on said Southerly line of the East-West Extension, to a point where said Southerly line intersects
with the East line of U.S. Route 52, thence Southeasterly on said East line of U.S. Route 52 to
the South line of the Northwest Quarter of said Section Ten, thence east on said South line of the
Northwest Quarter to the point of beginning.
EXCEPTING THEREFROM: Part of the Northwest Quarter of Section 10, Township 21 North,
Range 9 East of the 4th Principal Meridian, bounded and described as follows: Commencing at
the intersection of the west line of said Northwest quarter and the centerline of U.S. Route 52;
thence South 44 degrees 11 minutes 08 seconds East, along said centerline, 1548.3 7 feet to
Station 54+ 13.94; thence North 45 degrees 48 minutes 52 seconds East, perpendicular to the last
described course, 13 8.49 feet to the point of beginning of the hereinafter described tract of land;
thence continuing along the last described course, 444.00 feet; thence South 44 degrees 11
minutes 08 seconds East, parallel with the said centerline of U.S. Route 52, a distance of 620.62
feet to a point 200 feet radially distant from the centerline of Illinois Route 88 (East-West
Tollway); thence Westerly, parallel with said centerline, on a circular curve, an arc distance of
451.45 feet, said curve being concave to the South and having a radius of 3064.79 feet; thence
South 70 degrees 22 minutes 18 seconds West, parallel with said centerline of Illinois Route 88,
a distance of 16.09 feet; thence North 75 degrees 24 minutes 24 seconds West, 62. 77 feet to a
point 140 feet from the centerline of U.S. Route 52 (measured perpendicular); thence North 44
degrees 11 minutes 08 seconds West, parallel with the centerline of U.S. Route 52, a distance of
329.18 feet; thence North 50 degrees 21minutes19 seconds West, 14.02 feet to the point of
beginning, all in Lee County, Illinois.
EXCEPTING THEREFROM: Part of the Northeast Quarter and part of the Northwest Quarter of
Section 20, Township 21 North, Range 9 East of the 4th Principal Meridian, bounded and
described as follows:

Case: 3:12-cr-50027 Document #: 280-2 Filed: 12/18/15 Page 14 of 19 PageID #:1541

Beginning at the northwest comer of said Northeast Quarter; thence Easterly along the north line
of said Northeast Quarter, 1330.40 feet to the northeast corner of the Northwest Quarter of the
Northeast Quarter: thence Southerly, along the east line of said Northwest Quarter of the
Northeast Quarter at an angle of 9055'04", measured counterclockwise from the last described
course, 1316.89 feet to the southeast comer of said Northwest Quarter of the Northeast Quarter;
thence Westerly, along the south line of said Northwest Quarter of the Northeast Quarter, at an
angle of 8906'50", measured counterclockwise from the last described course, 344.23 feet;
thence Westerly, at an angle of 17258'00", measured counterclockwise from the last described
course, 607.63 feet; thence Southwesterly at an angle of 23519'56", measured counterclockwise
from the last described course, 99.65 feet (99. 72 feet deeded) to a point on the said south line of
the Northwest Quarter of the Northeast Quarter, 3 17.37 feet East of the southwest comer of said
Quarter-Quarter, said point being on the northerly Right of Way of the now abandoned Chicago
and Northwestern Railway Company; thence Westerly, along said Right of Way at an angle of
12434'55", measured cotmterclockwise from the last described course, 900.14 feet to the west
line of the East Half of the East Half of the said Northwest Quarter of Section 20; thence
Northerly, along said west line, at an angle of 9756' 19", measured counterclockwise from the
last described course, 601.21 feet to a point 594.00 feet South of the north line Of ,said
Northwest Quarter (measured along said west line); thence Easterly, parallel with said north line,
at an angle of 8909'08", measured counterclockwise from the last described course, 662.86 feet
to the east line of said Northwest Quarter: thence Northerly, along said east line, at an angle of
27053 '24", measured counterclockwise from the last described course, 594.00 feet to the point
of beginning, containing 49.299 acres more or less. Subject to that land used for public road
purposes and any easements of record.
All situated in South Dixon Township, Lee County, Illinois.
EXCEPTING THEREFROM: Part of the Northeast Quarter of Section 17, Township 21 North,
Range 9 East of the 4th Principal Meridian, bounded and described as follows:
PARCEL 1: Commencing at the southeast comer of said Northeast Quarter; thence Northerly,
along the east line of said Northeast Quarter, 66.00 feet to the point of beginning of the
hereinafter described tract of land; thence continuing along the last described course, 687 .20 feet;
thence Westerly at an angle of 90 degrees 19 minutes 45 seconds, measured clockwise from the
last described course, 426.00 feet; thence Southerly, parallel with the said east line of the
Northeast Quarter, at an angle of 89 degrees 40 minutes 15 seconds, measured clockwise from
the last described course, 687 .20 feet; thence Easterly at an angle of 90 degrees 19 minutes 45
seconds, measured clockwise from the last described course, 426.00 feet to the point of
beginning, all situated in South Dixon Township, Lee County, Illinois.
PARCEL 2: Part of the Northeast Quarter of Section 17, Township 21 North, Range 9 East of the
4th Principal Meridian, bounded and described as follows:

Case: 3:12-cr-50027 Document #: 280-2 Filed: 12/18/15 Page 15 of 19 PageID #:1542

Beginning at the northeast comer of said Northeast Quarter; thence South 0 degrees 00 minutes
00 seconds East, along the east line of said Northeast Quarter, 523.18 feet; thence North 89
degrees 54 minutes 34 seconds West, 1339.84 feet to the southeasterly Right of Way of the EastWest Tollway; thence North 46 degrees 20 minutes 11 seconds East, along said Right of Way,
209.25 feet; thence continuing along said Right of Way, on a circular curve, an arc distance of
374.06 feet, said curve being concave to the Southeast and having a radius of 3689.73 feet;
thence continuing along said Right of Way, North 56 degrees 34 minutes 10 seconds East,
260.59 feet to the north line of said Northeast Quarter; thence South 88 degrees 58 minutes 34
seconds East, along said north line, 688.93 feet to the point of beginning all situated in South
Dixon Township, Lee County, Illinois.

Case: 3:12-cr-50027 Document #: 280-2 Filed: 12/18/15 Page 16 of 19 PageID #:1543

EXHIBITB
Chicago Title Insurance Co

SCHEDULE A CONTINUED

The West Half (W 1/2) of the Southeast Quarter (SE 1/4) of Section Seventeen (17), Township Twenty-one
(21) North, Range Nine (9) East of the Fourth Principal Meridian, EXCEPTING THEREFROM part of the
Southeast Quarter of Section Seventeen (17), Township Twenty-one (21) North, Range Nine (9) East of the
Fourth Principal Meridian, described as follows: Beginning at the Southwest corner of the said Southeast
Quarter (SE 1/4); thence Northerly on the West line of the said Southeast Quarter (SE 1/4) 164.0 feet;
thence Easterly parallel with the South line of said Section 17, 177.0 feet; thence Southerly parallel with the
said West line of the Southeast Quarter (SE 1/4) 164.0 feet to the said South line; thence Westerly on the
said South line 177.0 feet to the said Point of Beginning, all situated in the County of Lee and State of Illinois.

REGISTERED AGENT:
Kenzley Tille Group, Inc, 87 S. Hennepin A.tenue, Dixon, IL 61021
Phone (815)288-3333 Fax: (815)288-3334
SCHEDULE A Continued
ALTACommitment-2006 (6/17/06)

(KL217221.PFD/KL217221/1)

Case: 3:12-cr-50027 Document #: 280-2 Filed: 12/18/15 Page 17 of 19 PageID #:1544

17th

Case: 3:12-cr-50027 Document #: 280-2 Filed: 12/18/15 Page 18 of 19 PageID #:1545

17

Case: 3:12-cr-50027 Document #: 280-2 Filed: 12/18/15 Page 19 of 19 PageID #:1546

d. Attorney's fees. Each party shall bear the cost of its own attorney's fees, costs
and expenses, except as otherwise provided by applicable federal law;
e. Section Headings. Section headings used herein are for convenience only and
shall not be deemed to limit or define the scope of any provision hereof; and

f. Counterparts. This contract may be signed in counterparts by each of the parties

thereto.
By and through the signatures affixed below of their duly authorized agents, the parties
hereby execute this Contract which shall become effective on the date of the last signature, as
indicated below.
THE UNITED STATES OF AMERICA,
by and through
THE UNITED STATES MARSHALS SERVICE
Edward L. Gilmore
United States Marshal
Northern District of Illinois

~:,o~

Dated: December 11, 2015.

Chief Inspector
Asset Forfeiture Division
U.S. Marshals Service

HUMPHREY FAMILY FARMS

(}ib};J!;~44 ~ Date~berg201s
By

Cd_Cl..v__, '})~

Dated: December __L.7, 2015.

Carol Ann Beardin

ByL~rkiu

Dated: December

3
Crundwcll-Conlract for Purchase nnd Snlc of Fann Real Property

/1, 2015.