suitcase in his vehicle. The action was filed pursuant to 21 U.S.C. § 881(a)(6), which authorizes forfeiture of currency used in illicit drug trafficking. Moore filed a pro se Verified Proof of Claim to the currency, as authorized by 18 U.S.C. § 983(a)(4)(A) and Rule G(5)(a) of the Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions (Supplemental Rules). The government then served interrogatories on him concerning his interest in and possession of the currency, see Supp. R. G(6)(a), which he failed to answer. He also failed to file an answer to the complaint. See 18 U.S.C. § 983(a)(4)(B) & Supp. R. G(5)(b). Represented by counsel, he sought and was granted four extensions of time to respond to the interrogatories, but he never did.
Based on his failure to file an answer or respond to the interrogatories, the government moved to strike Moore’s Verified Proof of Claim, see Supp. R. G(8)(c)(i)(A), which the district judge granted. Moore then filed a motion to reconsider, which the judge denied. The judge also denied on procedural and jurisdictional grounds Moore’s merits challenges to the seizure and forfeiture of the currency. Upon the government’s motion and over Moore's objection, a default was entered against him, pursuant to Fed. R. Civ. P. 55(a). In a subsequent order, the judge entered a default judgment and ordered the currency forfeited to the government. Moore appeals from the default judgment.
"Decisions to enter judgment by default are committed to the district court's sound discretion, and our review is for an abuse of discretion." Olcott v. Delaware
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