Case 1:18-cr-00204-NGG-VMS Document 430 Filed 03/13/19 Page 23 of 30 PageID #: 4311
United States Code, Section 7201, contrary to Title 18, United States Code, Section 1028(a)(7).
{Title 18, United States Code, Sections 1028(f) and 3551 et seq.)
CRIMINAL FORFEITURE ALLEGATION AS TO COUNTS ONE AND TWO
50. The United States hereby gives notice to the defendants charged in Counts One and Two that, upon their conviction of either of such offenses, the government will seek forfeiture in accordance with Title 18, United States Code, Section 1963(a), which requires any person convicted of such offenses to forfeit: (a) any interest the person acquired or maintained in violation of Title 18, United States Code, Section 1962; (b) any interest in, security of, claim against or property or contractual right of any kind affording a source of influence over any enterprise which the person has established, operated, controlled, conducted or participated in the conduct of, in violation of Title 18, United States Code, Section 1962; and (c) any property constituting, or derived from, any proceeds which the person obtained, directly or indirectly, from racketeering activity in violation of Title 18, United States Code, Section 1962.
51. If any of the above-described forfeitable property, as a result of any act or omission of the defendants:
- (a) cannot be located upon the exercise of due diligence;
- (b) has been transferred or sold to, or deposited with, a third party;
- (c) has been placed beyond the jurisdiction of the court;
- (d) has been substantially diminished in value; or
