Pandemic Darlings The pandemic economy, in original documents
Home Court filings U.S. v. Acree Motion for Preliminary Order of Forfeiture - United States v. Derek James Acree

Court filing

Motion for Preliminary Order of Forfeiture - United States v. Derek James Acree

Record facts

CourtU.S. District Court, Southern District of Florida
Filed2022-12-20

U.S. District Court, Southern District of Florida · No. 9:22-cr-80157-AHS · Doc. 19 · 2022-12-20 · Docket on CourtListener

Summary

The United States' unopposed motion for a preliminary order of forfeiture in United States v. Derek James Acree, Case No. 22-80157-AHS, in the U.S. District Court for the Southern District of Florida, entered on the docket December 20, 2022 as Document 19. The motion seeks a forfeiture money judgment of $869,682.83 under 18 U.S.C. § 982(a)(2)(A), the procedures of 21 U.S.C. § 853, and Rule 32.2 of the Federal Rules of Criminal Procedure. It recounts that an information filed September 27, 2022 charged one count of conspiracy to commit wire fraud under 18 U.S.C. § 1349 with forfeiture allegations, and that the court accepted a guilty plea to that count on October 11, 2022. A memorandum of law addresses directly forfeitable property, forfeiture money judgments, and the distinction the Eleventh Circuit draws between forfeiture and restitution. The document is 10 pages.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO.  22-80157-AHS 
 
UNITED STATES OF AMERICA 
 
vs. 
 
DEREK JAMES ACREE, 
  
 
Defendant. 
_____________________________________/ 
 
 
 
 
 
 
 
 
 
UNITED STATES’ UNOPPOSED MOTION FOR  
PRELIMINARY ORDER OF FORFEITURE  
 
Pursuant to 18 U.S.C. § 982(a)(2)(A), and the procedures set forth in 21 U.S.C. § 853 and 
Rule 32.2 of the Federal Rules of Criminal Procedure, the United States of America, by and 
through the undersigned Assistant United States Attorney, hereby moves for the entry of a 
Preliminary Order of Forfeiture against Defendant Derek James Acree (the “Defendant”) in the 
above-captioned matter.  The United States seeks a forfeiture money judgment in the amount of 
$869,682.83.  In support of this motion, the United States provides the following factual and legal 
bases. 
I. 
FACTUAL BACKGROUND AND PROCEDURAL HISTORY 
On September 27, 2022, the United States filed an Information charging the Defendant in 
Count 1 with conspiracy to commit wire fraud in violation of 18 U.S.C. § 1349.  Information, ECF 
No. 1.  The Information also contained forfeiture allegations, which alleged that upon conviction 
of a violation of 18 U.S.C. § 1349, the Defendant shall forfeit his proceeds, in the amount of 
approximately $869,682.83.  See id. at 6.   
On October 11, 2022, the Court accepted the Defendant’s guilty plea to Count 1 of the 
Information.  See Minute Entry, ECF No. 10; Plea Agreement ¶ 1, ECF No. 11.  As part of the 
Case 9:22-cr-80157-AHS   Document 19   Entered on FLSD Docket 12/20/2022   Page 1 of 10

2 
guilty plea, the Defendant agreed to a forfeiture money judgment in the amount of $869,682.83.  
Specifically, among other provisions in the Plea Agreement, the Defendant agreed to the 
following: 
11. 
The defendant agrees, in an individual and any other capacity, to 
forfeit to the United States, voluntarily and immediately, any right, title, and interest 
to any property, real or personal, which constitutes or is derived from proceeds 
traceable to the commission of the offense, in violation of 18 U.S.C. § 1349, 
pursuant to 18 U.S.C. § 981(a)(1)(C),[1] as incorporated by 28 U.S.C. § 2461(c), 
and the provisions of 21 U.S.C. § 853.  In addition, the defendant agrees to 
forfeiture of substitute property pursuant to 21 U.S.C. § 853(p). The property 
subject to forfeiture includes, but is not limited to:  
 
a. 
a forfeiture money judgment in the sum of approximately 
$869,682.83 in U.S. currency, which sum represents the value of 
any property that constitutes or is derived from proceeds traceable 
to the defendant’s commission of the offense(s) 
 
Plea Agreement ¶ 11.    
In support of the guilty plea, the Defendant executed a Factual Proffer, and the Court found 
that there was a factual basis to support the Defendant’s conviction.  See Factual Proffer, ECF No. 
12. The Factual Proffer also provided a basis for the forfeiture of property.  See id.  
 
1 The Information and Plea Agreement cite to 18 U.S.C. § 981(a)(1)(C) as the basis for forfeiture 
of proceeds. Section 981(a)(1)(C) does provide for forfeiture of proceeds traceable to wire-fraud 
offenses under 18 U.S.C. § 1343 (and conspiracies). See 18 U.S.C. § 981(a)(1)(C) (“(1)The 
following property is subject to forfeiture to the United States: … (C) Any property, real or 
personal, which constitutes or is derived from proceeds traceable to a violation of section … any 
offense constituting ‘specified unlawful activity’ (as defined in section 1956(c)(7) of this title)…, 
or a conspiracy to commit such offense.”); 18 U.S.C. § 1956(c)(7) (defining “specified unlawful 
activity” to include “any act or activity constituting an offense listed in section 1961(1) of this 
title”); 18 U.S.C. § 1961(1) (listing inter alia “section 1343 (relating to wire fraud)”). In this case, 
because the wire fraud affected a financial institution, 18 U.S.C. § 982(a)(2)(A) is the proper basis 
for Defendant to forfeit his proceeds. See 18 U.S.C. § 982(a)(2)(A) (“(2)The court, in imposing 
sentence on a person convicted of a violation of, or a conspiracy to violate—(A) section … 1344 
of this title, affecting a financial institution, … shall order that the person forfeit to the United 
States any property constituting, or derived from, proceeds the person obtained directly or 
indirectly, as the result of such violation.”). Under either section, Defendant must forfeit proceeds. 
Case 9:22-cr-80157-AHS   Document 19   Entered on FLSD Docket 12/20/2022   Page 2 of 10

3 
II. 
MEMORANDUM OF LAW 
A. Directly Forfeitable Property 
 
Any property, real or personal, that constitutes or is derived, directly or indirectly, from 
gross proceeds traceable to the commission of a wire-fraud offense affecting a financial institution 
is subject to forfeiture.  18 U.S.C. § 982(a)(2)(A). If a defendant is convicted of such violation, the 
Court “shall order” the forfeiture of property as part of the sentence.  See 18 U.S.C. § 982(a)(2).  
Criminal forfeiture is governed by the preponderance standard.  See United States v. Hasson, 333 
F.3d 1264, 1277 (11th Cir. 2003).  Upon finding that property is subject to forfeiture by a 
preponderance, the Court:    
. . . must promptly enter a preliminary order of forfeiture setting forth the amount 
of any money judgment, directing the forfeiture of specific property, and directing 
the forfeiture of any substitute property if the government has met the statutory 
criteria.  The court must enter the order without regard to any third party’s interest 
in the property.  Determining whether a third party has such an interest must be 
deferred until any third party files a claim in an ancillary proceeding under Rule 
32.2(c). 
 
Fed. R. Crim. P. 32.2(b)(2)(A).  
B. Forfeiture Money Judgments 
A forfeiture order may be sought as a money judgment.  See Fed. R. Crim. P. 32.2(b)(1)(A), 
(2)(A); see also United States v. Padron, 527 F.3d 1156, 1162 (11th Cir. 2008) (holding that 
Federal Rules of Criminal Procedure “explicitly contemplate the entry of money judgments in 
criminal forfeiture cases”).  The forfeiture money judgment is final as to the defendant “[a]t 
sentencing—or at any time before sentencing if the defendant consents.”  See Fed. R. Crim. P. 
32.2(b)(4)(A).  No ancillary proceeding is required when forfeiture consists solely of a money 
judgment.  See Fed. R. Crim. P. 32.2(c)(1).  As additional property is identified to satisfy the 
forfeiture money judgment, the Court must order the forfeiture of such property.  See Fed. R. Crim. 
Case 9:22-cr-80157-AHS   Document 19   Entered on FLSD Docket 12/20/2022   Page 3 of 10

4 
P. 32.2(e)(1) (“[T]he court may at any time enter an order of forfeiture or amend an existing order 
of forfeiture to include property that . . . is subject to forfeiture under an existing order of forfeiture 
but was located and identified after that order was entered; or . . . is substitute property . . . .”); see 
also Fed. R. Crim. P. 32.2(b)(2)(C). 
The amount of the money judgment should represent the full sum of directly forfeitable 
property, regardless of the defendant’s ability to satisfy the judgment at the time of sentencing.  
See United States v. McKay, 506 F. Supp. 2d 1206, 1211 (S.D. Fla. 2007) (adopting the majority 
rule); see also United States v. Blackman, 746 F.3d 137, 143-44 (4th Cir. 2014) (“The fact that a 
defendant is indigent or otherwise lacks adequate assets to satisfy a judgment does not operate to 
frustrate entry of a forfeiture order.”).  The Court determines the amount of the money judgment 
“based on evidence already in the record, including any written plea agreement, and any additional 
evidence or information submitted by the parties and accepted by the court as relevant and 
reliable.”  Fed. R. Crim. P. 32.2(b)(1)(B).  The Court in imposing a forfeiture money judgment 
may rely on an agent’s reliable hearsay.  See United States v. Stathakis, 2008 WL 413782, at *14 
n.2 (E.D.N.Y. Feb. 13, 2008).  The defendant’s money judgment amount can be based on a 
reasonable estimate on the amount of property subject to forfeiture.  See, e.g., United States v. 
Roberts, 660 F.3d 149, 166 (2d Cir. 2011); United States v. Peithman, 917 F.3d 635, 651 (8th Cir. 
2019); United States v. Vico, 2016 WL 233407, at *7 (S.D. Fla. Jan. 20, 2016) (calculation of 
money judgment does not require mathematical exactitude; district court may make a reasonable 
extrapolation supported by a preponderance of the evidence). 
C. Difference Between Forfeiture and Restitution 
Both forfeiture and restitution are mandatory in criminal cases.  See United States v. 
Brummer, 598 F.3d 1248, 1250-51 (11th Cir. 2010) (the word “shall” does not convey discretion 
Case 9:22-cr-80157-AHS   Document 19   Entered on FLSD Docket 12/20/2022   Page 4 of 10

5 
and the district court was required to order forfeiture of the property in accordance with Fed. R. 
Crim. P. 32.2); 18 U.S.C. § 3664(f)(1)(A) (requiring district courts to order restitution in the full 
amount of each victim’s losses).  Although sometimes conflated, forfeiture and restitution serve 
different purposes.  “While restitution seeks to make victims whole by reimbursing them for their 
losses, forfeiture is meant to punish the defendant by transferring his ill-gotten gains to the United 
States Department of Justice.”  United States v. Joseph, 743 F.3d 1350, 1354 (11th Cir. 2014) 
(citing United States v. Browne, 505 F.3d 1229, 1281 (11th Cir. 2007), United States v. Venturella, 
585 F.3d 1013, 1019-20 (7th Cir. 2009), and Libretti v. United States, 516 U.S. 29, 39 (1995)).  
Because of this distinction, the Eleventh Circuit has repeatedly held that district courts cannot use 
restitution to offset the forfeiture amount ordered, or vice versa.  See United States v. Hernandez, 
803 F.3d 1341, 1343-44 (11th Cir. 2015); Joseph, 743 F.3d at 1354 (“In light of the statutory 
framework governing restitution and forfeiture, we hold that a district court generally has no 
authority to offset a defendant’s restitution obligation by the value of forfeited property held by 
the government, which is consistent with the approach taken by the Fourth, Seventh, Eighth, Ninth, 
and Tenth Circuits.”); United States v. Bane, 720 F.3d 818, 827 n.8 (11th Cir. 2013); United States 
v. Hoffman-Vaile, 568 F.3d 1335, 1344-45 (11th Cir. 2009); Browne, 505 F.3d at 1281 (finding 
defendant’s disgorgement of illicit profits did not divest the United States of its forfeiture interest 
in the full amount of offense). 
D. Property Subject to Forfeiture in Instant Criminal Case 
National Financial Holdings, Inc., formerly National Financial Holdings LLC, was a 
Delaware corporation with a registered address in Wilmington, Delaware and a principal address 
in Palm Beach Gardens, Florida.  Defendant was the Chief Operating Officer of National Financial 
Holdings, Inc.  NFH Florida LLC was a Delaware limited liability company with a registered 
Case 9:22-cr-80157-AHS   Document 19   Entered on FLSD Docket 12/20/2022   Page 5 of 10

6 
address in Wilmington, Delaware.  Defendant was the Managing Member of NFH Florida LLC. 
National Financial Holdings Technology LLC, was a Delaware limited liability company with a 
registered address in Wilmington, Delaware.  Defendant was the Chief Operating Officer of 
National Financial Holdings Technology LLC.  
During the period of March 2020 and continuing through in or around August 2020, 
Defendant and co-conspirator 1 submitted and caused to be submitted several loan applications 
under the Economic Injury Disaster Loan (EIDL) Program and the Paycheck Protection Program 
which were developed under the CARES Act.  EIDL program was a U.S. Small Business 
Administration (SBA) program that existed before the COVID-19 pandemic to provide low-
interest financing to eligible small business, renters, and homeowners in regions affected by 
declared disasters.  The CARES Act authorized forgivable loans to qualified businesses and other 
organizations for job retention and certain other expenses, through the Paycheck Protection 
Program (PPP).  Such businesses were required to use PPP loan proceeds on payroll costs, interest 
on mortgages, rent, and utilities. 
On March 31, 2020, Defendant and co-conspirator 1 submitted and caused to be submitted 
via wire an EIDL application on behalf of National Financial Holdings, Inc., with a listed address 
of 4521 PGA Blvd., Suite 226, Palm Beach Gardens, FL, and sought approximately $509,900 in 
EIDL funds.  The initial application was submitted from an IP address which originated in Palm 
Beach Gardens.  Defendant and co-conspirator 1 executed the loan agreement as guarantors and 
falsely represented the gross revenues and number of employees of National Financial Holding 
Inc., during the 12-month period prior to the dated of the COVID disaster.  The application was 
approved and funded by SBA.   
Further, the approved EIDL funds were deposited into a BB&T (now Truist) account 
Case 9:22-cr-80157-AHS   Document 19   Entered on FLSD Docket 12/20/2022   Page 6 of 10

7 
ending in 5893, which was held in the name of an entity other than National Financial Holding, 
Inc.  The account holder for the BB&T (now Truist) account ending in 5893 was NFH Florida 
LLC, dba Finova Financial LLC.  After the EIDL proceeds were deposited into the BB&T (now 
Truist) account ending in 5893, between April 22, 2020, and August 5, 2020, funds were 
distributed and transferred in nine separate wires totaling $396,000 to personal and unrelated 
business accounts belonging to Defendant and co-conspirator 1.  EIDL application submitted 
through August 8, 2020, were serviced through Virginia.  BB&T’s (now Truist) servers located in 
North Carolina.  
On April 3, 2020, Defendant submitted and caused to be submitted via wire a PPP loan 
application on behalf of National Financial Holding, Inc., with a listed address of 4521 PGA Blvd., 
Suite 226, Palm Beach Gardens, FL.  This application sought approximately $376,356.03 in PPP 
funds based on purported average month payroll of $150,542.41 and represented that the entity 
employed 20 employees.  The certificate of completion of the application was submitted from an 
IP address which originated in Palm Beach Gardens.  Defendant executed the loan agreement as 
guarantor.  The application was approved and funded by First Home Bank.  Among the documents 
provided by Defendant in support of the PPP loan were BB&T (now Truist) bank statements for 
account ending in 5368, which were falsified, in that, the provided bank statements listed National 
Financial Holdings, Inc, as the account holder, when in truth and in fact, the account holder was 
NFH Florida LLC dba Finova LLC.  Further, the bank provided statements reflect different payroll 
line amounts and totals significantly less than the inflated payroll line amounts and totals reflected 
the bank statements provided by Defendant.  BB&T’s (now Truist) servers are located in North 
Carolina.  First Home Bank is Headquartered in St. Petersburg, Florida, however, its deposits to 
customer FHB DDA are serviced through Honolulu, Hawaii.  Further, the loan documents were 
Case 9:22-cr-80157-AHS   Document 19   Entered on FLSD Docket 12/20/2022   Page 7 of 10

8 
docusigned (with an IP Address originating in Palm Beach Gardens and Docusign is headquartered 
in San Francisco, California, with data centers outside of Florida.        
The approved PPP funds of $376,300 were deposited into a Silicon Valley Bank account 
ending in 0470 and held by National Financial Holdings Inc. for which Defendant is a signatory.  
After the PPP proceeds were deposited into SVB account ending in 0470, between May 1, 2020 
and December 7, 2020, funds, which included a wire transfer of $195,000 of EIDL proceeds from 
BB&T account ending in 5893, funds were distributed and transferred in a number of wires to 
various unrelated entities’ accounts, including wires in an aggregate amount of approximately 
$223,600 to co-conspirator 1’s unrelated business account; approximately $54,795 an unrelated 
business account, controlled by Defendant and co-conspirator 1; approximately $114,000 to 
Defendant’s unrelated business accounts; and to Salles Jewelers for the purchase of jewelry.  
On April 17, 2020, Defendant submitted and caused to be submitted via wire a PPP loan 
application on behalf of NFH Florida LLC, with a listed address of 4521 PGA Blvd., Suite 226, 
Palm Beach Gardens, FL.  This application sought approximately $376,400 in PPP funds based on 
purported average monthly income of $150,560 and claim of 20 active employees. Among the 
documents provided by Defendant in support of the application were a borrower’s worksheet 
which reported a total payroll cost of $1,806,508 for the 12-month period prior to the disaster and 
an IRS Form 940 (Schedule R) purportedly prepared by Insperity PEO Services, LP for Tax Year 
2019.  The application was approved and funded by Truist Bank, formerly BB&T, whose servers 
are located in North Carolina. Documentation from Insperity revealed that they did not prepare 
payroll for TY 2018 or TY 2019; however, Insperity was paid $80,983 during the period of April 
2020-June 2020.  
After the PPP funds were deposited, approximately $374,000 was moved through nine 
Case 9:22-cr-80157-AHS   Document 19   Entered on FLSD Docket 12/20/2022   Page 8 of 10

9 
separate wires and 21 bank account transfers.  Eight of the wires were traced to unrelated business 
accounts in which Defendant and the co-conspirator 1 were authorized signatories.    
On April 20, 2020, Defendant submitted and caused to be submitted via wire a PPP loan 
application on behalf of National Financial Holdings Technology LLC, with a listed address of 
1400 Centrepark Blvd., Suite 800, West Palm Beach, FL.  This application sought approximately 
$349,955 in PPP funds based on a purported monthly payroll of $139,982 and listed 18 active 
employees.  Defendant submitted the PPP application as General Counsel.  The application was 
approved and funded by Flagler Bank. Among the documents provided in support of the 
application was a PPP checklist signed by Defendant, as Officer, attesting to the company’s payroll 
payment for TY 2019 as $257,374.21 and IRS Forms 940 and 941 (Schedule R) purportedly 
prepared by Insperity.  Insperity found no record for Forms 940 or 941 had ever been prepared for 
National Financial Holdings Technology LLC. Or any of the related entities.  
On April 24, 2020, a Flagler Bank account was opened with $100 and the bank account 
agreements listed Defendant and co-conspirator 1 as signatories.  The account was funded on July 
27, 2020, however, the proceeds were pulled back on July 29, 2020.  Flagler Bank is Headquartered 
in West Palm Beach, FL.  All PPP applications submitted through August 8, 2020, were received 
through SBA E-Tran with servers located in Virginia. 
As indicated above, Defendant and co-conspirator 1 received approximately $1,612,555 in 
EIDL and PPP loan funds as a result of the false claims and representations in their EIDL and PPP 
loan applications.  Of the EIDL and PPP proceeds received, Defendant retained approximately 
$869,682.83 for his personal use, to include American Express credit card payments, USSA credit 
card payments for maintenance of an Audi, $11,000 payment to Trump National Golf Club, 
monthly payments of child school tuition, marine services for a vessel, Salles Jewelers in the 
Case 9:22-cr-80157-AHS   Document 19   Entered on FLSD Docket 12/20/2022   Page 9 of 10

10 
amount of $67,900, XO Global in the amount of $54,795 for private jet services, and $46,000 
down payment for a home located at 13058 Flamingo Terr., Palm Beach Gardens, FL. 
Based on the record in this case, the total value of the proceeds traceable to the offense of 
conviction is $869,682.83, which sum may be sought as a forfeiture money judgment pursuant to 
Rule 32.2 of the Federal Rules of Criminal Procedure. 
Accordingly, the Court should issue the attached proposed order, which provides for the 
entry of a forfeiture money judgment against the Defendant; the inclusion of the forfeiture as part 
of the Defendant’s sentence and judgment in this case; and permission to conduct discovery to 
locate assets ordered forfeited. 
WHEREFORE, pursuant to 18 U.S.C. § 982(a)(2)(A), and the procedures set forth in 21 
U.S.C. § 853 and Rule 32.2 of the Federal Rules of Criminal Procedure, the United States 
respectfully requests the entry of the attached order.  
LOCAL RULE 88.9 CERTIFICATION 
Pursuant to Local Rule 88.9, I hereby certify that the undersigned counsel has conferred 
with defense counsel via e-mail on December 20, 2022, and there is no opposition to the relief 
sought.  
 
Respectfully submitted, 
JUAN ANTONIO GONZALEZ 
UNITED STATES ATTORNEY 
 
By: 
     
/s/ 
 
               
 
 
Joshua Paster  
Court ID No. A5502616 
Assistant United States Attorneys 
99 N.E. 4th Street, 7th Floor 
Miami, Florida 33132-2111 
 
Telephone: (305) 961-9342 
joshua.paster@usdoj.gov 
Case 9:22-cr-80157-AHS   Document 19   Entered on FLSD Docket 12/20/2022   Page 10 of 10

File and source

File
gov.uscourts.flsd.620969.19.0.pdf
Size
230,328 bytes
SHA-256
ae66622fb9d9e1f63ab830641e0f7c78bfd10dd676ebd2d9e8dcff2144925232
Our copy
gov.uscourts.flsd.620969.19.0.pdf
Original
PACER (login required)
Back to top