Criminal Information — United States v. Andre Lee Gaines

Record facts

U.S. District Court for the Northern District of Georgia · No. 1:21-cr-00206-JPB · Doc. 1 · 2021-06-17 · Docket on CourtListener

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Case 1:21-cr-00206-JPB Document1 Filed 06/17/21 Pagei1of3

ILED IN OPE
USD. Alona

JUN 17 202
: JAMES N. HATTEN, Clerk
y:
DBYVWA Deputy Clerk
IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

UNITED STATES OF AMERICA

v. Criminal Information

ANDRE LEE GAINES No. 1:21-CR-206

THE UNITED STATES ATTORNEY CHARGES THAT:

On or about July 2, 2020, in the Northern District of Georgia, the defendant,
ANDRE LEE GAINES, did willfully and knowingly make a materially false,
fictitious, and fraudulent statement and representation in a matter within the
jurisdiction of the executive branch of the Government of the United States, by
stating to a Special Agent of the Federal Bureau of Investigation that Gaines
Reservation and Travel has 69 employees. The statement and representation
were false because, as ANDRE LEE GAINES then and there knew, Gaines
Reservation and Travel did not have any employees.

In violation of Title 18, United States Code, Section 1001.
Forfeiture

Upon conviction of the offense in violation of Title 18, United States Code,
Section 1001 set forth in the Information, the defendant, ANDRE LEE GAINES, shall
forfeit to the United States of America, pursuant to Title 18, United States Code,
Section 982(a)(3), any property, real or personal, which represents or is traceable
to the gross receipts obtained, directly or indirectly, as a result of such violation,

including, but not limited to:
Case 1:21-cr-00206-JPB Documenti Filed 06/17/21 Page2of3

a. MONEY JUDGMENT: A sum of money in U.S. currency representing the
value of the property involved in the offenses for which the defendant is
convicted.

b. $177,828.46 in funds seized from JPMorgan Chase account number
XXXXX6500 held in the name of Gaines Reservation and Travel.

c. $9,314.28 in funds seized from PNC Bank account number XXXXXX5124
held in the name of Gaines Reservation and Travel.

If any of the property described above, as a result of any act or omission

of the defendant:

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

e. has been commingled with other property which cannot be divided

without difficulty,
. the United States of America intends, pursuant to Title 21, United States Code,
Section 853(p), as incorporated by Title 18, United States Code, Section 982(b)(1)
and Title 28, United States Code, Section 2461(c), to seek forfeiture of any other

property of said defendant up to the value of the above forfeitable property.
Case 1:21-cr-00206-JPB Documenti Filed 06/17/21 Page3of3

KURT R. ERSKINE DANIEL S. KAHN
Acting United States Attorney Acting Chief, Fraud Section
U.S. Department of Justice

Gl Og Wleore

TAL C. CHAIKEN SIT MOORE
Assistant United States Attorney Trial Attorney, Fraud Section
Georgia Bar No. 273949 U.S. Department of Justice

NATHAN P. KITCHENS

Assistant United States Attorney
Georgia Bar No. 263930

600 U.S. Courthouse 1400 New York Ave, NW
75 Ted Turner Drive SW Bond Building, 11th Floor
Atlanta, GA 30303 Washington, DC 20005

404-581-6000; Fax: 404-581-6181 202-514-2000; Fax: 202-514-3708

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