Motion for Preliminary Order of Forfeiture — United States v. Edward McCorkle

Record facts

U.S. District Court, District of Maryland · No. 1:25-cr-00270-RDB · Doc. 21 · 2026-01-09 · Docket on CourtListener

Summary

The United States' motion for a preliminary order of forfeiture in United States of America v. Edward McCorkle, Criminal No. RDB-25-270, filed January 9, 2026 as Document 21 in the U.S. District Court for the District of Maryland. The motion is brought under 18 U.S.C. § 981(a)(1)(C), 28 U.S.C. § 2461(c) and Rule 32.2(b) of the Federal Rules of Criminal Procedure, and submits a proposed order. It states that an Information filed September 9, 2025 charged wire fraud conspiracy in violation of 18 U.S.C. § 1349 in Count One with a forfeiture allegation, that the defendant pled guilty on September 15, 2025, and that he agreed to a money judgment of at least $523,700.00. It seeks a forfeiture money judgment of $523,700.00, leave to conduct discovery under 21 U.S.C. § 853(m), and incorporation of the forfeiture in the sentence and criminal judgment.

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Full text

IN THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF MARYLAND 
 
UNITED STATES OF AMERICA 
 
v. 
 
EDWARD MCCORKLE, 
 
Defendant 
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CRIMINAL NO. RDB-25-270 
 
 
 
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UNITED STATES’ MOTION FOR PRELIMINARY ORDER OF FORFEITURE 
The United States of America, by its undersigned attorneys, respectfully moves this Court 
for the issuance of a Preliminary Order of Forfeiture in the above-captioned case pursuant to 18 
U.S.C. § 981(a)(1)(C), 28 U.S.C. § 2461(c), and Rule 32.2(b) of the Federal Rules of Criminal 
Procedure.  A proposed Preliminary Order of Forfeiture is submitted herewith.  In support 
thereof, the United States sets forth the following: 
1. 
On September 9, 2025, the United States of America filed an Information, charging 
Edward McCorkle (the “Defendant”) with Wire Fraud Conspiracy, in violation of 18 U.S.C. 
§ 1349 (Count One).  Dkt. No. 1. 
2. 
The Information also included a forfeiture allegation which provided notice that the 
United States intended to seek forfeiture, pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. 
§ 2461(c), upon conviction of the Defendant of the offense alleged in Count One of the 
Information.  Id. at 6.  
3. 
On September 15, 2025, the Defendant pled guilty to the offense alleged in Count 
One of the Information.  Dkt. No. 13.  As part of his guilty plea, the Defendant agreed to entry 
of an order of forfeiture to include a money judgment in the amount of at least $523,700.00 in U.S. 
currency equal to the value of the property derived from, or otherwise involved in, the Defendant’s 
Case 1:25-cr-00270-RDB     Document 21     Filed 01/09/26     Page 1 of 3

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offense.  Id. ¶ 12. 
4. 
In support of his guilty plea, the Defendant executed a Stipulation of Facts in which 
the Defendant admitted that from approximately May 2020 through February 2021, the Defendant 
and his co-conspirators engaged in a scheme to defraud a financial institution, Cross River Bank, 
and the United States Small Business Administration to obtain fraudulent loan for various 
purported businesses owned by the Defendant, under the Paycheck Protection Program which was 
part of the Coronavirus Aid, Relief, and Economic Security Act and the Economic Injury Disaster 
Loan program.  Dkt. No. 13-1.  Ultimately, the Defendant fraudulently obtained $523,700.00 as 
part of this scheme.  Id.  
5. 
Pursuant to 18 U.S.C. § 981(a)(1)(C), 28 U.S.C. § 2461(c), and Rule 32.2(b)(2) of 
the Federal Rules of Criminal Procedure, the United States is now entitled to a forfeiture money 
judgment in the amount of $523,700.00 in U.S. currency against the Defendant. 
6. 
Further, the United States may move at any time, pursuant to Rule 32.2(e)(1)(B) of 
the Federal Rules of Criminal Procedure and 21 U.S.C. § 853(p), to forfeit any property of the 
defendant up to the value of the forfeiture money judgment included in the Preliminary Order of 
Forfeiture.  Upon issuance of any order forfeiting specific property, the United States will publish 
notice in accordance with 21 U.S.C. § 853(n)(1) and Rule 32.2(b)(6) of the Federal Rules of 
Criminal Procedure. 
7. 
The United States also seeks permission to conduct any discovery that might be 
necessary to identify, locate, or dispose of forfeited property, pursuant to Rule 32.2(b)(3) of the 
Federal Rules of Criminal Procedure and 21 U.S.C. § 853(m). 
Case 1:25-cr-00270-RDB     Document 21     Filed 01/09/26     Page 2 of 3

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WHEREFORE, the United States requests that this Court: 
(a) 
enter the Preliminary Order of Forfeiture in the form submitted herewith; 
(b) 
include the forfeiture, as set forth in the Preliminary Order of Forfeiture, in the oral 
pronouncement of the Defendant’s sentence;  
(c) 
retain jurisdiction for the purpose of enforcing the forfeiture; and   
(d) 
incorporate the Preliminary Order of Forfeiture in the criminal judgment entered 
against the Defendant, pursuant to Federal Rule of Criminal Procedure 32.2(b)(4). 
 
Respectfully submitted, 
Kelly O. Hayes 
United States Attorney 
 
By: 
/s/              
    
 
Paul E. Budlow 
Assistant United States Attorney 
 
 
 
 
 
Case 1:25-cr-00270-RDB     Document 21     Filed 01/09/26     Page 3 of 3

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