Motion for Preliminary Order of Forfeiture — United States v. Andra Shirone Thompson

Record facts

U.S. District Court for the District of Maryland · No. 8:24-cr-00057-LKG · Doc. 20 · 2025-03-17 · Docket on CourtListener

Summary

The United States' Motion for Preliminary Order of Forfeiture, filed March 17, 2025 as Document 20 in United States v. Andra Shirone Thompson, No. 8:24-cr-00057-LKG, in the U.S. District Court for the District of Maryland. The motion asks the court to enter a preliminary order of forfeiture 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. It states that an Information filed February 26, 2024 charged the defendant with conspiracy in violation of 18 U.S.C. § 371 in Counts One and Two, that he pled guilty on May 2, 2024, and that he agreed to a money judgment of at least $847,280.00. It reports a stipulated total victim loss of approximately $1,113,360.00 from the charged schemes. The motion also seeks discovery and retained jurisdiction to enforce the forfeiture.

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Full text

THE UNITED STATES DISTRICT COURT 
FOR THE DISTRICT OF MARYLAND 
UNITED STATES OF AMERICA 
: 
: 
 
v. 
 :  Criminal No. 24-57-LKG 
:  
ANDRA SHIRONE THOMPSON, 
: 
a/k/a “RICO SERRAS” 
: 
 
 
 :
 
Defendant. 
  : 
: 
******************** 
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 February 26, 2024, the United States of America filed an Information,
charging Andra Shirone Thompson (the “Defendant”) with Conspiracy, in violation of 18 U.S.C. 
§ 371 (Counts One and Two).  ECF 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), 21 U.S.C. 
§ 853(p), and 28 U.S.C. § 2461(c), upon conviction of the Defendant of the offenses alleged in
Counts One and Two of the Information. 
3.
On May 2, 2024, the Defendant pled guilty to the offense alleged in each count of
the Information.  ECF. No. 7.  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 $847,280.00 in U.S. 
Case 8:24-cr-00057-LKG     Document 20     Filed 03/17/25     Page 1 of 3

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currency equal to the value of the property derived from, or otherwise involved in, the 
Defendant’s offense.  Id. ¶¶ 12. 
4.
In support of his guilty plea, the Defendant executed a Stipulation of Facts in
which the Defendant admitted that from at least November 2019 until present, he conspired with 
others in various schemes to defraud. Defendant stipulated she fraudulently applied for one PPP 
and three EIDL loans totaling at $716,575.00 and obtained at least $300,000.00 in EIDL 
benefits. Additionally, Defendant stipulates that he participated in at least three executions of the 
false invoice conspiracy’s scheme.  As part of those three wire fraud executions, defendant and 
his con-conspirators obtained approximately $813,360. Defendant further stipulated that the total 
victim loss from the schemes to defraud was at least approximately $1,113,360.00, of which he 
personally obtained approximately $847,280.00.  ECF 7-1. 
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 $847,280.00 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 8:24-cr-00057-LKG     Document 20     Filed 03/17/25     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/
 
Joseph Werner 
Assistant United States Attorney 
David Peters 
Trial Attorney 
Case 8:24-cr-00057-LKG     Document 20     Filed 03/17/25     Page 3 of 3

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