Bill of Particulars — No. 1:21-cr-00496 (Dkt. 83, E.D.N.Y.)

Summary

A bill of particulars for forfeiture of property, filed April 7, 2022 as Document 83 in United States v. Orlando Sanay, Keily Nunez, Keimi Nunez, Michael Pimental Veloz and Fanny Plasencia, No. 21-CR-496 (RJD)(MMH), in the U.S. District Court for the Eastern District of New York, filed by Assistant U.S. Attorney Tanisha R. Payne under Fed. R. Crim. P. Rule 7(f). It recalls that the indictment filed on September 22, 2021 gave notice of forfeiture under 18 U.S.C. §§ 981(a)(1)(C), 21 U.S.C. § 853(p) and 28 U.S.C. § 2461(c) in connection with Counts One through Seven. It gives notice of additional property sought, beginning with $39,285.00 in United States currency.

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 Case 1:21-cr-00496-RJD Document 83 Filed 04/07/22 Page 1 of 2 PageID #: 205




BGK:TRP
F. #2021R00254

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF NEW YORK
– – – – – – – – – – – – –X

UNITED STATES OF AMERICA                                       BILL OF PARTICULARS

        - against -                                            21-CR-496 (RJD)(MMH)

ORLANDO SANAY,
KEILY NUNEZ,
KEIMI NUNEZ
MICHAEL PIMENTAL VELOZ
and FANNY PLASENCIA,

                          Defendants.

– – – – – – – – – – – – –X

               The United States of America, by and through BREON PEACE, United States

Attorney for the Eastern District of New York, and Tanisha R. Payne, Assistant United States

Attorney, hereby files the following Bill of Particulars for Forfeiture of Property pursuant to Fed.

R. Crim. P. Rule 7(f).

               The above-captioned Indictment filed on September 22, 2021 provided notice of

the government’s intent to seek forfeiture of property pursuant to Title 18 U.S.C. §§ 981(a)(1)(C),

21 U.S.C. § 853(p) and 28 U.S.C. § 2461(c) in connection with Counts One through Seven of the

Indictment. The United States hereby gives notice to the defendants that the United States is

seeking forfeiture of the following additional property:

               1. Approximately thirty-nine thousand two hundred eighty-five dollars and zero
                  cents ($39,285.00) in United States currency seized on or about June 10, 2021
                  from a residence located on Guy R Brewer Blvd. in Jamaica, New York; and

               2. Approximately three (3) watches seized on or about June 10, 2021 from a
                  residence located on Guy R Brewer Blvd. in Jamaica, New York.
 Case 1:21-cr-00496-RJD Document 83 Filed 04/07/22 Page 2 of 2 PageID #: 206




             The United States reserves the right to supplement or amend this Bill of

      Particulars.

Dated: Brooklyn, New York
       April 7, 2022

                                          BREON PEACE
                                          United States Attorney
                                          Eastern District of New York
                                          271-A Cadman Plaza East
                                          Brooklyn, New York 11201

                                      By: /s/ Tanisha R. Payne
                                           Tanisha R. Payne
                                           Assistant United States Attorney
                                           (718) 254-6358

To: All Counsel of Record (by ECF)




                                          2


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