Consent judgment and order of forfeiture, United States v. William Ingram, D.N.J. No. 1:23-cr-00537 (Dkt. 6, filed July 5, 2023)

Summary

A Consent Judgment and Order of Forfeiture (Money Judgment) and Preliminary Order of Forfeiture as to Specific Property in United States v. William Ingram, Crim. No. 23-537-KMW. It was filed in the U.S. District Court for the District of New Jersey on July 5, 2023 as Document 6. It recites that the defendant pleaded guilty to an Information charging bank fraud conspiracy, contrary to 18 U.S.C. § 1344, in violation of 18 U.S.C. § 1349, and agreed to forfeit proceeds that the defendant agreed had a value of $551,600.00. The defendant consents to the Money Judgment and to forfeit the Specific Property listed in Exhibit A, which lists the contents of accounts at KeyBank and Wells Fargo in the names of King of Aces Barbershop LLC, Leader of the Pack Productions LLC and East Coast Commercial Investment LLC.

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Case 1:23-cr-00537-KMW Document6 - Filed 07/05/23 Page 1 of 8 PagelD: 33

2023R00437 /DAF/JMR/jw

UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY

UNITED STATES OF AMERICA : Hon.
Vv. : Crim. No. 23-537-KMW
WILLIAM INGRAM, : CONSENT JUDGMENT
AND ORDER OF FORFEITURE
Defendant. : (MONEY JUDGMENT) AND
PRELIMINARY ORDER OF
FORFEITURE AS TO

SPECIFIC PROPERTY (FINAL AS
TO THE DEFENDANT)

WHEREAS, on\4idn 2 2 “Ydefendant William Ingram (the “defendant”)
pleaded guilty, purs! | bh a plea agreement with the United States, to a one-
count Information (the “Information”), which charged him with bank fraud
conspiracy, contrary to 18 U.S.C. § 1344, in violation of 18 U.S.C. § 1349. In
the plea agreement, the defendant agreed to forfeit, pursuant to 18 U.S.C. §
982(a)(2)(A), any property, real or personal, constituting, or derived from,
proceeds the defendant obtained directly or indirectly as a result of the
commission of the conspiracy offense charged in the Information, which the
defendant agreed had a value of $551,600.00. In the plea agreement, the
defendant further acknowledged that one or more of the conditions set forth in
21 U.S.C. § 853(p) exists, and that the United States is therefore entitled to

forfeit substitute assets in an amount not to exceed $551,600.00 (the “Money

Judgment”);
Case 1:23-cr-00537-KMW Document6 - Filed 07/05/23 Page 2 of 8 PagelD: 34

WHEREAS, in the plea agreement, the defendant further agreed to forfeit
all of his right, title, and interest in the specific property set forth in Exhibit A
hereto (the “Specific Property”), which the defendant admits has the requisite
nexus to the bank fraud conspiracy offense charged in the Information and
therefore is forfeitable to the United States of America pursuant to 18 U.S.C. §
982(a)(2). Any forfeited money and the net proceeds derived from the sale of
forfeited specific property will be applied to the Money Judgment, in partial
satisfaction thereof;

WHEREAS, Rule 32.2(c){1) of the Federal Rules of Criminal Procedure
provides that no ancillary proceeding is required to the extent that the
forfeiture consists of a money judgment;

WHEREAS, the provisions of 21 U.S.C. § 853(n) (as incorporated by 18
U.S.C. § 982(b)(1)) require publication and notice to third parties known to
have alleged an interest in forfeited specific property and the disposition of any
petitions filed under 21 U.S.C. § 853(n) before the United States may have clear
title to such property; and

WHEREAS, defendant William Ingram:

(1) Consents to the entry of the Money Judgment, pursuant to
18 U.S.C. § 982(a)(2)(A);
(2) Agrees to forfeit to the United States all of his right, title, and

interest in the Specific Property;
Case 1:23-cr-00537-KMW Document6- Filed 07/05/23 Page 3 of 8 PagelD: 35

(3) Agrees to consent promptly upon request to the entry of any
orders deemed necessary by the government or the Court to complete the
forfeiture and disposition of property forfeited to satisfy the Money Judgment;

(4) Waives the requirements of Federal Rules of Criminal
Procedure 32.2 and 43({a) regarding notice of forfeiture in the charging
instrument, announcement of the forfeiture in the defendant’s presence at
sentencing, and incorporation of the forfeiture in the Judgment of Conviction;

(5) Acknowledges that he understands that forfeiture of property
will be part of the sentence imposed upon him in this case and waives any
failure by the Court to advise him of this, pursuant to Federal Rule of Criminal
Procedure 11(b)(1)(J), during the plea hearing; and

(6) Waives any and all claims that this forfeiture constitutes an
excessive fine and agrees that this forfeiture does not violate the Eighth
Amendment.

Having considered the plea agreement, the record as a whole, and the
applicable law, it is hereby ORDERED, ADJUDGED, AND DECREED AS
FOLLOWS:

1. All property, real or personal, which constitutes or is derived from
proceeds the defendant obtained traceable to the bank fraud conspiracy offense
charged in the Information, to which the defendant has pleaded guilty, is

forfeited to the United States, pursuant to 18 U.S.C. § 982(a)(2)(A).
Case 1:23-cr-00537-KMW Document6 Filed 07/05/23 Page 4 of 8 PagelD: 36

2. The defendant having conceded that one or more of the criteria set

forth in 21 U.S.C. § 853(p) are met, the United States is entitled to forfeit
proceeds and/or substitute assets equal to the value of the proceeds obtained
by the defendant, which was $551,600.00. A money judgment in the amount
of $551,600.00 is hereby entered against the defendant (the “Money
Judgment”), pursuant to 18 U.S.C. § 982(a)(2}(A), 21 U.S.C. § 853(p), and
Federal Rule of Criminal Procedure 32.2(b).

3. All payments on the Money Judgment shall be made by (i)
electronic funds transfer, as directed by the United States Attorney’s Office; or
(ii) postal money order, bank or certified check, made payable, in this instance
to the United States Marshals Service, and delivered to the United States
Attorney’s Office, District of New Jersey, Attn: Asset Forfeiture and Money
Laundering Unit, 970 Broad Street, 7th Floor, Newark, New Jersey 07102, and
shall indicate the defendant’s name and case number on the face of the check.

4. Until the defendant is sentenced, the United States Marshals
Service shall deposit all payments on the Money Judgment in its Seized Assets
Deposit Account. After the defendant is sentenced and the Judgment is
entered on the docket, all payments on the Money Judgment shall be forfeited
to the United States of America as substitute assets, pursuant to 21 U.S.C.

§ 853(p), and shall be deposited in the Assets Forfeiture Fund.

Specific Property

5. As a further result of the defendant’s conviction of the bank fraud

conspiracy offense charged in the Information, and pursuant to 18 U.S.C.

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Case 1:23-cr-00537-KMW Document6- Filed 07/05/23 Page 5 of 8 PagelD: 37

§ 982(a)(2) and Fed. R. Crim. P. 32.2(b}(1) and (b)(2), all of the defendant’s
right, title, and interest in the Specific Property is hereby forfeited to the United
States of America for disposition according to law, subject to the provisions of
21 U.S.C. § 853.

6, Pursuant to Rule 32.2(b)(3) of the Federal Rules of Criminal
Procedure, the United States Marshals Service, its agent or designee shall
maintain or take possession of the Specific Property and hold such property in
its secure custody and control.

7. Pursuant to 21 U.S.C. § 853(n)(1) and Rule 32.2(b}(6) of the
Federal Rules of Criminal Procedure, the United States shall publish notice of
this Order for at least 30 consecutive days on the government internet site
www.forfeiture.gov. The United States shall also send notice of this Order to
any person who reasonably appears to be a potential claimant with standing to
contest the forfeiture in the ancillary proceeding.

8. Pursuant to Fed R. Crim. P. 32.2(b)(6) and 21 U.S.C. § 853(n}(2)
and (n)(3), the notice of forfeiture must describe the forfeited property with
reasonable particularity, state the times by which a petition contesting the
forfeiture must be filed, and state the name and contact information for the
government attorney to be served with the petition. The notice shall also state
that the petition (i) shall be for a hearing to adjudicate the validity of the
petitioner's alleged interest in the Specific Property, (ii) shall be signed by the
petitioner under penalty of perjury, and (iii) shall set forth the nature and

extent of the petitioner's right, title, or interest in the Specific Property, the

_5-
Case 1:23-cr-00537-KMW Document6 Filed 07/05/23 Page 6 of 8 PagelD: 38

time and circumstances of the petitioner's acquisition of the right, title, and
interest in the Specific Property, any additional facts supporting the petitioner's
claim, and the relief sought.

9. Any person, other than the defendant, claiming interest in the
Specific Property must file a petition within 60 days from the first day of
publication of notice on the government internet site, or no later than 35 days
from the mailing of direct notice, whichever is earlier, pursuant to Rule
32.2(b)(6) of the Federal Rules of Criminal Procedure and Rule G(4) and G(5) of
the Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture
Actions.

10. Upon adjudication of all third-party interests, the Court will enter
a final order of forfeiture pursuant to 21 U.S.C. § 853(n)(7) and Fed. R. Crim.
P. 32.2(c)(2), in which all interests will be addressed.

Other Provisions

11. Pursuant to Rule 32.2(b)(4) of the Federal Rules of Criminal
Procedure, this Order of Forfeiture shall be final against the defendant, shall be
made part of the sentence of defendant, and shall be included in the judgment
of conviction therewith.

12. Any forfeited money and the net proceeds derived from the sale of
forfeited specific property will be applied to the Money Judgment, in partial
satisfaction thereof.

13. Pursuant to Federal Rule of Criminal Procedure 32.2(b)(3) and 21

U.S.C. § 853(n), upon entry of this Order, and until the Money Judgment is fully

-6-
Case 1:23-cr-00537-KMW Document6- Filed 07/05/23 Page 7 of 8 PagelD: 39

satisfied, the United States Attorney’s Office is authorized to conduct any
discovery needed to identify, locate, or dispose of assets to satisfy the Money
Judgment, or in connection with any petitions filed pursuant to 21 U.S.C.

§ 853(n), including depositions, interrogatories, requests for production of
documents, and the issuance of subpoenas.

14. The Clerk of the Court is directed to enter a criminal forfeiture
money judgment against the defendant in favor of the United States in the
amount of $551,600.00.

15. This Court shall retain jurisdiction to enforce this Order and to
amend it aS necessary.

Aw
ORDERED this /)' day “7 oy , 2023.
Y ©

HON. KAREN M. WILLIAMS

The undersigned hereby consent to
the form and entry of this Order:

PHILIP R. SELLINGER
United States Attorne

Qala fs ’ Dated: June 15, 2023

By: DANIEL A. FRIEDMAN
JASON M. RICHARDSON
Assistant United States Attorneys

MARIO PERSIANO, ESQ.
Attorney for Defendant William Ingram

VE ean Dated: {0° 49-205

WILLIAM INGRAM, Defendant
Case 1:23-cr-00537-KMW Document6 - Filed 07/05/23 Page 8 of 8 PagelD: 40

Exhibit A
¢ The contents of an account at KeyBank ending in -1628 in the name
of King of Aces Barbershop LLC.

¢ The contents of an account at KeyBank ending in -1586 in the name
of Leader of the Pack Productions LLC.

e The contents of an account at KeyBank ending in -1610 in the name
of East Coast Commercial Investment LLC,

¢ The contents of an account at Wells Fargo ending in -6018 in the
name of King of Aces Barbershop LLC.


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