Superseding Indictment — U.S. v. Carter and McGuire (N.D. Ill.)
Summary
A superseding indictment returned by the Special April 2021 Grand Jury against Robert Carter and Sirreginald McGuire, No. 21 CR 50024, in the U.S. District Court for the Northern District of Illinois, Western Division, charging violations of Title 18, United States Code, Sections 1957, 1343, 1341 and 1028A(a)(1). It alleges that from about June 2020 to March 2021 the defendants submitted fraudulent Pandemic Unemployment Assistance claims to agencies in California, Maryland and Virginia using their own and others' identities, resulting in more than $1,000,000 in benefits paid on debit cards mailed to residences tied to the scheme. Count One charges mail fraud over a debit card mailed on or about June 26, 2020, and later counts charge wire fraud and aggravated identity theft. The forfeiture allegations list watches including a Cartier Santos de Cartier watch.
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Cite this document
“Superseding Indictment — U.S. v. Carter and McGuire (N.D. Ill.).”
Original at www.justice.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-3-21-cr-50024-dkt-doj-n-d-ill-afbfe16657/
, SHA-256 5a0e70b7b3ce8920f3e1526690b5bad19e5cb230ed4d6c688ad9ecdc9e0b34a8.Full text
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
WESTERN DIVISION
UNITED STATES OF AMERICA )
) No. 21 CR 50024
vs. ) Violations: Title 18, United States
) Code, Sections 1957, 1343, 1341 and
ROBERT CARTER and ) 1028A(a)(1)
SIRREGINALD MCGUIRE ) Superseding Indictment
COUNT ONE
The SPECIAL APRIL 2021 GRAND JURY charges:
1. At times material to this superseding indictment:
a. The Social Security Act established the dual program of federal
and state unemployment benefits. Under the Act, each state administered its own
unemployment program through their State Workforce Agency, within the guidelines
of federal law.
b. State unemployment benefits were financed in part by state
payroll taxes, which were held in trust by the United States Department of Treasury’s
Unemployment Trust Fund.
c. The Coronavirus Aid, Relief, and Economic Security Act (“CARES
Act”) expanded states’ ability to provide unemployment insurance for many workers
impacted by the COVID-19 pandemic, including workers who were not ordinarily
eligible for unemployment benefits. One such program, the Federal Pandemic
Unemployment Compensation Program (“FPUC Program”), allowed eligible
individuals who were collecting certain unemployment benefits, including regular
1
unemployment compensation, to receive an additional $600 in federal benefits per
week for weeks of unemployment ending on or before July 31, 2020.
d. The Pandemic Emergency Unemployment Compensation
(“PEUC”) Program allowed those who had exhausted benefits under regular
unemployment compensation or other programs to receive up to 13 weeks of
additional federally funded benefits.
e. The Pandemic Unemployment Assistance (“PUA”) Program
allowed individuals who do not qualify for regular unemployment compensation and
were unable to continue working as a result of COVID-19, such as self-employed
workers and independent contractors, to file for unemployment benefits. PUA
provided up to 39 weeks of benefits to qualifying individuals who were otherwise able
to work and available for work within the meaning of applicable state law, except
that they were unemployed, partially unemployed, or unable or unavailable to work
due to COVID-19 related reasons, as defined in the CARES Act. Unemployment
benefit payments under PUA were retroactive for weeks of unemployment, partial
employment, or inability to work due to COVID-19 reasons starting on or after
January 27, 2020.
f. Residents of California, Maryland and Virginia, or individuals
who resided in another state but worked primarily in California, Maryland, or
Virginia respectively, and who became unemployed through no fault of their own, had
the option of initiating their unemployment claim electronically via the website for
2
the California Employment Development Department, the Maryland Division of
Unemployment Insurance or the Virginia Employment Commission respectively.
g. Unemployment insurance claims filed electronically with the
California Employment Development Department were processed by a server located
in California. For approved claims, the California Employment Development
Department paid the benefits via debit card issued by Bank of America. The debit
cards were mailed to the claimant’s mailing address via United States mail. All
transactions involving a Bank of America debit card issued on behalf of the California
Employment Development Department were processed through servers in Colorado.
h. Unemployment insurance claims filed electronically with the
Maryland Division of Unemployment Insurance were processed by a server located
in Virginia. For approved claims, the claimant had the option of receiving the
benefits through either a direct deposit into a bank account or requesting the benefits
be loaded onto a debit card that was mailed to the claimant’s address via United
States mail. Maryland Division of Unemployment Insurance debit cards were
issued by Bank of America and all transactions involving the Bank of America debit
card were processed through servers in Colorado.
i. Unemployment insurance claims filed electronically with the
Virginia Employment Commission were processed by a server located in Virginia. For
approved claims, the claimant had the option of receiving the benefits through either
a direct deposit into a bank account or requesting the Virginia Employment
3
Commission send a debit card to the claimant’s address via United States mail.
2. Beginning in or about June 2020, and continuing to in or about March
2021, in Homewood and DeKalb, in the Northern District of Illinois, and elsewhere,
ROBERT CARTER and
SIRREGINALD MCGUIRE,
defendants herein, and others known and unknown to the grand jury, knowingly
devised, intended to devise, and participated in a scheme to defraud the California
Employment Development Department, the Maryland Division of Unemployment
Insurance, and the Virginia Employment Commission and to obtain money and
property by means of materially false and fraudulent pretenses, representations, and
promises, which scheme is more fully set out below.
3. It was a part of the scheme that defendants CARTER and MCGUIRE
and others involved in the scheme electronically submitted fraudulent PUA
unemployment insurance claims to the California Employment Development
Department, the Maryland Division of Unemployment Insurance, and the Virginia
Employment Commission, resulting in more than $1,000,000 in unemployment
benefits for claimants who, as defendants knew, were not entitled to unemployment
benefits from the California Employment Development Department, the Maryland
Division of Unemployment Insurance, and the Virginia Employment Commission
respectively.
4. It was further part of the scheme that defendants CARTER and
MCGUIRE and others involved in the scheme used their own names, dates of birth,
4
and social security numbers, and used the names, dates of birth, and social security
numbers of others, in electronically filing fraudulent PUA unemployment insurance
claims with the California Employment Development Department, the Maryland
Division of Unemployment Insurance, and the Virginia Employment Commission for
claimants who, as defendants knew, did not work or live in California, Maryland and
Virginia respectively.
5. It was further part of the scheme that defendants CARTER and
MCGUIRE and others involved in the scheme opted to have the fraudulent
unemployment benefits paid via debit cards that were mailed to residences connected
to defendants and others involved in the scheme, including residences in Homewood
and DeKalb, Illinois, and Hampton, Georgia.
6. It was further part of the scheme that defendants CARTER and
MCGUIRE obtained the debit cards containing unemployment benefits in the names
of claimants who were not entitled to unemployment benefits from the California
Employment Development Department, the Maryland Division of Unemployment
Insurance, and the Virginia Employment Commission and withdrew funds from the
debit cards at financial institutions and automated teller machines located in Illinois.
7. It was further part of the scheme that defendants CARTER and
MCGUIRE misrepresented, concealed, and hid, and caused to be misrepresented,
concealed, and hidden acts done in furtherance of the scheme and the purpose of those
acts.
5
8. On or about June 26, 2020, at DeKalb, in the Northern District of
Illinois, Western Division, and elsewhere,
ROBERT CARTER and
SIRREGINALD MCGUIRE,
defendants herein, for the purpose of executing the scheme, and attempting to do so,
knowingly caused to be delivered by United States mail, according to the direction
thereon an envelope addressed to M.P. in DeKalb, Illinois, which envelope contained
a debit card containing unemployment benefits from the Maryland Division of
Unemployment Insurance;
In violation of Title 18, United States Code, Section 1341
6
COUNT TWO
The SPECIAL APRIL 2021 GRAND JURY further charges:
On or about June 24, 2020, at Homewood, in the Northern District of Illinois,
and elsewhere,
ROBERT CARTER,
defendant herein, knowingly transferred, possessed, and used, without lawful
authority, a means of identification of another person, namely, the name, date of birth
and social security number of M.P., to obtain unemployment insurance benefits from
the Maryland Division of Unemployment Insurance, during and in relation to a
felony, namely, a violation of Title 18, United States Code, Section 1341, as described
in Count One of the superseding indictment;
In violation of Title 18, United States Code, Section 1028A(a)(1).
7
COUNT THREE
The SPECIAL APRIL 2021 GRAND JURY further charges:
On or about June 30, 2020, at DeKalb, in the Northern District of Illinois,
Western Division, and elsewhere,
SIRREGINALD MCGUIRE,
defendant herein, knowingly transferred, possessed, and used, without lawful
authority, a means of identification of another person, namely, a Maryland Division
of Unemployment Insurance unemployment insurance debit card in the name of M.P.,
during and in relation to a felony, namely, a violation of Title 18, United States Code,
Section 1341, as described in Count One of the superseding indictment;
In violation of Title 18, United States Code, Section 1028A(a)(1).
8
COUNT FOUR
The SPECIAL APRIL 2021 GRAND JURY further charges:
On or about July 1, 2020, at Chicago, in the Northern District of Illinois, and
elsewhere,
ROBERT CARTER,
defendant herein, knowingly transferred, possessed, and used, without lawful
authority, a means of identification of another person, namely, a Maryland Division
of Unemployment Insurance unemployment insurance debit card in the name of M.P.,
during and in relation to a felony, namely, a violation of Title 18, United States Code,
Section 1341, as described in Count One of the superseding indictment;
In violation of Title 18, United States Code, Section 1028A(a)(1).
9
COUNT FIVE
The SPECIAL APRIL 2021 GRAND JURY further charges:
1. Paragraphs 1-7 of Count One of this superseding indictment are
incorporated here.
2. On or about June 23, 2020, at Homewood, in the Northern District of
Illinois, and elsewhere,
ROBERT CARTER and
SIRREGINALD MCGUIRE,
defendants herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communication in interstate commerce certain
writings, signs, signals, and sounds, namely, an unemployment insurance claim in
the name of F.M. sent from Homewood, Illinois to the Maryland Division of
Unemployment Insurance, processed through servers located in Virginia;
In violation of Title 18, United States Code, Section 1343.
10
COUNT SIX
The SPECIAL APRIL 2021 GRAND JURY further charges:
On or about June 23, 2020, at Homewood, in the Northern District of Illinois,
and elsewhere,
ROBERT CARTER,
defendant herein, knowingly transferred, possessed, and used, without lawful
authority, a means of identification of another person, namely, the name, date of birth
and social security number of F.M., to obtain unemployment insurance benefits from
the Maryland Division of Unemployment Insurance, during and in relation to a
felony, namely, a violation of Title 18, United States Code, Section 1343, as described
in Count Five of the superseding indictment;
In violation of Title 18, United States Code, Section 1028A(a)(1).
11
COUNT SEVEN
The SPECIAL APRIL 2021 GRAND JURY further charges:
1. Paragraphs 1-7 of Count One of this superseding indictment are
incorporated here.
2. On or about June 20, 2020, at Homewood, in the Northern District of
Illinois, and elsewhere,
ROBERT CARTER,
defendant herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communication in interstate commerce certain
writings, signs, signals, and sounds, namely, an unemployment insurance claim in
the name of R.S., sent from Homewood, Illinois to the Maryland Division of
Unemployment Insurance, processed through servers located in Virginia;
In violation of Title 18, United States Code, Section 1343.
12
COUNT EIGHT
The SPECIAL APRIL 2021 GRAND JURY further charges:
On or about June 20, 2020, at Homewood, in the Northern District of Illinois,
and elsewhere,
ROBERT CARTER,
defendant herein, knowingly transferred, possessed, and used, without lawful
authority, a means of identification of another person, namely, the name, date of birth
and social security number of R.S., to obtain unemployment insurance benefits from
the Maryland Division of Unemployment Insurance, during and in relation to a
felony, namely, a violation of Title 18, United States Code, Section 1343, as described
in Count Seven of the superseding indictment;
In violation of Title 18, United States Code, Section 1028A(a)(1).
13
COUNT NINE
The SPECIAL APRIL 2021 GRAND JURY further charges:
On or about June 29, 2020, at Country Club Hills, in the Northern District of
Illinois, and elsewhere,
ROBERT CARTER,
defendant herein, knowingly transferred, possessed, and used, without lawful
authority, a means of identification of another person, namely, a Maryland Division
of Unemployment Insurance unemployment insurance debit card in the name of R.S.,
during and in relation to a felony, namely, a violation of Title 18, United States Code,
Section 1343, as described in Count Seven of the superseding indictment;
In violation of Title 18, United States Code, Section 1028A(a)(1).
14
COUNT TEN
The SPECIAL APRIL 2021 GRAND JURY further charges:
On or about June 30, 2020, at Tinley Park, in the Northern District of Illinois,
and elsewhere,
ROBERT CARTER,
defendant herein, knowingly transferred, possessed, and used, without lawful
authority, a means of identification of another person, namely, a Maryland Division
of Unemployment Insurance unemployment insurance debit card in the name of R.S.,
during and in relation to a felony, namely, a violation of Title 18, United States Code,
Section 1343, as described in Count Seven of the superseding indictment;
In violation of Title 18, United States Code, Section 1028A(a)(1).
15
COUNT ELEVEN
The SPECIAL APRIL 2021 GRAND JURY further charges:
On or about July 1, 2020, at Country Club Hills, in the Northern District of
Illinois, and elsewhere,
ROBERT CARTER,
defendant herein, knowingly transferred, possessed, and used, without lawful
authority, a means of identification of another person, namely, a Maryland Division
of Unemployment Insurance unemployment insurance debit card in the name of R.S.,
during and in relation to a felony, namely, a violation of Title 18, United States Code,
Section 1343, as described in Count Seven of the superseding indictment;
In violation of Title 18, United States Code, Section 1028A(a)(1).
16
COUNT TWELVE
The SPECIAL APRIL 2021 GRAND JURY further charges:
On or about July 2, 2020, at Chicago, in the Northern District of Illinois, and
elsewhere,
ROBERT CARTER,
defendant herein, knowingly transferred, possessed, and used, without lawful
authority, a means of identification of another person, namely, a Maryland Division
of Unemployment Insurance unemployment insurance debit card in the name of R.S.,
during and in relation to a felony, namely, a violation of Title 18, United States Code,
Section 1343, as described in Count Seven of the superseding indictment;
In violation of Title 18, United States Code, Section 1028A(a)(1).
17
COUNT THIRTEEN
The SPECIAL APRIL 2021 GRAND JURY further charges:
1. Paragraphs 1-7 of Count One of this superseding indictment are
incorporated here.
2. On or about June 18, 2020, at Homewood, in the Northern District of
Illinois, and elsewhere,
ROBERT CARTER,
defendant herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communication in interstate commerce certain
writings, signs, signals, and sounds, namely, an unemployment insurance claim in
the name of defendant ROBERT CARTER, sent from Homewood, Illinois to the
Maryland Division of Unemployment Insurance, processed through servers located
in Virginia;
In violation of Title 18, United States Code, Section 1343.
18
COUNT FOURTEEN
The SPECIAL APRIL 2021 GRAND JURY further charges:
1. Paragraphs 1-7 of Count One of this superseding indictment are
incorporated here.
2. On or about June 19, 2020, at Homewood, in the Northern District of
Illinois, and elsewhere,
ROBERT CARTER and
SIRREGINALD MCGUIRE,
defendants herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communication in interstate commerce certain
writings, signs, signals, and sounds, namely, an unemployment insurance claim in
the name of defendant SIRREGINALD MCGUIRE, sent from Homewood, Illinois to
the Maryland Division of Unemployment Insurance, processed through servers
located in Virginia;
In violation of Title 18, United States Code, Section 1343.
19
COUNT FIFTEEN
The SPECIAL APRIL 2021 GRAND JURY further charges:
1. Paragraphs 1-7 of Count One of this superseding indictment are
incorporated here.
2. On or about June 19, 2020, at Homewood, in the Northern District of
Illinois, and elsewhere,
ROBERT CARTER,
defendant herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communication in interstate commerce certain
writings, signs, signals, and sounds, namely, an unemployment insurance claim in
the name of Q.G., sent from Homewood, Illinois to the Maryland Division of
Unemployment Insurance, processed through servers located in Virginia;
In violation of Title 18, United States Code, Section 1343.
20
COUNT SIXTEEN
The SPECIAL APRIL 2021 GRAND JURY further charges:
1. Paragraphs 1-7 of Count One of this superseding indictment are
incorporated here.
2. On or about July 16, 2020, at DeKalb, in the Northern District of Illinois,
Western Division, and elsewhere,
ROBERT CARTER and
SIRREGINALD MCGUIRE,
defendants herein, for the purpose of executing the scheme, and attempting to do so,
knowingly caused to be delivered by United States mail, according to the direction
thereon an envelope addressed to R.S. in DeKalb, Illinois, which envelope contained
a debit card containing unemployment benefits from the California Employment
Development Department;
In violation of Title 18, United States Code, Section 1341.
21
COUNT SEVENTEEN
The SPECIAL APRIL 2021 GRAND JURY further charges:
On or about July 20, 2020, at DeKalb, in the Northern District of Illinois,
Western Division, and elsewhere,
SIRREGINALD MCGUIRE,
defendant herein, knowingly transferred, possessed, and used, without lawful
authority, a means of identification of another person, namely, a California
Employment Development Department unemployment insurance debit card in the
name of R.S., during and in relation to a felony, namely, a violation of Title 18, United
States Code, Section 1341, as described in Count Sixteen of the superseding
indictment;
In violation of Title 18, United States Code, Section 1028A(a)(1).
22
COUNT EIGHTEEN
The SPECIAL APRIL 2021 GRAND JURY further charges:
On or about August 10, 2020, at Homewood, in the Northern District of Illinois,
and elsewhere,
ROBERT CARTER,
defendant herein, knowingly transferred, possessed, and used, without lawful
authority, a means of identification of another person, namely, a California
Employment Development Department unemployment insurance debit card in the
name of R.S., during and in relation to a felony, namely, a violation of Title 18, United
States Code, Section 1341, as described in Count Sixteen of the superseding
indictment;
In violation of Title 18, United States Code, Section 1028A(a)(1).
23
COUNT NINETEEN
The SPECIAL APRIL 2021 GRAND JURY further charges:
On or about August 11, 2020, at Olympia Fields, in the Northern District of
Illinois, and elsewhere,
ROBERT CARTER,
defendant herein, knowingly transferred, possessed, and used, without lawful
authority, a means of identification of another person, namely, a California
Employment Development Department unemployment insurance debit card in the
name of R.S., during and in relation to a felony, namely, a violation of Title 18, United
States Code, Section 1341, as described in Count Sixteen of the superseding
indictment;
In violation of Title 18, United States Code, Section 1028A(a)(1).
24
COUNT TWENTY
The SPECIAL APRIL 2021 GRAND JURY further charges:
1. Paragraphs 1-7 of Count One of this superseding indictment are
incorporated here.
2. On or about July 6, 2020, at Homewood, in the Northern District of
Illinois, and elsewhere,
ROBERT CARTER,
defendant herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communication in interstate commerce certain
writings, signs, signals, and sounds, namely, an unemployment insurance claim in
the name of defendant ROBERT CARTER, sent from Homewood, Illinois to the
California Employment Development Department, processed through servers located
in California;
In violation of Title 18, United States Code, Section 1343.
25
COUNT TWENTY-ONE
The SPECIAL APRIL 2021 GRAND JURY further charges:
1. Paragraphs 1-7 of Count One of this superseding indictment are
incorporated here.
2. On or about July 8, 2020, at DeKalb, in the Northern District of Illinois,
Western Division, and elsewhere,
SIRREGINALD MCGUIRE,
defendant herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communication in interstate commerce certain
writings, signs, signals, and sounds, namely, an unemployment insurance claim in
the name of defendant SIRREGINALD MCGUIRE, sent from DeKalb, Illinois to the
California Employment Development Department, processed through servers located
in California;
In violation of Title 18, United States Code, Section 1343.
26
COUNT TWENTY-TWO
The SPECIAL APRIL 2021 GRAND JURY further charges:
1. Paragraphs 1-7 of Count One of this superseding indictment are
incorporated here.
2. On or about June 19, 2020, at Homewood, in the Northern District of
Illinois, and elsewhere,
ROBERT CARTER,
defendant herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communication in interstate commerce certain
writings, signs, signals, and sounds, namely, an unemployment insurance claim in
the name of defendant ROBERT CARTER, sent from Homewood, Illinois to the
Virginia Employment Commission, processed through servers located in Virginia;
In violation of Title 18, United States Code, Section 1343.
27
COUNT TWENTY-THREE
The SPECIAL APRIL 2021 GRAND JURY further charges:
1. Paragraphs 1-7 of Count One of this superseding indictment are
incorporated here.
2. On or about July 14, 2020, at Homewood, in the Northern District of
Illinois, and elsewhere,
ROBERT CARTER and
SIRREGINALD MCGUIRE,
defendants herein, for the purpose of executing the scheme, knowingly caused to be
transmitted by means of wire communication in interstate commerce certain
writings, signs, signals, and sounds, namely, an unemployment insurance claim in
the name of defendant SIRREGINALD MCGUIRE, sent from Homewood, Illinois to
the Virginia Employment Commission, processed through servers located in Virginia;
In violation of Title 18, United States Code, Section 1343.
28
COUNT TWENTY-FOUR
The SPECIAL APRIL 2021 GRAND JURY further charges:
On or about August 14, 2020, at Chicago, in the Northern District of Illinois,
ROBERT CARTER,
defendant herein, did knowingly engage in a monetary transaction in and affecting
interstate commerce in criminally derived property of a value greater than $10,000,
namely, the purchase of a Cartier watch for $34,287.75 in United States currency,
such property having been derived from a specified unlawful activity, namely, wire
fraud and mail fraud;
In violation of Title 18, United States Code, Section 1957.
29
FIRST FORFEITURE ALLEGATION
The SPECIAL APRIL 2021 GRAND JURY further alleges:
1. Upon conviction of an offense in violation of Title 18, United States Code,
Sections 1341 and 1343, as set forth in this superseding indictment, defendants
ROBERT CARTER and SIRREGINALD MCGUIRE shall forfeit to the United States
of America any property which constitutes and is derived from proceeds traceable to
the offense, as provided in Title 18, United States Code, Section 981(a)(1)(C) and Title
28, United States Code, Section 2461(c).
2. The property to be forfeited includes, but is not limited to:
a. a personal money judgment in the amount of approximately
$500,187.07.
b. a Cartier Santos de Cartier watch with serial number
410910845ZX;
c. an Audemars Piguet AP two-tone watch;
d. a 14 karat white-gold Cuban bracelet;
e. a 14 karat rose gold and diamond ring;
f. a 14 karat white gold and diamond pendant;
g. a 10 karat rose gold baguette and round diamond ring;
h. a 14 karat rose gold diamond panther head ring;
i. a 10 karat rose gold and diamond star ring;
j. a 10 karat rose gold and diamond ring Mercedes logo;
30
k. a 10 karat rose gold and diamond eternity ring;
l. a 10 karat rose gold and diamond cluster ring;
m. a 14 karat yellow gold cluster earring;
n. a 10 karat yellow gold diamond “R” initial pendant;
o. a 10 karat gold diamond “peach” pendant;
p. a 10 karat yellow gold and rose gold chains;
r. a 10 karat white gold diamond Cuban link bracelet;
s. a 10 karat white/rose gold diamond Cuban link necklace;
t. a 10 karat white gold diamond “Mercedes” pendant;
u. an AP Royal Oak offshore diamond watch; and
v. a Gucci watch.
3. If any of the property described above, as a result of any act or omission
by defendant cannot: be located upon the exercise of due diligence; has been
transferred to, sold to, or deposited with a third person; has been placed beyond the
jurisdiction of the court; has been substantially diminished in value; or has been
commingled with other property that cannot be subdivided without difficulty; the
United States of America shall be entitled to forfeiture of substitute property as
provided in Title 21, United States Code, Section 853(p).
31
SECOND FORFEITURE ALLEGATION
The SPECIAL APRIL 2021 GRAND JURY further alleges:
1. Upon conviction of an offense in violation of Title 18, United States Code,
Section 1957, as set forth in this superseding indictment, defendant ROBERT
CARTER shall forfeit to the United States of America any property involved in such
offense, and any property traceable to such property, as provided Title 18, United
States Code, Section 982(a)(1).
2. The property to be forfeited includes, but is not limited to, a Cartier
Santos de Cartier watch with serial number 410910845ZX.
3. If any of the property described above, as a result of any act or omission
by defendant cannot: be located upon the exercise of due diligence; has been
transferred to, sold to, or deposited with a third person; has been placed beyond the
jurisdiction of the court; has been substantially diminished in value; or has been
commingled with other property that cannot be subdivided without difficulty; the
United States of America shall be entitled to forfeiture of substitute property as
provided in Title 21, United States Code, Section 853(p) and Title 18, United States
Code, Section 982(b)(2).
A TRUE BILL:
____________________________
FOREPERSON
UNITED STATES ATTORNEY
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