Proposed Forfeiture Jury Instructions — United States v. Emmet Bowens (Dkt. 205)

Summary

Proposed Forfeiture Jury Instructions filed December 15, 2025 in United States v. Emmet Bowens, Case No. 6:21-cr-141-RBD-NWH, in the U.S. District Court for the Middle District of Florida, Orlando Division (Document 205). The United States requests that, if the defendant is convicted of one or more of the offenses charged in Counts One, Two and Four through Six of the Indictment, and the Court grants a defense request for a jury determination, the instructions be given at a separate forfeiture hearing. The special jury charge describes assets seized from Barclays Bank accounts in the name of Emmet Bowens, in amounts of approximately $250,610.82, $250,668.76 and $115,321.18, and cites 18 U.S.C. § 981(a)(1)(C), 28 U.S.C. § 2461(c) and 18 U.S.C. § 982(a)(1). The signature block names Assistant United States Attorney Nicole M. Andrejko.

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Full text

Case 6:21-cr-00141-RBD-NWH Document 205 Filed 12/15/25 Page 1 of 5 PageID 588

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION

UNITED STATES OF AMERICA

v. Case No. 6:21-cr-141-RBD-NWH

EMMET BOWENS
a/k/a Emmitt Bowens

PROPOSED FORFEITURE JURY INSTRUCTIONS

The United States of America hereby requests that, if the defendant is

convicted of one or more of the offenses charged in Counts One, Two and Four

through Six of the Indictment, and, if the Court grants a request by the defendant for

a jury determination regarding the forfeiture of the specific assets identified in the

Indictment, the following proposed jury instructions be given during the separate

forfeiture hearing following the conviction.

Respectfully Submitted,

GREGORY W. KEHOE
United States Attorney

By: s/Nicole M. Andrejko _
NICOLE M. ANDREJKO
Assistant United States Attorney
Florida Bar No. 0820601
400 West Washington Street, Suite 3100
Orlando, Florida 32801
Telephone: (407) 648-7560
Facsimile: (407) 648-7643
E-Mail: Nicole.Andrejko@usdoj.gov
Case 6:21-cr-00141-RBD-NWH Document 205 Filed 12/15/25 Page 2 of 5 PageID 589

CERTIFICATE OF SERVICE

I hereby certify that on December 15, 2025, I electronically filed the foregoing

with the Clerk of the Court by using the CM/ECF system that will send a notice of

electronic filing to counsel of record.

s/Nicole M. Andrejko___________
NICOLE M. ANDREJKO
Assistant United States Attorney
Case 6:21-cr-00141-RBD-NWH Document 205 Filed 12/15/25 Page 3 of 5 PageID 590

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
ORLANDO DIVISION

UNITED STATES OF AMERICA

v. Case No. 6:21-cr-141-RBD-NWH

EMMET BOWENS
a/k/a Emmitt Bowens

SPECIAL JURY CHARGE

FORFEITURE

Members Of The Jury:

Your verdict in this case does not complete your jury service, as it would in

most cases, because there is another matter you must now consider and decide,

namely, whether there is a nexus between certain assets identified in the Indictment

and the crimes for which the defendant was convicted.

In a section of the Indictment not previously disclosed to you, it is alleged that

certain assets (a) constitute or are derived from proceeds obtained, directly or

indirectly, as a result of the offenses charged in Counts One and/or Two; and/or (b)

are property involved in the money laundering offenses as charged in Counts Four

through Six.

In view of your guilty verdict, you must also decide, under the law I will now

explain to you, whether such asset should be forfeited to the United States.

The term "forfeited" simply means for someone to be divested or deprived of

the ownership of something as a part of the punishment allowed by law for the
Case 6:21-cr-00141-RBD-NWH Document 205 Filed 12/15/25 Page 4 of 5 PageID 591

commission of certain criminal offenses.

In deciding these issues, you should consider all of the evidence you have

already heard during the trial plus the additional evidence that will be presented to

you when I finish giving you these instructions.

A copy of the forfeiture allegations of the Indictment will be given to you to

consider during your supplemental deliberations. It describes in particular the

property allegedly subject to forfeiture to the United States:

a. approximately $250,610.82 seized from Barclays Bank
account number 1300066779467 held in the name of Emmet
Bowens;

b. approximately $250,668.76 seized from Barclays Bank
account number 130006698297 held in the name of Emmet
Bowens; and

c. approximately $115,321.18 seized from Barclays Bank
account number 130006698303 held in the name of Emmet
Bowens.

To be entitled to the forfeiture of any of those items, the Government must

have proved by a preponderance of the evidence:

Option No. One

First: That the property to be forfeited constitutes, or was derived from, the

proceeds the Defendant obtained, directly or indirectly, as the result of committing

the offenses charged in Counts One and/or Two of the Indictment. 1

1
18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c).
Case 6:21-cr-00141-RBD-NWH Document 205 Filed 12/15/25 Page 5 of 5 PageID 592

Option No. Two

That the property to be forfeited was involved in the offenses charged in

Counts Four through Six. 2

A “preponderance of the evidence” simply means an amount of evidence that

is enough to persuade you that a claim or contention is more likely true than not

true.

To be “derived” from something means that the property under consideration

must have been formed or developed out of the original source so as to be directly

descended from that source.

While deliberating concerning the issue of forfeiture you must not reexamine

your previous determination regarding the Defendant’s guilt. But all the instructions

previously given to you concerning your consideration of the evidence, the credibility

of the witnesses, your duty to deliberate together, your duty to base your verdict

solely on the evidence without prejudice, bias, or sympathy, and the necessity of a

unanimous verdict, will continue to apply during these supplemental deliberations.

2
18 U.S.C. § 982(a)(1).

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