Indictment — United States v. Diarra Williams and Nicholas Warford (Dkt. 2, E.D. Mo.)

Summary

A federal grand jury in the Eastern District of Missouri indicted Diarra Williams and Nicholas Warford, a married couple, on charges of wire fraud conspiracy, wire fraud (Counts Two through Eight), money laundering conspiracy and obstruction of an official proceeding. The indictment alleges that through their nonprofit, The Bailey Foundation, the couple defrauded the State of Missouri of more than seven million dollars in federally funded meal money meant for low-income children by claiming meals that were never served. It says Williams sent over $6 million in state meal funds to Warford's Classic Catering LLC, which the couple controlled, and covered the payments with phony invoices. The indictment lists a $1.44 million residence in Edwardsville, vehicles, vacations and $460,320.00 paid to Warford's mother among the uses of the money, and seeks forfeiture of the house and vehicles.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

FILED
UNITED STATES DISTRJCT COURT FEB 2 2025
EASTERN DISTRICT OF MISSOURI
U.S. DIS
EASTERN DIVISION EA li;t DI 0
ST.

UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
V. ) No .
)
)
DIARRA WILLIAMS, and
NICHOLAS WARFORD,
)
)
4:25CR93-HEA!RHH
)
Defendants. )

INDICTMENT

The Grand Jury charges that, at all times material to this Indictment, unless otherwise

specified below:

INTRODUCTION

1. During their crimes outlined below, Defendant Diarra Williams and Defendant

Nicholas Warford defrauded the State of Missouri out of more than seven million dollars in

taxpayer funds that were supposed to be spent on feeding low-income children. In committing

their crimes, Defendant Williams and Defendant Warford laundered millions of dollars that they

received from the State of Missouri so that they could pay for extravagant vacations, luxury

vehicles, and a $1.44 million residence for themselves.

2. • Defendant Williams and Defendant Warford are married to each other, and they

executed the scheme to defraud through their operation of a non-profit organization called The

Bailey Foundation ("T.B.F."), which was located in the Eastern District of Missouri. As the owner

of T.B.F., Defendant Williams ran her purported charity ' s day-to -day operations. Defendant
Warford-along with his wife-incorporated T.B.F. , and Defendant Warford helped Defendant

Williams defraud the State of Missouri through their operation of T.B.F.

3. Defendant Warfare! also owned a company called Warford' s Classic Catering LLC

(" W.C.C.") that he and Defendant Williams used to launder millions of dollars in fraudulently

obtained state meal funds . As the only two signors on the W.C.C. bank account (Midwest

BankCentre account ending in 5875), Defendant Warford and Defendant Williams controlled the

finances ofW.C.C. To launder the fraudulently obtained money that T.B.F. received to feed low-

income children, Defendants paid those funds to W.C.C. and created phony invoices to make it

appear as though the funds were spent on children ' s meals . In reality , Defendant Williams and

Defendant Warford used the vast majority of the state ' s dollars to fund their own personal

expenses.

T.B.F. 's Participation in Missouri's Food and Nutrition Programs for Children

4. The State of Missouri, through its .Department of Health and Senior Services

("Missouri DHSS"), administered food and nutrition programs designed to provide nutritious

meals to low-income Missouri children. To fulfill the mission of feeding low-income Missouri

children, Missouri DHSS administered two programs: (1) the At-Risk, Afterschool Child Food

Program , and (2) the Summer Food Service Program (collectively "Missouri ' s Food and Nutrition

Programs for Children" ). Both programs are funded by the United States Department of

Agriculture. Missouri's Food and Nutrition Programs for Children provided funds for meals served

to low-income, school-age students after school and during the summer, when school was not in

session. The meals were served by schools and community-based, nonprofit organizations at

hundreds of locations throughout Missouri.

2
5. Through Missouri ' s Food and Nutrition Programs for Children , Missouri DHSS

paid reimbursements to nonprofits that provided qualifying meals to low-income children in

Missouri . To qualify for those state meal reimbursements, nonprofits-like T.B.F. -had to

truthfully represent in their reimbursement claims that qualifying meals were provided to low-

income Missouri children. For a meal to be reimbursable under both programs, the meal had to

include several specific items, including an eight-ounce serving of fluid , white milk, a meat, a

vegetable, a fruit, and a grain .

6. As another requirement to receive reimbursements from Missouri ' s Food and

Nutrition Programs for Children, T.B.F. had to agree to use state meal reimbursement funds only

in connection with the nonprofit's provision of meals to low-income children . To obtain state meal

reimbursement dollars, Defendant Williams, on behalf of T.B.F. , agreed that all "reimbursement

funds ... [would be] used solely for the conduct of the food service operation, orto improve the

food service operation , principally for the benefit of enrolled [children]."

7. For a nonprofit to continue receiving state meal reimbursement dollars, the

nonprofit also had to submit annual_management plans. In each required annual management plan,

the nonprofit had to answer several questions designed to ensure that state meal reimbursement

dollars were spent only in connection with the provision of meals to low-income children. For

example, T.B.F. had to answer whether .the organization "purchase[s] supplies, equipment,

furniture, or other items with an aggregate purchase cost over $5000 in a one-year period ?" In

addition, T.B.F. had to detail for Missouri DHSS all of the equipment that was purchased with

more than $5 ,000 in meal reimbursement funds every year. To continue receiving state meal

reimbursement dollars, Defendant Williams represented to the State of Missouri that T.B.F. did

not purchase any items over $5 ,000.

3
8. In the annual management plan , T.B.F. also had to answer the following question:

"How will you ensure that all operational and administrative co sts incurred are allowable and

accurately reflect the operation of the program ? (All costs must be included in your budget.)" To

continue receiving state meal reimbursement dollars, Defendant Williams answered this question

by representing to the State of Missouri that " all costs are accurately and directly related to the

efficient operation of the program[.]"

COUNT ONE
(Wire Fraud Conspiracy: 18 U.S.C. § 1349)

9. Each of the above allegations is hereby incorporated by reference as if fully set

forth herein .

10. Beginning in or about November 2018, and continuing through at least in or about

February 2025 , in the Eastern District of Missouri and elsewhere, the defendants,

DIARRA WILLIAMS and
NICHOLAS WARFORD,

voluntarily and intentionally combined, conspired , confederated, and agreed with ea.ch other and

others known and unknown to the Grand Jury, to committhe following offense against the United

States :

(a) Having devised and intended to devise a scheme and artifice to defraud and obtain

money and property by means of materially false and fraudulent pretenses and

representations and for the purpose of executing such scheme, and attempting to do

so , did knowingly cause and attempt to cause to be transmitted by means of wire

communication in interstate commerce, writings, signs, and signals in the form of

interstate electronic communications, in violation of Title 18, United States Code,

Section 1343.

4
All in violation of Title 18, United States Code , Section 1349.

Manner and Means of the Scheme and the Conspiracy

13. The primary purpose of the conspiracy was to execute a wire fraud scheme and

artifice to defraud and obtain money , specifically, public funds from Missouri DHSS, by means of

materially false and fraudulent pretenses, representations, and promises. The conspiracy was

carried out by Defendants in the following manner:

I. Defendant Williams and Defendant Warford Defrauded the State of Missouri-and
Enriched Themselves-Through the Submission of Fraudulent Meal Reimbursement
Claims for Millions of Meals that T.B.F. Never Served.

14. Between in or about March 2020 and in or about July 2022, Defendant Williams-

on behalf of T.B.F. and within the Eastern District of Missouri- submitted false and fraudulent

meal reimbursement claims to Missouri DHSS. Defendant Williams submitted these false and

fraudu lent meal reimbursement claims so that she and Defendant Warford could take millions of

dollars from Missouri' s Food and Nutrition Programs for Ch ildren that they were not entitled to

receive .

15. In furtherance of the fraud scheme , Defendant Williams submitted fraudulent meal

reimbursement claims to Missouri DHSS for millions of meals that T.B.F. never served. Through

her fraudulent reimbursement claims, Defendant Williams falsely represented that T.B.F. served a

total of 2,237 ,337 reimbursablemeals to low-income Missouri children. In truth and fact, however,

neither the Defendants, nor any of their entities, ever purchased enough food and milk to serve

more than approximately one-third of the meals for which they were paid. Based on Defendant

Williams ' material misrepresentations in her fraudulent meal reimbursement claims, Missouri

DHSS paid out nearly five million dollars that Defendants were not entitled to receive.

5
II. Defendant Williams and Defendant Warford Attempted to Conceal Their Scheme to
Defraud the State of Missouri.

16. During their scheme to defraud the State of Missouri out of millions of dollars that

Defendants had agreed to spend on feeding children , Defendant Williams and Defendant Warford

attempted to conceal their scheme by sending mill ions of dollars in state meal reimbursement funds

to W.C.C., creating phony W.C.C. invoices reflecting reimbursable meal purchases that were never

made, and making false representations to Missouri DHSS about their use of the state meal funds.

A. To Make it Appear as Though T.B.F. Purchased Meals When it Did Not,
Defendants Sent Millions of Dollars in Public Funds to W.C.C. and Created
Phony W.C.C. Invoices Reflecting Meal Purchases That Were Never Made.

17. In working together to conceal the fraudulent reimbursement claims for millions of

meals that T.B .F. never served, Defendant Williams and Defendant ~arford created a false paper

trail, making it appear as though T.B.F. purchased reimbursable meals from W.C.C. when it did

not. To create the false record of fake meal purchases, Defendant Williams regularly sent payments

from her T.B.F. bank account (Midwest BankCentre bank account ending in 5927) to the W.C.C.

bank account (Midwest BankCentre account ending in 5875) that she controlled along with

Defendant Warford. In truth and fact, Defendant Williams made those payments- not only to

reimburse W.C.C. ' s minimal food purchases-butto allow herselfand Defendant Warford to use

public funds for their own personal expenses.

18. To further conceal Defendant Williams ' fraudulent reimbursement claims for meals

that T.B .F. never served , Defendants created phony monthly invoices for W.C.C. reflecting

purchases of reimbursable meals that were never made . For example, Defendants created a phony

W .C.C. monthly invoice for April 2021 , which falsely represented that W .C,.C. delivered to T.B.F

208 ,456 reimbursable meals, with each meal including an eight-ounce serving of milk. In reality,

6
however, W.C.C. paid less than $5,000 on food and did not purchase a single eight-oun ce serving

of milk durin g April 202 1.

19. Also as part of their scheme, Defendant Warford emailed many of the phony

W.C .C. in voices to Defendant William s in a further attempt to create a false paper trail of meal

purchases that were neve r made by T.B.F. To further conceal their fraud , Defe nd ant Williams and

Defendant Warford produced p hony W.C.C. invoices in response to federal grand jury su bpoenas.

B. Defendant Williams and Defendant Warford Attempted to Conceal Their
Improper Use of Public Funds.

20. To obtain state meal reimbursement dollars, Defendant Williams falsely

represented to Missouri DHSS that T.B.F. ' s " reimbursement funds . .. [would be] used so lely for

the condu ct of the food service operation, or to improve the food service operation, principally for

the benefit of enrolled [children] ." In truth and fact, however, Defendant Williams provided over

$6 million in state meal funds to W.C.C. so that she and Defendant Warford could use state meal

funds for their own perso nal expenses. In doing so , Defendant Williams and Defendant Warford

used the public funds- that they promised to spend on feeding low-income ch ildren-on the

fo llowing personal residence and vehicles for themselves.

Purchase Property Purchased Amount Paid .
Da~ -
' .
3/27/2021 Personal vehicle of Defendant Williams, 2018 Linco ln $63 ,236.54
Navi ator VIN: 5LMJJ2LT2JEL02437
6/9/2021 Personal res idence of Defendant Williams and Defendant $ 1,449 ,000.00
Warford, located at 8416 Rockrid e, Edwardsvi lle, IL 62025
l l /9/2021 Personal ve hicle of Defendant Warford, 2019 Ram 1500 $38 ,531 .36
Rebel (VIN: 1C6SRFLT5KN784521)
2/l l /2022 Personal ve hicle of Defendant Williams, 2017 Chrys ler $ 11 ,879.94
Pacifica VIN: 2C4RC1GG3HR811929

7
21. To further conceal Defendants ' use of public meal dollars to purchase themselves

a $1.44 million residence, Defendant Warford wired the purchase price of the home from

Defendants ' W.C.C. bank account (Midwest BankCentre account end in g in 5875) to his own

personal checkingaccount(Navy Federal Credit Union bankaccountnumberending in 0939), and

then to First American Title-all within 24 hours of Defendants ' home purchase.

22. To further disguise Defendants ' improper, personal use of public funds , Defendant

Warford falsely represented to the Internal Revenue Service that Defendants ' $ 1.44 million home

purchase, their 20 18 Lincoln Navigator purchase, their 2019 Ram purchase, and their 2017

Chrysler Pacifica purchase were all business expenses of W.C.C.

23. Defendant Williams and Defendant Warford also used state meal funds- that

Defendant Williams sent from T.B.F. to W.C.C. -to spend over $140,000 on extravagant

vacations-for themselves, to pay over $100,000 on furniture, home electronics, and land scaping

for their new residence (that was also purchased with state meal dollars), and to fund more than

$50,000 in tuition payments fortheirchildren ' s school. On top of the millions in public meal funds

that Defendants spent on themselves, Defendant Williams and Defendant Warford also provided

Defendant Warford' s mother with $460 ,320.00 in funds thatthey promised to spend on feeding

low-income children. To disguise this improper use of public funds , Defendant Warford falsely

represented to the Internal Revenue Service that public meal fund payments to his mother were

business expenses of W.C.C.

24. In addition , Defendant Williams submitted to Missouri DHSS annual T.B.F.

budgets and management plans, which included false and fraudulent representations designed to

conceal Defendants ' improper use of public meal funds. For example, in T.B.F.' s ann ual

management plan that Defendant Williams submitted on or about April 5, 202 1, Defendant

8
Williams falsely and fraudulently represented that T.B.F. did not purchase any items over $5,000.

But just four months prior, on or about December 22 , 2020 , Defendant Warford used $16,000.00

in T.B.F. ' s meal reimbursement dollars- that were supposed to be spent on feeding children-to

purchase a 2011 Mercedes Benz Sprinter (VIN: WD3PE7CC0B5602167). In that same

management plan , Defendant Williams falsely and fraudulently represented to the State of

Missouri, on behalf of T.B.F., that "a ll costs are accurately and directly related to the efficient

operation of the program[.]" Yet, in truth and fact, Defendant Williams and Defendant Warford

spent the vast majority of the meal reimbursement funds received by T.B.F. on their own personal

expenses.

25. Based on the material misrepresentations that Defendant Williams made to

Missouri DHSS throughout the scheme to defraud , Missouri DHSS paid Defendants more than

seven million dollars in public funds .

COUNTS TWO - EIGHT
(Wire Fraud: 18 U.S.C. §§ 1343 and 2)

26. Each of the allegations included in this Indictment is hereby incorporated by

reference as if fully set forth herein .

27. Beginning by at least on or about November 28 , 2018, and continuing through at

least on or about February 28, 2024, in the Eastern District of Missouri, and elsewhere, the

defendants,

DIARRA WILLIAMS and
NICHOLAS WARFORD,

with the intentto defraud , devised and intended to devise a scheme and artifice to defraud Missouri

DHSS and to obtain money and property from Misso uri DHSS by means of material false and

fraudulent pretenses, representations, and promises, as described further herein.

9
28. On or about the dates set forth below, within the Eastern District of Missouri, for

the purpose of executing the above-described scheme and artifice to defraud and obtain money

and property by means of false and fraudulent pretenses, representations and promises and for the

purpose of executing the same , Defendants did knowingly transmit and cause to be transmitted by

means of wire communication in and affecting interstate commerce, certain writings, signs,

signals, pictures, or sounds, to wit:

I Count Date .- WJr~ Dcscriptio!}
2 1/15/2021 The State of Missouri's payment of $512,276.94 in meal reimbursement
funds to T.B.F.'s bank account
3 2/19/2021 The State of Missouri ' s payment of $565,745.19 in meal reimbursement
funds to T.B.F.'s bank account
4 3/18/2021 The State of Missouri ' s payment of $624,537.16 in meal reimbursement
funds to T.B.F. ' s bank account
5 4/5/2021 Defendant Williams ' email to Missouri DHSS containing an annual
management plan
6 4/16/2021 The State of Missouri 's payment of $790,342.37 in meal reimbursement
funds to T.B.F.' s bank account
7 5/14/2021 The State of Missouri' s payment of $694,679.62 in meal reimbursement
funds to T.B.F.' s bank account
8 7/1 4/2021 The State of Missouri ' s payment of $1 ,178,006.26 m meal
reimbursement funds to T.B.F.' s bank account

All in violation of Title 18, United States Code, Sections 1343 and 2.

COUNT NINE
(Money Laundering Conspiracy: 18 U.S.C. § 1956(h))

29. Each of the allegations included in this Indictment is hereby incorporated by

reference as if fully set forth herein .

30. As described above, Defendant Williams and Defendant Warford worked together

to conceal T.B.F.'s fraudulent reimbursement claims for millions of meals that T.B.F. never

served. They did so by creating a false paper trial-through financial transactions and phony

invoices- making it appear as though T.B.F. purchased meals when it did not. To create the false
record of meal purchases, Defendant Williams wrote checks from her T.B.F. bank account

(Midwest BankCentre bank account ending in 5927) to the W.C.C. bank account (Midwest

BankCentre account ending in 5875) that she controlled a_long with Defendant Warford.

Defendants executed these financial tran sactions to conceal the nature , source, ownership, and

control of the fraudulent proceeds that T.B.F. received as a result of their wire fraud scheme.

31. Over the course of their conspiracy, Defendant Williams wrote . the fo llowing

checks from her T.B.F. bank account (Midwest Bank Centre bank account ending in 5927) to the

W.C.C. bank account (Midwest BankCentre account ending in 5875) that she controlled along

with Defendant Warford .

r. Date I Check# '
Memo
, ' .•.~ ~ '
Amount
06/22/2020 1001 Food service/vendor $ 16,000.00
06/26/2020 1004 Food service $ 44 ,593.00
07/17/2020 1023 Food service $49,537.20
08/26/2020 1005 Food service/vendor $ 40 ,000 .00
09/01/2020 1008 Food service/vendor $ 68 ,000 .00
09/28/2020 1009 Food service $ 17,900 .00
10/20/2020 1012 Food service $ 50,000 .00
10/26/2020 1013 Food service $ 9,025.50
11/16/2020 1016 Vendor $ 50,000 .00
12/l l /2020 1017 Vendor $ 25 ,000.00
12/21/2020 1019 Vendor $ 165 ,000.00
01/27/2021 1061 Vendor Servicer $ 300,000.00
01/2 7/2021 1062 Vendor pay $ 27 ,342.50
03 /03 /2021 1026 Vendor/SFSP/CACFP $ 354,638 .14
04/13/2021 1066 food service $ 130,667.00
04/13 /2021 1067 Food Service $ 535 ,986.88
04/2 1/2021 1070 Vendor pay $ 671 ,186.46
06/07/2021 1073 Vendor pay $ 572,459.06
07/08/2021 1074 Vendor pay $ 572,459.00
09/01/2021 2001 June 2021 invoice $ 498 ,099.94
09/01 /2021 2004 July inv. $ 442 ,444 .54
03 /02/2022 1001 Vendor services $ 386,787.40
03/02/2022 1002 Vendor services $ 58,969.90
03/02/2022 1005 Vendor services $ 273 ,442.76
03 /02/2022 1006 Vendor services $ 1 019.15

11
03 /02/2022 1007 Vendor services $ 22 ,961.75
03/02/2022 1008 Vendor serv ices $ 40 ,968 .20
08/05/2022 1106 22001 Invoice $ 129,733.25
09/07/2022 1108 Inv 22 -0 003 $ 136,029.45
09/07/2022 110 9 Inv 22-0004 $ 131 ,946.00
10/20/2022 1113 Inv 22-0005 $ 133 ,881.85
12/27/2022 1117 Inv 22-0002 $ 110,612.43
08/01/2023 1122 June. invoice 23-006 $ 33 ,038.40
09/29/2023 $ 12,000.00

32. These financial transactions were designed to conceal the nature, source,

ownersh ip , and control of the fraudulent proceeds that T.B.F. received as a result of their wire

fraud scheme. To further conceal and disguise the nature, source, ownership, and contro l of the

fraudulently received state meal funds , Defendants created phony W.C.C. invoices to fa lsely and

fraudu lently make it appear that the payments from T.B.F. were for reimbursable meals that

W.C.C. provided to T.B.F. In truth and fact, however, those invoices were created to enable

Defendants' impro per use of state meal funds for the ir own personal expenses.

33 . Also in furtherance of their conspiracy, Defendants conducted financial

transactio ns from their W .C.C. bank account (Midwest BankCentre account ending in 5 87 5) with

fraud proceeds that were designed to conceal the nature, so urce, ownership , and control of those

proceeds. For example, to conceal Defendants ' use of sto len public meal dollars to purchase

themselves a $1.44 mill io n res idence, Defendant Warford wired the purchase price of the home

from Defendants ' W.C.C. bank account (Midwest BankCentre account end ing in 58 75) to h is own

personal checkingaccount(Navy Federal Credit Union bank accountnumberendingin 0939), and

the n to First American Title-all within 24 hours of Defendants ' home purchase. Then, to fu rther

disguise Defendants ' improper, personal use of public funds , Defendant Warford represented to

12
the Internal Revenue Service that Defendants ' $1.44 million home purchase was a business

expense of W.C.C.

34. Beginning in or about September 2020 , and continuing through at least on or about

February 26 , 2025 , in the Eastern District of Missouri and elsewhere, the defendants,

DIARRA WILLIAMS and
NICHOLAS WARFORD,

voluntarily and intentionally combined, conspired , confederated, and agreed with each other and

others known and unknown to the Grand Jury, to commit the following offense against the United

States:

(a) To knowingly conduct and attemptto conduct financial transactions affecting interstate

and foreign commerce, which involved the proceeds of specified unlawful activities,

that is, wire fraud , in violation of Title 18 , United States Code, Section 1343 , knowing

that the transactions were designed in whole or in part to conceal and disguise the

nature, location, source, ownership , and control of the proceeds of such specified

unlawful activity , and that while conducting the financial transactions, knew that the

property involved in the financial transactions represented the proceeds of some fonn

of unlawful activity, in violation of Title 18, United States Code, Section

l 956(a)(l)(B)(i).

All in violation of Title 18, United States Code, Section l 956(h).

COUNT TEN
(Obstruction of an Official Proceeding: 18 U.S.C. § 1512(c)(2))

35. Each of the allegations in this Indictment is hereby incorporated by reference as if

fully set forth herein.

36. On or aboutNovember29 , 2023 , in the Eastern DistrictofMissouri, the defendants,

13
DIARRA WILLIAMS,
NICHOLAS WARFORD,

did corruptly obstruct, influence, and impede, and did attempt to corruptly obstruct, influence, and

impede, an official proceeding, to wit, in response to a federal grand jury subpoena, Defendants

produced phony W.C.C. invoices, wh ich falsely reflected purchases of reimbursable meals that

were never made.

All in violation of Title 18, United States Code, Sections 1512(c)(2) and 2.

FORFEITURE ALLEGATION

The Grand Jury further alleges there is probable cause that:

1. Pursuant to Title 18, United States Code, Sections 982(a)(2), upon conviction of an

offense in violation of Title 18, United States Code, Section 1343, as set forth in Counts One

through Eight, Defendants Williams and Warford shall forfeit to the United States of America any

property constituting, or derived from , any proceeds obtained, directly or indirectly, as a result of

such vio lation. Subjectto forfeiture is a sum of money equal to the total valu e of any property, real

or personal, constituting or derived from any proceeds traceable to such vio lation .

2. Pursuant to Title 18 , United States Code, Sections 982(a), upon conviction ofan

offense in vio lation of Title 18, United States Code, Section 1956, as set forth in Count Nine, the

defendants shall forfeit to the United States of America any property , real or personal , involved in

such offense, and any property traceable to such property. Subject to forfeiture is a sum of money

equal to the total value of any property, real or personal, involved in such offense, or any property

traceable to such property.

3. Specific property subject to forfeiture includes, but is not limited to , the following

a. A property located at 8416 Rockrid ge, Edwardsvi lle, IL 62025;
b. A 2019 Ram 1500 Rebel (VIN: 1C6SRFLT5KN784521);
c. A 20 18 Lincoln Navigator (VIN: 5LMJJ2LT2JEL0243 7);
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d. A 2011 Mercedes Benz Sprinter (VIN: WD3PE7CC0B5602167);
e. A 2021 Ram Promaster (VIN: 3C6LRVBG7ME512286);
f. A 2021 Ram Promaster (VIN: 3C6LRVBG9ME512287); and
g. A 2017 Chrysler Pacifica (VIN: 2C4RC1GG3HR811929).

3. If any of the property described above, as a result of any act or omission of the

defendant:

a. cannot be located upon the exercise of due diligence ;
b. has been transferred or sold to , or deposited with , a third party ;
c. has been placed beyond the jurisdiction of the court;
d. has been substantially diminished in value ; or
e. has been commingled with other property which cannot be divided without
difficulty,

the United States of America will be entitled to the forfeiture of substitute property pursuant to

Title 21 , United States Code, Section 853(p).

A TRUE BILL.

FOREPERSON

SAYLER A. FLEMING
United States Attorney

DEREK J. WISEMAN, #67257MO
Assistant United States Attorney

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