Indictment — United States v. Ashlee Parker, Southern District of Georgia (Document 1)

Summary

An indictment in United States of America v. Ashlee Parker, Case 4:22-cr-00100-RSB-CLR, in the U.S. District Court for the Southern District of Georgia, Savannah Division, filed July 13, 2022 as Document 1. The caption lists conspiracy to commit wire and bank fraud (18 U.S.C. § 1349), wire fraud (18 U.S.C. § 1343), false document (18 U.S.C. § 1001(a)(3)), money laundering conspiracy (18 U.S.C. § 1956(h)) and false statement (18 U.S.C. § 1001(a)(2)). The grand jury alleges that from about May 2020 until about April 2021 Parker submitted more than two dozen EIDL applications with false revenue, employee and formation-date information for her own companies and for others, taking a percentage of the proceeds, and ran proceeds through her tax preparation business's merchant account. It alleges that the United States was defrauded out of over two million dollars.

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Case 4:22-cr-00100-RSB-CLR Document 1

Filed 07/13/22 Page 1 of 22

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF GEORGIA
SAVANNAH DIVISION

UNITED STATES OF AMERICA

Vv.

ASHLEE PARKER

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THE GRAND JURY CHARGES THAT:

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INDICTMENT NO.

18 U.S.C. § 1349

Conspiracy to Commit Wire and
Bank Fraud

18 U.S.C. § 1343
Wire Fraud

CR422-160

18 U.S.C. § 1001(a)(3)
False Document

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

18 U.S.C. § 1001(a)(2)
False Statement

At all times relevant to this Indictment:

INTRODUCTION

1. Beginning in or about May 2020 and continuing until in or about April

2021, ASHLEE PARKER led a scheme to defraud the United States by submitting

fraudulent Economic Injury Disaster Loan (“EIDL”) applications to the U.S. Small

Business Administration (“SBA”) that contained materially false representations.

ie PARKER submitted more than two dozen EIDL applications in her

name, the name of various businesses she purportedly owned, and in the names of

others. Nearly all of the applications submitted by PARKER included false

representations designed to obtain fraudulent proceeds from the SBA. For the EIDLs
Case 4:22-cr-00100-RSB-CLR Document1 Filed 07/13/22 Page 2 of 22

she submitted for others, she took a percentage of the fraudulent proceeds for her
services in orchestrating the fraud.

3. PARKER then ran the fraudulent proceeds through her tax preparation
business’s merchant account in an effort to disguise the nature and purpose of the
payment.

4, As a result of PARKER’s scheme, the United States was defrauded out
of over two million dollars. PARKER used the proceeds of her fraud to her own
personal benefit, including spending thousands of dollars at luxury stores and paying
for a cosmetic surgery procedure for herself.

The Defendant and Her Purported Businesses

5. PARKER was an individual residing in Georgia who submitted EIDL
applications for individuals in several states, including for several individuals
residing in the Savannah Division of the Southern District of Georgia.

6. Proficient Tax, LLC was a Georgia limited liability company owned and
controlled by PARKER.

7. The Harris Parker Group, LLC was a Georgia limited lability company
owned and controlled by PARKER.

8. AMP Credit Solutions, LLC was a dissolved Florida limited liability
company formerly owned and controlled by PARKER.

The COVID-19 Pandemic and the CARES Act
9. The Coronavirus Aid, Relief, and Economic Security (“CARES”) Act was

a federal law enacted in or about March 2020 designed to provide emergency financial
Case 4:22-cr-00100-RSB-CLR Document1 Filed 07/13/22 Page 3 of 22

assistance to the millions who are suffering the economic effects caused by the
COVID-19 pandemic.

10. Among other relief efforts, the United States sought to provide financial
support to eligible businesses that could be used to offset certain business expenses.

11. The SBA was an executive branch agency of the United States
government that provided support to entrepreneurs and small businesses. The SBA
was headquartered in Washington, DC and maintained its computer servers outside
of the State of Georgia. The SBA’s mission was to maintain and strengthen the
nation’s economy by enabling the establishment and viability of small businesses and
by assisting in the economic recovery of communities after disasters.

12. As part of this effort, the SBA enabled and provided for loans through
banks, credit unions, and other lenders. These loans have government-backed
guarantees. In addition, the SBA provided loans that came directly from the U.S.
Government.

Economic Injury Disaster Loans

18. One source of relief provided by the CARES Act was the authorization
for the SBA to provide EIDLs to eligible small businesses experiencing substantial
financial disruption due to the COVID-19 pandemic.

14. In order to obtain an EIDL, a qualifying business had to submit an
online application to the SBA and provide information about its operations, such as
the number of employees, gross revenues for the twelve-month period preceding the

disaster, and the cost of goods the business sold in the twelve-month period preceding
the disaster. In the case of EIDLs, the twelve-month period was that preceding
January 31, 2020. The applicant also had to certify that all the information in its
application was true and correct to the best of the applicant’s knowledge.

15. In addition, the CARES Act authorized the SBA to issue advances of up
to $10,000 to small businesses within three days of applying for an EIDL “EIDL
Advance”). The amount of the EIDL Advance was determined the number of
employees the applicant certified having.

16. EIDL applications were submitted directly to the SBA online at
https://covid19relief.sba.gov/#/ and processed by the agency with support from a
government contractor, Rapid Finance. The amount of each loan was determined
based, in part, on the information provided by the application about employment,
revenue, and cost of goods, as described above. Any funds issued under an EIDL were
issued directly by the SBA.

17. EIDL funds could be used for payroll expenses, sick leave, production
costs, and business obligations, such as debts, rent, and mortgage payments.

The Paycheck Protection Program

18. Another source of relief provided by the CARES Act was the
authorization of up to $349 billion in forgivable loans to small businesses for job
retention and certain other expenses, through a program referred to as the Paycheck
Protection Program (“PPP”). In or around April 2020, Congress authorized over $300

billion in additional PPP funding.
Case 4:22-cr-00100-RSB-CLR Document1 Filed 07/13/22 Page5of 22

19. Inorder to obtain a PPP loan, a qualifying business had to submit a PPP
loan application signed by an authorized representative of the business. The PPP loan
application required the business (through its authorized representative) to
acknowledge the program rules and make certain affirmative certifications in order
to be eligible to obtain the PPP loan. In the PPP loan application, the small business
(through its authorized representative) had to state, among other things, its: (a)
average monthly payroll expenses; and (b) number of employees. These figures were
then used to calculate the amount of money the small business was eligible to receive
under the PPP. In addition, a business applying for a PPP loan had to provide
documentation showing its payroll expenses.

20. A PPP loan application must be processed by a participating lender,
such as a financial institution. If a PPP loan is approved, the participating lender
funds the PPP loan using its own monies, which are 100% guaranteed by the SBA.
Data from the application, including the information about the borrower, the total
amount of the loan, and the listed number of employees, is transmitted by the lender
to the SBA in the course of processing the loan.

21. The PPP loan proceeds must be used by the business on certain
permissible expenses—payroll costs, interest on mortgages, rent, and utilities. The
PPP allows the interest and principal of the PPP loan to be entirely forgiven if the
business spends the loan proceeds on these expense items within a designated period

of time and uses a certain percentage of the PPP loan proceeds on payroll expenses.
COUNT ONE
Conspiracy to Commit Wire and Bank Fraud
18 U.S.C. § 1349

22. The Grand Jury re-alleges and incorporates by reference the factual
allegations contained in paragraphs 1 through 21 of this Indictment as if fully set
forth herein.

23. Beginning in or about May 2020 and continuing until in or about April
2021, in the Southern District of Georgia, and elsewhere, the Defendant,

ASHLEE PARKER,
with other co-conspirators, known and unknown, did conspire, confederate, and agree
with each other to commit the following offenses:

a. wire fraud, that is, to devise and intend to devise a scheme and
artifice to defraud individuals and to obtain money and property by means of
materially false and fraudulent pretenses, representations and promises, and
for the purpose of executing this scheme, and attempting to do so, caused to be
transmitted by means of wire communication in interstate commerce signals
and sounds, all in violation of Section 1848 of Title 18 of the United States
Code; and

b. bank fraud, that is, to knowingly execute or attempt to execute a
scheme and artifice to obtain any of the moneys, funds, credits, assets,
securities, and other property under the custody and control of a financial
institution by means of false and fraudulent pretenses, representations, and

promises, all in violation of Section 1344 of Title 18 of the United States Code.
Case 4:22-cr-00100-RSB-CLR Document1 Filed 07/13/22 Page 7 of 22

24,

The Object of the Conspiracy

It was the object of the conspiracy for PARKER and others to

unlawfully enrich themselves by, among other things, obtaining EIDL and PPP

proceeds under false and fraudulent pretenses, including by making false statements

about the applicant’s company’s gross revenue, payroll, and formation date.

25.

Manner and Means of Wire Fraud Conspiracy

The manner and means by which PARKER and others sought to

accomplish the object of the wire fraud conspiracy included, among others, the

following:

a. On or about June 16, 2020, PARKER submitted, or caused to be

submitted, an electronic application for an EIDL from the SBA on
behalf of a dissolved company she had formerly owned called AMP
Credit Solutions, LLC (““EIDL Application 5031”). In connection with
EIDL Application 5031, PARKER falsely affirmed that AMP Credit
Solutions, LLC had earned $382,000 in gross revenue in the twelve

months prior to January 31, 2020.

. On or about June 30, 2020, PARKER submitted, or caused to be

submitted, an electronic application for an EIDL from the SBA on
behalf of “Company 1” (‘EIDL Application 1616”) owned by
Individual 1. In connection with EJDL Application 1616, PARKER
falsely affirmed that Company 1 was established on May 19, 2019

and had earned $287,613 in gross revenue in the twelve months prior
Case 4:22-cr-00100-RSB-CLR Document1 Filed 07/13/22 Page 8 of 22

to January 31, 2020. Individual 1 received a $88,700 EIDL and a
$6,000 EIDL Advance from the SBA based on PARKER’s fraudulent
submission. Individual 1 then paid PARKER several thousand
dollars for filling out the application.

c. On or about July 2, 2020, PARKER submitted, or caused to be
submitted, an electronic application for an EJDL from the SBA on
behalf of “Company 2” (“EIDL Application 8823”) owned by
Individual 2. In connection with EIDL Application 8823, PARKER
falsely affirmed that Company 2 had 10 employees and had earned
$316,270 in gross revenue in the twelve months prior to January 31,
2020. Individual 2 received a $113,300 EIDL and a $10,000 EIDL
Advance from the SBA based on PARKER’s fraudulent submission.
Individual 2 then paid PARKER several thousand dollars for filling
out the application.

d. On or about July 2, 2020, PARKER submitted, or caused to be
submitted, an electronic application for an EIDL from the SBA on
behalf of “Company 3” (“EIDL Application 6301”) owned by
Individual 3. In connection with EIDL Application 6301, PARKER
falsely affirmed that Company 3 had 10 employees and had earned
$348,970 in gross revenue in the twelve months prior to January 31,
2020. Individual 3 received a $136,400 EIDL and a $10,000 EIDL

Advance from the SBA based on PARKER’s fraudulent submission.
H.L. then paid PARKER several thousand dollars for filling out the
application.

e. On or about July 3, 2020, PARKER submitted, or caused to be
submitted, an electronic application for an EIDL from the SBA on
behalf of “Company 4” (“EIDL Application 9969”) owned by
Individual 4. In connection with EIDL Application 9969, PARKER
falsely affirmed that Company 4 had 10 employees and earned
$297,520 in gross revenue in the twelve months prior to January 31,
2020.

f. On or about July 8, 2020, PARKER submitted, or caused to be
submitted, an electronic application for an EIDL from the SBA on
behalf of “Company 5” (“EIDL Application 5365”) owned by
Individual 5. In connection with EIDL Application 5365, PARKER
falsely affirmed that Company 5 had 8 employees and earned
$192,840 in gross revenue in the twelve months prior to January 31,
2020. Individual 5 received a $65,200 EIDL from the SBA based on
PARKER’s fraudulent submission. Individual 5 then paid PARKER
several thousand dollars for filling out the application.

g. On or about July 10, 2020, PARKER submitted, or caused to be
submitted, an electronic application for an EIDL from the SBA on
behalf of “Company 6” (“EIDL Application 4779”) owned by

Individual 6. In connection with EIDL Application 4779, PARKER
Case 4:22-cr-00100-RSB-CLR Document1 Filed 07/13/22 Page 10 of 22

falsely affirmed that Company 6 was established on January 14,
2019, had 10 employees, and earned $349,400 in gross revenue in the
twelve months prior to January 31, 2020. Individual 6 received a
$141,300 EIDL from the SBA based on PARKER’s fraudulent
submission. Individual 6 then paid PARKER several thousand
dollars for filling out the application.

h. On or about July 14, 2020, PARKER submitted, or caused to be
submitted, an electronic application for an EIDL from the SBA on
behalf of “Company 7” (“EIDL Application 8047”) owned by
Individual 7. In connection with EIDL Application 8047, PARKER
falsely affirmed that Company 7 was a retail business and had
earned $102,840 in gross revenue in the twelve months prior to
January 31, 2020. Individual 7 received a $41,000 EIDL from the
SBA based on PARKER’s fraudulent submission. Individual 7 then
paid PARKER a percentage of the proceeds for filling out the
application.

i. On or about July 14, 2020, PARKER submitted, or caused to be
submitted, an electronic application for an EIDL from the SBA on
behalf of “Company 8” (“EIDL Application 5110”) owned by
Individual 8. In connection with EIDL Application 5110, PARKER

falsely affirmed that Company 8 was established on July 1, 2019 and

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Case 4:22-cr-00100-RSB-CLR Document1 Filed 07/13/22 Page11 of 22

had earned $152,030 in gross revenue in the twelve months prior to
January 31, 2020.

j. On or about July 16, 2020, PARKER submitted, or caused to be
submitted, an electronic application for an EIDL from the SBA on
behalf of “Company 9” (“EIDL Application 2877”) owned by
Individual 9. In connection with EIDL Application 2877, PARKER
falsely affirmed that Company 9 was established on June 29, 2019
and had earned $182,100 in gross revenue in the twelve months prior
to January 31, 2020. Individual 9 received a $63,200 EIDL from the
SBA based on PARKER’s fraudulent submission.

k. On or about August 5, 2020, PARKER submitted, or caused to be
submitted, an electronic application for an EIDL from the SBA on
behalf of “Company 10” (“EIDL Application 7516”) owned by
Individual 10. In connection with EIDL Application 7516, PARKER
falsely affirmed that Company 10 had earned $157,820 in gross
revenue in the twelve months prior to January 31, 2020. Individual
10 received a $65,000 EIDL from the SBA based on PARKER’s
fraudulent submission.

1. On or about January 11, 2021, PARKER submitted, or caused to be
submitted, an electronic application for an EIDL from the SBA on
behalf of a company she owned called The Harris Parker Group, LLC

(““EIDL Application 7531”). In connection with EIDL Application

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26.

7531, PARKER falsely affirmed that The Harris Parker Group, LLC
had earned $157,800 in gross revenue in the twelve months prior to

January 31, 2020.

. On or about April 29, 2021, PARKER submitted, or caused to be

submitted, an electronic application for an EIDL from the SBA on
behalf of a sole-proprietorship real estate business she owned called
“Ashlee Parker” (““EIDL Application 2201”). In connection with EIDL
Application 2201, PARKER falsely affirmed that her real estate
business had earned $217,820 in gross revenue in the twelve months

prior to January 31, 2020.

Manner and Means of Bank Fraud Conspiracy

The means and manner by which PARKER and others sought to

accomplish the object of the bank fraud conspiracy included, among others, the

following:

a. On or about May 10, 2020, PARKER submitted, or caused to be

submitted, an electronic application for a PPP loan to a financial
institution on behalf of her husband, Individual 11’s, business. In
connection with this application, PARKER submitted, or caused to
be submitted, a fake tax document to the financial institution with
ginned up numbers. Based on this false information, the financial

institution provided Individual 11’s business a $20,833 PPP loan.

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Case 4:22-cr-00100-RSB-CLR Document1 Filed 07/13/22 Page 13 of 22

b. On or about June 28, 2020, PARKER submitted, or caused to be
submitted, an electronic application for a PPP loan to a financial
institution on behalf of a business owned by Individual 12 In
connection with this application, PARKER submitted, or caused to
be submitted, a fake invoice from Individual 12’s company.
Individual 12’s application also falsely claimed that Individual 12
had an average monthly payroll of $8,334. Based on this false
information, the financial institution provided Individual 12 a
$20,833 PPP loan.

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

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Case 4:22-cr-00100-RSB-CLR Document1 Filed 07/13/22 Page 14 of 22

27.

COUNTS TWO through EIGHT
Wire Fraud

18 U.S.C. §§ 1343 and 2

The Grand Jury re-alleges and incorporates by reference the factual

allegations contained in paragraphs 1 through 21 of this Indictment as if fully set

forth herein.

28.

On or about the dates specified as to each count below, in the Southern

District of Georgia, and elsewhere, PARKER, aided and abetted by others, did

knowingly devise and intend to devise a scheme and artifice to defraud, and to obtain

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

representations, and promises, and for the purpose of executing the scheme and

artifice and to obtain money and property, caused interstate and foreign wire

communications to be made, in furtherance of the scheme and artifice to defraud, as

set forth below, each constituting a separate count:

Count Approximate Date Description

2 June 30, 2020 Online submission of EIDL Application 1616
on behalf Individual 1

3 July 2, 2020 Online submission of EIDL Application 8823
on behalf of Individual 2

4 July 3, 2020 Online submission of EIDL Application 9969
on behalf of Individual 4

5 July 14, 2020 Online submission of EIDL Application 8047
on behalf of Individual 7

6 July 14, 2020 Online submission of EIDL Application 5110
on behalf of Individual 8

7 July 16, 2020 Online submission of EIDL Application 2877
on behalf of Individual 9

8 August 5, 2020 Online submission of EIDL Application 7516
on behalf of Individual 10

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

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Case 4:22-cr-00100-RSB-CLR Document1 Filed 07/13/22 Page 15of 22

COUNT NINE
False Document
18 U.S.C. §§ 1001(a)(8) and 2
29. The Grand Jury re-alleges and incorporates by reference the allegations
in paragraphs 1 through 21 of this Indictment.
30. On or about August 1, 2020, in the Southern District of Georgia, and
elsewhere, the Defendant
ASHLEE PARKER
aided and abetted by others, did willfully and knowingly make and use a false writing
and document, knowing the same to contain a materially false, fictitious, and
fraudulent statement and entry in a matter within the jurisdiction of the executive
branch of the Government of the United States, by transmitting to the SBA a tax
document that falsely stated that Individual 7 had a Retail-Clothing business, located
within the Southern District of Georgia, that earned $102,840 in gross income in 2019
in connection with EIDL Application 8047, when in fact, as PARKER then and there

well knew, the transmitted tax document contained false data.

All in violation of Title 18, United States Code, Sections 1001(a)(3) and 2.

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Case 4:22-cr-00100-RSB-CLR Document1 Filed 07/13/22 Page 16 of 22

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

31. The Grand Jury re-alleges and incorporates by reference the allegations
set forth in paragraphs 1 through 21 of this Indictment.

32. From in or about May 2020 up to and continuing until in or about April
2021, in the Southern District of Georgia and elsewhere, the Defendant,

ASHLEE PARKER
and others known and unknown, willfully and knowingly did combine, conspire,
confederate, and agree together and with each other to commit money laundering, in
violation of Title 18, United States Code, Sections 1956(a)(1)(B)@ and 1957.

33. It was part and an object of the conspiracy that PARKER, and others
known and unknown, knowing that the property involved in certain financial
transactions represented the proceeds of some form of unlawful activity, would and
did conduct and attempt to conduct such financial transactions that in fact involved
the proceeds of specified unlawful activity, that is, the wire and bank fraud schemes
and conspiracy charged in Counts One through Eight of this Indictment, knowing
that the transactions were designed in whole and in part to conceal and disguise the
nature, the location, the source, the ownership, and the control of the proceeds of
specified unlawful activity, in violation of Title 18, United States Code, Section

34. It was also part and an object of the conspiracy that PARKER, and

others known and unknown, within the United States, knowingly engaged and

16
attempted to engage in monetary transactions in criminally derived property of a
value greater than $10,000.00 that was derived from specified unlawful activity, that
is, fraud schemes involving COVID-19 stimulus funds, including EIDL funds and
PPP funds, in violation of Title 18, United States Code, Section 1957.

35. In furtherance of the money laundering conspiracy, PARKER
instructed individuals for whom she obtained fraudulent COVID-19 stimulus funds
to launder the funds by designating transactions as payroll. For example, and in
furtherance of the conspiracy, on July 3, 2020, PARKER was asked by one such
individual “Before I accept this money[ w]hat can’t I do with it?” That individual then
texted PARKER “I was reading the documents and it wants me to keep receipts, buy
American made, etc.” PARKER replied with a text message on July 4, 2020, stating
“Hey friend....ORRRRR you can just pay yourself or whoever and deposit the money

into another account and then spend it however 8.” A few days later, PARKER

instructed that same person that she cannot give PARKER a “gift” with the funds,
but that person should give PARKER “10% of the loan” and that PARKER would
“run it through my machine as bookkeeping and it'll say from Proficient Tax.”

36. Also in furtherance of the money laundering conspiracy, PARKER used
proceeds of her EIDL and PPP fraudulent schemes to engage in one or more
transactions of value greater than $10,000. For example, and in furtherance of the
conspiracy, on or about August 12, 2020, PARKER transferred $13,955.00 in
criminally derived funds to Plastic Surgery Clinic 1 as payment for a breast

augmentation procedure and abdominoplasty with flank liposuction that Plastic

17
Case 4:22-cr-00100-RSB-CLR Document1 Filed 07/13/22 Page 18 of 22

Surgery Clinic 1 performed on PARKER. PARKER then and there knew that the
funds used in such transaction were criminally derived proceeds, and in fact were the
proceeds of PARKER’s EJIDL and PPP fraudulent schemes, and that were being held
in the name of PARKER’s tax business, Proficient Tax, LLC, which had received
fraudulent EIDL and PPP funds from others.

All in violation of Title 18, United States Code, Section 1956(h).

18
COUNT ELEVEN
False Statement
18 U.S.C. § 1001(a)(2)

37. The Grand Jury re-alleges and incorporates by reference the allegations
set forth in paragraphs 1 through 21 of this Indictment.

38. On or about September 22, 2021, in the Southern District of Georgia,
and elsewhere, the Defendant

ASHLEE PARKER

did willfully and knowingly make a materially false, fictitious, and fraudulent
statement and representation in a matter within the jurisdiction of the executive
branch of the Government of the United States, to wit, during an interview with
federal agents about PARKER filling out EIDL applications on behalf of clients,
PARKER falsely stated that she relied on information supplied to her by her clients
with respect to gross revenue when filling out the EIDL application with the SBA and
that she was paid in the form of a consultation fee for the year for providing business
planning services, when in truth and fact as PARKER then and there knew,
PARKER made up gross revenue numbers that she put on her client’s EIDL
applications and she charged her clients a percentage of the EIDL that they had
received, not a consultation fee for business planning services.

All in violation of Title 18, United States Code, Section 1001(a)(2).

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Case 4:22-cr-00100-RSB-CLR Document1 Filed 07/13/22 Page 20 of 22

FORFEITURE ALLEGATIONS

The allegations contained in Counts One through Eight of this Indictment are
hereby re-alleged and incorporated by reference for the purpose of alleging forfeitures
pursuant to Title 18, United States Code, Sections 981(a)(1)(C), 982(a)(8), and Title
28, United States Code, Section 2461(c).

Upon conviction of the offense set forth in Count One of the defendant,
ASHLEE PARKER shall forfeit to the United States pursuant to Title 18, United
States Code, Section 981(a)(1)(C) and Title 28, United States Code, Section 2461(c),
any property, real or personal, which constitutes or is derived from proceeds traceable
to a violation.

Additionally, upon conviction of the offenses set forth in Counts Two through
Eight defendant, ASHLEE PARKER shall forfeit to the United States pursuant to
Title 18, United States Code, Section 982(a)(8), any property, real or personal, which
represents or is traceable to the gross receipts obtained, directly or indirectly, as a
result of the violation.

If any of the property described above, as a result of any act or commission 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,

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the United States of America shall be entitled to forfeiture of substitute property
pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title 28,

United States Code, Section 2461(c).

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