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Information — United States v. Hanalei Aipoalani, District of Columbia (Document 1)

Summary

An Information in United States of America v. Hanalei Aipoalani, Case 1:20-cr-00286-RBW, in the U.S. District Court for the District of Columbia, filed December 18, 2020 as Document 1. Count One charges federal programs embezzlement under 18 U.S.C. § 666(a)(1)(A). It alleges that from in or about May 2018 to in or about May 2019, while an agent of Non-Profit 1, which received federal benefits in excess of $10,000, the defendant obtained more than $5,000 in Non-Profit 1 funds by falsely representing they were required to support its AmeriCorps program, and converted them to personal use. The forfeiture allegation names a 2014 Ford Fusion Hybrid. The signature block names Assistant United States Attorney Amanda R. Vaughn.

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“Information — United States v. Hanalei Aipoalani, District of Columbia (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-no-1-20-cr-00286-dkt-1-d-d-c-3acd0099e5/, SHA-256 f137b2ae40f7a0e7a98abfe70a7c0f3dba24b676c0b776e3891f6e23ab9dce86.

Full text

            Case 1:20-cr-00286-RBW Document 1 Filed 12/18/20 Page 1 of 3




                       IN THE UNITED STATES DISTRICT COURT
                           FOR THE DISTRICT OF COLUMBIA

 UNITED STATES OF AMERICA,                       :
                                                 :
                       v.                        :     Criminal No. 1:20-
                                                 :
 HANALEI AIPOALANI,                              :     VIOLATIONS:
                                                 :     18 U.S.C. § 666(a)(1)(A)
                  Defendant.                     :     (Federal Programs Embezzlement)

                                        INFORMATION

       The United States of America charges that:

                                          COUNT ONE

       1.      Between in or about May 2018 and in or about May 2019, NON-PROFIT 1 received

benefits in excess of $10,000 under a Federal program involving a grant, contract, subsidy, loan,

guarantee, insurance, or other form of Federal assistance.

       2.      From in or about May 2018 to in or about May 2019, within the District of

Columbia and elsewhere, the defendant, HANALEI AIPOALANI (hereinafter “AIPOALANI”),

while an agent of NON-PROFIT 1, did embezzle, steal, obtain by fraud, and otherwise without

authority knowingly convert to the use of any person other than the rightful owner and intentionally

misapply property that was owned by and under the care, custody, and control of NON-PROFIT

1 and was valued at $5,000 or more, that is, AIPOALANI obtained more than $5,000 in NON-

PROFIT 1 funds by falsely representing the funds were required to support NON-PROFIT 1’s

AmeriCorps program, when, in fact, AIPOALANI converted the funds to his and others’ personal

use.

       All in violation of Title 18, United States Code, Section 666(a)(1)(A).
          Case 1:20-cr-00286-RBW Document 1 Filed 12/18/20 Page 2 of 3




                                FORFEITURE ALLEGATION

       Upon conviction of the offense alleged in Count 1 of this Information, the defendant shall

forfeit to the United States any property, real or personal, which constitutes or is derived from

proceeds traceable to this offense, pursuant to Title 18, United States Code, Section 981(a)(1)(C)

and Title 28, United States Code, Section 2461(c).

       The United States will also seek the forfeiture of the following specific property: a 2014

Ford Fusion Hybrid, with Vehicle Identification Number 3FA6P0LU5ER256328.

       If any of the property described above as being subject to forfeiture, 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 that cannot be divided without
                       difficulty;

the defendant shall forfeit to the United States any other property of the defendant, up to the value

of the property described above, pursuant to Title 18, United States Code, Section 981(a)(1)(C),

Title 28, United Sates Code, Section 2461(c), and Title 21, United States Code, Section 853(p)).




                                                 2
Case 1:20-cr-00286-RBW Document 1 Filed 12/18/20 Page 3 of 3




                           MICHAEL R. SHERWIN
                           ACTING UNITED STATES ATTORNEY


                     By:
                           AMANDA R. VAUGHN
                           MD Bar
                           Assistant United States Attorney
                           Public Corruption and Civil Rights Section
                           U.S. Attorney’s Office
                           555 4th Street, N.W., 5th Floor
                           Washington, D.C. 20530
                           (202) 252-1793
                           amanda.vaughn@usdoj.gov




                              3

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