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Information — United States v. Wendy Villatoro, District of Columbia (Document 1)

Summary

A criminal information filed by the United States Attorney against Wendy Villatoro, Case 1:24-cr-00446-CJN, in the U.S. District Court for the District of Columbia, filed October 2, 2024 as Document 1. Count One charges bank fraud under Title 18, United States Code, Section 1344, alleging that from on or about March 31, 2020 through at least in or around August 4, 2021 Villatoro did knowingly and intentionally execute and/or attempt to execute a scheme or artifice to defraud a financial institution then insured by the Federal Deposit Insurance Corporation. The forfeiture allegation states the United States will seek a forfeiture money judgment equal to the proceeds traceable to the offense under 18 U.S.C. § 982(a)(2)(A). The information is signed by Assistant United States Attorney Jared English.

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“Information — United States v. Wendy Villatoro, District of Columbia (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-no-1-24-cr-00446-dkt-1-d-d-c-071628ab1c/, SHA-256 4d0f0dfb9a6d08e26e2d265af18c25cdb61802130df79a1ecfcf6e6b9575753a.

Full text

           Case 1:24-cr-00446-CJN Document 1 Filed 10/02/24 Page 1 of 2




                              UNITED STATES DISTRICT COURT
                              FOR THE DISTRICT OF COLUMBIA

 UNITED STATES OF AMERICA                           :    CRIMINAL NO.
                                                    :
                       v.                           :
                                                    :
 WENDY VILLATORO,                                   :    VIOLATION:
                                                    :    18 U.S.C. § 1344
                            Defendant.              :    (Bank Fraud)
                                                    :
                                                    :    FORFEITURE:
                                                    :    18 USC 982(a)(2)(A), 21 USC 853(p), 28
                                                    :    U.S.C. § 2461(c)

                                       INFORMATION

        The United States Attorney charges that:

                                            COUNT ONE

        On or about March 31, 2020, and continuing through at least in or around August 4, 2021,

within the District of Columbia, the defendant, WENDY VILLATORO did knowingly and

intentionally execute and/or attempt to execute a scheme or artifice to defraud a financial institution

that was then insured by the Federal Deposit Insurance Corporation and to obtain money, funds, assets,

securities, and other property owned by and under the custody and control of a financial institution by

means of materially false or fraudulent pretenses, representations, and promises.

        (Bank Fraud, in violation of Title 18, United States Code, Section 1344)

                                  FORFEITURE ALLEGATION

        Upon conviction of any of the offense alleged in Count One, the defendant shall forfeit to the

United States any property, real or personal, which constitutes or is derived from proceeds traceable to

the offense, pursuant to 18 U.S.C. § 982(a)(2)(A) and 28 U.S.C. § 2461(c). The United States will

seek a forfeiture money judgment against the defendant in an amount equal to the value of any property,

real or personal, which constitutes or is derived from proceeds traceable to the offense.
           Case 1:24-cr-00446-CJN Document 1 Filed 10/02/24 Page 2 of 2




        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 21 U.S.C. § 853(p), as incorporated by 18 U.S.C. § 982(b).

        (Criminal Forfeiture, pursuant to Title 18, United States Code, Section 982(a)(2)(A), Title
        28, United States Code, Section 2461(c), and Title 21, United States Code, Section 853(p))

                                                Respectfully submitted,

                                                MATTHEW M. GRAVES
                                                United States Attorney
                                                D.C. Bar No. 481052

                                        By:           /s/ Jared English
                                                JARED ENGLISH
                                                Assistant United States Attorney
                                                D.C. Bar No. 1023926
                                                601 D Street, N.W.
                                                Washington, DC 20530
                                                (202) 252-2628
                                                Jared.English@usdoj.gov




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