Motion for an Order of Forfeiture — United States of America v. Keevin Antonio Jones, M.D. Fla. (Document 19)

Summary

The United States' motion for an order of forfeiture, filed March 9, 2026 as Document 19 in United States v. Keevin Antonio Jones, Case No. 6:26-cr-8-JA-RMN, in the U.S. District Court for the Middle District of Florida, Orlando Division. It asks the court under 18 U.S.C. § 981(a)(1)(C), 28 U.S.C. § 2461(c) and Fed. R. Crim. P. 32.2(b)(2) to enter an order of forfeiture of $29,610, the proceeds of the wire fraud charged in Count One of the Information. The motion states the defendant pled guilty and admitted submitting four fraudulent PPP and EIDL applications between about June 2020 and July 2021, and that the proceeds were transferred to third parties and cannot be located. It asks that the order be final at entry and that the court retain jurisdiction over substitute assets. It is signed by Assistant United States Attorney Nicole M. Andrejko.

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Case 6:26-cr-00008-JA-RMN       Document 19      Filed 03/09/26   Page 1 of 5 PageID 79




                      UNITED STATES DISTRICT COURT
                       MIDDLE DISTRICT OF FLORIDA
                           ORLANDO DIVISION

 UNITED STATES OF AMERICA

 v.                                              Case No. 6:26-cr-8-JA-RMN

 KEEVIN ANTONIO JONES

                         UNITED STATES’ MOTION
                       FOR AN ORDER OF FORFEITURE

      The United States moves this Court, pursuant to 18 U.S.C. § 981(a)(1)(C), 28

U.S.C. § 2461(c), and Fed. R. Crim. P. 32.2(b)(2), to enter an order of forfeiture

against the defendant in the amount of $29,610, representing the amount of proceeds

he personally obtained as the a result of the wire fraud offense, in violation of 18

U.S.C. § 1343, as charged in Count One of the Information. In support thereof, the

United States submits the following.

                            MEMORANDUM OF LAW

I.    Statement of Facts

      A.     Allegations Against the Defendant

      1.     The defendant was charged in an Information with wire fraud, in

violation of 18 U.S.C. § 1343. Doc. 1.

      2.     The Information contained forfeiture allegations putting the defendant

on notice that, pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c), the

United States would forfeit any property constituting, or derived from proceeds the
Case 6:26-cr-00008-JA-RMN       Document 19          Filed 03/09/26   Page 2 of 5 PageID 80




defendant obtained, directly or indirectly, as a result of such violation, including, but

not limited to, a $29,610 order of forfeiture. Id.

       B.     Findings of Guilt and Admissions Related to Forfeiture

       3.     The defendant pled guilty to Count One of the Information. Doc. 17.

The Court accepted the defendant’s plea and adjudicated him guilty. Doc. 18.

       4.     The defendant admitted in his Plea Agreement (Doc. 4 at 16-20), that

between on or about June 2020 and July 2021, he participated in a wire fraud scheme

by submitting to the SBA and other lenders four different fraudulent applications for

PPP and EIDL loans for businesses controlled by him. In total, the defendant

received $29,610 in proceeds from the fraudulent scheme. The defendant used the

loan proceeds for his own personal use. Id.

       5.     Pursuant to 18 U.S.C. § 981(a)(1)(C) and 28 U.S.C. § 2461(c), the

defendant admitted and agreed that the United States was entitled to an order of

forfeiture in the amount of $29,610, representing the amount of proceeds he

personally obtained as a result of the wire fraud scheme. Doc. 4 at 4. Moreover, the

defendant agreed that the fraudulently obtained proceeds were transferred to third

parties and could not be located upon the exercise of due diligence. Id. at 5. Lastly,

the defendant agreed that the order of forfeiture would be final upon entry. Id.




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II.   Applicable Law

      A.     Forfeiture Statute

      The Court’s authority to order civil forfeiture of property for violations of 18

U.S.C. § 1343 is found in 18 U.S.C. § 981(a)(1)(C). Section 981(a)(1)(C) provides for

the civil forfeiture of any property, real or personal, which constitutes or is derived

from proceeds from any offense constituting “specified unlawful activity” as defined

in 18 U.S.C. § 1956(c)(7), or a conspiracy to commit such offenses. A “specified

unlawful activity,” as defined in 18 U.S.C. § 1956(c)(7), includes offenses listed in 18

U.S.C. § 1961(1). Specifically, 18 U.S.C. § 1961(1) includes violations of 18 U.S.C. §

1343. Pursuant to 28 U.S.C. § 2461(c), the government is authorized to forfeit this

property criminally, and the procedures for the forfeiture and disposition of the

property are governed by 21 U.S.C. § 853

      B.     Court’s Determination of Forfeiture

      Pursuant to Rule 32.2(b)(2), because the United States could not locate the

specific property constituting or derived from the proceeds the defendant obtained

from his wire fraud scheme, the United States seeks an order of forfeiture against the

defendant in the amount of proceeds he obtained from his wire fraud scheme. Indeed,

for cases in which a defendant no longer has the actual dollars or property traceable to

proceeds in his/her possession, or the government cannot locate those assets, the

obligation to forfeit simply takes the form of an order of forfeiture in favor of the

United States. See United States v. Padron, 527 F.3d 1156, 1161-62 (11th Cir. 2008).

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Case 6:26-cr-00008-JA-RMN       Document 19      Filed 03/09/26    Page 4 of 5 PageID 82




       Rule 32.2(b)(1) provides that the court must determine the amount of money

that the defendant will be ordered to pay. The Court’s determination may be based on

evidence submitted by the parties and accepted by the Court as relevant and reliable.

Fed. R. Crim. P. 32.2(b)(1)(B). As the defendant has agreed, he personally obtained

$29,610 in proceeds as a result of the wire fraud scheme. If the Court finds that the

defendant obtained at least $29,610 as a result of his wire fraud scheme and that the

defendant has dissipated those proceeds, then it is appropriate for the Court to enter an

order of forfeiture against the defendant in that amount pursuant to Rule 32.2(b)(2).

III.   Conclusion

       For the reasons stated above, the United States requests that the Court,

pursuant to 18 U.S.C. § 981(a)(1)(C), 28 U.S.C. § 2461(c), and Fed. R. Crim. P.

32.2(b)(2), enter an Order of Forfeiture against the defendant in the amount of

$29,610.

       As required by Federal Rule of Criminal Procedure 32.2(b)(4)(B), the United

States requests that the Court include the forfeiture when orally pronouncing the

sentence and include the forfeiture order, directly or by reference, in the judgment.

See Fed. R. Crim. P. 32.2(b)(4)(A) and (B).

       In accordance with Rule 32.2(b)(4) and the defendant’s plea agreement (Doc.

4 at 5), the United States asks that the order of forfeiture be made final as to the

defendant at the time it is entered.



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Case 6:26-cr-00008-JA-RMN       Document 19          Filed 03/09/26   Page 5 of 5 PageID 83




       Finally, the United States further requests that the Court retain jurisdiction

to order any substitute assets forfeited to the United States up to the amount of the

order of forfeiture.

                                               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


                            CERTIFICATE OF SERVICE

       I hereby certify that on March 9, 2026, 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




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