United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 455: Opinion and order on the writs of garnishment (Apr. 29, 2026)

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An Opinion & Order, Document 455, filed 04/29/26 in United States v. Nathan Reis and Stephanie Hockridge, Criminal Action No. 4:24-CR-00287-O, in the U.S. District Court for the Northern District of Texas, Fort Worth Division. The opinion states that, after the court ordered the defendants to pay over $60 million in restitution, jointly and severally, the Government obtained writs of garnishment on SEI Private Trust Company and Balentine, LLC under the Federal Debt Collection Procedures Act. It finds that the Trusts hold Defendants' assets as Defendants' nominees. The court denies the Family Trustee's Petition to Modify and Defendants' Claims for Exemption and Requests for Hearing, grants the Government's Cross-Motion for Final Order of Garnishment, and says the final order will be docketed separately.

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“United States v. Reis and Hockridge, N.D. Tex. No. 4:24-cr-00287-O, Doc. 455: Opinion and order on the writs of garnishment (Apr. 29, 2026).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/united-states-v-reis-and-hockridge-n-d-tex-no-4-24-cr-00287-o-doc-455-7a621c1fd0/, SHA-256 4abf2fe840552358826110bc0fff1ccf98a4eaae17da8a36a73bfcb62fe40d3d.

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Case 4:24-cr-00287-O Document 455 Filed 04/29/26 Page 1 of 11 PageID 13109

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION

UNITED STATES OF AMERICA §
§
Plaintiff, §
§
v. § Criminal Action No. 4:24-CR-00287-O
§
NATHAN REIS (01) §
STEPHANIE HOCKRIDGE (02) §
§
Defendants. §

OPINION & ORDER
Before the Court are the Garnishees’ Answers to the Writs of Garnishment (ECF Nos. 397, 408);

Defendants’ Preliminary Objections (ECF Nos. 412, 418, 420, 423, 424); the Family Trustee’s Petition

to Modify and Objections to the Writs of Garnishment (ECF No. 428); the Government’s Response (ECF

No. 436); Defendants’ Claims for Exemption and Requests for Hearing (ECF Nos. 430, 431, 435); the

Government’s Response to Defendants’ Objections and Cross-Motion for Final Order of Garnishment

(ECF No. 433); the Family Trustees’ Response (ECF No. 443); Defendants’ Responses (ECF Nos. 444,

445); and the Government’s Reply (ECF No. 448). Having considered the Motions, briefing, objections,

and applicable law, the Family Trustee’s Petition to Modify and Defendants’ Claims for Exemption and

Requests for Hearing are DENIED. The Government’s Cross-Motion for Final Order of Garnishment is

GRANTED.

I. BACKGROUND

Defendants Nathan Reis and Stephanie Hockridge (collectively, “Defendants”) were convicted

for their role in a scheme to defraud the federal Paycheck Protection Program during a national crisis.

This Court sentenced Defendants and ordered them to pay, jointly and severally, over $60 million in

restitution. 1 To enforce the Court’s restitution orders, the Government sought, obtained, and served writs

1
See Judgments, ECF Nos. 362, 390.
1
Case 4:24-cr-00287-O Document 455 Filed 04/29/26 Page 2 of 11 PageID 13110

of garnishment on SEI Private Trust Company (SEI) and Balentine, LLC (Balentine) (collectively, the

“Garnishees”) under the Federal Debt Collection Procedures Act (FDCPA).

The Garnishees filed answers to the writs and identified the substantial assets owned by

Defendants or various trusts. As the Government has previously explained, these trusts were originally

funded by Defendants’ personal brokerage accounts. 2 From July to November 2022, Reis transferred

over $46 million to the Nathan J Reis 2022 Irrevocable Trust and the Nathan J Reis Family Protection

Trust (now named the Mint Legacy Trust and the Mint Family Trust), and Hockridge transferred over

$29 million to the Stephanie Reis 2002 Irrevocable Trust and the Stephanie Reis Family Protection Trust

(now named the Marietta Legacy Trust and the Marietta Family Trust) (collectively, the “Trusts”). 3

The Government served Defendants with the garnishments on December 17, 2025. 4 The

Government also served Billy Hockridge, Family Trustee for the Mint and Marietta Family Trusts and

the Mint and Marietta Legacy Trusts (“Trustee”), on January 14, 2026. 5 After receiving notice of this

garnishment action, Defendants each filed timely requests to transfer this proceeding to the District of

Puerto Rico under 28 U.S.C. § 3004(b)(2), 6 which the Court denied. 7 Defendants filed objections to the

garnishees’ answers within 20 days of receiving the answers under 28 U.S.C § 3205(c)(5). The Trusts

have not filed any objections.

II. LEGAL STANDARD

Federal law makes “a restitution order enforceable to the same extent as a tax lien.” United States

v. Loftis, 607 F.3d 173, 179 n.7 (5th Cir. 2010) (citing 18 U.S.C. § 3613(c)). The government may use

the garnishment provisions of the FDCPA, 28 U.S.C. §§ 3001–3308, to collect a restitution obligation

imposed by a judgment of conviction. United States v. Phillips, 303 F.3d 548, 550–51 (5th Cir. 2002).

2
See Application 6–8, ECF No. 311.
3
Id. at 6–7; see also Friedemann Aff. ¶¶ 10–11, ECF No. 311-3; Hockridge PSR ¶ 112, ECF No. 281-1.
4
Certificate of Service, ECF No. 432.
5
Id.
6
ECF Nos. 403, 404.
7
See Order, ECF No. 429.
2
Case 4:24-cr-00287-O Document 455 Filed 04/29/26 Page 3 of 11 PageID 13111

Under the FDCPA, a court may garnish “property (including nonexempt disposable earnings) in which

the debtor has a substantial nonexempt interest and which is in the possession, custody, or control of a

person other than the debtor, in order to satisfy the judgment against the debtor.” 28 U.S.C. § 3205(a).

“Property” for these purposes includes the present and future right to receive payments under a contract.

See 28 U.S.C. § 3002(12).

Although federal law thus creates a lien on property, it is state law that “defines the property

interests to which the lien attaches.” United States v. Elashi, 789 F.3d 547, 548–49 (5th Cir. 2015);

See also United States v. Rodgers, 461 U.S. 677, 683 (1983) ( “[I]t has long been an axiom of our tax

collection scheme that, although the definition of underlying property interests is left to state law, the

consequences that attach to those interests is a matter left to federal law.”). In this context, federal law

“creates no property rights but merely attaches consequences, federally defined, to rights created under

state law.” United States v. Craft, 535 U.S. 274, 278 (2002) (internal citations and quotation marks

omitted).

III. ANALYSIS

A. Defendants’ Objections

To begin, the Government asserts that Defendants’ objections are not properly before the Court

because they failed to submit the objections pursuant to 28 U.S.C. § 3202(d)’s procedural requirements,

and that Defendants lack standing to object because they disclaimed the property interests held in the

Trusts. 8 The FDCPA provides two statutory avenues for a defendant or interested party to object to a

garnishment. 28 U.S.C. §§ 3202(d), 3205(c)(5). The Government argues that because none of

Defendants’ objections indicate whether the filing was served on the Garnishees, the objections should

be rejected as procedurally deficient. The Court disagrees.

8
Gov.’s Cross-Mot. Garnishment 8, 10, ECF No. 433.
3
Case 4:24-cr-00287-O Document 455 Filed 04/29/26 Page 4 of 11 PageID 13112

Typically, under the FDCPA, an incomplete certificate of service does not bar a filing when the

party has actual notice of the proceeding. See United States v. Potts, No. 4:09-CR-79-3, 2025 WL

3633213, at *6 (E.D. Va. Dec. 15, 2025). Moreover, the Court has discretion to extend time for service.

Thompson v. Brown, 91 F.3d 20, 21 (5th Cir. 1996) (holding that courts have discretion to extend time

for service, even if no good cause exists for the delay). Accordingly, the Court finds that the substance

of Defendants’ objections are properly before the Court.

The Government’s standing argument similarly lacks merit. Because the Government seeks final

writs that implicate Defendants as judgment debtors on the basis that Defendants have an interest in the

Trusts’ assets, Defendants have standing to litigate the issue. See United States v. Latorre, No. 3:12-CR-

439-D 01, 2014 WL 3530830, at *2 n.4 (N.D. Tex. July 16, 2014) (“The United States also argues that

Latorre does not have standing to object to the garnishment of the joint checking accounts because he

has disclaimed any interest in the accounts. Because the court determines that the property in question

is not exempt, the court assumes arguendo that Latorre has standing to object to the garnishment.”).

B. Nominee Status

Defendants’ and the Trustee’s objections to the writs of garnishment make essentially two

arguments in opposition: (1) that Defendants’ do not have any substantial nonexempt interests in the

Trust assets; 9 and (2) that Defendants transfer of wealth to their trusts between 2022 and 2023 was “legal

and commonplace estate planning.” 10 The Government argues that the Trusts are simply Defendants’

nominees because Defendants continue to enjoy the benefits of the property contained in the Trusts. 11

The Court agrees with the Government and finds that the Trusts hold Defendants’ assets as Defendants’

nominees.

9
See e.g., Def. Hockridge’s Obj. 2–3, ECF No. 412; Def. Reis’ Obj. 3–5, ECF No. 423.
10
E.g., ECF No. 418 at 4.
11
Gov.’s Mot. Garnishment 7–11, ECF No. 433.
4
Case 4:24-cr-00287-O Document 455 Filed 04/29/26 Page 5 of 11 PageID 13113

A nominee is a person who holds legal title to a property for the benefit of another. Oxford

Capital Corp. v. United States, 211 F.3d 280, 284 (5th Cir. 2000). “Whether property is held by a []

nominee is determined by reference to state law, but when the law of the forum state does not set forth

a test for determining whether an entity is the nominee of another, the court is ‘guided by the common-

law factors generally applied by federal courts to determine the existence of a nominee relationship.’”

United States v. Fields, No. Civil Action No. 3:06CV697, 2009 WL 605775, at *5 (S.D. Miss. Mar. 9,

2009) (quoting May v. United States, No. 07–10531, 2007 WL 3287513, at *2 (11th Cir. Nov. 8, 2007)).

The Trusts were created pursuant to Nevada law, so the Court looks there first. 12 Nevada law recognizes

the nominee theory but “does not appear to address the factors necessary to determine whether an entity

is the nominee of a taxpayer.” United States v. Steele, No. 3:18-cv-00063, 2019 WL 2411422, at *9 (D.

Nev. June 7, 2019), aff’d, 830 F. App’x 250 (9th Cir. 2020). Consequently, the Court looks to federal

court nominee factors. Id.

In the Fifth Circuit, courts generally consider the following non-exclusive factors to establish

nominee status: “(1) whether adequate consideration was given by the nominee for the property; (2)

whether the property was placed in the name of the nominee in anticipation of a suit or occurrence of

liabilities; (3) whether there is a close relationship between the transferor and the nominee; (4) whether

the conveyance was recorded; (5) whether the transferor retained possession of the property; and (6)

whether the transferor continued to enjoy the benefits of the property.” United States v. Dolenz, No. 3-

09-CV-1311-O-BD, 2011 WL 4351558, *2 (N.D. Tex. June 16, 2011) (citing Oxford Cap. Corp., 211

F.3d at 284 n.1), report and recommendation adopted, No. 3:09-CV-1311-O, 2011 WL 4348295 (N.D.

Tex. Sept. 15, 2011). At bottom, nominee status is determined by whether Defendants engaged in “a

legal fiction’ by placing title to property in the hands of a third party, while retaining some or all of the

12
See Def. Reis’ Resp. 10 n.12, ECF No. 445
5
Case 4:24-cr-00287-O Document 455 Filed 04/29/26 Page 6 of 11 PageID 13114

benefits of actual ownership.” Ogle v. Cabelka, No. 7:21-CV-00129-O-BP, 2023 WL 4980954, at *2

(N.D. Tex. July 17, 2023) (internal citation omitted).

First, the Government argues that the uncontested fact that the Trusts received no consideration

for the assets that they received from Defendants supports its nominee theory. 13 Defendants respond that

Nevada law does not require consideration for the transfer of assets to the trustees of an irrevocable

trust. 14 Because consideration was not required for formation of the Trusts at issue, the Court finds that

this the first factor weighs neutrally.

Second, the Government argues that the Trust assets were placed in the Trusts’ name in

anticipation of a suit or liabilities as evidenced by the names of Trusts 15 and the fact that Defendants’

counsel had suggested the possibility of sequestering funds from Defendants’ “estate planning that would

be sufficient to satisfy any potential monetary liability under the Government’s theory at the time.” 16

Defendants respond that the Trusts were created and funded by November 2022 prior to Defendants’

having an reason to suspect that would be subject to investigation or restitution. 17 The Court disagrees

with Defendants.

“Having defrauded the government out of a significant sum of money, any reasonable person

should have believed a criminal investigation would be possible.” United States v. Brantley, Criminal

Action No. 4:15-CR-0225-O, 2019 WL 8012585, at *5 (N.D. Tex. Nov. 8, 2019) (O’Connor, J.), aff’d,

816 F. App’x 934 (5th Cir. 2020). Regardless of Defendants’ subjective intentions regarding estate

planning, the Government has presented sufficient evidence that Defendants anticipated a criminal

investigation as a result of the fraud they committed prior to the creation of the Trusts. Such anticipation

13
Gov.’s Mot. Garnishment 13, ECF No. 433.
14
See e.g. Def. Hockrige’s Resp. 12, ECF No. 444.
15
Two of the Trusts were originally named as the Reis and Hockridge “Family Protection Trust.”
16
Def. Hockridge’s Obj. SEI’s Answer 3, ECF No. 424.
17
See Def. Ries’s Resp. 16, ECF No. 445; Def. Hockrige’s Resp. 12, ECF No. 444.
6
Case 4:24-cr-00287-O Document 455 Filed 04/29/26 Page 7 of 11 PageID 13115

of investigation is necessarily accompanied by anticipation of the potential consequences of a criminal

investigation, namely, restitution liability.

That Defendants were not necessarily facing restitution liability at the moment they transferred

the assets into the Trusts does not negate the evidentiary significance of Defendants’ anticipated

liabilities. Nassar Family Irrevocable Tr. v. United States, No. 13 CIV. 5680 (ER), 2016 WL 5793737,

at *9 (S.D.N.Y. Sept. 30, 2016). The fact remains that Defendants anticipated restitution liability and

transferring their assets into the Trusts has insulated them from a number of future liabilities and could

theoretically insulate them from restitution liability. Id. (finding that the defendant’s transfer of property

to a trust had insulated him from various liabilities including “his criminal restitution”). Accordingly,

the Court finds that the third factor weighs in favor of the Trusts’ nominee status.

With regard to the third factor, Defendants clearly have a close relationship with the Trusts. It is

undisputed that both Defendants were—at one time or another—family trustees of the Trusts, that

Hockridge is a trust beneficiary, and one of the current family trustees is Defendant Hockridge’s father.

See United States v. Washington, Civil Action No. H-09-3996, 2011 WL 3902737, at *19 (S.D. Tex.

Sept. 6, 2011) (finding that the close relationship factor weighed in favor of nominee status because two

of the five trust owners were defendant’s children). Regardless of the scope of Defendants’ authority

over the Trusts, which Defendants argue was limited, Hockridge’s status as beneficiary of two of the

trusts combined with the close family ties is sufficient for this factor to weight in favor of nominee status.

See Nassar Fam. Irrev. Tr., 2016 WL 5793737, at *8 (finding the “fact that Nassar is both a beneficiary

and trustee of the Trust” as “indicative of a close relationship” between them).

The Government argues that the fifth and sixth 18 factors, weigh heavily in favor of the Trusts’

nominee status because Defendants’ and their entities have been able to obtain and use millions of dollars

18
The Government does not contest that the fourth factor weighs against nominee liability since the formation
and funding of the trusts appears to have been recorded in accordance with applicable law.
7
Case 4:24-cr-00287-O Document 455 Filed 04/29/26 Page 8 of 11 PageID 13116

from the Trusts for their benefit. Defendants attempt to explain away—but do not deny—the millions of

dollars disbursed from the Trusts to pay for, amongst other things, Hockridge’s “living space” and

Defendants’ legal fees. 19 The Government has presented sufficient evidence to show that Defendants

effectively retained possession of the Trust assets; and that they continued to enjoy the benefits of the

property.

Defendants and the Trustee argue extensively that the formation of the Trusts was in accordance

with Nevada law and that the Trusts have operated in accordance with the applicable laws and the Trusts’

instruments. But these arguments miss the central inquiry of whether a nominee relationship exists. The

inquiry should be aimed at determining whether Defendants “exercised active or substantial control over

the property.” United States v. Evseroff, No. 00-CV-06029 KAM, 2012 WL 1514860, at *10 (E.D.N.Y.

Apr. 30, 2012), aff’d, 528 F. App’x 75 (2d Cir. 2013) (quoting Richards v. United States (In re

Richards), 231 B.R. 571, 579 (E.D.Pa.1999)). Compliance with certain rules does not negate the benefits

Defendants received nor the control they exercised. Nassar Fam. Irrev. Tr., 2016 WL 5793737, at *8

n.12 (“The critical issue in resolving a nominee . . . claim is not motive, but control.” (citation modified)).

Accordingly, the Court finds that the relationship between the Defendants and their Trusts is a nominee

relationship and the Trusts are subject to garnishment. See Crimson Ventures & Consulting LLC v.

United States, No. 5:24-CV-018-H, 2024 WL 3841614, at *8 (N.D. Tex. Aug. 14, 2024) (finding

nominee relationship where party had “very close relationship” with entity and made “personal use” of

entity’s funds). 20

C. The Remaining Objections

First, Defendants challenge the writ issued to Balentine as improper, arguing that Balentine does

not have custody of the financial accounts in question (because the assets in those accounts are custodied

19
See Def. Reis’ Resp. 17, ECF No. 445; Def. Hockridge’s Resp. 15, ECF No. 444.
20
Because the Court finds that the Trusts are subject to garnishment under the nominee theory, the Court does not
reach the Government’s other arguments.
8
Case 4:24-cr-00287-O Document 455 Filed 04/29/26 Page 9 of 11 PageID 13117

by the other garnishee, SEI). 21 But as the Government points out,

“Balentine’s answer states that its affiliate ‘acts as the general partner’ for certain partnerships in which

the trusts are ‘limited partners in private investment funds.’” 22 Because the FDCPA provides that the

Government may garnish a partnership interest by naming “any partner other than the debtor” as the

“garnishee on behalf of the partnership” the Court finds that the writ is proper as to Balentine. See §

3205(b)(2)(B).

Second, Hockridge argues that “the assets in the trusts now subject to garnishment are not

proceeds of any crime.” 23 But the origin of the assets to be garnished is not a statutory requirement under

18 U.S.C. § 3613(c) which creates a lien on “all property and rights to property” that Defendant possess.

See United States v. Ogbemudia, 361 F. App’x 583, 583–84 (5th Cir. 2010) (noting government’s efforts

to enforce restitution order are “distinct from a forfeiture proceeding” and do not require tracing to the

origin).

Finally, Hockridge also raises a collateral attack on the restitution order itself, alleging that it is

“constitutionally infirm” because the Court imposed restitution “without any jury findings.” 24 This

argument is likewise misplaced. “It is well-settled that a defendant may not use a garnishment proceeding

to challenge the underlying judgment and restitution order in [her] case.” United States v. Onyeri, 996

F.3d 274, 281 (5th Cir. 2021). Accordingly, the Court overrules Defendants’ objections.

D. Defendant’s Request for Hearing

Defendants request a hearing under § 3205(c)(5). 25 Defendants have not disputed the essential

evidence that underpins the Court’s finding of the Trusts’ nominee status nor have Defendants indicated

with specificity the evidence they would present at a hearing. Regardless, Defendants’ request for a

21
See e.g., Def. Hockridge’s Obj. 2, ECF No. 412.
22
Gov.’s Cross-Mot. Garnishment 17–18, ECF No. 433 (quoting Balentine LLC’s Answer 3, ECF No. 397).
23
Def. Hockridge’s Obj. SEI’s Answer 6, ECF No. 424.
24
Def. Hockridge’s Obj. SEI’s Answer 8, ECF No. 424.
25
See e.g., Def. Reis’ Resp. 14, 21, ECF No. 445.
9
Case 4:24-cr-00287-O Document 455 Filed 04/29/26 Page 10 of 11 PageID 13118

hearing is fatally deficient because none of the objections raised fall within the scope

of § 3205(c)(5) triggering a mandatory hearing.

Though the Fifth Circuit has not directly addressed it, the plain language interpretation

of § 3205(c)(5) indicates that a hearing under § 3205(c)(5) is warranted only where the objections filed

are to an answer. See e.g., § 3205(c)(5) (“[T]he judgment debtor . . . may file a written objection to the

answer.” (emphasis added)). Where, as here, Defendants’ objections are to the writs of garnishment

themselves, the objections do not fall “within the scope of § 3205(c)(5) triggering a mandatory hearing.”

United States v. Ingleman, No. 3:12-CV-1597-B, 2013 WL 12137733, at *3 (N.D. Tex. June 26, 2013).

Despite titling their filings as objections to the Garnishees’ answers, all of Defendants’ objections

are attempts to attack the writs themselves. 26 To the extent Defendants direct their objections to the

Garnishees’ answers, they are agreeing—not objecting—to the contents of the answers. 27 At bottom,

Defendants’ objections are to the characterization of the Trusts’ assets as garnishable property. But

objections to the characterization of property “is not an objection to the garnishee’s answer, but to the

garnishment generally” and thus, do not trigger a hearing. Id. Accordingly, Defendants have not made

an objection within the scope of § 3205(c)(5) that would trigger a mandatory hearing and their request

for a hearing is DENIED.

IV. CONCLUSION

For the forgoing reasons, the Family Trustee’s Petition to Modify the Writs of Garnishment (ECF

No. 428) and Defendants’ Claims for Exemption and Requests for Hearing (ECF Nos. 430, 431, 435)

are DENIED. The Government’s Cross-Motion for Final Order of Garnishment (ECF No. 433) is

26
See e.g., Def. Hockridge’s Obj. Garnishee Balentine’s Answer 3, ECF No. 412 (“To the extent the writs attempt
to garnish the assets in the trusts, the writs exceed their permitted authority.”); Def. Reis’ Obj. Garnishee
Balentine’s Answer 4, ECF No. 418 (“The government provides no authority to support its claimed ability to
garnish trust assets to satisfy a restitution judgment[.]”).
27
See e.g., Def. Hockridge’s Obj. Garnishee Balentine’s Answer 2, ECF No. 412.
10
Case 4:24-cr-00287-O Document 455 Filed 04/29/26 Page 11 of 11 PageID 13119

GRANTED. Any objection or argument not explicitly addressed herein would not have affected the

Court’s ruling and is overruled. The final order of garnishment will be docketed separately.

SO ORDERED this 28th day of April, 2026.

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