On or about_________ , in the ______________District of __________, JOHN DOE, defendant herein, in contemplation of a bankruptcy case under Title 11 of the United States Code by XYZ Company, specifically the case entitled XYZ Co, Case No.________, filed __________ in this district, and with the intent to defeat the provisions of Title 11, knowingly and fraudulently transferred to ABC, Inc., a corporation owned in part by John Doe, 36 vehicles titled to XYZ Company. The vehicles are described as follows:
1988 Ford Tractor
All in violation of 18 U.S.C. §§ 152(7) and 2.
[cited in USAM 9-41.001]