On or about __________ , in the _________ District of ________, JOHN DOE, defendant herein, knowingly and fraudulently falsified financial records of XYZ Company, then a debtor under Title 11, Case No. _______, relating to its property, by altering the debtor company's records to show that John Smith had paid his account in full, when JOHN DOE well knew the account had not been paid.
All in violation of 18 U.S.C. § 152(8).
[cited in USAM 9-41.001]