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872. Sample Indictment—Embezzlement by Trustee or Employee, 18 U.S.C. §§ 153 and 645

From on or about ----, to on or about ------ in the -------District of -----,

JOHN DOE,

defendant herein, being an employee of Richard Roe, trustee for the bankruptcy estate of John Chase, Bankruptcy Case No. ------, did unlawfully retain and convert to his own use [or to the use of another] approximately $118,000 in money belonging to said estate, which money came into his hands by virtue of his employment with United States Trustee Richard Roe and the official position of Richard Roe.

All in violation of 18 U.S.C. § 645.

[cited in USAM 9-41.001]

Updated May 26, 2015