Sample IndictmentConcealing Assets, 18 U.S.C.
- At all times material to this indictment defendant JOHN DOE was
of Robert Roe Nursery, Inc.which was a tree nursery.
- On ________ JOHN DOE filed or caused to be filed a petition for
reorganization under Chapter 11 of Title 11 of the United States Code in the
Bankruptcy Court for this District. The matter was captioned Robert Roe
Inc., Case No______. This case remained open at all times pertinent to this
- As a debtor under Chapter 11, Robert Roe Nursery, Inc., was
to continue business as a Debtor in Possession. As such the company was
to close existing bank accounts and to open two new accounts; one entitled
Roe Nursery, Inc., Debtor in Possession; and one entitled Robert Roe
Inc., Debtor in Possession (Payroll) and to place all moneys received into
of those accounts. All disbursements were required to be made from one of
- From on or about the _____day of ______ , to on or about ______day
of ______, in the ______District of________,
defendant herein, did knowingly and fraudulently conceal and cause to be
concealed from creditors and from the United States Trustee the following
accounts receivable which were the property of the bankruptcy estate and
he deposited or caused to be deposited into a personal account entitled
Count Date of Deposit Acct. Rec. Ck. No. Amount
One 11/7/94 Sun Gardens 5215 $6,583.30
Two ---------- etc.
All in violation of 18 U.S.C. §§ 152(1) and 2.
[cited in USAM 9-41.001]