857

Sample Indictment—Attorney's Fee, Bankruptcy Fraud, 18 U.S.C. § 152(6)

At all times pertinent to this indictment defendant, JOHN DOE, was an attorney specializing in bankruptcy law. At all times pertinent to this indictment Richard Roe, debtor in bankruptcy case -------, was a client of JOHN DOE. Prior to ----- date when Richard Roe filed bankruptcy, he owed JOHN DOE $75,000 in legal fees. Neither JOHN DOE nor his law firm was listed as a creditor in the bankruptcy case. On or about _____________, in the _________ District of _________, JOHN DOE, defendant herein, knowingly and fraudulently received a promise from Richard Roe in the form of a "Reviver Agreement" that his law firm would be paid $75,000 by the debtor in return for forbearing to file a claim as a creditor against the debtor. All in violation of 18 U.S. C. § 152(6). [cited in USAM 9-41.001]