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THE GRAND JURY CHARGES:
Jurisdictional Allegations (long form)
1. At all times material to this Indictment the (name of
employee benefit plan) was an employee [welfare]/ [pension] benefit
plan, within the meaning of and subject to Title I of the Employee
Retirement Income Security Act of 1974, as amended (hereafter ERISA) (29
U.S.C. 1001-1169), established and maintained by [ (name of union)
(hereinafter "Union"), an employee organization],/[ (name of
employer) , an employer],/[both (name of union) , an
employee organization and (name of employer) , an employer], for
the benefit of the [members of (name of union) ]/[employees of
(name of employer)].
2a. The (name of union) was an employee organization which
represented employees engaged in commerce and in an industry and
activity affecting commerce as those terms are defined in ERISA (29
U.S.C. 1002-1003)].
2b. The (name of employer) was an employer engaged in
commerce and in an industry and activity affecting commerce as those
terms are defined in ERISA (29 U.S.C. 1002 and 1003).
3a. At all times material to the Indictment (name of recipient)
, was (a)n [administrator]/[officer]/[trustee]/
[custodian]/[counsel]/[agent]/[employee] of the plan.
3b. At all times material to this Indictment, (name of
recipient) , was a[n] [officer]/[counsel]/[agent]/[employee] of an
employer some of whose employees were covered by the plan.
3c. At all times material to this Indictment, (name of
recipient) , was a[n] [officer]/[counsel]/[agent]/[employee] of the
Union, some of whose members were covered by the plan.
3d. At all times material to this Indictment, (name of
recipient) , was a[n] [person who provided benefit plan services to
the plan]/[officer]/[counsel]/[agent]/[employee] of (name of
organization) , an organization which provided benefit plan services
to the plan.
4. [Operative paragraph concerning payment or offer, solicitation or
receipt.]
[cited in USAM 9-134.010] |