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

(Prior to November 1994, § 153 did not cover employees of trustee or other officers of the court.)

From on or about ________, to on or about ___________ in the ___________ District of ______, JOHN DOE, defendant herein, knowingly and fraudulently appropriated to his own use funds which belonged to the Chase Bankruptcy Estate, Case No. ________ and which came into his charge and custody as Trustee of the Chase Bankruptcy Estate.

All in violation of 18 U.S.C. §§ 153 and 2.

[cited in JM 9-41.001]

Updated January 21, 2020