On or about __________ , in the ____________District of _______________
JOHN DOE, defendant herein, in the case of Southeast Banking, No._________, a case under Title 11, knowingly and fraudulently agreed to pay Jane Roe, a competing bidder at a bankruptcy auction for the sale of a Beechcraft King Air aircraft, $20,000 in return for Jane Roe agreeing not to make further bids for said aircraft.
All in violation of 18 U.S.C. § 152(6).
[cited in JM 9-41.001]