From on or about ________ until on or about _____________,in the_______District of____, JOHN DOE and JANE DOE, defendants herein, individually and as officers and agents of Bust Out Company ------, debtor, Bankruptcy Case No. __________ and in contemplation of the filing of bankruptcy proceedings by [against] said company, knowingly and fraudulently and with intent to defeat the provisions of Title 11, transferred to, and wilfully aided and abetted in the transfer to, themselves property belonging to the estate of the debtor, specifically, cash and clothing: by causing to be ordered and received large amounts of men's clothing; by paying for only a small portion of the clothing ordered; by causing to be sold and by secreting all but a small portion of the clothing ordered and received; and by keeping for themselves a large amount of the clothing and cash proceeds from the sale of the clothing, thereby causing a loss of assets to the debtor of cash and clothing, and by concealing the existence of the cash and clothing from the trustee, creditors and other officers of the court.
All in violation of 18 U.S.C. §§ 152(7) and 2.
[cited in JM 9-41.001]