On or about __________ , in the ___________ District of __________, JOHN DOE, defendant herein, knowingly and fraudulently withheld the canceled checks of XYZ Company relating to the financial affairs of the debtor from the trustee and the United States Trustee, XYZ Company, then being in bankruptcy under Title 11, Case No. ______.
All in violation of 18 U.S.C. § 152(9).
[cited in USAM 9-41.001]