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United States v. Reynolds

United States District Court, D. New Jersey

December 18, 2019

UNITED STATES OF AMERICA
v.
MELISSA REYNOLDS, Defendant.

          CRAIG CARPENITO United States Attorney

          By: ANT HONY MOSCATO LAKSHMI HERMAN Assistant United States Attorneys

          ROBERT DEGROOT, ESQ. ATTORNEY FOR DEFENDANT MELISSA REYNOLDS

          MELISSA REYNOLDS, DEFENDANT

          CONSENT JUDGMENT AND ORDER OF FORFEITURE (MONEY JUDGMENT)

          HONORABLE JOHN M. VAZQUEZ UNITED STATES DISTRICT JUDGE

         WHEREAS, on or about November 14, 2018, defendant Melissa Reynolds pleaded guilty pursuant to a plea agreement with the United States to a one-count Information, which charged her with conspiracy to commit mail and bank fraud, contrary to 18 U.S.C. §§ 1341 and 1344, in violation of 18 U.S.C. § 1349;

         WHEREAS, pursuant to 18 U.S.C. § 982(a)(2)(A), a person convicted of conspiracy to commit mail and bank fraud, contrary to 18 U.S.C. §§ 1341 and 1344, in violation of 18 U.S.C. § 1349, which affects a financial institution, as alleged in the Information, shall forfeit to the United States all property, real and personal, constituting, or derived from, proceeds the person obtained directly or indirectly as a result of such violation;

         WHEREAS, in the plea agreement, the defendant consented to the imposition of a criminal forfeiture money judgment in the amount of $548, 242, and stipulated that such amount represents the property constituting, or derived from, proceeds the defendant obtained directly or indirectly as a result of the violation charged in the Information;

         WHEREAS, Rule 32.2(c)(1) of the Federal Rules of Criminal Procedure provides that no ancillary proceeding is required to the extent that the forfeiture consists of a money judgment;

         WHEREAS, Rule 32.2(b)(4)(A) of the Federal Rules of Criminal Procedure provides that a preliminary order of forfeiture, including a preliminary order of forfeiture consisting of a money judgment, may become final at any time before sentencing if the defendant consents;

         WHEREAS, defendant Melissa Reynolds:

         (1) Consents to the forfeiture to the United States of $548, 242 as a sum of money representing the property constituting, or derived from, proceeds the defendant obtained directly or indirectly as a result of the offense charged in the Information, to which the defendant has pleaded guilty;

         (2) Consents to the imposition of a money judgment in the amount of $548, 242 pursuant to 18 U.S.C. § 982(a)(2)(A) (the "Money Judgment"), and agrees that this Order is final at the time of its entry by the Court, pursuant to Rule 32.2(b)(4)(A) of the Federal Rules of Criminal Procedure;

         (3) Agrees to consent promptly upon request to the entry of any orders deemed necessary by the government or the Court to complete the forfeiture and disposition of ...


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