United States District Court, E.D. Michigan, Southern Division
MATTHEW SCHNEIDER United States Attorney NANCY A. ABRAHAM
Assistant United States Attorney
BARRY
A. WOLF Attorney for Defendant
STIPULATED PRELIMINARY ORDER OF FORFEITURE
HON.
MATTHEW F. LEITMAN, UNITED STATES DISTRICT JUDGE
The
United States of America, by and through its attorneys,
MATTHEW SCHNEIDER, United States Attorney for the Eastern
District of Michigan, and NANCY A. ABRAHAM, Assistant United
States Attorney, together with Defendant DOMINIQUE GILBERT
(“Defendant”), through his attorney, BARRY A.
WOLF, ESQ., hereby submit this Stipulated Preliminary Order
of Forfeiture:
1. A
First Superseding Information was filed on or around May 16,
2019, which charged Defendant with Count One, Possession of
Device-Making Equipment, in violation of 18 U.S.C. §
1029(a)(4), and Count Two, Aggravated Identity Theft/Aiding
and Abetting, in violation of 18 U.S.C. § 1028A(a)(1),
18 U.S.C. § 2. (ECF No. 17).
2. The
Superseding Information provided notice that upon
Defendant's conviction on Count One of the First
Superseding Information, the government's intended to
forfeit, pursuant to 18 U.S.C. §§ 982(a)(2)(B), any
property constituting, or derived from, proceeds obtained,
directly or indirectly, as a result of such violation, and
pursuant to 18 U.S.C. § 1029(c)(2), any personal
property used or intended to be used to commit the offenses.
3. On
or about May 28, 2019, the defendant pleaded guilty to Counts
One and Two of the First Superseding Information. In his Rule
11 Agreement (ECF No. 20) the Defendant also agreed to
forfeit his interest in the following property to the United
States, pursuant to 18 U.S.C. §§ 982(a)(2)(B),
1029(c)(2) and 28 U.S.C. § 2461(c):
• Acer Laptop, serial number LXRGK02015121416CF1601;
• Dell Laptop, serial number CXPW562;
• Five Flash Drives;
• Apple Cellular Telephone, serial number DNPWF341JCL7;
• ASUS Laptop model number 726NGW
• Pointman ID Card ...