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United States v. Kern

United States District Court, D. Nevada

December 23, 2019

UNITED STATES OF AMERICA, Plaintiff,
v.
PATTI KERN, Defendant.

          NICHOLAS A. TRUTANICH UNITED STATES ATTORNEY

          DANIEL D. HOLLINGSWORTH ASSISTANT UNITED STATES ATTORNEY

          MICHAEL KERN MICHAEL K. KERN AS TRUSTEE OF THE KERN PATTI ANN KERN

          STIPULATION FOR ENTRY OF ORDER OF FORFEITURE AS TO MICHAEL KERN AND MICHAEL K. KERN AND PATTI ANN KERN, AS TRUSTEES OF THE KERN FAMILY TRUST DATED SEPTEMBER 26, 2006, AND ORDER

          RICHARD F. BOULWARE, II UNITED STATES DISTRICT JUDGE.

         The United States of America, Michael Kern, and Michael K. Kern and Patti Ann Kern, as Trustees of the Kern Family Trust dated September 26, 2006 (Trust), agree as follows:

         1. The government filed a One-Count Criminal Information against Patti Kern for violations of 18 U.S.C. §§ 1341 and 1349. Information, ECF No. 8.

         2. Patti Kern pled guilty to Count One of a One-Count Criminal Information charging her with conspiracy to commit mail fraud in violation of 18 U.S.C. §§ 1341 and 1349 and agreed to the forfeiture of property set forth in the Plea Agreement and the Forfeiture Allegation of the Criminal Information. Criminal Information, ECF No. 8; Change of Plea, ECF No. 14; Plea Agreement, ECF No. 10.

         3. Patti Kern agreed to the substitution and forfeiture of property as set forth in the Plea Agreement pursuant to Fed. R. Crim. P. 32.2(e) and 21 U.S.C. § 853(p).

         4. Michael Kern and the Trust knowingly and voluntarily agree to the abandonment, the civil administrative forfeiture, the civil judicial forfeiture, or the criminal forfeiture of the following property:

1. $106, 150;
2. $20, 400.32;
3. $34, 364;
4. $40, 010;
5. $50, 126.59;
6. $4, 998;
7. $10, 908;
8. $15, 278;
9. $6, 975;
10. $4, 644.;
11. $3, ...

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