Case 1: 19- c?r? ?00037 JJM- PAS Document 3 Filed 04/09/19 Page 1 of 24 PageID 3

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UNITED STATES DISTRICT COURT g3? 93$ Gt}
FOR THE DISTRICT OF RHODE We ?395 Sigiiz?v

UNITED STATES OF AMERICA Criminal Case No.
. In violation of 18 U.S.C. 1343 (Wire
Fraud), 18 U. S. C. 1957 (Money
Laundering), 26 U. S. C. 7201 (Tax
THOMAS HULING Evasion) . g- 9 0
INDICTMENT I
The Grand Jury charges that:
GENERAL ALLEGATION 
Introduction

At times relevant to this Indictment:

1. Defendant THOMAS HULING resided in East Greenwich and West
Warwick, Rhode Island. Between approximately 2000 and 2008, defendant HULING
was a mortgage broker.

2. Between approximately 2008 and 2018, HULING held himself out as an
. investment broker, entrepreneur, and funds manager, soliciting funds, including loans,
from individual investors for various purported investment projects.

3. The Internal Revenue Service was an agency of the United States
Department of the Treasury responsible for administering and enforcing the tax laws of
the United States, and collecting taxes owed to the United States.

4. In general, individual taxpayers are required to report their income, any
allowable deductions, and tax liability on US. Individual Income Tax Returns, Forms

1040 (?Forms 1040?), and related IRS Schedules and Forms attached thereto.

?Pea.
i. 

 

 

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5. US. Income Tax Returns for an Corporation, Forms 11208 (?Forms
11208?), are a type of annual return used by corporations to declare receipts, income,
and deductible expenses. 8 Corporations do not themselves have tax liability for net

business income. Instead, the Corporation?s owner reports any net business income

 

ul? loss fiuf? the Corporation as ?flow through? incmne or loss um the manta 
104:0.
Huling?s Scheme to Defraud Investors

6. From in or about 2008 to in or about October 2018, THOMAS HULING,
the defendant, did knowingly and willfully devise a scheme and artifice to defraud
investors who entrusted funds to him, and to obtain money from these investors by
means of materially false and fraudulent pretenses, representations, and promises. To
execute the scheme, HULING, among other things: solicited millions of dollars of
funds under false pretenses, and by making false and fraudulent promises and
representations to induce the investors; (ii) misappropriated and converted investors?
funds to own benefit and the benefit of others without the knowledge or
authorization of the investors; lulled the investors with false and fraudulent excuses
and promises in order to discourage legal action when the investors complained that
their funds had not been returned as promised; (iv) placated and appeased certain
earlier by paying them back using new investor monies; and used multiple

nominee entities and shell companies, and multiple bank accounts to receive, transfer,

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and spend investor proceeds, thereby attempting to obfuscate the source and
disposition of funds.

7. It was part of fraud scheme that he would and did solicit
funds from investors by making false and fraudulent promises and representations.
HULING represented and led investors to believe that the funds they provided would 
be used for the investment projects he was promoting, and that substantial investment
returns that carried little to no risk would be realized within short periods of time. To
enhance his credibility and build trust, HULING, among other things, would at times
incorporate religion and the possibility of charitable good works into his sales pitch,
and claim that he had association with well-known individuals who in turn had interest
in his investments. HULING would also promote different projects to the same
investor to improve his chances at obtaining funds. Examples of false and
fraudulent inducements, promises, and representations include, but are not limited to:

a. Between in or about 2008 and in or about 2011, defendant HULING
fraudulently solicited investors to provide funds for offshore ?private placement?-
investments and high-yielding bond trading platforms by leading the investors to
believe he would use their funds for these investments. HULING promised high
returns within a short time frame, including returns to some investors as high as 450

percent within forty days. HULING further led these individuals to believe the

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purported trading platforms and investment funds he was pitching carried little if any
risk;
b. Between in or about 2010 and in or about 2016, defendant HULING

solicited funds from investors, including two to whom he pitched the high-yielding

 

 

i1 acting platfunn luv ing and de Clupli 1g
technology originating in Germany designed to reduce car emissions. HULING made
false and fraudulent representations concerning, among other things: how the funds
provided by the investors would be used; (ii) outside interest in the technology by well-
known individuals; and the investors? degree of ownership in the technology and
related business; and

c. Between in or about 2017 and in or about 2018, defendant
HULING raised funds from investors purportedly for an internet marketing and
advertising platform for businesses. To lure these individuals, HULING, among other
things, represented that the funds provided by the investors would be used for the
purchase and development of the marketing program.

8. It was part of the scheme that, upon receiving funds from the investors

into bank accounts he controlled, defendant HULING misappropriated, diverted,
converted, and spent investor monies to fund his lifestyle. Such expenditures

included, but were not limited to: funding for substantial improvements to his

residence; multiple luxury vehicles, including a Cadillac Escalade and a Mercedes Benz;

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and scooters; membership and golf fees at multiple country clubs and golf
courses; clothes and fashion; food, including substantial spending at restaurants; family
pet expenses; vacations and travel; and gambling at casinos. Between 2008 and 2018,

defendant spent millions in investor funds on living expenses, unbeknownst to the

 

 

 

investors, and contrary to the repr esentatiuns he inadetUT'ltent.

9. It was further part of the scheme that when the promised returns did not
materialize, and the investors expressed their worry and concern to HULING about
their investments, defendant attempted to lull the investors and string them along with
false and fraudulent excuses and promises. Often times HULING refused to return
calls and avoided speaking to investors.

10. It was part of the scheme that HULING further attempted to placate and
appease earlier investors by paying them with funds raised from new investors. For
example, HULING would and did fraudulently repay certain trading platform
investors with funds raised from car emissions technology investors.

11. It was part of scheme that he used multiple entities and shell
companies, as well as multiple bank accounts at different domestic and foreign banks,
to commingle, obfuscate and conceal the source, movement, and disposition of investor
funds. Between in or about 2008 and 2018, defendant opened more than fifty bank
accounts at nine different banks using approximately eight different entity names.

Defendant commingled funds from different investment projects, executed multiple

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transfers between accounts, and ultimately withdrew funds from multiple accounts
using debit cards, checks, and substantial cash to pay for personal expenditures. The
entities defendant HULING established and used to facilitate his scheme to defraud

included, but were not limited to:

 

 

 

TH Enter prises, LLC 
b. Global Funding Group, 
c. Global Investment Company, 
d. 46 Well Realty, 
e. Global Technology, 
f. World Holding Group, and
g. WebDreams, LLC.
12. It was in furtherance of the scheme that defendant HULING, between
2008 and 2018, used interstate wires and electronic communications to receive funds
from investors, to pay funds to investors, to communicate with investors, to transfer
funds between bank accounts, and to withdraw funds from bank accounts to spend on
his lifestyle.
13. HULING fraudulently obtained approximately $14 million in investor
funds. While paying earlier investors back with new investor monies as part of his

scheme, HULING caused a loss to the remaining investors totaling more than $6

million.

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The Tax Evasion Scheme

14. Between in or about 2009 through in or about April 2018, defendant
HULING, while defrauding investors, simultaneously endeavored to defraud the
United States. While living a lifestyle supported by investors? funds, defendant

and committed mulH ?l
affirmative acts in an effort to conceal his income and mislead the IRS.

15. In or about June 2009, defendant I-IULING belatedly filed, after the
deadline imposed by law, a joint US. Individual Income Tax Return for 2007,
acknowledging that he had an income tax due and owing totaling $26,520. Defendant
did not pay his self-assessed tax for 2007.

16. In or about August 2009, the IRS began sending collection notices to
defendant I-IULING demanding payment of his 2007 past-due taxes. Still, HULING
did not pay the taxes due and owing.

17. Knowing full well of his outstanding tax bill for 2007, and determined to
defraud the United States concerning subsequent tax years, defendant HULING,
between 2009 and 2018, engaged in a course of conduct designed to thwart IRS
collection, conceal his income, and evade the assessment of taxes, including, but not
limited to:

a. Establishing and using multiple nominee entities and shell

companies, and utilizing multiple bank accounts at different domestic and foreign

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banks in the names of these entities, in order to conceal and obscure the source and
disposition of funds;
b. Using multiple entity and shell company bank accounts to directly

fund personal expenditures, including by using debit cards tied to those entity

 

accounts;
1 c. Making extensive use of cash;

d. Causing the manipulation and falsification of the books and
records of his entities in order to disguise his personal expenditures and conceal
distributions of income. HULING, among other things, would cause his bookkeeper to
fraudulently book as loans income he took out of shell company bank accounts when he
had no intent to repay;

e. Causing to be provided false and fraudulent information to his tax
return preparer that overstated expenses and understated income;

f. Causing to be prepared and filed with the IRS false and. fraudulent
Forms 1040 for the tax years 2009, 2010, and 2011 reporting no taxable income and no
tax due, despite knowing full Well that he had substantial income. to report, and
substantial tax to pay, for these years;

g. CauSing to be prepared and filed with the IRS false and fraudulent

Forms 11208 in which HULING claimed business expenses and corporate losses, losses

 

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that he could purportedly offset against any personal income. The fraudulent
corporate tax returns he caused to be filed, included, but are not limited to:

i. In or about November 2015, Forms 11208, for TH
Enterprises, for the tax years 2012, 2013, and 2014, claiming false and fraudulent



 

purported ?flow-through? entity whose net losses would be deductible on his
individual tax returns.

ii. In or about February 2016, Forms 11208, for 46 Well Realty,
for the tax years 2009 and 2010, claiming false and fraudulent business expenses and
?flow-through? losses to HULING as sole owner;

In or about March 2016, Forms 11205, for Global Funding
Group, for the tax years 2009 and 2010, claiming false and fraudulent business expenses

and ?flow- throug losses to HULING as sole owner;

h. Failing to file any individual income tax returns for the tax years
2012 through 2017;
i. Titling personal assets, including real estate, luxury cars, and

in the names of nominee entities; and
j. Providing false and fraudulent statements special agents on

or about December 2, 2015, after being notified of a criminal investigation, related to,

 

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among other items, his income, expenses, and business activities for the 2009, 2010, and

2011 tax years.

COUNTS ONE through TWELVE
(Wire Fraud)

18. . Paragraphs 1 through 13 of this Indictment are incorporated by reference

 

herein.
19. On or about the dates set forth below, in the District of Rhode Island and
elsewhere, the defendant,
THOMAS HULING,
for the purpose of executing and attempting to execute his above-described scheme and
artifice to Obtain money and property from investors by means of materially false and
fraudulent pretenses, representations, and promises, did cause to be transmitted in

interstate commerce by means of wire communications certain writings, signs, signals,

and sounds, the following:

 
   

Withdrawal and deposit of $20,000 between HULING
controlled accounts in Rhode Island, from Navigant
1 5/ 7/ 2014 Credit Union Account #5302 to account #6008 ,in the

- name of ?World Holding Group with wire
transmission routed through New Jersey.
Withdrawal and deposit of $10,000 between HULING
controlled accounts in Rhode Island, from Navigant
2 6/ 9/ 2014 Credit Union Account #5302 to account #6016 in the
name of "World Holding Group with wire
transmission routed through New jersey.

 

 

 

 

 

 

10

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ectromc ove1t car purc ase,
Club, using Navigant Credit Union Account #6008 in
3 8/ 2/ 2014 the name of ?World Holding Group, Rhode
Island, with electronic transfer routed through New
Jersey.

Electronic debit card purchase, $1,049 at Briden

 

 

Nurseries, usmg Nav1gant Credit Union Account
4 8/ 6/ 2014 #6008 in the name of ?World Holding Group, in
Rhode Island, with electronic transfer routed through
New Jersey.
Electronic debit card purchase, $227 at Mercedes-Benz
Warwick, using Navigant Credit Union Account
5 10/ 22/ 2014 #6008 in the name of ?World Holding Group, in
Rhode Island, with electronic transfer routed through
New Jersey.
Electronic debit card purchase, $1,892 at the Guitar
Center, using Navigant Credit Union Account #5302
in the name of Thomas Huling in Rhode Island with
electronic transfer routed through New Jersey.
Electronic debit card purchase, $4,635 at Valley
Country Club, using Navigant Credit Union Account
7 11/26/2014 #6008 in the name of ?World Holding Group, in
Rhode Island, with electronic transfer routed through
New Jersey.
Email from ?Global Technology? to Individual AZ. in
Rhode Island, via an email server located outside of
8 6/2/2015 Rhode Island, with promotional documents
concerning the car emissions technology investment
attached.
Electronic debit card purchase, $1,042 at the Foxwoods
Resort, using Navigant Credit Union Account #5802 in
Rhode Island, with electronic transfer routed through
New Jersey.
Wire Transfer of $250,000, from Individual bank
account at Washington Trust in Rhode Island to
defendant bank account, Navigant Credit
Union Account #9007 in the name of ?Global

 

 

6 11/19/2014

 

 

 

9 9/3/2015

 

10 10/14/2016

 

 

 

 

 

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Case Document 3 Filed 04/09/19 Page 12 of 24 PageID 14

   
 
 

 
 

  
 

   

.w ..

Tec ogy, LLC in one Is ans, wit ectronic
transmission routed outside of Rhode Island.

Wire transfer of $21,000, from Individual bank
account at Family Trust FCU in South Carolina to

11 1 10/ 2018 defendant bank account, Citizens Bank
Account #5419, in the name of ?WebDrearns, in

  
 

 

 

 

Rhode Island.

Wire transfer of $22,500, from Individual bank
account at Hometown Bank, in Massachusetts, to

12 2/ 20/ 2018 defendant bank account, Citizens Bank
Account #5419, in the name of ?WebDrearns, in
Rhode Island.

 

 

 

 

 

 

All in violation of Title 18, United States Code, Section 1343.

COUNTS THIRTEEN and FOURTEEN
(Money Laundering)

20. Paragraphs 1 through 13 of this Indictment are incorporated by reference
herein.

21. On or about each date listed below, in the District of Rhode Island and
elsewhere, the defendant,

THOMAS HULING,

did knowingly engage and attempt to engage in the following monetary transactions
by, through, or to a financial institution, affecting interstate or foreign commerce, in
criminally derived property of a value greater than $10,000, such property having been
derived from specified unlawful activity - wire fraud in violation of Title 18, United

States Code, Section 1848, as described below:

12

 

 

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Check #125, in the amount of $15,190, drawn on
Navigant Credit Union Account #5302, payable

 

 

13 4/ 29/ 2014 to of Manchester for the Purchase of
a 2012 Can-Am Spyder 
Check #126, in the amount of $34,258, drawn on
14 7/7/ 2014 Navigant Credit Union Account #5302, payable

to CarMax for the Purchase of a 2013 Mercedes?
Benz SL550

 

 

 

 

 

All in violation of Title 18, United States Code, Sections 1957 and 2.

COUNT FIFTEEN
(Tax Evasion - Evasion of Payment)

22. Paragraphs 1 through 17(g), and 17(i) through 17(j), of this Indictment are
incorporated by reference herein.

23. From in or about August 2009 to in or about April 2018, in the District of
Rhode Island and elsewhere, the defendant,

THOMAS HULING,
a resident of Rhode Island, did willfully attempt to evade and defeat the payment of
income taxes due and owing by him to the United States of America, for the calendar
year 2007, by committing the following affirmative acts, among others:
a. Establishing and using multiple nominee entities and multiple

associated bank accounts to deposit and transfer funds, and to conceal and obscure the
source and disposition of income;

b. Using entity bank accounts to pay for personal expenditures;

13

 

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c. Making extensive use of cash;

Causing the manipulation and falsification of the books and
records of his entities to disguise distributions, personal expenditures, and other income
to him, including by falsely and fraudulently characterizing personal distributions and
expenditures as loans; 

e. Providing and causing to be provided to his accountant and tax
return preparer false and fraudulent information concerning income and expenses;

f. Causing to be prepared and filed With the IRS false and fraudulent
individual income tax returns;

g. Causing to be prepared and filed with the IRS false and fraudulent
corporate tax returns;

h. Titling personal assets, such as real estate and vehicles, in the
names of nominee entities; and

i. . Providing false and fraudulent statements to IRS special agents

material to his income, expenses, and business activities.

All in violation of Title 26, United States Code, Section 7201.

14

 

Case Document 3 Filed 04/09/19 Page 15 of 24 PageID 17

COUNT SIXTEEN
(Tax Evasion - Evasion of Assessment)

 

24. Paragraphs 1 through 17(g), and 17(i) through 17(j), of this Indictment are
incorporated by reference herein.

25. From in or about January 2009 through in or about March 2016, in the

 

District of Rhode Island and elsewhere?,the defendant,

THOMAS HULING,
a resident of Rhode Island, willfully attempted to evade and defeat income tax due and
owing by him to the United States of America, for the calendar year 2009, by
committing the following affirmative acts, among others: preparing and causing to
be prepared, and signing and causing to be signed, a false and fraudulent 2009 US.
Individual Income Tax Return, Form 1040, which was submitted to the Internal
Revenue Service; establishing and using multiple nominee entities and shell
companies, as well as multiple bank accounts tied to those entities, to deposit,
withdraw, and transfer funds; using entity bank accounts to pay for personal
expenditures; making extensive use of cash; causing to be manipulated and
falsified the books and records of his entities to disguise his income; causing to be
provided false and fraudulent information to his tax return preparer; causing to be
prepared and filed false and fraudulent 2009 corporate tax returns in the names of TH
Enterprises, 46 Well Realty, and Global Funding Group claiming expenses, and flow

through losses to and on or about December 2, 2015, providing false and

15

 

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fraudulent statements to IRS special agents material to his 2009 income, expenses, and
business activities:
All in violation of Title 26, United States Code, Section 7201.

COUNT SEVENTEEN
(Tax Evasion - Evasion of Assessment)

26. Paragraphs 1 through 17(g), and 17(i) through 17(1), of this Indictment are
incorporated by reference herein.

27. From in or about January 2010 through in or about March 2016, in the
District of Rhode Island and elsewhere, the defendant,

THOMAS HULING,

a resident of Rhode Island, willfully attempted to evade and defeat income tax due and
owing by him to the United States of America, for the calendar year 2010, by
committing the following affirmative acts, among others: preparing and causing to
be prepared, and signing and causing to be signed, a false and fraudulent 2010 US.
Individual Income Tax Return, Form 1040, which was submitted to the Internal
Revenue Service; establishing and using multiple nominee entities and shell
companies, as well as multiple bank accounts tied to those entities, to deposit,
withdraw, and transfer funds; using entity bank accounts to pay for personal
expenditures; making extensive use of cash; causing to be manipulated and
falsified the books and records of his entities to disguise his income; causing to be

provided false and fraudulent information to his tax return preparer; causing to be

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Case Document 3 Filed 04/09/19 Page 17 of 24 PageID 19

prepared and filed false and fraudulent 2010 corporate tax returns in the names of TH
Enterprises, 46 Wells Realty, and Global Funding Group claiming expenses, and flow
through losses to and on or about December 2, 2015, providing false and
fraudulent statements to IRS special agents material to his 2010 income, expenses, and
Business? aetiv?itiesi

All in violation of Title 26, United States Code, Section 7201.

COUNT EIGHTEEN
(Tax Evasion Evasion of Assessment)

28. Paragraphs 1 through 17(g), and 17(i) through 17(j), of this Indictment are
incorporated by reference herein.

29. From in or about January 2011 through in or about December 2015, in the
District of Rhode Island and elsewhere, the defendant,

THOMAS HULING,

a resident of Rhode Island, willfully attempted to evade and defeat income tax due and
owing by him to the United States of America, for the calendar year 2011, by
committing the following affirmative acts, among others: preparing and causing to
be prepared, and signing and causing to be signed, a false and fraudulent 2011 US.
Individual Income Tax Return, Form 1040, which was submitted to the Internal
Revenue Service; establishing and using multiple nominee entities and shell
companies, as well as multiple bank accounts tied to those entities, to deposit,

withdraw, and transfer funds; using entity bank accounts to pay for personal

17

 

 

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expenditures; making extensive use of cash; causing to be manipulated and
falsified the books and records of his entities to disguise his income; causing to be
provided false and fraudulent information to his tax return preparer; causing to be
prepared and filed false and fraudulent 2011 corporate tax returns in the names of TH
Enterprises and 46 Wells Realty claiming expenses, and flow through losses to
and on or about December 2, 2015, providing false and fraudulent
statements to IRS special agents material to his 2011 income, expenses, and business
activities:

All in violation of Title 26, United States Code, Section 7201.

COUNT NINETEEN
(Tax Evasion Evasion of Assessment)

30. Paragraphs 1 through 17(g), and 17(i) through 170), of this Indictment are
incorporated by reference herein.

31. During the calendar year 2012, the defendant,

THOMAS HULING,

who was a resident of Rhode Island, had and received taxable income upon which there
was income tax due and owing to the United States of America. Knowing and
believing the foregoing facts, and failing to make an income tax return on or before
April 15, 2013, as required by law, to any proper officer of the IRS, and to pay the
income tax to the IRS, defendant HULING, from in or about January 2012 through in or

about December 2015, in the District of Rhode Island and elsewhere, did willfully

18

 

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attempt to evade and defeat the said income taxes due and owing by him to the United
States of America fer said calendar year by committing the following affirmative acts,
among others: establishing and using multiple nominee entities and shell companies,
as well as multiple bank accounts tied to those entities, to deposit, withdraw, and
transfer funds; using nominee entity bank accounts to pay for personal
expenditures; making extensive use of cash; causing to be manipulated and
falsified the books and records of his entities to disguise his income; causing to be
provided false and fraudulent information to his tax return preparer; (Q causing to be
prepared and filed a false and fraudulent 2012 corporate tax return in the name of TH
Enterprises claiming expenses, and flow through losses to and providing
false and fraudulent statements to IRS special agents material to his 2012 income,
expenses, and business activities.

All in violation of Title 26, United States Code, Section 7201.

COUNT TWENTY
(Tax Evasion - Evasion of Assessment)

32. Paragraphs 1 through 17(g), and 17(i) through 17(j), of this Indictment are
incorporated by reference herein.
33. During the calendar year 2016, the defendant,
THOMAS HULING,
who was a resident of Rhode Island, had and received taxable income upon which there

was income tax due and owing to the United States of America. Knowing and

'19

 

 

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believing the foregoing facts, and failing to make an income tax return on or before
April 18, 2017, as required by law, to any proper officer of the IRS, and to pay the
income tax to the IRS, defendant HULING, from in or about January 2016 through in or
about April 2017, in the District of Rhode Island and elsewhere, did willfully attempt to
evade and defeat the said income taxes due and owing by him to the United States of
America for said calendar year by committing the following affirmative acts, among
others: Using nominee entities and shell companies to deposit income and to pay for
personal expenditures; and making extensive use of cash.

All in violation of Title 26, United States Code, Section 7201.

COUNT TWENTY -ONE
(Tax Evasion Evasion of Assessment)

34. Paragraphs 1 through 17(g), and 17(i) through 170), of this Indictment are
incorporated by reference herein. I

35. During the calendar year 2017, the defendant,

THOMAS HULING,

who was a resident of Rhode Island, had and received taxable income upon which there
was income tax due and owing to the United States of America. Knowing and
believing the foregoing facts, and failing to make an income tax return on or before
April 17, 2018, as required by law, to any proper officer of the IRS, and to pay the
income tax to the IRS, defendant HULING, from in or about January 2017 through in or

about April 2018, in the District of Rhode Island and elsewhere, did willfully attempt to

20

 

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evade and defeat the said income taxes due and owing by him to the United States of
America for said calendar year by com-mittmg the following affirmative acts, among
others: Using nominee entities and shell companies to deposit income and to pay for
personal expenditures; and making extensive use of cash.

All in violation of Title 26, United States Code, Section 7201.

21

 

Case Document 3 Filed 04/09/19 Page 22 of 24 PageID 24

FORFEITURE ALLEGATIONS
The Grand Jury for the District of Rhode Island further charges that:

1. Pursuant to Federal Rule of Criminal Procedure 32.2, notice is hereby
given to the defendant that the United States will seek forfeiture as part of any sentence
in accordance with Title 18, United States Code, Sections 982(a)(2), and
982(a)(1), and Title 28, United States Code, Section 2461(c), in the event of the
defendant?s conviction on Counts One through Fourteen of this Indictment.

Wire Fraud Forfeiture

2. Upon conviction of an offense in violation of Title 18, United States Code,

Section 1343 set forth in Counts One through Twelve of this Indictment, the defendant,
THOMAS HULING,

shall forfeit to the United States of America, pursuant to Title 18, United States Code,

Section 982(a)(2), and Title 28, United States Code, Section 2461(c), any

property, real or personal, which constitutes or is derived from proceeds traceable to

the offenses, including but not limited to a sum of money equal to the total amount of

any property, real or personal, which constitutes or is derived from proceeds involved

in the offense.

22

 

 

Case Document 3 Filed 04/09/19 Page 23 of 24 PageID 25

Money Laundering Forfeiture

3. 7 Upon conviction of an offense in violation of Title 18, United States Code,
Section 1957 set forth in Counts Thirteen and Fourteen of this Indictment, the
defendant,

THOMAS HULING,

shall forfeit to the United States of America, pursuant to Title 18, United States Code,
Section 982(a)(1), any property, real or personal, involved in such offense, and any
property traceable to such property, including but not limited to a sum of money equal
to the total amount of any property, real or personal, which constitutes or is derived
from proceeds involved in the offense.

Substitute Assets

 

4. If any of the property described above, as a result of any act or omission of
the defendant:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has been, placed beyond the jurisdiction of the court,
d. has been substantially diminished in value; or
e. has beenicommingled with other property which cannot be divided

Without difficulty,

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Case Document 3 Filed 04/09/19 Page 24 of 24 PageID 26

the United States of America shall be entitled to forfeiture of substitute property up to

the value of the forfeitable property described above pursuant to Title 21, United States

Code, Section 853(p), as incorporated by Title 28, United States Code, Section 2461(c)

and 18 U.S.C. 982(b)(1).

U.S.C. 24613:).

Date:




Date:




M/a


By:

By:

All in violation of Title 18 U.S.C. 982(a)(1), 982(a)(2), and Title 28





RICHARD E. ZUCKERMAN
Principal Deputy Assistant Attorney General



N. KANE, 
ssistant Chief
US. Department of Justice, Tax Division
Northern Criminal Enforcement Section

AARON L. WEISMAN
United States Attorney

 

22 
SANDRA R. HEBERT kg/Q
Assistant US. Attorney

24