Case 1:17-cr-00201-ABJ Document 190-1 Filed 02/22/18 Page 36 of 37 obtained, directly or indirectly, as a result of such violation(s). Notice is further given that, upon conviction, the United States intends to seek a judgment against each defendant for a sum of money representing the property described in this paragraph, as applicable to each defendant (to be offset by the forfeiture of any specific property). 76. The grand jury finds probable cause to believe that the property subject to forfeiture by PAUL J. MANAFORT, JR., includes, but is not limited to, the following listed assets: a. All funds held in account number XXXXXX0969 at Lender D, and any property traceable thereto. Substitute Assets 77. If any of the property described above as being subject to forfeiture, as a result of any act or omission of any 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 been commingled with other property that cannot be subdivided without difficulty; it is the intent of the United States of America, pursuant to Title 18, United States Code, Section 982(b) and Title 28, United States Code, Section 2461(c), incorporating Title 21, United States Code, Section 853, to seek forfeiture of any other property of said defendant. (18 U.S.C. ยง 982) 36
Manafort and Gates superseding indictment Page 35 Page 37