United States v. Paul Johnson, Southern District of New York (Dec. 19, 2024)

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 

UNITED STATES OF AMERICA 

PAUL JOHNSON, 
a/k/a "PJ Glizzy," 

V. 

Defendant. 

COUNT ONE 

SEALED INDICTMENT 

24 Cr. 

.:. CRIM 70 6 

(The OGz Enterprise Racketeering Conspiracy) 

The Grand Jury charges: 

THE OGz ENTERPRISE 

1. From at least in or about 2019, up to and including in or about December 2024, 

PAUL JOHNSON, a/k/a "PJ Glizzy," the defendant, and others known and unknown, were 

members and associates of the Original Goons ("OGz"), a criminal organization whose members 

and associates engaged in, among other things, acts involving murder and the distribution of 

controlled substances, and who operated principally in the Bronx, New York. 

2. The OGz, including its leadership, membership, and associates, constituted an 

"enterprise" (the "OGz Enterprise") as defined by Title 18, United States Code, Section 1961 ( 4 ), 

that is, a group of individuals associated in fact, although not a legal entity. The OGz Enterprise 

constituted an ongoing organization whose members functioned as a continuing unit for a common 

purpose of achieving the objectives of the OGz Enterprise. At all times relevant to this Indictment, 

the OGz Enterprise was engaged in, and its activities affected, interstate and foreign commerce. 

3. PAUL JOHNSON, a/k/a "PJ Glizzy," the defendant, participated in unlawful and 

other activities in furtherance of the conduct of the OGz Enterprise's affairs. 



PURPOSES OF THE OGz ENTERPRISE 

4. The purposes of the OGz Enterprise included the following: 

a. Preserving and protecting the power of the OGz Enterprise and its members 

and associates through acts involving murder, other acts of violence, and threats of violence. 

b. Enriching the members and associates of the OGz Enterprise through, 

among other things, the distribution of controlled substances, including cocaine, codeine, and 

marijuana. 

c. Promoting and enhancing the OGz Enterprise and the reputation and 

activities of its members and associates. 

MEANS AND METHODS OF THE OGz ENTERPRISE 

5. Among the means and methods by which the members and associates of the OGz 

Enterprise conducted and participated in the conduct of the affairs of the OGz Enterprise were the 

following: 

a. Members and associates of the OGz Enterprise committed, conspired to 

commit, and attempted to commit acts of violence, including acts involving murder, to protect and 

expand the Enterprise's criminal operations, and in connection with rivalries with members of 

other street gangs. 

b. Members and associates of the OGz Enterprise sold controlled substances, 

including cocaine, codeine, and marijuana. 

c. Members and associates of the OGz Enterprise obtained, possessed, and 

used firearms and ammunition. 

THE RACKETEERING CONSPIRACY 

6. From in or about 2019, up to and including in or about December 2024, in the 

Southern District of New York and elsewhere, PAUL JOHNSON, a/k/a "PJ Glizzy," the 

2 



defendant, and others known and unknown, being persons employed by and associated with the 

OGz Enterprise described in Paragraphs 1 through 5 of this Indictment, knowingly combined, 

conspired, confederated, and agreed with each other to violate the racketeering laws of the United 

States, to wit, Section 1962( c) of Title 18, United States Code, that is, to conduct and participate, 

directly and indirectly, in the conduct of the affairs of the OGz Enterprise, which was engaged in, 

and the activities of which affected, interstate and foreign commerce, through a pattern of 

racketeering activity, as defined in Title 18, United States Code, Section 1961 ( 1) and ( 5), 

consisting of: 

a. multiple acts involving murder, chargeable under the following provisions 

of state law: New York Penal Law, Sections 125.25(1) and (2) (murder), 105.15 (conspiracy), 

110.00 (attempt), and 20.00 (aiding and abetting); and 

b. multiple offenses involving the distribution of narcotics and controlled 

substances, including cocaine, codeine, and marijuana, chargeable under Title 21 , United States 

Code, Sections 84l(a)(l) (distribution and possession with intent to distribute) and 846 

(conspiracy), and Title 18, United States Code, Section 2 (aiding and abetting, and willfully 

causing). 

7. It was a part of the conspiracy that PAUL JOHNSON, a/k/a "PJ Glizzy," the 

defendant, agreed that a conspirator would commit at least two acts of racketeering activity in the 

conduct of the affairs of the OGz Enterprise. 

Notice of Special Sentencing Factors 

8. On or about February 6, 2022, in the Southern District of New York and elsewhere, 

as part of his agreement to conduct and participate in the conduct of the affairs of the OGz 

Enterprise through a pattern of racketeering activity, PAUL JOHNSON, a/k/a "PJ Glizzy," the 

defendant, and others known and unknown, murdered Jayquan McKenley, and aided and abetted 

3 



the same, in the vicinity of Greene Avenue and Lewis Avenue, in Brooklyn, New York, in violation 

ofNew York Penal Law, Sections 125.25(1) and (2) and 20.00, in that, (i) with intent to cause the 

death of another person, JOHNSON caused the death of McKenley, and aided and abetted the 

same; and (ii) under circumstances evincing a depraved indifference to human life, JOHNSON 

recklessly engaged in conduct which created a grave risk of death to another person, and thereby 

caused the death of McKenley, and aided and abetted the same. 

(Title 18, United States Code, Section 1962( d).) 

COUNT TWO 
(Conspiracy to Commit Murder in Aid of Racketeering) 

The Grand Jury further charges: 

9. At all times relevant to this Indictment, the OGz, as described in paragraphs 1 

through 5 of Count One of this Indictment, which are repeated and incorporated by reference as 

though fully set forth herein, including its leadership, membership, and associates, constituted an 

enterprise, as that term is defined in Title 18, United States Code, Section 1959(b )(2), that is, a 

group of individuals associated in fact, which engaged in, and the activities of which affected, 

interstate and foreign commerce. The OGz Enterprise constituted an ongoing organization whose 

members functioned as a continuing unit for a common purpose of achieving the objectives of the 

OGz Enterprise. 

10. At all relevant times to this Indictment, the OGz Enterprise, through its members 

and associates, engaged in racketeering activity, as that term is defined in Title 18, United States 

Code, Sections 1961(1) and 1959(b)(l), namely acts involving murder, in violation of New York 

Penal Law, and offenses involving the distribution of controlled substances, including cocaine, 

codeine, and marijuana, in violation of Title 21 , United States Code, Sections 812, 841 ( a)(l ), and 

846, and Title 18, United States Code, Section 2. 

4 



11. On or about February 6, 2022, in the Southern District of New York and elsewhere, 

PAUL JOHNSON, a/k/a "PJ Glizzy," the defendant, and others known and unknown, for the 

purpose of gaining entrance to and maintaining and increasing position in the OGz Enterprise, an 

enterprise engaged in racketeering activity, as described above, did knowingly combine, conspire, 

confederate, and agree to murder Jayquan McKenley, in violation of New York Penal Law, 

Sections 125.25 and 105.15. 

(Title 18, United States Code, Section l 959(a)(5).) 

COUNT THREE 
(Murder in Aid of Racketeering) 

The Grand Jury further charges: 

12. At all times relevant to this Indictment, the OGz, as described in paragraphs 1 

through 5 of Count One of this Indictment, which are repeated and incorporated by reference as 

though fully set forth herein, including its leadership, membership, and associates, constituted an 

enterprise, as that term is defined in Title 18, United States Code, Section 1959(b )(2), that is, a 

group of individuals associated in fact, which engaged in, and the activities of which affected, 

interstate and foreign commerce. The OGz Enterprise constituted an ongoing organization whose 

members functioned as a continuing unit for a common purpose of achieving the objectives of the 

OGz Enterprise. 

13. At all relevant times to this Indictment, the OGz Enterprise, through its members 

and associates, engaged in racketeering activity, as that term is defined in Title 18, United States 

Code, Sections 1961(1) and 1959(b)(l), namely acts involving murder, in violation of New York 

Penal Law, and offenses involving the distribution of controlled substances, including cocaine, 

codeine, and marijuana and codeine, in violation of Title 21 , United States Code, Sections 812, 

841 ( a)(l ), and 846 and Title 18, United States Code, Section 2. 

5 



14. On or about February 6, 2022, in the Southern District of New York and elsewhere, 

PAUL JOHNSON, a/k/a "PJ Glizzy," the defendant, and others known and unknown, for the 

purpose of gaining entrance to and maintaining and increasing position in the OGz Enterprise, an 

enterprise engaged in racketeering activity, as described above, murdered and aided and abetted 

the murder of Jayquan McKenley in the vicinity of Greene Avenue and Lewis Avenue, in 

Brooklyn, New York, in that, (i) with intent to cause the death of another person, JOHNSON 

caused the death of McKenley, and aided and abetted the same; and (ii) under circumstances 

evincing a depraved indifference to human life, JOHNSON recklessly engaged in conduct which 

created a grave risk of death to another person, and thereby caused the death of McKenley, and 

aided and abetted the same, in violation of New York Penal Law, Sections 125.25(1), 125.25(2), 

and 20.00. 

(Title 18, United States Code, Sections 1959(a)(l) and 2.) 

SPECIAL FINDINGS AS TO PAUL JOHNSON, A/KIA "PJ GLIZZY" 

15. Counts Three of this Indictment is realleged and incorporated by reference as 

though fully set forth herein. As to Count Three of the Indictment, alleging the murder of Jayquan 

McKenley, PAUL JOHNSON, a/k/a "PJ Glizzy," the defendant: 

a. was 18 years of age or older at the time of the offense; 

b. intentionally participated in an act, contemplating that the life of a 

person would be taken and intending that lethal force would be used in connection with a person, 

other than one of the participants in the offense, and Jayquan McKenley died as a direct result of 

the act (Title 18, United States Code, Section 3591(a)(2)(C)); and, 

c. intentionally and specifically engaged in an act of violence, 

knowing that the act created a grave risk of death to a person, other than one of the participants 

6 



in the offense, such that participation in the act constituted a reckless disregard for human life 

and the victim died as a direct result efthe act (Title 18, United States Code, Section 

3591(a)(2)(D)). 

COUNTFOUR 
(Firearms Use, Carrying, and Possession) 

The Grand Jury further charges: 

16. On or about February 6, 2022, in the Southern District of New York and elsewhere, 

PAUL JOHNSON, a/k/a "PJ Glizzy," the defendant, during and in relation to a crime of violence 

for which he may be prosecuted in a court of the United States, namely, the murder in aid of 

racketeering charged in Count Three ofthis Indictment, knowingly used and carried a firearm, and, 

in furtherance of such crime, possessed a firearm, and aided and abetted the use, carrying, and 

possession of a firearm, which was brandished and discharged. 

(Title 18, United States Code, Sections 924( c )(1 )(A)(i), (ii), and (iii), and 2.) 

FORFEITURE ALLEGATIONS 

17. As a result of committing the offense alleged in Count One of this Indictment, 

PAUL JOHNSON, a/k/a "PJ Glizzy," the defendant, shall forfeit to the United States, pursuant to 

Title 18, United States Code, Section 1963, any and all interests the defendant acquired or 

maintained in violation of Title 18, United States Code, Section 1962; any and all interests in, 

securities of, claims against, and property or contractual rights of any kind affording a source of 

influence over, the enterprise named and described herein which the defendant established, 

operated, controlled, conducted, and participated in the conduct of, in violation of Title 18, United 

States Code, Section 1962; and any and all property constituting and derived from proceeds 

obtained, directly and indirectly, from the offense alleged in Count One of this Indictment, 

7 



including but not limited to a sum of money in United States currency representing the amount of 

proceeds traceable to the commission of said offense. 

18. As a result of committing the offense alleged in Count Four of this Indictment, 

PAUL JOHNSON, a/k/a "PJ Glizzy," the defendant, shall forfeit to the United States, pursuant to 

Title 18, United States Code, Section 924( d)(l ), and Title 28, United States Code, Section 2461 ( c ), 

any and all firearms and ammunition involved in or used in said offense. 

Substitute Assets Provision 

19. If any of the above-described forfeitable property, 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 person; 

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 which cannot be subdivided 
without difficulty; 

it is the intent of the United States, pursuant to Title 28, United States Code, Section 1963(m) and 

2461 ( c ), to seek forfeiture of any other property of the defendant up to the value of the above 

forfeitable property. 

FOREPERSON 

(Title 18, United States Code, Sections 924 and 1963; 
Title 21 , United States Code, Section 853; and 
Title 28, United States Code, Section 2461.) 

~ ~ 
EDWARD Y. KIM 
Acting United States Attorney 

8

UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF NEW YORK 

UNITED STATES OF AMERICA 

PAUL JOHNSON, 
a/k/a "PJ Glizzy," 

V. 

Defendant. 

COUNT ONE 

SEALED INDICTMENT 

24 Cr. 

.:. CRIM 70 6 

(The OGz Enterprise Racketeering Conspiracy) 

The Grand Jury charges: 

THE OGz ENTERPRISE 

1. From at least in or about 2019, up to and including in or about December 2024, 

PAUL JOHNSON, a/k/a "PJ Glizzy," the defendant, and others known and unknown, were 

members and associates of the Original Goons ("OGz"), a criminal organization whose members 

and associates engaged in, among other things, acts involving murder and the distribution of 

controlled substances, and who operated principally in the Bronx, New York. 

2. The OGz, including its leadership, membership, and associates, constituted an 

"enterprise" (the "OGz Enterprise") as defined by Title 18, United States Code, Section 1961 ( 4 ), 

that is, a group of individuals associated in fact, although not a legal entity. The OGz Enterprise 

constituted an ongoing organization whose members functioned as a continuing unit for a common 

purpose of achieving the objectives of the OGz Enterprise. At all times relevant to this Indictment, 

the OGz Enterprise was engaged in, and its activities affected, interstate and foreign commerce. 

3. PAUL JOHNSON, a/k/a "PJ Glizzy," the defendant, participated in unlawful and 

other activities in furtherance of the conduct of the OGz Enterprise's affairs. 



PURPOSES OF THE OGz ENTERPRISE 

4. The purposes of the OGz Enterprise included the following: 

a. Preserving and protecting the power of the OGz Enterprise and its members 

and associates through acts involving murder, other acts of violence, and threats of violence. 

b. Enriching the members and associates of the OGz Enterprise through, 

among other things, the distribution of controlled substances, including cocaine, codeine, and 

marijuana. 

c. Promoting and enhancing the OGz Enterprise and the reputation and 

activities of its members and associates. 

MEANS AND METHODS OF THE OGz ENTERPRISE 

5. Among the means and methods by which the members and associates of the OGz 

Enterprise conducted and participated in the conduct of the affairs of the OGz Enterprise were the 

following: 

a. Members and associates of the OGz Enterprise committed, conspired to 

commit, and attempted to commit acts of violence, including acts involving murder, to protect and 

expand the Enterprise's criminal operations, and in connection with rivalries with members of 

other street gangs. 

b. Members and associates of the OGz Enterprise sold controlled substances, 

including cocaine, codeine, and marijuana. 

c. Members and associates of the OGz Enterprise obtained, possessed, and 

used firearms and ammunition. 

THE RACKETEERING CONSPIRACY 

6. From in or about 2019, up to and including in or about December 2024, in the 

Southern District of New York and elsewhere, PAUL JOHNSON, a/k/a "PJ Glizzy," the 

2 



defendant, and others known and unknown, being persons employed by and associated with the 

OGz Enterprise described in Paragraphs 1 through 5 of this Indictment, knowingly combined, 

conspired, confederated, and agreed with each other to violate the racketeering laws of the United 

States, to wit, Section 1962( c) of Title 18, United States Code, that is, to conduct and participate, 

directly and indirectly, in the conduct of the affairs of the OGz Enterprise, which was engaged in, 

and the activities of which affected, interstate and foreign commerce, through a pattern of 

racketeering activity, as defined in Title 18, United States Code, Section 1961 ( 1) and ( 5), 

consisting of: 

a. multiple acts involving murder, chargeable under the following provisions 

of state law: New York Penal Law, Sections 125.25(1) and (2) (murder), 105.15 (conspiracy), 

110.00 (attempt), and 20.00 (aiding and abetting); and 

b. multiple offenses involving the distribution of narcotics and controlled 

substances, including cocaine, codeine, and marijuana, chargeable under Title 21 , United States 

Code, Sections 84l(a)(l) (distribution and possession with intent to distribute) and 846 

(conspiracy), and Title 18, United States Code, Section 2 (aiding and abetting, and willfully 

causing). 

7. It was a part of the conspiracy that PAUL JOHNSON, a/k/a "PJ Glizzy," the 

defendant, agreed that a conspirator would commit at least two acts of racketeering activity in the 

conduct of the affairs of the OGz Enterprise. 

Notice of Special Sentencing Factors 

8. On or about February 6, 2022, in the Southern District of New York and elsewhere, 

as part of his agreement to conduct and participate in the conduct of the affairs of the OGz 

Enterprise through a pattern of racketeering activity, PAUL JOHNSON, a/k/a "PJ Glizzy," the 

defendant, and others known and unknown, murdered Jayquan McKenley, and aided and abetted 

3 



the same, in the vicinity of Greene Avenue and Lewis Avenue, in Brooklyn, New York, in violation 

ofNew York Penal Law, Sections 125.25(1) and (2) and 20.00, in that, (i) with intent to cause the 

death of another person, JOHNSON caused the death of McKenley, and aided and abetted the 

same; and (ii) under circumstances evincing a depraved indifference to human life, JOHNSON 

recklessly engaged in conduct which created a grave risk of death to another person, and thereby 

caused the death of McKenley, and aided and abetted the same. 

(Title 18, United States Code, Section 1962( d).) 

COUNT TWO 
(Conspiracy to Commit Murder in Aid of Racketeering) 

The Grand Jury further charges: 

9. At all times relevant to this Indictment, the OGz, as described in paragraphs 1 

through 5 of Count One of this Indictment, which are repeated and incorporated by reference as 

though fully set forth herein, including its leadership, membership, and associates, constituted an 

enterprise, as that term is defined in Title 18, United States Code, Section 1959(b )(2), that is, a 

group of individuals associated in fact, which engaged in, and the activities of which affected, 

interstate and foreign commerce. The OGz Enterprise constituted an ongoing organization whose 

members functioned as a continuing unit for a common purpose of achieving the objectives of the 

OGz Enterprise. 

10. At all relevant times to this Indictment, the OGz Enterprise, through its members 

and associates, engaged in racketeering activity, as that term is defined in Title 18, United States 

Code, Sections 1961(1) and 1959(b)(l), namely acts involving murder, in violation of New York 

Penal Law, and offenses involving the distribution of controlled substances, including cocaine, 

codeine, and marijuana, in violation of Title 21 , United States Code, Sections 812, 841 ( a)(l ), and 

846, and Title 18, United States Code, Section 2. 

4 



11. On or about February 6, 2022, in the Southern District of New York and elsewhere, 

PAUL JOHNSON, a/k/a "PJ Glizzy," the defendant, and others known and unknown, for the 

purpose of gaining entrance to and maintaining and increasing position in the OGz Enterprise, an 

enterprise engaged in racketeering activity, as described above, did knowingly combine, conspire, 

confederate, and agree to murder Jayquan McKenley, in violation of New York Penal Law, 

Sections 125.25 and 105.15. 

(Title 18, United States Code, Section l 959(a)(5).) 

COUNT THREE 
(Murder in Aid of Racketeering) 

The Grand Jury further charges: 

12. At all times relevant to this Indictment, the OGz, as described in paragraphs 1 

through 5 of Count One of this Indictment, which are repeated and incorporated by reference as 

though fully set forth herein, including its leadership, membership, and associates, constituted an 

enterprise, as that term is defined in Title 18, United States Code, Section 1959(b )(2), that is, a 

group of individuals associated in fact, which engaged in, and the activities of which affected, 

interstate and foreign commerce. The OGz Enterprise constituted an ongoing organization whose 

members functioned as a continuing unit for a common purpose of achieving the objectives of the 

OGz Enterprise. 

13. At all relevant times to this Indictment, the OGz Enterprise, through its members 

and associates, engaged in racketeering activity, as that term is defined in Title 18, United States 

Code, Sections 1961(1) and 1959(b)(l), namely acts involving murder, in violation of New York 

Penal Law, and offenses involving the distribution of controlled substances, including cocaine, 

codeine, and marijuana and codeine, in violation of Title 21 , United States Code, Sections 812, 

841 ( a)(l ), and 846 and Title 18, United States Code, Section 2. 

5 



14. On or about February 6, 2022, in the Southern District of New York and elsewhere, 

PAUL JOHNSON, a/k/a "PJ Glizzy," the defendant, and others known and unknown, for the 

purpose of gaining entrance to and maintaining and increasing position in the OGz Enterprise, an 

enterprise engaged in racketeering activity, as described above, murdered and aided and abetted 

the murder of Jayquan McKenley in the vicinity of Greene Avenue and Lewis Avenue, in 

Brooklyn, New York, in that, (i) with intent to cause the death of another person, JOHNSON 

caused the death of McKenley, and aided and abetted the same; and (ii) under circumstances 

evincing a depraved indifference to human life, JOHNSON recklessly engaged in conduct which 

created a grave risk of death to another person, and thereby caused the death of McKenley, and 

aided and abetted the same, in violation of New York Penal Law, Sections 125.25(1), 125.25(2), 

and 20.00. 

(Title 18, United States Code, Sections 1959(a)(l) and 2.) 

SPECIAL FINDINGS AS TO PAUL JOHNSON, A/KIA "PJ GLIZZY" 

15. Counts Three of this Indictment is realleged and incorporated by reference as 

though fully set forth herein. As to Count Three of the Indictment, alleging the murder of Jayquan 

McKenley, PAUL JOHNSON, a/k/a "PJ Glizzy," the defendant: 

a. was 18 years of age or older at the time of the offense; 

b. intentionally participated in an act, contemplating that the life of a 

person would be taken and intending that lethal force would be used in connection with a person, 

other than one of the participants in the offense, and Jayquan McKenley died as a direct result of 

the act (Title 18, United States Code, Section 3591(a)(2)(C)); and, 

c. intentionally and specifically engaged in an act of violence, 

knowing that the act created a grave risk of death to a person, other than one of the participants 

6 



in the offense, such that participation in the act constituted a reckless disregard for human life 

and the victim died as a direct result efthe act (Title 18, United States Code, Section 

3591(a)(2)(D)). 

COUNTFOUR 
(Firearms Use, Carrying, and Possession) 

The Grand Jury further charges: 

16. On or about February 6, 2022, in the Southern District of New York and elsewhere, 

PAUL JOHNSON, a/k/a "PJ Glizzy," the defendant, during and in relation to a crime of violence 

for which he may be prosecuted in a court of the United States, namely, the murder in aid of 

racketeering charged in Count Three ofthis Indictment, knowingly used and carried a firearm, and, 

in furtherance of such crime, possessed a firearm, and aided and abetted the use, carrying, and 

possession of a firearm, which was brandished and discharged. 

(Title 18, United States Code, Sections 924( c )(1 )(A)(i), (ii), and (iii), and 2.) 

FORFEITURE ALLEGATIONS 

17. As a result of committing the offense alleged in Count One of this Indictment, 

PAUL JOHNSON, a/k/a "PJ Glizzy," the defendant, shall forfeit to the United States, pursuant to 

Title 18, United States Code, Section 1963, any and all interests the defendant acquired or 

maintained in violation of Title 18, United States Code, Section 1962; any and all interests in, 

securities of, claims against, and property or contractual rights of any kind affording a source of 

influence over, the enterprise named and described herein which the defendant established, 

operated, controlled, conducted, and participated in the conduct of, in violation of Title 18, United 

States Code, Section 1962; and any and all property constituting and derived from proceeds 

obtained, directly and indirectly, from the offense alleged in Count One of this Indictment, 

7 



including but not limited to a sum of money in United States currency representing the amount of 

proceeds traceable to the commission of said offense. 

18. As a result of committing the offense alleged in Count Four of this Indictment, 

PAUL JOHNSON, a/k/a "PJ Glizzy," the defendant, shall forfeit to the United States, pursuant to 

Title 18, United States Code, Section 924( d)(l ), and Title 28, United States Code, Section 2461 ( c ), 

any and all firearms and ammunition involved in or used in said offense. 

Substitute Assets Provision 

19. If any of the above-described forfeitable property, 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 person; 

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 which cannot be subdivided 
without difficulty; 

it is the intent of the United States, pursuant to Title 28, United States Code, Section 1963(m) and 

2461 ( c ), to seek forfeiture of any other property of the defendant up to the value of the above 

forfeitable property. 

FOREPERSON 

(Title 18, United States Code, Sections 924 and 1963; 
Title 21 , United States Code, Section 853; and 
Title 28, United States Code, Section 2461.) 

~ ~ 
EDWARD Y. KIM 
Acting United States Attorney 

8