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UNITED STATES DISTRICT COURT
District of Kansas
(Kansas City Docket)
UNITED STATES OF AMERICA.
Plaintiff,
CASENO. 21.2OO6O.JAR-JPO
Filed Under Seal
KAABA MAJEED,
YUNUS RASSOUL, a.k.a. Yunus Rassoull,
JAMES STATON, a.k.a. Adam Winthrop,,
RANDOLPH RODNEY HADLEY,
DANIEL AUBREY JENKINS,
DANA PEACH,
ETENIA KINARD, a.k.a. Etenia Kinnard, and
JACELYN GREENWELL,
Defendants.
INDICTMENT
THE GRAND JURY CHARGES:
Introduction
At all times material to the indictment:
I . United Nation of Islam (IJNOI) was an organization that was founded by
Royalt Jenkins ("Jenkins"). Contrary to the teachings of the Islamic faith, Jcnkins
represented that he, himself, was Allah, or God. Jenkins claimed that in approximately
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1978, he was abducted by angels who transported him through the galaxy in a spaceship
and instructed him how to rule on Earth.
2. Jenkins began gathering members in Maryland but later moved the IINOI
headquarters in the late 1990s to Kansas City, Kansas, where the organization continued to
grow in membership. TINOI eventually grew to include hundreds of members.
3. United Nation of Islam, Inc. was incorporated in 1999 in the State of
Louisiana with Jenkins as its President and defendant JAMES STATON, a.k.a. Adam
Winthrop ("STATON'), as its Secretary.
4. Over the years since its inception, UNOI has also been known as The Value
Creators and The Promise Keepers.
5. Jenkins led UNOI until approximately 2012. His responsibility was to
oversee ali activities of 1INOI and approve all decisions after consultation with his wives
and officials, who assisted him in managing UNOI operations.
6. Jenkins created, drove, and asserted INOI principles, which included rules
that members had to follow, required "duty" or unpaid labor, and emphasized the etemal
consequences of noncompliance.
7. UNOI operated locations or "temples" in various cities around the United
States, including but not limited to Kansas City, Kansas; New York, New York; Cincinnati,
Ohio; Atlanta, Georgia; Raleigh, North Carolina; and Newark, New Jersey. The term
"temple" did not denote any specific building, physical structure, or house of worship, but
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rather referenced a geographic area where UNOI operated businesses or where a significant
numbcr o1- members rcsided.
8. LINOI had a national and local organizational structure. Nationally, there
was a Secretary, Lieutenant, and Minister, as well as other specialized positions, such as a
leader who oversaw the youth or men. I-ocal leadership of each individual "temple"
generally mirored the national leadcrship structure. such that each individual "temple" had
a local Secretary, Lieutenant, and Minister, as well as a position referred to as Captain.
Jenkins appointed these officials.
9. Jenkins was the overall leader, referred to within the organization as "Allah,"
or "Father." STATON helped grow the organization along with Jenkins and became
National Secretary. Delendants KAABA MAJEED ("MAJEED"), YUNUS RASSOUL
("R{SSOUL"). RANDOLPH RODNEY HADLEY ('IIADLEY"). and DANIEL
AUBREY JENKINS ("A[IBRXY") also quickly rose to official status within UNOI.
MAJEED became National Lieutenant: RASSOUL bccame National Minister: HADLEY
became a Captain; and AUBRXY oversaw the male membership. Def'endants ETENIA
IflNARD ("KINARD"). DANA PEACH ("PEACH"). and JACELYN GRLENWELL
f'GREENWELL") rvcre tfuee o1'Jcnkins's man1, wivcs. KINARD and GREENWELL
oversaw the youth membership. All ol the defendants assisted Jenkins in managing the
organization.
10. I-NOI opened and operated at least ten businesses around the United States
that were staffed entirely by unpaid UNOI members. These businesses were primarily
reslaurants and bakeries, but also included other businesses such as a gas station and
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clothing store. UNOI required members to staff these businesses as part of their "duty,"
and did not pay these members, many of whom were minor children or young adults.
LrNOI operated businesses in Kansas City, Kansas; Newark, New Jersey; New York, New
York; Wichita, Kansas; Cincinnati, Ohio; Dayon, Ohio; Temple Hills, Maryland;
Baltimore, Maryland; Atlanta, Georgia; New Haven, Connecticut; Hamden, Connecticut;
Durham, North Carolina; Mobile, Alabama; and elsewhere.
11. UNOI recruited hundreds of full-time and part-time members. Full-time
members lived in housing provided by UNOI and worked without pay at fINOI businesses.
Part-time members lived and worked outside of TINOI but donated financially to IINOI.
UNOI employed without pay many children who joined with their parents or were bom to
parents who were already members of the organization.
12. UNOI encouraged many adult members to send their children to Kansas
City, Kansas for the purpose of attending a IINOI-run school and working in TINOI-
operated businesses. UNOI enticed parents to send their children by promising a fulsome
education and the development of life skills through working in UNOl-operated
businesses. TINOI did not inform the parents that their children would work extended
hours, sometimes in lieu of attending school, or be sent to other fNOI businesses around
the country to work extended hours and receive no legitimate education.
13. IJNOI "dispatched" and transported the children of adult members around
the country to work at TINOI businesses. "Dispatching" was the practice of deciding that
youth members would move to and work in a specific location without pay, and then
transporting those youth members to that location, fypically without their paxents or other
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adult family members. UNOI housed these youth members with other non-familial adult
members or in lINOl-operated dormitories or barracks. IJNOI did not always tell the youth
members' parents where or when they were "dispatching" their children.
14. Each UNOI business had a manager, and each house or dormitory had an
adult member in charge. The members at each "temple" reported to the business and house
managers. These managers then reported to local officials, such as the First Lieutenant or
Captain, or sometimes directly to national oflicials such as the National Lieutenant.
15. The defendants required the youth members to live in crowded conditions,
follow a very restricted diet, and work long hours in lJNol-operated businesses.
Conversely, the defendants and their immediate families tlpically resided in spacious
accommodations, ate what they wanted, and worked at their own discretion.
COUNT I
CONSPIRACY TO COMMIT FORCED LABOR
ll8 u.s.c. $ 371I
1,6. On or about October 28, 2000 and continuing through November 30,2012,
in the District ofKansas and elsewhere, the defendants,
KAABA MAJEED,
YUNUS RASSOULL, a.k.a. Yunus Rassoul
JAMES STATON, a.k.a. Adam Winthrop'
RANDOLPH RODNEY HADLEY,
DANIEL AUBREY JENKINS,
DANA PEACH,
ETBNIA KINARD, a.k.a. Etenia Kinnard, and
JACELYN GREENWELL,
and others known and unknown to the Grand Jury, did knowingly conspire and agree
with each other to provide and obtain the labor and services ofone and more persons by
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threats of serious harm to, and physical restraint against, that person and another person;
by means ofany scheme, plan, and pattem intcnded to cause the person to believe that, if
the person did not perlorm such labor and services, that person and another person would
suffer serious harm and physical restraint; and by means ofthe abuse and threatened
abuse of law and thc lcgal process, in violation of 18 U.S.C. $ 1589.
Obiect of the Conspiracy
17. The factual allegations in paragraphs I through 15 of this Indictment are
incorporated by ref-erence and realleged as though fully set forth herein.
18. The object of the conspiracy was lor the defendants, and others known and
unknown to the grand jury, to obtain the uncompensated labor and services ofat least one
victim in the District of Kansas and elservhere.
Manner and Means of the Conspiracy
The manner and means by which the co-conspirators carried out the object ofthe
conspiracy included, but were not limited to, the following:
19. Although members could be any age, the defendants pdmarily relied on the
labor and services of young victims, many of whom were minors, to benefit finaricially.
UNOI compelled the labor and services of victims as young as eight years old.
20. The defendants very rarely allowed the victims to live with their parents.
They instead housed the victims in overcrowded dormitories, barracks, or households of
adult members who were not related to the victims.
21. Jenkins created rules to control the victims while the other defendants
enfbrced the rules
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22. The defendants controlled the whereabouts of all of the victims. The
defendants transported the victims to different cities on a regular basis, sometimes with
mere hours' notice.
23. Jenkins controlled what the members viewed and read. He generally
restricted victims to reading UNOI publications and did not allow outside newspapers or
books.
24. The defendants required the victims to dress in [JNOI-made clothing and use
l-INOl-produced toiletries. Victims had to make official requests for outside clothing or
toiletries, and the defendants routinely denied such requests.
25. The defendants also restricted communications. They often required the
victims to ask permission to speak, and prohibited victims from using certain words such
as "hello," and "say." The defendants generally prohibited victims from speaking to
members of the opposite sex, or to non-members, including non-members from their own
families. The defendants also controlled whether victims could speak to their families and
parents within IJNOI and often monitored those calls.
26. The defendants directed the victims to shower in a certain way and required
some victims to undergo colonics performed by adult members. A colonic is a procedure
designed to cleanse the colon by streaming gallons ol water through a tube inserted into
the rectum.
27. The defendants controlled the diet of their members, restricting many of the
victims to eat only bean soup, salad, and occasionally fruit. They also restricted many of
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the victims to two meals per day, or ordered them to "cleanse" by consuming only lemon
juice for days. The defendants required the victims, particularly female victims, to
maintain a certain weight. Jenkins's wives subjected female victims to weekly weigh-ins
where they would humiliate the victims for their weight and subsequently make them fast.
28. The defendants did not allow the victims to come and go freely from their
residences. With few exceptions, the defendants required the victims to be transported or
accompanied everywhere by a UNOI member, usually an official or trusted member.
29. The defendants rarely permitted victims to seek outside medical attention.
The defendants often denied victims medical attention altogether. When a defendant did
allow a victim to receive medical attention, they sent the victim to a doctor employed by
IINOI or to PEACH, who was not a licensed medical doctor. PEACH would then
personally "treat" the victims herself.
30. The defendants required the victims to perform "duty," which consisted of
working long hours without pay in IJNOI-owned businesses such as bakeries, restaurants,
gas stations, a sewing factory, a factory that produced personal hygiene products, and
others. The defendants also required many victims to perform "duty" in households, such
as cleaning and childcare. The defendants required some victims to work up to 16 hours
per day without compensation.
31. The defendants did not permit the victims to receive an accredited education
from a licensed school. IINOI ran its own unlicensed school known as the "University of
Arts and Logistics of Civilization" (UALC) in Kansas City, Kansas, in the District of
Kansas. Victims who lived in Kansas city, Kansas attended the UAIC but did not receive
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appropriate instruction in traditional subjects such as mathematics, reading, writing, and
sclence The defendants denied the victims who lived outside of Kansas City, Kansas of
any legitimate education, and required them to provide labor in lieu of attending school.
32. The defendants regularly conducted meetings with large groups of members
to humiliate the victims and other members who committed "intiactions." Infractions
included failing to follow rules or properly perform "duty," as well as innumerable other
offenses, such as stealing food. During these meetings. the delendants called victims to a
microphone in order to humiliate them by announcing their infraction and punishment to
other members.
33. The defendants regularly punished the victims who committed infractions.
The punishments included withholding fbod, silence, public humiliation. extra "duty," and
physical abuse. Physical abuse included hitting victims with a paddle, among other actions
34. The defendants instilted in the victims a fear of noncompliance and a fear of
leaving UNOI and TINOI housing. The defendants promoted the idea that the victims
"owed a duty to Allah," which meant working at IINOI businesses. The defendants
convinced the victims that if they did not comply with the rules, including performing their
"duty," or ifthey left LINOI, they would bum in an "etemal hellfire" or experience tragedy.
Overt Acts
35. In furtherance of the conspiracy, and to accomplish the object of the
conspiracy, at least one of the def'endants committed or caused to be commilted at least one
of the following overt acts, among others, in the District of Kansas, and elsewhere:
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36. In or about and between October 2002 and October 2003, KINARD and
GREENWELL punished Minor Victim 1 C'MV- 1'), whose identity is known to the grand
.jury, for buming a pie at the UNOl-operated bakery in Kansas by requiring MV-1 to make
extra pies and causing MV-l to work until midnight.
37. On or about and between October 28, 2000 and December 31,2004,
AUBREY, MAJEED, and HADLEY used a paddle to hit Minor Victim 2 ('MV-2"),
whose identity is known to the grand jury, as punishment on multiple occasions in Kansas.
38. In or about and between 2003 and 2005, KINARD beat Minor Victim 3
("MV-3"), whose identity is known to the grand jury, with an extension cord for neglecting
to throw out a diaper while MV-3 provided childcare in a IJNOI-run household.
39. On or about and between 2004 and 2006, RASSOUL refused to allow MV-
3 to seek proper medical attention and recuperate when MV-3 fainted from fatigue and hit
MV-3's head on a brick floor while working at a restaurant that RASSOUL managed in
Connecticut.
40. In or about and between 2004 and 2006, STATON denied Minor Victim 4
C'MV-4), whose identity is known to the grand jury, use of MV-4's inhaler to treat MV-
4's diagnosed asthma when MV-4 lived and performed household work in his home,
located in Kansas.
41. In or about 2007, Jenkins and PEACH transported MV-l from Kansas to
New Jersey for the purpose of securing MV- I 's labor.
42. On or about and between October 28,2000 and December 3 1, 2008, Jenkins,
MAJEED, RASSOUL, AUBREY, STATON, KINARD, PEACH, ANd GREENWELL
l0
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made decisions about where in the country to move victims for labor. The defendants made
these decisions through in-person discussions that occurred in the District of Kansas or
through telephonic discussions in which some defendants were physically present in the
District of Kansas.
43 . On or about and between October 28, 2000 and December 3 1, 2008, Jenkins,
MAJEED, RASSOUL, AUBREY, STATON, KINARD, and GREENWELL
participated in meetings to decide which disciplinary action to impose on victims, such as
withholding food. The defendants made these decisions through either in-person
discussions that occurred in the District ofKansas or telephonic discussions in which some
defendants were physically present in the District ofKansas.
44. In or about 2008, MAJEED instructed victims to lie to customers about their
age and working status so that they could continue to work in the restaurant that he
managed in New York.
45. Beginning on or about October 28,, 2000 and continuing through on or about
December 31,2009, all dates being approximate and inclusive, GREENWELL was
responsible for youth-related matters. In this capacity, she made decisions about victims'
labor and services, as well as whether and how to discipiine victims.
46. Beginning on or about and October 28,2000 and continuing through on or
about December 31, 2009, AUBREY engaged in "Fruit of Islam Beatdowns" or "FOI
Beatdowns" in which he physically abused male LNOI members as punishment for
infractions.
]l
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47. In or about and between 2008 and 2009, MAJEED transported MV-3 lrom
Kansas to New Jersey for the purpose of securing MV-3's labor.
48. In or about and between 2008 and 2009, Jenkins announced to victims and
members that he had his daughter killed flor leaving I-NOI.
49. In or about and between 2008 and 2009 Minor Victim 5 ("MV-5"), whose
identity is known to the grand jury, and who was a local UNOI lieutenant in Kansas at the
time, observed HADLEY punish a member by knocking him unconscious in the District
of Kansas.
50. In or about and between 2008 and 2009. after MV-5 reported to Jenkins that
HADLEY had punished a member too harshly, Jenkins indicated that he agreed with
HADLEY'S punishrnent.
51. In or about and between 2008 and 2009, as a result of MV-5 reporting
HADLEY to Jenkins, MAJEED punished MV-5 by not allowing MV-5 to speak without
permission, requiring MV-5 to perlorm extra work hours, and stripping MV-5 of MV-5's
position as lieutenant.
52. In or about 2010, HADLEY transpoded Minor Victim 6 ("MV-6"). whose
identity is known to the grand jury, from Kansas to New Jersey for the purpose ofsecuring
MV-6's labor in a UNol-operated restaurant.
53. On or about and between 2005 and 201i, PEACH supervised UNOI
businesses in New Jersey and New York. In her roles as supervisor, she made decisions
about victims' labor and services, as well as whether and how to discipline victims.
t2
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54. On or about and between October 28, 2000 and December 31, 2011,
KINARD was responsible for youth-related matters. In this capacity, she made decisions
about victims' labor and services, as well as whether and how to discipline victims.
55. In or about and between 2003 and 2012, RASSOUL supervised a LrNOI-
operated restaurant in Connecticut. In his role as supervisor, he made decisions about
victims' labor and services, as well as whether and how to discipline victims.
56. In or about and between 2005 and 2012, MAJEED supervised a UNOI
location in New Jersey where multiple victims and other IINOI members lived in
overcrowded conditions, such as ten or more individuals in a bedroom.
57. In or about and between 2007 and 2012, MAJEED and RASSOUL
supervised a IINOI-operated restaurant in North Carolina.
58. On or about and between October 28,2000 and January 2012, Jenkins,
MAJEED, RASSOUL, AUBREY, and STATON led meetings in which they publicly
chastised the victims and other individuals for violating UNOI rules. The defendants held
these meetings in the District of Kansas and elsewhere.
59. Beginning in or about October 28, 2000 and continuing through in or about
November 30,2012, all dates being approximate and inclusive, in the District of Kansas
and elsewhere, HADLEY used a paddle on multiple occasions to hit victims as
punishment.
60. On or about and between October 28, 2000 and November 30, 2012,
MAJEED and RASSOUL supervised l,DtrOI businesses in Kansas. In their roles as
l3
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supervisors, they made decisions about victims' labor and services, as well as whether and
how to discipline victims.
61. On or about and between October 28, 2000 and November 30,2012,
MAJEED and HADLEY engaged in "Fruit of Islam Beatdowns" or "FOI Beatdowns" in
which they physically abused male UNOI members as punishment for infractions.
62. On or about and between October 28,2000 and November 30, 2012, Jenkins
led and participated in meetings in which he addressed INOI members and discussed
l,TIllOI principles. Jenkins held these meetings in Kansas and elsewhere.
63. On or about and between January 1, 2005 and November 30, 2012,
MAJEED supe ised UNOI businesses in New Jersey and New York. In his role as
supervisor, he made decisions about victims' labor and services, as well as whether and
how to discipline victims.
In violation of Title 18, United States Code, Sections 371 and 1589.
COUNTS 2 THROUGH 8
FORCED LABOR
ll8 u.s.c. s 1s891
64. Beginning on or about the dates listed below, and continuing through on or
about the corresponding dates indicated below, in the District ofKansas and elsewhere.
the below-named defendants, and others known and unknown to the Grand Jury, aiding
and abetting each other and others, did knowingly provide and obtain the labor and
services ofthe victims referenced in each respective count below, whose identities are
known to the grand jury, by threats ofserious harm to, and physical restraint against, that
l4
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person and another person; by means of any scheme. p1an, and pattern intended to cause
the person to believe that, if the person did not perform such labor and services, that
person and another person would suffer serious harm and physical restraint; and by
means ofthe abuse and threatened abuse of law and the legal process, and attempted to
do so:
APPROXIMATE DATES OF
COUNT \rICTIM DEFENDANTS FORCED LABOR
2 MV-3 Kaaba Majeed, Yunus October 28, 2000-August 31 ,
Rassoul, James Staton, 2012
Dana Peach, Etenia
Kinard, Jacelyn Greenwell
J MV-7 Kaaba Majeed, Yunus October 28, 20O0-February 28,
Rassoul, James Staton, 2012
Etenia Kinard, Jacelyn
Greenwell
4 MV-8 Kaaba Majeed, James October 28, 2000-November 30,
Staton, Etenia Kinard, 2012
Jacelyn Greenwell
5 MV-9 Kaaba Majeed, Yunus October 28, 2000-November 30,
Rassoul, James Staton, 2012
Daniel Aubrey Jenkins
6 MV.1O Kaaba Majeed, James January 1, 2001-November 30,
Staton, Randolph Rodney 2012
IIadley, Etenia Kinard
15
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7 MV-5 Kaaba Majeed, James January l, 2002-November 30,
Staton, Randolph Rodney 20ll
Hadley, Daniel Aubrey
Jenkins, Jacelyn Greenwell
8 MV-,1 Kaaba Majeed, James January l, 2004-March 31, 2012
Staton, Randolph Rodney
Hadlev
In violation of Title 18, United States Code, Sections 1589,1594(a), &.2.
FORFEITURE NOTICE
65. The allegations contained in Counts 1-8 ofthis Indictment are hereby
realleged and incorporated by reference for the purpose ofalleging forfeiture pursuant to
Title 18, United States Code, Section 1594.
66. Upon conviction ofone or more ofthe offenses set forth in Counts 1-8, the
defendants shall forfeit to the United States of America, pursuant to Title 18, United
States Code, Section I 594, (l ) any property, real or personal, involved in, used, or intended to
be used to commit or to facilitate the commission of the offenses, and any property traceable to
such property; and (2) any property, real or personal, constituting or derived from, any proceeds
obtained, directly or indirectly, as a result ofthe offenses, and any property traceable to such
property. The property to be forfeited includes, but is not limited to, the following:
A. A forfeiture money judgment against defendant Kaaba Majeed in an
amount equal to the amount ofgross proceeds obtained or derived by him
from the commission of Counts 1-8;
B. A forfeituremoney judgment against defendant Yunus Rassoul in an
amount equal to the amount ofgross proceeds obtained or derived by him
fiom the commission of Counts 1,2,3, and 5;
l6
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C. A forfeiture money judgment against delendant James Staton in an
amount equal to the amount ofgross proceeds obtained or derived by him
liom the commission of Counts 1-8:
D. A forfeiture money judgment against def'endant Randolph Rodney
Hadley in an amount equal to the amount ofgross proceeds obtained or
derived by him from the commission of Counts 1, and 6-8;
E. A lorfeiture money judgment against defendant Daniel Aubrey Jenkins
in an amount equal to the amount ofgross proceeds obtained or derived by
him from the commission of Counts 1, 5. and 7;
F. A forfeituremoney judgment against defendant Dana Peach in an
amount equal to the amount ofgross proceeds obtained or derived by her
from the commission of Counts 1 and 2:
G. A forfeiture money judgment against defendant Etenia Kinard in an
amount equal to the amount ofgross proceeds obtained or derived by her
liom the commission of Counts 1,2.3.4, and 6:
H. A forfeiture money judgment against defendant Jacelyn Greenwell in
an amount equal to the amount ofgross proceeds obtained or derived by her
lrom the cornrnission ofCounts 1,2,3.4, andll.
67. Ifany ofthe property described above, as a result ofany act or omission of
the defendants:
A. cannot be located upon the exercise ofdue diligence;
B has been translbrred or sold to, or deposited with, a third party;
C has been placed beyond the jurisdiction of the court:
D has been substantiallv diminished in value: or
E, has been commingled with other propefty which cannot be divided
without difficulty,
11
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the United States of America shall be entitled to forfeiture of substitute properry pursuant
to Title 21, United States Code, Section 853(p).
A TRIIE BILL.
October 20 2021 s/Foreperson
DATE FOREPERSON OF THE GRAND JURY
DUSTON J. SLINKARD
ACTING UNITED STATES ATTORNEY
By : /s/ Ryan J. Huschka
Ryan J. Huschka
Assistant United States Attomey
District of Kansas
500 State Avenue, Suite 360
Kansas City, Kansas 66101
Ph: (913) 55 I -6730
Fax: (913) 551-6541
Email : Ryan.Huschka@usdoj.gov
Ks. S. Ct. No. 23840
KRISTEN CLARKE
ASSISTANT ATTORNEY GENERAL
By : /s/ Vasantha Rao
Vasantha Rao
Trial Attomey
USDOJ Civil Rights Division
950 Pennsylvania Avenue NW
Ph: (202) 616-2576
Email: Vasantha.Rao@usdoj.gov
NYBarNo.4402996
By: /s/ Kate A. Alexander
Kate A. Alexander
Trial Attorney
USDOJ Civil Rights Division
t8
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950 Pennsylvania Avenue NW
Ph: (202) 3s3-3539
Email: Kate.Alexander@usdoj.gov
FL Bar No. 27393
II-IS REQUESI'ED I'IIAI"IIIE TRIAL BE HELD IN KANSAS CITY, KANSAS
t9
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PENALTIES
Count 1: Conspiracy, l8 U.S.C. S 371
Punishable by a term of imprisonment of not more than five (5) years, 18 U.S.C.
$ 371.
A term ofsupervised release ofnot more than three (3) years. 18 U.S.C. $
3583(b)(2).
a A fine not to exceed $250,000. l8 U.S.C. $ 3571(bX3).
a A mandatory special assessment of $100.00. l8 U.S.C. $ 3013(a)(2)(A).
a Forfeiture
Counts 2-8: Forced Labor, l8 U.S.C. $ 1589
Punishable by a term of imprisonment of not more than twenty (20) years. 18
u.s.c. $ 1s8e(d).
A term ofsupervised release ofnot more than three (3) years. 18 U.S.C. $
3s83(bX2).
a A fine not to exceed $250,000. l8 U.S.C. $ 3571(bX3).
a A mandatory special assessment of $100.00. l8 U.S.C. $ 3013(aX2XA).
A mandatory special assessment of $5,000. l8 U.S.C. $ 3014(a).
a F'orfeiture.
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Case 5:21-mj-02036-RN Document 1 Filed 10/25/21 Page 20 of 20
