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On or about ________ , in the ____________District of ____________, JOHN DOE defendant herein, knowingly and fraudulently destroyed and mutilated inventory records relating to the property of XYZ Company, which company was then in bankruptcy under Title 11, Case No. _________.
All in violation of 18 U.S.C. § 152(8).
[cited in USAM 9-41.001]