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persons who had worked for or engaged in transactions with the
Hoyt organization, including April and David Barnes, charging
them with numerous counts of conspiracy and mail fraud. On June
2, 1999, the Government filed a superseding indictment against
the same defendants, which, among other things, charged Jay Hoyt
with 54 counts of conspiracy to commit fraud, mail fraud,
bankruptcy fraud, and money laundering. See United States v.
Barnes, et al., No. CR 98-529-JO-04 (D. Or. Feb. 12, 2001), affd.
sub nom. United States v. Hoyt, 47 Fed. Appx. 834 (9th Cir.
2002). All future references to Jay Hoyt’s indictment are to the
superseding indictment of June 2, 1999.
Following a jury trial in the U.S. District Court case noted
above, on February 12, 2001, Jay Hoyt was convicted of 1 count of
conspiracy to commit fraud, 31 counts of mail fraud, 3 counts of
bankruptcy fraud, and 17 counts of money laundering. See id.
The U.S. District Court then sentenced Jay Hoyt to 235 months of
imprisonment and also ordered him to pay restitution of over $102
million to the individual victims of his crimes. This $102
million figure represented the total amount that the Government
(using Hoyt organization records) determined was paid to the Hoyt
organization from 1982 through 1998 by investor-partners in the
cattle partnerships, the sheep partnerships, and other similar
partnerships that Jay Hoyt promoted. The fraud perpetrated by
Jay Hoyt “impacted over 4,000 people and had actual and intended
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