Whether the court of appeals erred in affirming a criminal forfeiture judgment encompassing all potential trades despite a general jury verdict and the jury being told it could convict on one trade alone

QUESTION PRESENTED In this insider trading case, the court of appeals affirmed a sweeping criminal forfeiture judgment encompassing all potential trades combined in a single count, even though the jury returned only a general verdict beyond a reasonable doubt and was expressly told it could convict on one trade alone. Should this Court address (i) the conflicts between the decision below and other courts of appeal holding that criminal forfeiture statutes require that forfeiture only be based on convicted conduct found by the jury and (Gi) whether this Court should also extend the Sixth Amendment right to trial by jury, as expounded after Apprendi v. New Jersey, 530 U.S. 466 (2000), to criminal forfeiture cases, and if need be, overrule the Court’s pre-Apprendi decision in Libretti v. United States, 516 U.S. 29, 48-49 (1995)? i STATEMENT PURSUANT TO RULE 14.1(b) AND RULE 29.6 The names of all parties to this petition appear in the caption of the case on the cover page. The parties have no parent or subsidiary companies and do not issue stock. The proceedings directly related to this case are as follows: e United States v. Afriyie, No. U.S. District Court for the Southern District of New York. Judgments entered July 28, 2017 and December 12, 2017. e United States v. Afriyie, Nos. 17-2444, 17-4045, U.S. Court of Appeals for the Second Circuit. Judgments entered July 8, 2019 and October 11, 2019. ii