jurisper, ... "Para 11 defines the property in question to be anything connected with the crime he owns or has or had at some point control over, directly or indirectly; or anything "traceable to, derived from, fungible with or a substitute for" such property.
That seems to clearly make him liable for the the whole $4.8M, to the extent he ever had direct or indirect control over the money ..."
Do you think Matt had control over the whole $4M? Or, did he just have control over part of it? The "traceable to" or "derived from," IMO, relates back to the property in question he had control over.
I doubt the validity of your conclusion. But, you could be right.
Control (did Matt have possession, did Matt have the right to access to accounts of others, did Matt have power to direct the allocations, etc.) is what the hearing will focus on. Just have to see what happens. ... eom