Indictment — United States v. Jeffrey Allen Abel et al., No. 4:21-cr-00493

Summary

An Indictment, Document 2, filed on 11/03/21, Case 4:21-cr-00493-GKF, United States of America v. Jeffrey Allen Abel, Brandon Jamal Baldwin, Linda Ann Been and other named defendants, Northern District of Oklahoma. COUNT ONE is headed Conspiracy, and other headings cover Wire Fraud, Conspiracy to Commit Wire Fraud, Conspiracy to Commit Money Laundering, and Engaging in Monetary Transactions in Property Derived from Specified Unlawful Activity, plus a Forfeiture Allegation. Count One states that from in or about January 2018 the defendants conspired to steal goods, including over-the-counter ("OTC") medication, from retail stores and sell them to fencing operations outside Oklahoma, and that Been received approximately $4.5 million in payments from fencing operations.

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Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 1 of 36

SEALED

IN THE UNITED STATES DISTRICT COURT

NOV 08 2021

FOR THE NORTHERN DISTRICT OF OKLAHOMA Mark C. MeCarit, Clerk

UNITED STATES OF AMERICA,
Plaintiff,

JEFFREY ALLEN ABEL,
BRANDON JAMAL BALDWIN,
LINDA ANN BEEN,

AMERICA JABRIELLE VOSHA
BROWN,

AMBER MARIE CLAYSON,
AMBER CHARDA CRAWFORD,
TONI LARAE CRISP,

LATOYA EFFIE LAWSHAWN
DUHART,

DEREK JAMES ENLOE,

COREY RAY FIELDS,

SHAREE NASHAWN GALLOWAY,
ASHLEY NICOLE GILL,
BRITTANY NICOLE HARKINS,
JESSICA MARIE HOOKS,
STEPHEN ANTHONY JENNINGS,
AMANDA JOHNSON,

BILLY DON OSBORNE,

JUSTON PAUL OSBORNE,
DANIEL EUGENE PAYNE,
TAILYR MAEGAN PAYNE,
KATRINA DANIELLE ROBISON,
KARISSA RAY RUSSELL,
GE’RAE QUIN’SHAY THOMPSON,

Defendants.

THE GRAND JURY CHARGES:

U.S. DISTRICT COURT
FILED UNDER SEAL

Case No. 2 1 CR 49 o GKF

[COUNT ONE: 18 U.S.C. §§ 371 and 2
— Conspiracy;

COUNTS TWO through ONE
HUNDRED SIXTY-SIX: 18 U.S.C.

§ 1343 — Wire Fraud;

COUNT ONE HUNDRED SIXTY-
SEVEN: 18 U.S.C. § 1349 —
Conspiracy to Commit Wire Fraud;
COUNTS ONE HUNDRED SIXTY-
EIGHT and ONE HUNDRED SIXTY-
NINE: 18 U.S.C. § 1956(h) -
Conspiracy to Commit Money
Laundering;

COUNTS ONE HUNDRED
SEVENTY through TWO HUNDRED
FOURTEEN; 18 U.S.C. § 1957(a) -
Relating to Engaging in Monetary
Transactions in Property Derived from
Specified Unlawful Activity;
FORFEITURE ALLEGATION: 18
U.S.C. §§ 981(a)(1)(c) and 982(a) and
28 U.S.C. § 2461 — Conspiracy, Fraud,
and Racketeering Forfeiture]
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 2 of 36

COUNT ONE
[18 U.S.C. §§ 371 and 2]

INTRODUCTION

1. As used in the Indictment, the following terms have the following
meanings:

2. A “booster” is a person who steals goods and merchandise, specifically, but
not limited to over-the-counter medication (“OTC”) from retail stores.

3. A “fence” or “fencing operation” is a person, organization or entity that
purchases or receives stolen goods and merchandise from boosters. The fence or
fencing operation then re-sells the stolen goods and merchandise to third parties.

4. “OTC” is medicine that does not require a prescription and includes non-
prescription personal hygiene products that can be readily sold in a secondary
market. OTC includes, but is not limited to, the following products: Allegra,
Prevagen, Zantac, Rogaine, Zyrtec, Viviscal, Mucinex, Claritin, Culturelle, Flonase,
Nasacort, and assorted vitamin products.

5. “Mobile Payment Services” are payment services operated under financial
regulation and performed from or via a mobile device. Mobile Payment Services
include the following:

a. “PayPal” is an online payments system operated by PayPal Holdings,
Inc. that supports online money transfers, and serves as an electronic
alternative to traditional paper methods such as checks and money

orders.
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 3 of 36

b. “Venmo” is a mobile payment service owned by PayPal.

c. “CashApp” is a mobile payment service operated by Square, Inc. that
allows users to transfer money to one another using a mobile phone
application.

THE CONSPIRACY AND ITS OBJECTS

6. From in or about January 2018 to the date of this Indictment, in the
Northern District of Oklahoma and elsewhere, the defendants, JEFFREY ALLEN
ABEL (“ABEL”), BRANDON JAMAL BALDWIN (“BALDWIN”), LINDA
ANN BEEN (“BEEN”), AMERICA JABRIELLE VOSHA BROWN
(“BROWN”), AMBER MARIE CLAYSON (“CLAYSON”), AMBER CHARDA
CRAWFORD (“CRAWFORD”), TONI LARAE CRISP (“CRISP”), LATOYA
EFFIE LAWSHAWN DUHART (“DUHART”), DEREK JAMES ENLOE
(“ENLOE”), COREY RAY FIELDS (“FIELDS”), SHAREE NASHAWN
GALLOWAY (“GALLOWAY”), ASHLEY NICOLE GILL (“GILL”),
BRITTANY NICOLE HARKINS (“HARKINS”), JESSICA MARTE HOOKS
(“HOOKS”), STEPHEN ANTHONY JENNINGS (“JENNINGS”), AMANDA
JOHNSON (“JOHNSON”), BILLY DON OSBORNE (“B. OSBORNE”),
JUSTON PAUL OSBORNE (“J. OSBORNE”), DANIEL EUGENE PAYNE
(“D. PAYNE”), TAILYR MAEGAN PAYNE (“T. PAYNE”), KARISSA RAY
RUSSELL (“RUSSELL”), KATRINA DANIELLE ROBISON (“ROBISON”),

and GE’RAE QUIN’SHAY THOMPSON (“THOMPSON”), did knowingly and
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 4 of 36

willfully conspire, confederate, and agree, with each other and others, known and
unknown to the Grand Jury (collectively, the “Conspirators”’), to commit certain
offenses against the United States, that is,

a. to violate Title 18, United States Code, Section 2314, by transporting,
transmitting, and transferring in interstate commerce goods, wares, and
merchandise, of the value of $5,000 or more, knowing the same to have
been stolen, converted, and taken by fraud, as described below;

b. to violate Title 18, United States Code, Section 2315, by receiving,
possessing, concealing, storing, bartering, selling, and disposing of any
goods, wares, and merchandise, of the value of $5,000 or more, which
had crossed a State boundary after being stolen, unlawfully converted,
and taken, knowing the same to have been stolen, unlawfully
converted, and taken, as described below.

THE PURPOSE OF THE CONSPIRACY
7. The purpose of the Conspiracy was for the Conspirators to unlawfully
enrich themselves by stealing goods, wares, and merchandise, including OTC items,
from retail stores and pharmacies within the Northern District of Oklahoma and
elsewhere, and selling the goods, wares, and merchandise to fences and fencing

operations outside the state of Oklahoma.
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 5 of 36

MANNER AND MEANS OF THE CONSPIRACY
BEEN’s Origins with Online Retail

8. It was part of the Conspiracy that the Conspirators used the following manner
and means to accomplish the Conspiracy:

9. Between approximately 2015 and 2018, BEEN was married to “C.B.,” a
person known to the Grand Jury, who maintained and operated an eBay account
under the account name “Super C Deals.”

10. In or about 2016, “A.Y.,” a person known to the Grand Jury, introduced
BEEN to the practice of purchasing and reselling stolen merchandise acquired from
boosters.

11.In or about 2016, BEEN began utilizing the Super C Deals eBay account to
sell merchandise she obtained from boosters.

12. Through her use of eBay, BEEN became acquainted with various fences and
fencing operations located throughout the United States who were interested in
purchasing stolen merchandise in bulk quantities.

13. Using the Super C Deals account, BEEN sold bulk quantities of stolen OTC,
at prices below market value, to various fencing operations located throughout the

United States.
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The Conspirators Acquisition of Stolen Property

14.To keep up with growing demand from fences, beginning in or about January
2018, BEEN and other Conspirators, including JENNINGS, ROBISON and
RUSSELL, recruited additional boosters to help her obtain product.

15.Fences would email and text message BEEN detailed lists of items and prices
they would pay for each.

16. Fences generally agreed to pay BEEN half the retail value of any given item.
In turn, BEEN generally paid boosters half the amount she expected to receive from
fences for the item.

17. BEEN, through emails and text messages, provided boosters with detailed lists
of the items she wanted and the amount she would pay for each item, and instructed
boosters on stores to target.

18. Boosters targeted the following stores and pharmacies for theft: Sam’s Club,
CVS, Akin’s Natural Foods, GNC, Reasors, Sprouts, Target, Walmart, Walgreen’s,
and others.

19. BEEN would sometimes drive and accompany boosters to retail stores around
Tulsa and elsewhere to steal products at her direction.

20. Boosters travelled outside the state of Oklahoma to commit thefts in states

including Kansas, Texas, Missouri, Arkansas, Colorado, and others.
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 7 of 36

21. When boosters traveled outside of Oklahoma to engage in thefts, BEEN sent
payments via Mobile Payment Platforms to assist with the boosters’ travel expenses,
including gas, food, and lodging.

22. Boosters entered targeted businesses, concealed and seized inventory, and
exited points of sale without paying for seized products.

23. Boosters engaged in “box-stuffing,” namely, concealing high value items
inside a lower-valued item box, and only paying for the lower-valued item, thus
absconding with the concealed items.

24. After stealing items, boosters delivered products to BEEN at various locations,
including, but not limited to:

a. BEEN’s residence at the Canyon Creek RV Park in Tulsa, Oklahoma;

b. BEEN’s residence at the Edgewater Mobile Home Park in Cleveland,
Oklahoma;

c. C&B Welding and Fabrication, a business warehouse located in Sand
Springs, Oklahoma, and operated by B. OSBORNE and FIELDS; and

d. J. OSBORNE’s residence in Sand Springs, Oklahoma.

25.BEEN used cash and Mobile Payment Platforms, including Venmo,
CashApp, and PayPal, to pay boosters for stolen property.

26. When boosters were arrested by law enforcement for theft or larcenies, BEEN
facilitated bond payments for their release, thereby allowing boosters to continue

stealing in furtherance of the Conspiracy.
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 8 of 36

27.I1f BEEN was unable to secure a booster’s release from jail through bond,
BEEN would provide money to the individual’s jail commissary account and family
members to deter a booster’s cooperation with law enforcement.

The Conspirators’ Interstate Sale of Stolen Property

28. After obtaining stolen products from boosters, BEEN and other Conspirators,
including B. OSBORNE, J. OSBORNE, FIELDS, and JOHNSON, stored the
inventory in preparation for shipment to fencing operations.

29.The Conspirators organized stolen inventory in preparation for interstate
shipment at storage locations, including both the C&B Welding and Fabrication
warehouse and Suburban Revival Boutique, a retail store located in Sand Springs,
Oklahoma, controlled and operated by JOHNSON.

30. BEEN coordinated shipment of the items to fencing operations located outside
the state of Oklahoma, as follows:

a. BEEN, and others known to the Grand Jury, prepared invoices
identifying products to be shipped to the fencing operations, and sent
the invoices to the fencing operations through e-mail and other
electronic communications;

b. Fences sent BEEN payment for the anticipated inventory through
Mobile Payment Platforms;

c. BEEN coordinated interstate shipments of stolen property to fences

through various freight companies;
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 9 of 36

d. Conspirators, including B. OSBORNE, FIELDS, and J. OSBORNE
organized pallets of inventory for delivery to contracted freight
companies; and

e. Contracted freight companies received pallets of inventory from the
Conspirators’ storage locations for delivery to fencing operations.

31.BEEN received approximately $4.5 million in payments from fencing
operations for shipment of stolen property.

OVERT ACTS

32.In furtherance of the Conspiracy, the Conspirators committed, in the Northern
District of Oklahoma and elsewhere, one or more of the following acts:

33.On or about January 13, 2019, ENLOE stole miscellaneous OTC and health
and beauty products, including Nicorette Gum, Viviscal hair growth product, and
Xyzal allergy medications, from Walmart at 2301 West Kenosha Street, Broken
Arrow, Oklahoma.

34: On or about March 31, 2019, BEEN drove “C.F’ and “J.G”, boosters known
to the Grand Jury, from Tulsa, Oklahoma to Oklahoma City, Oklahoma with the
intent to steal targeted OTC from retail stores.

35.On or about March 31, 2019, BEEN, C.F and J.G stole OTC items from CVS
at 5025 North May Avenue, Oklahoma City, Oklahoma.

36.On or about March 31, 2019, BEEN drove C.F. and J.G. to Target at 5400

North May, Oklahoma City, Oklahoma.
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 10 of 36

37.On or about March 31, 2019, C.F. and J.G. stole approximately 300 boxes of
targeted OTC products, including Mucinex, Claritin, Zyrtec, Flonase and Frontline,
valued at $2,480, from Target at 5400 North May Avenue, Oklahoma City,
Oklahoma to provide to BEEN.

38.On or about May 25, 2019, CRAWFORD stole Crest White strips, valued at
approximately $3,374.27, from Target at 10711 East 71st Street, Tulsa, Oklahoma.

39.On or about June 10, 2019, BEEN caused approximately $2,000 to be
transferred through PayPal to ROBISON for the payment of stolen OTC.

40.On or about July 8, 2019, CRAWFORD attempted to steal approximately
$2,552 worth of OTC, including Mucinex and Zyrtec, utilizing the box stuffing
method described herein, from Sam’s Club located at 4420 South Sheridan Road,
Tulsa, Oklahoma.

41.On or about July 23, 2019, CRAWFORD and an unknown female stole OTC
products, including Alli weight loss supplements and Nicorette gum, valued at
approximately $704.88, from the Target located at 9010 N. 121 East Avenue in
Owasso, Oklahoma.

42.On or about July 31, 2019, BEEN caused approximately $2,000 to be
transferred through PayPal to ROBISON for the payment of stolen OTC.

43.On or about August 9, 2019, RUSSELL and JENNINGS drove from Tulsa,

Oklahoma, to Arlington, Texas, with the intent to steal OTC products for BEEN.

10
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 11 of 36

44.On or about August 9, 2019, RUSSELL and JENNINGS stole eight boxes of
SeroVital dietary supplements and 88 boxes of Frontline flea treatment, valued at
approximately $7,535.04, from Costco located at 600 West Arbrook Boulevard,
Arlington, Texas.

45.On or about September 4, 2019, BEEN caused approximately $2,344 to be
transferred through PayPal to RUSSELL for the payment of stolen OTC.

46.On or about September 4, 2019, DOUHART, CLAYSON and two uncharged
co-conspirators stole OTC products, including Flonase, Mucinex, Nexium, Zegrid,
Allegra, valued at approximately $1,329.07, from Reasors located at 446 South Elm
Street, Jenks, Oklahoma.

47.On or about September 5, 2019, BEEN caused approximately $200 to be
transferred through CashApp to DUHART for the payment of stolen OTC.

48.On or about September 15, 2019, BEEN caused approximately $705 to be
transferred through CashApp to DUHART for the payment of stolen OTC.

49.On or about September 17, 2019, BEEN caused approximately $602 to be
transferred through CashApp to DUHART for the payment of stolen OTC.

50.On or about November 2, 2019, CLAYSON and T. PAYNE stole
approximately $1,500 of vitamin products, including fish oil supplements, from
Natural Grocers located at 3126 South Harvard, Tulsa, Oklahoma.

51.On or about November 3, 2019, BEEN caused approximately $105 to be

transferred through CashApp to T. PAYNE for the payment of stolen OTC.

11
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52.On or about November 4, 2019, BEEN caused approximately $276 to be
transferred though CashApp to T. PAYNE for the payment of OTC.

53.On or about November 13, 2019, BEEN caused approximately $1,064 to be
transferred through PayPal to D. PAYNE for the payment of stolen OTC.

54.On or about November 23, 2019, BEEN caused approximately $834 to be
transferred through CashApp to DUHART for the payment of stolen OTC.

55.On or about November 28, 2019, T. PAYNE stole approximately $553 worth
of Abreva from CVS located at 7041 South Yale Avenue, Tulsa, Oklahoma.

56.On or about December 1, 2019, BEEN caused approximately $105 to be
transferred through CashApp to T. PAYNE for the payment of stolen OTC.

57.On or about December 30, 2019, BEEN caused approximately $400 to be
transferred through Venmo to CLAYSON for the payment of stolen OTC.

58.On or about January 21, 2020, HOOKS stole approximately $500 worth of
beauty products, including Prilosec, Nexium and Flonase, from Walgreen’s located
at 11650 East 86th Street North, Owasso, Oklahoma.

59.On or about February 4, 2020, T. PAYNE stole OTC medications, valued at
approximately $1,500, from CVS located at 2110 South Harvard Avenue in Tulsa,
Oklahoma.

60.On or about February 6, 2020, HOOKS and an unknown coconspirator stole

OTC and health and beauty items, including Claritin, Flonase and Abreva, valued at

12
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 13 of 36

approximately $4,333.46, from Walgreen’s located at 950 East Kenosha Street,
Broken Arrow, Oklahoma.

61.On or about February 8, 2020, D. PAYNE drove to Sam’s Club located at
4420 South Sheridan Road in Tulsa, Oklahoma with the intent to steal targeted
products for BEEN. Upon entering the store, D. PAYNE, using the box-stuffing
tactic discussed herein, stole approximately $1,116.51 of miscellaneous OTC
medications and other products, including whitening strips and Phillips Norelco
shavers.

62.On or about February 12, 2020, BEEN caused approximately $500 to be
transferred through PayPal to HARKINS for the payment of stolen OTC.

63.On or about February 14, 2020, BEEN caused approximately $250 to be
transferred through PayPal to HARKINS for the payment of stolen OTC.

64.On or about February 14, 2020, D. PAYNE stole Gillette razors, hair dryers
and eye drops, valued at approximately $1,299.86, utilizing the box stuffing method
discussed herein, from Sam’s Club at 7757 South Olympia Avenue, Tulsa,
Oklahoma.

65.On or about February 16, 2020, D. PAYNE stole beauty products and OTC,
including electronic toothbrushes, vitamins, Allegra and Crest Whitening Strips,
valued at approximately $701, utilizing the box stuffing method discussed herein,

from Sam’s Club located at 4420 South Sheridan Road, Tulsa, Oklahoma.

13
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 14 of 36

66.On or about February 18, 2020, D. PAYNE stole OTC, including Irwin
Naturals vitamins and supplements, valued at approximately $302.72, from Sam’s
Club located at 6922 S. Mingo Road, Tulsa, Oklahoma.

67.On or about February 24, 2020, BEEN caused approximately $292 to be
transferred through CashApp to HOOKS for the payment of stolen OTC.

68.On or about February 29, 2020, BEEN caused approximately $1,845 to be
transferred through PayPal to D. PAYNE for the payment of stolen OTC.

69.On or about March 3, 2020, T. PAYNE stole OTC, including vitamins,
valued at approximately $1,041 from CVS located at 4107 South Harvard Avenue,
Tulsa, Oklahoma.

70.On or about March 5, 2020, T. PAYNE and an unknown female stole OTC,
valued at approximately $400, from CVS located at 2110 South Harvard Avenue,
Tulsa, Oklahoma.

71.On or about March 7, 2020, BEEN caused approximately $105 to be
transferred through PayPal to T. PAYNE for the payment of stolen OTC.

72.On or about March 11, 2020, BEEN caused approximately $400 to be
transferred through PayPal to T. PAYNE for the payment of stolen OTC.

73.On or about March 11, 2020, CLAYSON and other uncharged co-
conspirators attempted to steal OTC merchandise from Walgreens located at 11332

East 31% Street in Tulsa, Oklahoma.

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Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 15 of 36

74.On or about March 16, 2020, BEEN caused approximately $200 to be
transferred through CashApp to HOOKS for the payment of stolen OTC.

75.On or about March 20, 2020, CRAWFORD and another unidentified male
and female stole multiple OTC, including Mucinex, valued at approximately $738,
from Sam’s Club located at 4420 South Sheridan Road in Tulsa, Oklahoma.

76.On or about March 24, 2020, CRISP concealed and stole Curamed vitamins,
valued at approximately $444.88, from Akin’s Natural Foods located at 7807 East
51* Street in Tulsa, Oklahoma.

77.On or about March 24, 2020, BEEN caused approximately $75 to be
transferred to CRISP through CashApp for the payment of stolen OTC.

78.On or about March 31, 2020, BEEN caused approximately $200 to be
transferred through CashApp to JOHNSON to facilitate the storage of stolen OTC at
the Suburban Revival Boutique.

79.On or about May 12, 2020, BEEN caused approximately $400 to be
transferred through PayPal to BALDWIN for the payment of stolen OTC.

80.On or about June 8, 2020, BEEN caused approximately $1,000 and $650 to be
transferred through PayPal and approximately $350 to be transferred through
CashApp to HARKINS for the payment of stolen OTC.

81.On or about August 1, 2020, CRISP and an uncharged co-conspirator
attempted to steal approximately $411.05 of OTC, including probiotics, from Sprouts

located at 24 East 2" Street, Edmond, Oklahoma.

15
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 16 of 36

82.On or about August 7, 2020, GILL stole multiple items of OTC from Sam’s
Club at 6922 South Mingo Road in Tulsa, Oklahoma.

83.On or about August 12, 2020, BROWN and THOMPSON drove from Tulsa,
Oklahoma, to Oklahoma City, Oklahoma, with the intent to steal targeted OTC for
BEEN.

84.On or about August 12, 2020, BROWN and THOMPSON stole multiple
items of OTC, including Mucinex, Claritin, Allegra, Flonase and Zyrtec, valued at
approximately $1,640.36, from Walgreen’s located at 1201 Northwest 12™ Street,
Moore, Oklahoma.

85.On or about August 12, 2020, BROWN, THOMPSON, and a juvenile co-
conspirator stole multiple items of OTC, including Plan B and Flonase, valued at
approximately $1,657.58, from Walgreen’s located at 1041 Southwest 19" Street,
Moore, Oklahoma.

86.On or about August 14, 2020, BALDWIN was in possession of approximately
$400 worth of various stolen OTC with the intent to sell it to BEEN.

87.On or about August 16, 2020, THOMPSON, BROWN and a juvenile co-
conspirator stole multiple OTC items, including Prilosec and Nexium, valued at
approximately $395.86, from Walgreen’s located at 2100 West Britton Road in

Oklahoma City, Oklahoma.

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88.On or about September 24, 2020, BEEN caused approximately $500 to be
transferred through CashApp to JOHNSON to facilitate the storage of stolen OTC at
Suburban Revival Boutique.

89.On or about December 22, 2020, BROWN and an uncharged co-conspirator
drove from Tulsa, Oklahoma to Grapevine, Texas, in a 2005 Acura registered to
BEEN with the intent to steal targeted OTC from Texas retail stores for BEEN.

90.On or about January 11, 2021, BEEN caused approximately $370 to be
transferred through CashApp to ENLOE for the payment of stolen OTC.

All in violation of Title 18, United States Code, Sections 371 and 2.

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COUNTS TWO through ONE HUNDRED SIXTY-SIX
[18 U.S.C. § 1343]

INTRODUCTION

91.The Grand Jury hereby incorporates and realleges paragraphs 1 through 90 of
this Indictment.

92.On or about the dates stated below, in the Northern District of Oklahoma and
elsewhere, Defendants LINDA ANN BEEN (“BEEN”), BRANDON JAMAL
BALDWIN (“BALDWIN”), AMBER MARIE CLAYSON (“CLAYSON”),
AMBER CHARDA CRAWFORD (“CRAWFORD”), TONI LARAE CRISP
(“CRISP”), LATOYA EFFIE LAWSHAWN DUHART (“DUHART”), DEREK
JAMES ENLOE (“ENLOE”), SHAREE NASHAWN GALLOWAY
(“GALLOWAY”), BRITTANY NICOLE HARKINS (“HARKINS”), JESSICA
MARIE HOOKS (“HOOKS”), AMANDA JOHNSON (“JOHNSON”), JUSTON
PAUL OSBORNE (“J. OSBORNE”), DANIEL EUGENE PAYNE (“D.
PAYNE”), TAILYR MAEGAN PAYNE (“T. PAYNE”), KARISSA RAY
RUSSELL (“RUSSELL”) and KATRINA DANIELLE ROBISON
(“ROBISON”’), as specified in the Payor and Payee columns in the table below,
having devised and intending to devise a scheme and artifice to defraud, and for
obtaining money and property by means of false and fraudulent pretenses,
representations and promises, as described in paragraphs 1 through 90 of this
Indictment, the allegations of which are incorporated into these Counts by reference

(“the Scheme”), knowingly transmitted, and caused to be transmitted, writings,

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signs, signals, pictures, and sounds by means of wire communications in interstate

commerce for the purpose of executing the Scheme, as described below. The wire

communications described below were payments from BEEN, specifically, electronic

funds transfers coordinated by BEEN through Mobile Payment Services, in the

approximate amounts stated below:

Payment.
Count Date Payor Payee Amount Platform
2 06/10/2019 | BEEN ROBISON $2,000.00 PayPal
3 07/31/2019 | BEEN ROBISON $2,000.00 PayPal
4 08/12/2019 | BEEN ROBISON $2,500.00 PayPal
5 08/23/2019} BEEN CRAWFORD $270.00 PayPal
6 08/25/2019| BEEN CRAWFORD $100.00 PayPal
7 08/25/2019| BEEN D. PAYNE $500.00 PayPal
8 08/26/2019| BEEN CRAWFORD $150.00 PayPal
9 08/29/2019} BEEN DUHART $290.00 Venmo
10 08/30/2019 | BEEN CRAWFORD $100.00 PayPal
11 09/01/2019} BEEN CRAWFORD $20.00 PayPal
12 09/04/2019 | BEEN CRAWFORD $150.00 CashApp
13 09/04/2019 | BEEN RUSSELL $2,344.00 PayPal
14 09/05/2019 | BEEN CRAWFORD $808.00 CashApp
15 09/06/2019 | BEEN CRAWFORD $200.00 CashApp
16 09/07/2019 | BEEN CRAWFORD $200.00 CashApp
17 09/07/2019 | BEEN CRAWFORD $200.00 CashApp
18 09/08/2019 | BEEN CRAWFORD $300.00 CashApp
19 09/09/2019 | BEEN CRAWFORD $300.00 CashApp
20 09/11/2019} BEEN CRAWFORD $280.00 CashApp
21 09/12/2019 | BEEN CRAWFORD $100.00 CashApp
22 09/14/2019 | BEEN CRAWFORD $20.00 CashApp
23 09/15/2019} BEEN CRAWFORD $400.00 CashApp
24 09/15/2019 | BEEN RUSSELL $1,820.00 PayPal
25 09/15/2019 | BEEN DUHART $705.00 CashApp
26 09/16/2019 | BEEN CRAWFORD $300.00 CashApp
27 09/21/2019 | BEEN DUHART $581.00 CashApp
28 09/22/2019; BEEN CRAWFORD $635.00 CashApp
29 09/22/2019| BEEN RUSSELL $1,445.00 PayPal
30 09/26/2019} BEEN DUHART $512.00 CashApp

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Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 20 of 36

Payment
Count Date Payor Payee Amount Platform
31 10/09/2019 | BEEN D. PAYNE $418.00 PayPal
32 10/11/2019 | BEEN RUSSELL $1,200.00 PayPal
33 10/13/2019 | BEEN DUHART $506.00 CashApp
34 10/22/2019 | BEEN DUHART $623.00 CashApp
35 10/25/2019 | BEEN DUHART $500.00 CashApp
36 10/29/2019 | BEEN D. PAYNE $1,164.00 PayPal
37 10/31/2019 | BEEN T. PAYNE $141.50 CashApp
38 11/01/2019 | BEEN T. PAYNE $50.00 CashApp
39 11/02/2019 | BEEN DUHART $558.00 CashApp
40 11/03/2019 | BEEN T. PAYNE $105.00 CashApp
Al 11/04/2019 | BEEN T. PAYNE $276.00 CashApp
42 11/04/2019 | BEEN ROBISON $2,082.00 PayPal
43 11/09/2019 | BEEN T. PAYNE $25.00 CashApp
44 11/09/2019 | BEEN T. PAYNE $100.00 CashApp
45 11/13/2019 | BEEN D. PAYNE $1,064.00 PayPal
46 11/16/2019 | BEEN DUHART $843.00 CashApp
47 11/22/2019 | BEEN T. PAYNE $50.00 CashApp
48 11/22/2019 | BEEN DUHART $628.00 CashApp
49 11/23/2019 | BEEN T. PAYNE $50.00 CashApp
50 11/24/2019 | BEEN DUHART $834.00 CashApp
51 11/26/2019 | BEEN T. PAYNE $150.00 CashApp
52 12/01/2019 | BEEN T. PAYNE $105.00 CashApp
53 12/04/2019 | BEEN T. PAYNE $50.00 CashApp
54 12/06/2019 | BEEN T. PAYNE $630.00 CashApp
55 12/06/2019 | BEEN GALLOWAY $660.00 CashApp
56 12/08/2019 | BEEN T. PAYNE $120.00 CashApp
57 12/09/2019 | BEEN T. PAYNE $612.00 CashApp
58 12/11/2019 | BEEN DUHART $630.50 CashApp
59 12/11/2019} BEEN GALLOWAY | $1,252.00 CashApp
60 12/13/2019 | BEEN T. PAYNE $100.00 CashApp
61 12/17/2019 | BEEN T. PAYNE $150.00 CashApp
62 12/18/2019 | BEEN HARKINS $232.00 CashApp
63 12/30/2019 | BEEN CLAYSON $400.00 Venmo
64 01/10/2020 | BEEN HARKINS $360.00 CashApp
65 01/13/2020 | BEEN HARKINS $200.00 CashApp
66 01/14/2020 | BEEN JOHNSON $100.00 CashApp
67 01/21/2020 | BEEN JOHNSON $125.00 CashApp
68 02/12/2020 | BEEN HARKINS $500.00 PayPal

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Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 21 of 36

Count Date Payor Payee Amount rea
69 02/12/2020 | BEEN DUHART $500.00 CashApp
70 02/13/2020 | BEEN HARKINS $80.00 PayPal
71 02/14/2020 | BEEN HARKINS $250.00 PayPal
72 02/24/2020 | BEEN HOOKS $292.00 CashApp
73 02/26/2020 | BEEN JOHNSON $144.00 CashApp
74 02/29/2020 | BEEN D. PAYNE $1,845.00 PayPal
75 03/02/2020 | BEEN HOOKS $397.00 CashApp
76 03/03/2020 | BEEN HOOKS $309.00 CashApp
77 03/04/2020 | BEEN HOOKS $328.00 CashApp
78 03/06/2020 | BEEN JOHNSON $168.00 CashApp
79 03/07/2020 | BEEN T. PAYNE $105.00 PayPal
80 03/11/2020 | BEEN T. PAYNE $400.00 PayPal
81 03/16/2020 | BEEN HOOKS $200.00 CashApp
82 03/20/2020 | BEEN GALLOWAY $684.00 PayPal
83 03/22/2020 | BEEN GALLOWAY | $1,070.00 PayPal
84 03/23/2020 | BEEN CRISP $75.00 CashApp
85 03/23/2020 | BEEN HOOKS $200.00 CashApp
86 03/25/2020 | BEEN CRISP $75.00 CashApp
87 03/31/2020 | BEEN JOHNSON $200.00 CashApp
88 04/02/2020 | BEEN CRISP $25.00 CashApp
89 04/05/2020 | BEEN HARKINS $241.00 PayPal
90 04/06/2020 | BEEN CRISP $75.00 CashApp
91 04/06/2020 | BEEN HOOKS $220.00 CashApp
92 04/06/2020 | BEEN HOOKS $500.00 CashApp
93 04/24/2020 | BEEN JOHNSON $100.00 CashApp
94 04/30/2020 | BEEN BALDWIN $400.00 PayPal
95 05/01/2020 | BEEN BALDWIN $400.00 PayPal
96 05/12/2020 | BEEN BALDWIN $400.00 PayPal
97 05/12/2020 | BEEN HARKINS $605.00 CashApp
98 05/12/2020 | BEEN HOOKS $605.00 CashApp
99 05/15/2020 | BEEN HARKINS $416.00 CashApp

100 | 05/15/2020} BEEN HOOKS $500.00 CashApp
101 05/22/2020 | BEEN HOOKS $265.00 CashApp
102 | 05/26/2020 | BEEN HOOKS $200.00 CashApp
103 06/01/2020 | BEEN HOOKS $510.00 CashApp
104 | 06/07/2020 | BEEN HARKINS $360.00 CashApp
105 | 06/08/2020 | BEEN HARKINS $1,000.00 PayPal

106 | 06/08/2020| BEEN HARKINS $650.00 PayPal

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Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 24 of 36

COUNT ONE HUNDRED SIXTY-SEVEN
[18 U.S.C. § 1349]

93.The Grand Jury hereby incorporates and realleges paragraphs | through 92 of
this Indictment.

94.From in or about January 2018 to the date of this Indictment, in the Northern
District of Oklahoma and elsewhere, the defendants JEFFREY ALLEN ABEL
(“ABEL”), BRANDON JAMAL BALDWIN (“BALDWIN”), LINDA ANN
BEEN (“BEEN”), AMERICA JABRIELLE VOSHA BROWN (“BROWN”),
AMBER MARIE CLAYSON (“CLAYSON”), AMBER CHARDA CRAWFORD
(“CRAWFORD”), TONI LARAE CRISP (“CRISP”), LATOYA EFFIE
LAWSHAWN DUHART (“DUHART”), DEREK JAMES ENLOE (“ENLOE”),
COREY RAY FIELDS (“FIELDS”), SHAREE NASHAWN GALLOWAY
(“GALLOWAY”), ASHLEY NICOLE GILL (“GILL”), BRITTANY NICOLE
HARKINS (“HARKINS”), JESSICA MARIE HOOKS (“HOOKS”), STEPHEN
ANTHONY JENNINGS (“JENNINGS”), AMANDA JOHNSON
(“JOHNSON”), BILLY DON OSBORNE (“B. OSBORNE”), JUSTON PAUL
OSBORNE (“J. OSBORNE”), DANIEL EUGENE PAYNE (“D. PAYNE”),
TAILYR MAEGAN PAYNE (“T. PAYNE”), KARISSA RAY RUSSELL
(“RUSSELL”), KATRINA DANIELLE ROBISON (“ROBISON”), and GE’RAE
QUIN’SHAY THOMPSON (“THOMPSON”), did knowingly and willfully
conspire, confederate, and agree, with each other and others, known and unknown

to the Grand Jury (collectively, the “Conspirators”), that is, to violate Title 18,

24
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 25 of 36

United States Code, Section 1343, by knowingly transmitting and causing to be
transmitted, writings, signs, signals, pictures, and sounds by means of wire
communications in interstate commerce after devising and intending to devise a
scheme and artifice to defraud, and for obtaining money and property by means of
material false and fraudulent pretenses, representations and promises, as described
below.
THE PURPOSE OF THE CONSPIRACY

95. The allegations of paragraph 7 of this Indictment are incorporated in this

Count by reference.
MANNER AND MEANS OF THE CONSPIRACY

96. The allegations in paragraphs 8 through 31 and 92 of this Indictment are

incorporated in this Count by reference.

All in violation of Title 18, United States Code, Section 1349.

25
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 26 of 36

COUNT ONE HUNDRED SIXTY-EIGHT
[18 U.S.C. § 1956(h)]

97.The Grand Jury hereby incorporates and realleges paragraphs 1 through 96 of

this Indictment.
THE CONSPIRACY AND ITS OBJECTS

98. Beginning at least as early as in or about January 2018 and continuing through
the date of this Indictment, the exact dates being unknown to the Grand Jury, in the
Northern District of Oklahoma and elsewhere, Defendants LINDA ANN BEEN
and BILLY DON OSBORNE (the “Co-Conspirators”), and others, known and
unknown to the Grand Jury, knowingly and willfully conspired to commit the
following offenses against the United States: to knowingly conduct and attempt to
conduct financial transactions affecting interstate and foreign commerce, and
involving property which in fact involved the proceeds of specified unlawful activity
(Interstate Transportation of Stolen Property and Wire Fraud) with the intent to
promote the carrying on of specified unlawful activity, in violation of Title 18,
United States Code, Section 1956(a)(1)(A)Q).

MANNER AND MEANS OF THE CONSPIRACY

99. The Co-conspirators used the following manner and means to achieve the
objects of the conspiracy:

100. The allegations of paragraphs 7 through 29 are incorporated in this Count

by reference.

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Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 27 of 36

101. On or about the dates and in the approximate amounts stated below, and

with the intent to promote the carrying on of the offenses of Interstate Transportation

of Stolen Property and Wire Fraud, BEEN and B. OSBORNE transferred and

caused the transfer of proceeds derived from the commission of the offenses of

Interstate Transportation of Stolen Property and Wire Fraud, from Tulsa Teacher

Credit Union member account number xxxx52 (S14) by negotiating the following

checks for cash:

Date Payor Payee Amount Source
06/19/2020 BEEN B. OSBORNE $7,500.00 Check 1027
07/03/2020 BEEN B. OSBORNE $6,000.00 Check 1029
07/13/2020 BEEN B. OSBORNE $6,000.00 Check 1030
07/21/2020 BEEN B. OSBORNE $7,000.00 Check 1034
07/24/2020 BEEN B. OSBORNE $7,000.00 Check 1035
07/28/2020 BEEN B. OSBORNE $7,000.00 Check 1038
07/31/2020 BEEN B. OSBORNE $8,000.00 Check 1039
08/03/2020 BEEN B. OSBORNE $7,000.00 Check 1040
08/06/2020 BEEN B. OSBORNE $7,000.00 Check 1041
08/07/2020 BEEN B. OSBORNE $7,000.00 Check 1042
08/13/2020 BEEN B. OSBORNE $8,000.00 Check 1043
08/14/2020 BEEN B. OSBORNE $8,000.00 Check 1045
08/27/2020 BEEN B. OSBORNE $8,000.00 Check 1046
08/28/2020 BEEN B. OSBORNE $8,000.00 Check 1047
09/11/2020 BEEN B. OSBORNE $8,000.00 Check 1048
09/17/2020 BEEN B. OSBORNE $8,000.00 Check 1049
09/29/2020 BEEN B. OSBORNE $8,000.00 Check 1076
10/02/2020 BEEN B. OSBORNE $8,000.00 Check 1077
10/07/2020 BEEN B. OSBORNE $8,000.00 Check 1078
11/09/2020 BEEN B. OSBORNE $8,000.00 Check 1082
11/12/2020 BEEN B. OSBORNE $8,000.00 Check 1083
11/16/2020 BEEN B. OSBORNE $4,000.00 Check 1085
02/03/2021 BEEN B. OSBORNE $8,000.00 Check 1053
02/12/2021 BEEN B. OSBORNE $5,000.00 Check 1054
03/11/2021 BEEN B. OSBORNE $8,000.00 Check 1058
03/29/2021 BEEN B. OSBORNE $2,500.00 Check 1064

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Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 28 of 36

Date Payor Payee Amount ___ Source
04/13/2021 BEEN B. OSBORNE $8,000.00 Check 1067
05/07/2021 BEEN B. OSBORNE $8,500.00 Check 1073

All in violation of Title 18, United States Code, Section 1956(h).

28
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 29 of 36

COUNT ONE HUNDRED SIXTY-NINE
[18 U.S.C. § 1956(h)]

102. The Grand Jury hereby incorporates and realleges paragraphs 1 through

101 of this Indictment.
THE CONSPIRACY AND ITS OBJECTS

103. Beginning at least as early as in or about January 2018 and continuing
through approximately May 2021, the exact dates being unknown to the Grand Jury,
in the Northern District of Oklahoma and elsewhere, Defendants LINDA ANN
BEEN (“BEEN”) and JUSTON OSBORNE (the “Co-Conspirators”), and others,
known and unknown to the Grand Jury, knowingly and willfully conspired to
commit the following offenses against the United States: to knowingly conduct and
attempt to conduct financial transactions affecting interstate and foreign commerce,
and involving property which in fact involved the proceeds of specified unlawful
activity (Interstate Transportation of Stolen Property and Wire Fraud) with the intent
to promote the carrying on of specified unlawful activity, in violation of Title 18,
United States Code, Section 1956(a)(1)(A)(i).

MANNER AND MEANS OF THE CONSPIRACY

104. The Co-conspirators used the following manner and means to achieve the
objects of the conspiracy:

105. The allegations of paragraphs 8 through 31 are incorporated in this Count

by reference.

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Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 30 of 36

106. On or about the dates and in the amounts stated below, and with the intent
to promote the carrying on of the offenses of Interstate Transportation of Stolen

Property and Wire Fraud, BEEN and J. OSBORNE transferred and caused the

transfer of proceeds derived from the commission of the offenses of Interstate

Transportation of Stolen Property and Wire Fraud, from Tulsa Teacher Credit

Union member account number xxxx52 by negotiating the following checks:

Date Payor — Payee Amount Source
02/23/21 BEEN J. OSBORNE $8,000.00 | Check 1057
03/11/21 BEEN J. OSBORNE $5,000.00 | Check 1059
03/22/21 BEEN J. OSBORNE $9,320.00 | Check 1063
03/31/21 BEEN J. OSBORNE | $10,000.00 | Check 1065
04/13/21 BEEN J. OSBORNE | $10,000.00 | Check 1066
04/21/21 BEEN J. OSBORNE $6,778.00 | Check 1069
05/04/21 BEEN J. OSBORNE $3,550.00 | Check 1072

All in violation of Title 18, United States Code, Section 1956(h).

30
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 31 of 36

COUNT ONE HUNDRED SEVENTY through TWO HUNDRED FOURTEEN
[18 U.S.C. § 1957(a)]

107. The Grand Jury hereby incorporates and realleges paragraphs 1 through
106 of this Indictment.

108. From in or about April 2019 through in or about May 2021, as stated
below, in the Northern District of Oklahoma and elsewhere, the defendant LINDA
ANN BEEN, knowingly engaged and attempted to engage in monetary transactions,
as described below, in criminally derived property of a value greater than $10,000
and derived from specified unlawful activities. The specified unlawful activities were
Interstate Transportation of Stolen Property in violation of Title 18, United States
Code, Section 2314, and Sale or Receipt of Stolen Goods, in violation of Title 18,
United States Code, Section 2315, and Wire Fraud, in violation of Title 18, United
States Code, Section 1343.

109. The monetary transactions described below were funds BEEN transferred
from her Mobile Payment Service accounts to her personal financial institution

accounts:

31
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 34 of 36

FORFEITURE ALLEGATION
[18 U.S.C. §§ 981(a)(1)(c) and 982(a) and 28 U.S.C. § 2461]

The allegations contained in this Indictment are hereby realleged and
incorporated by reference for the purpose of alleging forfeitures pursuant to Title 18,
United States Code, Sections 981(a)(1)(c) and 982(a) and Title 28, United States
Code, Section 2461.

Upon conviction of the offenses alleged in this Indictment, as a part of their
sentences, the defendants, LINDA ANN BEEN (“BEEN”), JEFFREY ALLEN
ABEL (“ABEL”), BRANDON JAMAL BALDWIN (“BALDWIN”), AMERICA
JABRIELLE VOSHA BROWN (“BROWN”), AMBER MARIE CLAYSON
(“CLAYSON”), AMBER CHARDA CRAWFORD (“CRAWFORD”), TONI
LARAE CRISP (“CRISP”), LATOYA EFFIE LAWSHAWN DUHART
(“DUHART”), DEREK JAMES ENLOE (“ENLOE”), COREY RAY FIELDS
(“FIELDS”), SHAREE NASHAWN GALLOWAY (“GALLOWAY”),
ASHLEY NICOLE GILL (“GILL”), BRITTANY NICOLE HARKINS
(“HARKINS”), JESSICA MARIE HOOKS (“HOOKS”), STEPHEN ANTHONY
JENNINGS (“JENNINGS”), AMANDA JOHNSON (“JOHNSON”), BILLY
DON OSBORNE (“B. OSBORNE”), JUSTON PAUL OSBORNE (“J.
OSBORNE”), DANIEL EUGENE PAYNE (“D. PAYNE”), TAILYR MAEGAN
PAYNE (“T. PAYNE”), KARISSA RAY RUSSELL (“RUSSELL”), KATRINA
DANIELLE ROBISON (“ROBISON”), and GE’RAE QUIN’SHAY

THOMPSON (“THOMPSON”), shall forfeit to the United States, any property
34
Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 35 of 36

constituting, or derived from, or traceable to, the proceeds obtained, directly or

indirectly, as a result of such violations, and any property, real or personal, that was

used or intended to be used to commit or to facilitate the violation of federal law.

The property to be forfeited includes, but is not limited to:

MONEY JUDGMENT

1,

A money judgment in an amount representing proceeds obtained by each
Defendant as a result of the offenses;

REAL PROPERTY

2.

All that lot and parcel of land, together with all buildings, appurtenances,
improvements, fixtures, attachments and easements thereon, and all rights
appertaining thereto, located at 1098 South County Road 1575, Osage
County, Oklahoma, more particularly described as the east half of the
southwest quarter (E/2 of SW/4) lying west of County Road 1575 in Section
Thirty-five (35), Township Twenty-one (21) North, Range Nine (9) East of the
Indian Meridian, Osage County, Oklahoma;

CURRENCY

3.

All U.S. currency, funds and other monetary instruments credited to or seized
from Tulsa Teacher Credit Union Member Number xxxx52 (S14) account;

PERSONAL PROPERTY

4,

5.

6.

7.

8.

9.

A 2012 Chevrolet Sonic, VIN 1G1JC6SH4C4132704;

A 2018 Chevrolet Cruze, VIN 3G1BE6SM1JS552221;

A 2009 Cadillac Escalade, VIN IGYFK13209R264202;

A 2014-Chevrolet Silverado, VIN 3GCUKSECXEG246955;
A 2016 Chvrolet Silverado 3500, 1GC4K1E89GF241594;

A 2008 Chevrolet Silverado, VIN 1GCEC14X08Z323238;

10.A 2018 Harley Davidson FLHX motorcycle, VIN 1HD1KBC16JB664774;

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Case 4:21-cr-00493-GKF Document 2 Filed in USDC ND/OK on 11/03/21 Page 36 of 36

11.A 2016 Jayco travel trailer, VIN 1UJBJOBT2G1T90200; and

12.A 2020 Jayco Pinnacle luxury fifth wheel, situated on the property at 1098
South County Road 1575, Osage County, Oklahoma, and owned by BEEN.

Pursuant to Title 21, United States Code, Section 853(p), as incorporated by Title
18, United States Code, Sections 982(b)(1) and 1028(g), and Title 28, United States
Code, Section 2461(c), the defendants shall forfeit substitute property, up to the value
of the property described above if, by any act or omission of the defendant, the
property described above, or any portion thereof, cannot be located upon the exercise
of due diligence; has been transferred or sold to, or deposited with, a third party; has
been placed beyond the jurisdiction of the court; has been substantially diminished in
value; or has been commingled with other property which cannot be divided without
difficulty.

All pursuant to Title 18, United States Code, Sections 981(a)(1)(c) and 982(a) and

Title 28, United States Code, Section 2461.

CLINTON J. JOHNSON A TRUE BILL
Acting United States Attorney

[ MZ /s/ Grand Jury Foreperson

RI@HARD M.CELLA Grand Jury Foreperson
_AGsistant United States Attorney

36


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