Information — United States v. Matthew Colbert (Western District of Oklahoma, Document 1, filed July 15, 2020)

Summary

This Information, filed July 15, 2020, in the Western District of Oklahoma, charges Matthew Colbert in Count 1 (Conspiracy to Commit Wire Fraud) under Title 18, United States Code, Section 371. It alleges that Colbert worked at Continental Resources from 2013 until late 2015, including as a division order analyst, and that co-conspirators forged mineral deeds to move balances out of suspended Continental accounts into entities they controlled. It alleges that on or about July 30, 2015, Continental approved two conveyances and wired a combined $153,448.38 from the two suspended accounts to an entity formed by one co-conspirator. The Information also contains forfeiture allegations.

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“Information — United States v. Matthew Colbert (Western District of Oklahoma, Document 1, filed July 15, 2020).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-5-20-cr-00182-dkt-1-0803924c26/, SHA-256 a22421b08beb652e997fb4d70910fc037644908dcbad82492ebf15955a141cb2.

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Case 5:20-cr-00182-R Document 1 Filed 07/15/20 Page 1 of 7

IN THE UNITED STATES DISTRICT COURT FOR THE

WESTERN DISTRICT OF OKLAHOMA

UNITED STATES OF AMERICA, )
)
Plaintiff, )
) CR-20-182-R
-vs- ) No.
)
MATTHEW COLBERT, ) Violations: 18 U.S.C. $ 371
) l8 U.S.C. $ e81(aXlXC)
Defendant. ) 28 U.S.C. $ 2461(c)

INFORMATION
The United States Attorney charges:

Introduction

At all times material to this Infbrmation:

1. Continental Resources. Inc. ("Continental") was an Oklahoma corporation

rvith its principal place olbusiness in Oklahoma Cit.v, Oklahoma. Continental was an

independent oil and gas cxploration and production company with operalions in

Oklahoma and other states. Continental made routine royalty and mineral rights

payments to landowners and owners of rrineral interesls. Continental was required to

report unclaimed and abandoned accounts to the state. Continental would make a diligent

effort to locate the rightful owners ofthese suspended accounts befbre designating the

accounts as unclaimed or abandoned. After exhausting these efforts, Continental would
Case 5:20-cr-00182-R Document 1 Filed 07/15/20 Page 2 of 7

then report to the state when it could not locate the orvners of the accounts. The state

would then claim the accounts through the process of escheatment.

2. Matthew Colbert was a resident of Norman. Oklahoma. Colbert worked

at Continental fiom 2013 until late 2015. Colbert initiallv worked as contractor for

division orders before being promoted by Continental to a division order analyst. While

employed at Continental, Colbert researched the ownership of oil and gas mineral

interests related to suspended Continental accounts where the true owners ofthe interests

had died or for whom Continental did not have a current address or contact information.

3. Co-Conspirator 1 ("CC-l') was a resident of Edmond, Oklahoma. CC-1

vvorked at Continental until 2013. CC-l was a principal ofat least one entity involved in

the conspiracy

4. Co-Conspirator 2 ("CC-2") was a resident of Edmond, Oklahoma. CC-2

was a principal of at least five entities involved in the scheme.

COUNT 1
(Conspiracy to Commit Wire Fraud)

5 I'he United States Attorney incorporates by ref'erence paragraphs I to 4.

6 Beginning in or before October 2013, and continuing through December

2015, in the Western District of Oklahoma and elsewhere.

MATTHEW COLBERT

knowingly, .rl'iltfully, unlawfully, and with interdependence, combined, conspired,

confederated. and agreed with CC-1, CC-2, and with other persons, both known and

2
Case 5:20-cr-00182-R Document 1 Filed 07/15/20 Page 3 of 7

unknown, to commit offenses against the United States, namely, Wire Fraud, in violation

of Title 18. United States Code. Section 371

7. The purpose of the conspiracy was 10 fraudulently obtain royalty and

mineral interest paymcnts from suspended accounts held in trust at Continental. The co-

conspirators utilized various corporate entities to further the conspiracy

8. It was part of the conspiracy that the co-conspirators used their knowledge

and access at Continental to identifu specific mineral interest accounts that had

signilicant suspended balances and could be fraudulently transf'erred with little chance of

being discovered due to the rightful owners being deceased or unable to be located.

9. It was further part of the conspiracy that after identifuing these accounts,

the co-conspirators fbrged liaudulent dceds purporting 10 conve)'the rnineral interests

and royalties, including the accrued balances in the suspended accounts as well as any

future earnings, fiom the rightful owners to the entities controlled by the co-conspirators.

10. It was further part of the conspiracy that the co-conspirators filed these
fiaudulent deeds in the county where the producing property was located. The co-

conspirators submitted these fraudulent deeds to Continental, causing Continental to wrre

transler the balance in these suspended accounts to the entities controlled by the co-

conspirators. In addition to wiring the balance from these suspended accounts at the time

the fraudulent decd was reccived, Continental wired routine payments to the entities

controlled by the co-conspirators in the event the fraudulent deed was for a property thal

was still generating mineral interest payments.
Case 5:20-cr-00182-R Document 1 Filed 07/15/20 Page 4 of 7

I l. It was further part of the conspiracy that upon receiving these lraudulent

payments from Continental, the co-conspirator controlling the bank account receiving the

payment would divide the proceeds up among the co-conspirators and u'ire transfer each

respective co-conspirator a portion of the proceeds.

Overt Acts in Furtherance of the Conspiracy

In furtherance of the conspiracy and to effect the objects thereof, the co-

conspirators committed the follou'ing overt acts, among others, for the purpose of

executing and continuing the conspiracy and agreement:

12. In January 2014,ihe co-conspirators identified a suspended Continental
account that they rvould target. On or about Februarl' l, 2014, CC-1 and CC-2

manufactured a fraudulent mineral deed for this suspended Continental mineral interest

account, which belonged to "C. G." At the time, Continental owed approximately

$128,162.46 in mineral interest payments to "C. G." fbr operations on "C. G.'s" property

in Dunn County. North Dakota. Thc fraudulent mineral deed assigned all interests iiom

"C. G." to an entity CC-2 had formed in January 2014. CC-l and CC-2 forged "C. G.'s"

name on the mineral deed and caused it to be filed in Dunn County, North Dakota, on

Irebruarv 6, 2014. On Fcbruarl' 17 .2014. CC-2 cmailcd the lraudulent rnineral deed to

Continental and instructed Continental to transfer the ownership ofthe account to his

entit.v. Continental approved the transfbr. and on March 28.2014, it wired 5125,119.51

fiom "C. G.'s" suspended account to Bank of America checking account XXXX XXXX

XX38 belonging to CC-2's entity. At the time of this wire, CC-2 was the only person

with signature authority over this account and the account had a balance of approximately

I
Case 5:20-cr-00182-R Document 1 Filed 07/15/20 Page 5 of 7

$66.00. Within days of receiving this transl'er, CC-2 wired 532,291.59. CC-2 then

provided approximately $26,000.00 to Colbert

13. In June 20i5, the co-conspirators identified a suspended Continental
account that they would target. OnoraboutJune24,20l5, CC-l and CC-2 manufactured

a fraudulent mineral deed fbr this suspended Continental rnineral interest account, which

belonged to "M. N." At the time, Continental owed approximately 580,816.54 in mineral

interest payments to "M. N." for operations on "M. N.'s" property in Garvin County,

Oklahoma. The fraudulent mineral deed assigned all interests frorn "M. N." to an entity

formed by CC-2. On Jrne24,20l5, CC-1 and CC-2 forged "M. N.'s" name on the

mineral deed. "M. N." had passed away in 1983. In early July 2015, CC-2 provided the

fraudulent rnineral dced to Colbert. Colbert, in his capacity as a Continental division

order analyst, processed the conveyance and recommended Continental approve the

transf'er

14. In June 2015, the co-conspirators identified another suspended Continental
account that they would target. On or about l::ne 27 ,2015, CC-l and CC-2 manufactured

a fraudulent mineral deed for this suspended Continental mineral interest account, which

belonged to "R. C." At the time, Continental ou,ed approximately $79,592.65 in mineral

interest payments to "R. C." for operations on "R. C.'s" property in Garvin County,

Oklahoma. The fraudulent rnineral deed assigned all interests from "R. C." to an entity

formed by CC-2. CC-1 and CC-2 forged "R. C.'s" name on the mineral deed on J:une 27,

2015. "R. C." was deceased at that time. In early July 2015, CC-2 provided the

fraudulent mineral deed to Colbert. Colbert, in his capacity as a Continental division

5
Case 5:20-cr-00182-R Document 1 Filed 07/15/20 Page 6 of 7

order analyst, processed the conveyance and recommended Continentai approve the

tran sl'e r-

15. On or about July 30, 2015, Continental approved the 1wo fraudulent
conveyances described in paragraphs 13 and 14. On that same date, Continental wired a

combined $153,448.38 from "M. N.'s" and "R. C.'s" suspended accounts to Bank of

America checking account XXXX XXXX XX53 belonging to an entity formed by CC-2.

At the time of this wire, CC-2 was the only person with signature authority over this

account and the account had a balance of approximately $2,300.00. Soon after receiving

this transfer, CC-2 wired $50,352.00 from this account to CC-1. CC-2 then wired

another $50,352.00 frorn his Bank of Arnerica checking account XXXX XXXX XX53 to

a separate entity he controlled.

All in violation of Title 1 8. United States Code. Section 3 7 1 .

FORFEITURE ALLEGATIONS

The allegations contained in this Infomration are hereby re-alleged and

incorporated for the purpose ofalleging forfeiture.

Upon conviction of the offense alleged in Count 1 of this Information, Colbert

shall forfeit to the United States, pursuant to Title 18, United States Code, Section

981(aXlXC), and Title 28, United States Code, Section 2461(c), any property, real or

personal, constituting or derived from proceeds traceable to said offense, inciuding, but

not limited to, a money judgmenl representing the proceeds obtained as a result of the

offense.

6
Case 5:20-cr-00182-R Document 1 Filed 07/15/20 Page 7 of 7

Pursuant to Title 2 1, United States Code. Section 853(p), as incorporated by Title

28. United States Code. Section 2461(c), Colbert shall fbrf-eit substitute propert,v. up to

the value of the amount described in the above paragraph, if, by any act or omission of

the def'endant, the propcrty described above, or any portion thereof, cannot be located

upon the exercise ofdue diligence; has been transferred, 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, Section 981(a)(1XC), and Title 28,

United States Code, Section 2461(c)

TIMOTHYJ. DOWNING
United States Attorney

O2*:*r__
CHARLES W. BROWN
WILLIAM E. FARRIOR
Assistant United States Attornevs

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