Motion for an Order of Forfeiture — United States v. Ford (W.D. Okla., Document 14)

Summary

A Motion for an Order of Forfeiture and Imposition of Forfeiture Money Judgment filed by the United States on April 20, 2022 as Document 14 in United States of America v. Jill Nicole Ford, No. CR-22-9-JD (Case 5:22-cr-00009-JD), in the U.S. District Court for the Western District of Oklahoma. The motion states that the Defendant pled guilty on January 20, 2022 to a two-count Information filed January 7, 2022, and that the Plea Agreement provides for a personal forfeiture money judgment of $252,143.35 representing proceeds obtained as a result of the offenses. It states that the United States has not identified specific assets or substitute assets under 21 U.S.C. § 853(p). It asks for an order of forfeiture as a personal money judgment against the defendant in that amount, as a final order.

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“Motion for an Order of Forfeiture — United States v. Ford (W.D. Okla., Document 14).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-w-d-okla-no-5-22-cr-00009-dkt-14-bfcc99d96a/, SHA-256 fef26535fc9005e2ba2e2936ae7523cfcc002f1958313122b85ea4ffa9474a77.

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Case 5:22-cr-00009-JD Document 14 Filed 04/20/22 Page 1 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE

WESTERN DISTRICT OF OKLAHOMA

UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
-vs- ) No. CR-22-9-JD
)
JILL NICOLE FORD, )
)
Defendant. )

MOTION FOR AN ORDER OF FORFEITURE
AND IMPOSITION OF FORFEITURE MONEY JUDGMENT

The United States of America respectfully moves the Court for an Order of

Forfeiture and Imposition of Forfeiture Judgment. In support of its motion, the United

States shows the Court as follows:

On January 20, 2022, the Defendant Jill Nicole Ford pled guilty to a two-count

Information filed January 7, 2022. In relation to the counts, the United States gave notice

in the Information that, in the event of conviction, she would be required to forfeit to the

United States “any property constituting, or derived from, proceeds obtained directly or

indirectly, as a result of such offense” and “any property, real or personal, involved in such

offense, or any property traceable to such property.” (Doc. 1 at 5)

In her Plea Agreement (Doc. 8 at 10), the defendant agreed to a personal forfeiture

money judgment in the amount of $252,143.35 representing the amount of proceeds

obtained as a result of the offenses.
Case 5:22-cr-00009-JD Document 14 Filed 04/20/22 Page 2 of 4

The United States has not, as of this date, identified specific assets that were derived

from the offenses for the defendant has been convicted. Nor has the United States yet

identified any property of the defendant that could be forfeited as a substitute asset in

accordance with 21 U.S.C. § 853(p).

Accordingly, the United States seeks the entry of an order of forfeiture consisting

of a personal money judgment against the defendant, Jill Nicole Ford, in the amount of

$252,143.35. Because the proposed order involves only a money judgment, rather than

specific property, it should be a final order, with no need for adjudication of the rights of

third parties. Fed. R. Crim. P. 32.2(b)(4)(A).

The entry of an Order of Forfeiture in the form of a personal money judgment is

specifically authorized by Rule 32.2(b)(1) and (c)(1) of the Federal Rules of Criminal

Procedure. Such orders of forfeiture are commonplace. See United States v. McGinty,

610 F.3d 1242, 1246 (10th Cir. 2010) (stating that government is entitled to a money

judgment against the defendant for the money he obtained from his criminal activity)

(citing 18 U.S.C. § 982(a)(2)).

Once the order of forfeiture is entered, the United States may move at any time,

pursuant to Rule 32.2(e)(1)(B), to amend the Order to forfeit specific property of the

defendant, having a value up to the amount of the money judgment, as substitute assets.

See United States v. Candelaria-Silva, 166 F.3d 19, 42 (1st Cir. 1999) (once the

Government has obtained a money judgment, it may forfeit defendant’s real property in

partial satisfaction of that judgment); see also United States v. Baker, 227 F.3d 955, 968
2
Case 5:22-cr-00009-JD Document 14 Filed 04/20/22 Page 3 of 4

(7th Cir. 2000) (same); United States v. Numisgroup Int’l. Corp, 169 F. Supp. 2d 133, 136-

37 (E.D.N.Y. 2001) (holding that Rule 32.2(e) authorizes forfeiture of substitute assets to

satisfy a money judgment, including a judgment based on the value of the missing

proceeds).

The United States respectfully moves for entry of an order of forfeiture in the form

of a personal money judgment against Jill Nicole Ford in the amount of $252,143.35.

Respectfully submitted,

ROBERT J. TROESTER
United States Attorney

s/Jessica L. Perry
JESSICA L. PERRY
Assistant U.S. Attorney
210 Park Avenue, Suite 400
Oklahoma City, Oklahoma 73102
(405) 553-8743 (Office)
(405) 553-8888 (Fax)
jessica.perry@usdoj.gov

3
Case 5:22-cr-00009-JD Document 14 Filed 04/20/22 Page 4 of 4

CERTIFICATE OF SERVICE

I hereby certify that on April 20, 2022, I electronically filed the foregoing Motion for an
Order of Forfeiture and Imposition of Forfeiture Money Judgment of the United States with
the Clerk of the Court using the CM/ECF system which will send notification of such filing
to all counsel of record.

s/Jessica L. Perry
JESSICA L. PERRY
Assistant U.S. Attorney

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