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Petition to Enter Plea of Guilty — United States v. Ford (W.D. Okla., Document 7)

Summary

Petition to Enter Plea of Guilty (form OKWD Plea Petition) filed January 20, 2022 as Document 7 in United States v. Jill Nicole Ford, Case 5:22-cr-00009-JD, in the U.S. District Court in Oklahoma. The defendant states that the defendant wants to plead GUILTY to counts of the Information. The form's questions cover background, the constitutional rights given up by a plea of guilty, and sentencing, including the Sentencing Guidelines. It lists maximum sentences for Bank Fraud and Money Laundering, forfeiture of a Money Judgment in the amount of $252,143.35, and a total special assessment of $200. It closes with certificates for an attorney for the defendant and an attorney for the government.

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“Petition to Enter Plea of Guilty — United States v. Ford (W.D. Okla., Document 7).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-w-d-okla-no-5-22-cr-00009-dkt-7-7ab9d82009/, SHA-256 f106cf30d4d17ec693f41ca8e7a4506e7107fc85eebfdfff26993f6b0dfa1740.

Full text

            Case 5:22-cr-00009-JD Document 7 Filed 01/20/22 Page 1 of 13



                IN THE UNITED STATES DISTRICT COURT FOR THE
                       WESTER}I DISTRICT OF OKLAHOMA


LINITED STATES OF AMERICA,                      )
                                                )
                           Plaintiff,           )
                                                )           cASENo. CR-   a]- q- sD
                                                )
J ILL NICOLE   FORD                             )
                                                )
                                                )
                                                )
                         Defendant.             )

                          PETITION TO ENTER PLEA OF GUILTY

     The defendant states to the Court that the defendant wants to enter a plea of
GUILTY to the following counts of the Indictment or Information:
Counts I and ll of the lnformation


       In connection with this plea of GUILTY, I, Jill Nicole Ford               , the
defendant in this case, inform the Court, under penalty of pe{ury, that I have discussed
these matters with my attorney and the answers to the following questions are true and
correct to the best of my knowledge and belief.

A.      BACKGROUNDOUESTIONS

       Before the Court can accept your plea of guilty, it is necessary that the Court has
certain background information about you and this case. The questions in this section are
asked for this purpose.

I   .   (a)     What is your name?       Jill Nicole Ford


        (b) What is your age?           30


2       Are you currently employed? Yes             X
                                                    No
        Ifyes, what are the name, address and telephone number of your employer?
        Z3ST 1528 Bardella Dr. Leander TX 78641 917-2854420     -

3.      How much education have you had?             Bachelor's Degree
                 Case 5:22-cr-00009-JD Document 7 Filed 01/20/22 Page 2 of 13



  4        Have you ever received medical care or treatment for drug addiction and/or alcohol
           abuse? Yes             No x

           [If so, prior to the hearing on the Petition to Enter Plea of Guilty, counsel for
           defendant shall submit to thejudge's orders mailbox a list of the dates, places, and
           t)?es of treatment received by defendant.]

  5        Have you ever received medical care or treatment for a mental or emotional
           condition? Yes X      No

           [If so, prior to the hearing on the Petition to Enter Plea of Guilty, counsel for
           defendant shall submit to thejudge's orders mailbox a list of the dates, places, and
           types of treatment received by defendant.]

  6        (a) Have you consumed any drug, alcohol or medication that is now impairing
           your ability to think clearly or to understand and answer the questions in this Petition
           to Enter Plea of Guilty? Yes    _         No X
           (b)     Are there any medications prescribed for you that you are not now taking as
                   directed? Yes             No X
                   Ifyes, does the fact that you are not taking the medication as directed impair
                   your ability to -
                                  think clearly or to understand and answer the questions in this
                   Petition to Enter Plea of Guilty? Yes _          No _

t&,        If an attorney is now representing
                                   'Q"llt,I,.you in this case, what is your attomey's name?
v?P               Q^tri"t
  8        Ifyou have an attorney, have you had enough time to talk with your attorney about
           your case? Yes X          No _

  9        If you have an attomey, have you told your attomey everything you know about
           your case? Yes     X     No

  l0       If you have an attorney, are-you satisfied with the services your attorney has
           provided for you? Yes X             No

  I   l.                                       - you? Yes X
           Do you understand the charge(s) against                         No




                                         Page 2 of 13
  OKwD Plca Petition (5/18)
              Case 5:22-cr-00009-JD Document 7 Filed 01/20/22 Page 3 of 13



B.      CONSTITUTIONAL RIGHTS - WAIVERS

       Before the Court can accept your plea of guilty, it is important that you understand
that you will be giving up many valuable constitutional rights by entering a plea of guilty.
The questions in this section are designed to inform you of those rights.

12.     Do you understand you have a right to plead NOT GUILTY to every charge filed
        against you? Yes     X       No _

13.     Do you understand if you plead NOT GtllLTY you have the following
        constitutional rights:

        (a)     the right to a speedy and public trial by jury?
                Yes X        No

        (b)     the right to counsel at all stages of the proceedings, and that if
                you cannot afford to pay a lawyer, one will be appointed to
                represent you? Yes     X        No   _
        (c) the right to see and hear all witnesses called to testify against
            you and the right to cross-examine them?
            Yes X         No

        (d)     the right to use the subpoena power ofthe Court to compel the
                attendance of witnesses at trial and the production of other
                forms of evidence? Yes     X      No

        (e)     the right not to be compelled to incriminate yourself by taking
                the witness stand; and that if you do not take the witness stand,
                no inference of guilt may be drawn from your failure to do so?
                Yes X        No

        (fl     the right to be presumed innocent until the government has
                proved you guilty beyond a reasonable doubt by the unanimous
                agreement of all twelve of the jury members?
                Yes X        No

14.    Do you understand if you plead GUILTY you will be found guilty without a trial
       and you will have given up all of the above rights, except the right to counsel?
       Yes X        No




                                      Page 3 of 13
oKWD Plea Petition (5/18)
            Case 5:22-cr-00009-JD Document 7 Filed 01/20/22 Page 4 of 13



15.     Do you understand if you plead GUILTY to a felony offense this may deprive you
        ofvaluable civil rights including the right to vote, the right to hold public office, the
        right to serve on a jury, the right to possess any kind of firearm, destructive device
        or ammunition, and may make you ineligible for certain government benefits?
        Yes X         No            Not Applicable

l6      If you are not a-citizen of the United States, pleading guilty may affect your
        immigration status. Pleading guilty may result in your deportation or removal from
        the United States, may prevent you from ever lawfully reentering or remaining in
        the United States, and may result in the denial of naturalization. Deportation is
        mandatory for certain offenses, including most crimes involving controlled
        substances. You may be deported or removed from the United States even if you
        are a legal resident and even if you have legally lived in the United States for many
        years. Do you understand?
        Yes X           No           Not Applicable x

C.      SENTENCI\G -GENERAL
                             -
       Before the Court can accept your plea of guilty, it is important that you understand
certain aspects of the sentencing process. The questions in this section are designed for
that purpose.

17.     Do you realize if you plead GUILTY the maximum statutory sentence the judge
        may impose remains the same as if you had pled NOT GUILTY and had been
        convicted by a jury? Yes X      No _

l8      Do you know the sentence you will receive is solely a matter for the judge to decide?
        Yes   X    No

19.     (a) What is the maximum sentence the law provides for the offense(s) to which
                you want to plead GUILTY?

                Count l: Bank Fraud: NMT 30 Years' lmprisnment and/or fine of $1 ,000,000
                Count ll: Money Laundering: NMT 10 Years' lmprisonment and/or fine of $250,000




        (b)     Is there a minimum mandatory sentence the law provides for the offense(s)
                to which you want to plead GUILTY? Yes _         No X        If yes, what
                is it?




                                       Page 4 of 13
oKWD Plea Petition (5/18)
            Case 5:22-cr-00009-JD Document 7 Filed 01/20/22 Page 5 of 13




        (c)     For certain offenses a term of supervised release must be imposed to be
                served after the person is released from a term of imprisonment. Is there a
                mandatory term ofsupervised release for the offense(s) to which you want to
                plead GUILTY? Yes _               No X        If yes, what is the mandatory
                term?




                For all other offenses, thejudge may, in thejudge's discretion. impose a term
                of supervised release to be served following the person's release from
                imprisonment. What is the maximum term of supervised release that could
                be imposed in this case?

                Count l: NMT 5 Years
                Counl ll: NMT 3 Years




                What is the maximum term of imprisonment that could be imposed if your
                supervised release were revoked?

                Count l: 3 Years
                Count ll: 2 Years




        (d) Will you be forfeiting any property to the United States as a result of your
            guiltyplea? Yes Y No _                 Ifyes,whatproperty?
                Money Judgment in the amount of $252,143.35




                                        Page 5 of 13
OKWD Plea Petition (5/18)
            Case 5:22-cr-00009-JD Document 7 Filed 01/20/22 Page 6 of 13



20.     If you plead GUILTY, the judge may require you to make restitution to any victim
        of the offense [18 U.S.C. S$ 3663 and 3664]. If you plead GUILTY to an oflense
        that occurred on or after April24, 1996, and the offense falls into certain categories
        ofoffenses, including property offenses and crimes ofviolence, ordinarily the judge
        is required to order you to pay restitution to any victim of the offense [ 8 U.S.C.
        $ 3663A1. Also, in certain cases, the law identifies specific classes of people or
        organizations that may be entitled to restitution. Restitution is a continuing
        obligation that does not end until it is paid in full. In other words, the United States
        may continue to seek restifution from you even though you are no longer serving a
        sentence of confinement or supervision. Do you understand all of this?
        Yes x          No

2l      The judge must impose a special assessment for each count to which you enter a
        plea of guilty. The amount of the special assessment depends on whether the
        offense is a felony or a misdemeanor [8 U.S.C. $ 3013]. In your case, taking into
        account each offense to which you want to plead guilty, the total amount ofspecial
        ss5sssrngnl is $    200                                    This amount will be due
        at the time of sentencing. Do you understand this? Yes        x    No      _
22      If you are on probation or parole in this or any other court, do you know that by
        pleading GUILTY here your probation or parole may be revoked and you may be
        required to serve a sentence as a result ofthat revocation in addition to any sentence
        imposed upon you in this case? Yes      x        No  _
23.     Do you understand that in certain circumstances a federal judge may order a federal
        sentence of imprisonment to run at the same time as a state sentence of
        imprisonment? Yes x            No _

24.     Do you understand if you are convicted of a violation of Title 18, United States
        Code, Section 924(c), the term of imprisonment imposed for that conviction cannot
        be served concurrently with any other term of imprisonment?
        Yes x        No _        Not Applicable x
D.      SENTENCING GUIDELINES AND OTHER                                  SENTENCING
        CONSIDERATIONS

25.     In determining an appropriate sentence for a federal crime, the judge must consider
        the Sentencing Guidelines developed by the United States Sentencing Commission.
        The Sentencing Guidelines are advisory in nature, not mandatory. The judge must
        consider imposing a sentence within the range established by the Sentencing
        Guidelines, but the judge may impose a sentence either above or below that range.
        Do you understand this? Yes x          No _


                                     Page 6 of 13
OKWD Plea Petition (5/18)
            Case 5:22-cr-00009-JD Document 7 Filed 01/20/22 Page 7 of 13



26. In calculating the range of sentence under the advisory Sentencing Guidelines, the
       judge will take into account all conduct, circumstances, and injuries associated with
        your criminal conduct, whether or not this conduct is formally charged by the
        govemment. The judge will consider all relevant conduct at the time of sentencing
        even though you are pleading guilty to fewer than all counts in the Indictment or
        Information. Do you understand this? Yes x            No _

27     Also, there is no limitation placed on the information the judge can consider at the
       time of sentencing concerning your background, character, and conduct so long as
       the information is reliable. The judge will take all of these factors into
       consideration in determining an appropriate sentence. Do you understand this?
       Yes    x      No

28.     If the judge orders a presentence investigation, a U.S. Probation Officer will be
       assigned to conduct a thorough investigation and prepare a presentence report for
       the judge's use. Do you understand that if you lie to the U.S. Probation Officer, or
       if you cause others to lie on your behalf, this can be considered by the judge and
       may increase the range of sentence calculated under the advisory Sentencing
       Guidelines? Yes x           No

29     Your history of prior criminal convictions will be used to compute your Criminal
       History Category under the Sentencing Guidelines. If you have prior felony
       convictions which were imposed or for which you have served time within the past
       l5 years, your Criminal History Category may be increased. Similarly, if you have
       received misdemeanor convictions within the past l0 years, your Criminal History
       Category may be increased. Certain exceptions may apply in your case that would
       exclude a conviction from the Criminal History Category computation.
       Nonetheless, do you understand your prior criminal history has a direct impact on
       the calculation ofthe sentencing range under the advisory Sentencing Guidelines?
       Yes    x     No

30.    Do you understand if you committed the present offense(s) while you were on
       probation, parole, supervised release, or escape status, this will increase the number
       of points assessed in your criminal history computation. If this increases your
       Criminal History Category, do you understand it may increase the range of sentence
       calculated under the advisory Sentencing Guidelines? Yes x               No _




                                    Page 7 of 13
oKWD Plea Petition (5/18)
            Case 5:22-cr-00009-JD Document 7 Filed 01/20/22 Page 8 of 13



31.     Do you understand if this offense is a crime ofviolence ora drug trafficking offense,
        and if you have two prior felony convictions ofeither a crime ofviolence or a drug
        trafficking offense, you could be sentenced as a career criminal offender which
        would increase the sentence you receive?
        Yes _        No _        Not Applicable x

32.     The maximum sentence for the offense(s) to which you want to plead guilty is the
        statutory maximum set out in fllJ I 9, 20 and 2 I above. If you are pleading guilty to
        more than one count, you could receive the maximum sentence on each count of
        conviction running consecutively (C/S). See USSG $ 5G1.2. Do you understand
        this? Yes     x    No

JJ.     In certain cases, the law requires the judge to impose a mandatory minimum term
        of imprisonment. The judge may not impose a sentence below a mandatory
        minimum term unless the United States Attomey, in his or her discretion, files a
        motion. Do you understand this? Yes x           No _     Not Applicable )gj

34.     Parole is not available in the federal system. If you are sentenced to a term of
        imprisonment, you will serve the entire time imposed (less any earned good time
        credits that may be applied to reduce the amount of time you actually serve). The
        maximum amount of credit you may receive against your sentence will be
        determined by the Bureau of Prisons and is limited by statute [8 U.S.C. $ 3624].
        Do you understand this? Yes     x       No   _
35. If at least one year of imprisonment is ordered in your case, the judge may also
        impose a term of supervised release, which you will begin serving after you are
        released from custody. For certain offenses, a term of supervised release is
        mandatory. During any term of supervised release, you will be subject to
        conditions that will include refraining from any additional violations oflocal, state
        or federal law, reporting requirements, travel and residence restrictions, and testing
        for controlled substance use. If you violate the conditions of your supervised
        release, the judge may revoke your supervised release and sentence you to an
        additional term of imprisonment. This additional term of imprisonment would be
        served without credit for the time you successfully spent on supervised release. Do
        you understand this? Yes    x        No

        The judge has the discretion to impose another term of supervised release, to be
        served after you serve your sentence for violating the first term of supervised
        release. If you violate your supervised release again, you can be sentenced to serve
        more time, followed by more supervised release, at the discretion of the judge.
        Under certain circumstances there is no limit to the number of times supervised



                                     Page 8 of 13
OKWD Plea Petition (5/18)
            Case 5:22-cr-00009-JD Document 7 Filed 01/20/22 Page 9 of 13



        release can be revoked and another term of supervised release imposed. Do you
        understand this? Yes     x   No

36.     In some circumstances, the judge may decide that your case warrants imposing a
        sentence with conditions other than incarceration for the full term of the sentence.
        Options available to the judge include probation, home confinement, community
        confinement, electronic monitoring, intermittent confinement, or a combination of
        any of these. Do you understand this? Yes x           No _

37.     If you plea d guilty to a federal sex offense, you may be subject to state laws
        requiring th e registration ofsex offenders. Do you understand this?
        Yes x         No _          Not Applicable x

E.      VOLUNTARYNATUREOFPLEA

38.     Are your plea(s) of GUILTY and the waivers of your rights made voluntarily and
        completely of your own free choice, free of any force or threats or pressures from
        anyone? Yes x         No _

39. (a)         Have you entered into a plea agreement with the govemment?
                Yes x       No

        (b) Ifso:
                Is this a conditional plea pursuant to Fed. R. Crim. P. I l(aX2) that reserves
                certain rights to appeal? Yes _         No x

        If yes, what issues are reserved for appeal?




        Have you read the plea agreement or had the plea agreement read to you?
        Yes x      No

        Have you had enough time to discuss the plea agreement with your attomey?
        Yes x         No

        Were all the terms of the plea agreement explained to you, including any
        waivers of your rights? Yes x      No


                                     Page 9 of 13
OKWD Plea Petition (5/18)
            Case 5:22-cr-00009-JD Document 7 Filed 01/20/22 Page 10 of 13




        Do you understand all of the terns of the plea agreement, including the
        waivers of your rights? Yes x      No _

         (c)       What are your reasons for making that agreement?
         I want to take responsibility for my actions and I feel that it is in my best interest to make the
         agreement.
                               Ji   Ford


        (d) If your plea of GUILTY involves a plea agreement, do you understand that
        the judge can reject the plea agreement after completion of the presentence
        investigation if the judge finds that the plea agreement is not in the interests of
        justice? Yes x                No _

40      Has any promise been made by anyone that causes you to plead GUILTY aside from
        the plea agreement, ifany, set out in your answer to question 39?
        Yes    _    No       x If yes, what promise has been made and by whom?



4t.     (a) Has any officer, attorney or agent ofany branch of govemment (federal, state
        or local) promised or predicted that you will receive a lighter sentence, or probation,
        or any other form of leniency if you plead GUILTY?
        Yes              No x
        (b)    Do you understand no one has any authority to make any such promise or
        prediction on your sentence because the matter of sentencing is exclusively within
        the control of the judge and no one else? Yes          No   x               _
42      Has the judge made any suggestion as to what the actual sentence will be?
        Yes             No x
43      Are you pleading GUILTY because you are guilty? Yes x                               No _
44      Is there any other information or advice that you want before you enter a plea?
        Yes             No x




                                           Page l0 of 13
OKWD Plea Petition (5/t 8)
           Case 5:22-cr-00009-JD Document 7 Filed 01/20/22 Page 11 of 13



F.      CONCLUSION/FACTUALBASIS

45.     Has your attorney reviewed and discussed with you all ofthese questions and your
        answers to them? Yes            x
                                       No

46. Do you understand all of these questions? Yes x                                 No

        If not, which questions do you not understand?



47   . (a)       Do you now want to plead GUILTY? Yes x                                 No

        (b) Are you GUILTY? Yes x                              No

48      State what you did to comnit the offense(s) to which you are now pleading
        GUILTY.
        Count l: From on ow aboul gl'1112020 through on or about 111512020, in the Western District of Oklahoma,
        l, Jill Ford, knowingly and with the intent to defraud , executed a scheme/artiface to obtain money that
        was under the custody and control of a FD|C-insured flnancial institution by means of
        materially false and fraudulent pretenses, promises, and representations. The false statements
        I made to the financial institution were material and capable of influencing the decision ofthe
        financial institution.

        Count ll: On or aboul10l23l2O20 in the Western District of Oklahoma, l, Jill Ford, knowingly engaged in a
        monetary transaction of $73,632.58 that I knew was derived from the crime of bank fraud




                                                                              Ji Ford




                                            Page    ll of 13
OKWD Plea Petition (5/18)
             Case 5:22-cr-00009-JD Document 7 Filed 01/20/22 Page 12 of 13



**************************************,i,i*********'t                      ***.***********.**!t!***)t*


       I understand that if I have knowingly and intentionally made any false answers in
this Petition to Enter Plea of Guilty, my answers may be used against me in another
prosecution for perjury or making a false statement.

       Signed by me and affirmed to be true under penalty of perjury in the presence of my
attorney en 1fils 6th       day ol              January       ,2022

                                                             t\oryr1
                                                             Defendant U

                            CERTIFICATE OF DEFENSE COUNSEL

           I, as attomey for the defendant Jill Nicole Ford                                          , hereby
certify:

           1. I have read and fully explained to the defendant the allegations contained in
the Indictment or Information in this case.
       2. To the best of my knowledge and belief the statements, representations, and
declarations made by the defendant in this Petition to Enter Plea of Guilty are in all respects
accurate and true.
           3.     The plea of guilty offered by the defendant to Count(s)
accords with my understanding of the facts the defendant has related to me, is consistent
with my advice to the defendant, and in my opinion is knowingly and voluntarily made.
           4. I asswe the Court that I have advised the defendant about the applicable
sentencing procedures, including procedures under the Sentencing Guidelines, and I have
explained to the defendant the potential consequences of a plea of guilty in light of the
questions and concerns set forth in Sections C and D of this Petition.

      Signed by me in the pre sence of the defendant and aft                      full discussion of the
contents of this certificate with the defendant, this                                            day of
     \h*.*r-.-             ,20
  o--=T                                                                                      >.

                                                             Attorne for Defendant




                                             Page 12 of 13
OKWD Plea Petition (5/18)
           Case 5:22-cr-00009-JD Document 7 Filed 01/20/22 Page 13 of 13



*,t *******************************************:********************{.***1.{.*


                    CERTIFICATE OF PRO                      IN    ATT

        As attorney for the govemment, I hereby certify:

       l. I have read and fully discussed with defense counsel the allegations
contained in the Indictment or Information in this case.
       2. I have also reviewed this Petition to Enter Plea of Guilty and find it to be in
accordance with my knowledge of the defendant and this case.
       3. In my judgment, acceptance of the defendant's plea(s) of guilty to the
charge(s) in question will not undermine the statutory purposes of sentencing.

        Signed by me this this     J     aay of     . l6NilJlv11                     20&L
                                                                  d

                                                                  fot the        t




                                       Page 13 of 13
OKWD Plea Petition (5/18)


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