Plea Agreement — United States v. Ford (W.D. Okla., Document 8)

Summary

Plea Agreement filed January 20, 2022 as Document 8 in United States v. Jill Nicole Ford, Case 5:22-cr-00009-JD, in the U.S. District Court for the Western District of Oklahoma. It states that it contains the entire agreement between Defendant Jill Nicole Ford and the United States concerning Defendant's plea. Defendant agrees to plead guilty to a two-count Information charging bank fraud (Title 18, United States Code, Section 1344(2)) and money laundering (Section 1957(a)). The agreement sets out maximum penalties, restitution of $241,543.35 to Citizens Bank of Edmond and $10,600 to the U.S. Small Business Administration, forfeiture, financial disclosures, Sentencing Guidelines stipulations and a waiver of the right to appeal.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Plea Agreement — United States v. Ford (W.D. Okla., Document 8).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-w-d-okla-no-5-22-cr-00009-dkt-8-06c71928cf/, SHA-256 5910846bcaf29eaa266f79b9c28ec1d76ce734679acabc6a1502dea291055cf6.

Full text

Case 5:22-cr-00009-JD Document 8 Filed 01/20/22 Page 1 of 15

IN THE T]NITED S1'AI'I'S DISTRI('I'COURT I.'OR'I'HE

WESTERN DISTRICT OF OKLAHOMA

UNITED STATES oF AMERICA, )
)
Plaintiff, )
)
-\'s- ) AD
)
JILL NICOLE FORD. )
)
Defe ntla n t. )

PLEA AGREEMI'NI'

lntroduction

l. This Plea Agreement. t conjunction with a Plea Supplemenr filed

contemporaneously undcr scal. contains the entirc agrcement bctween Defendant Jill

Nicole Iiord and the lJnited States conceming Defendant's plea ol-guilq,.in this casc. No

other agreement or promise exists, nor ma1, any additional agreement be entered into unless

in u,riting and signed by all parties. Any unilateral modilication ol'rhis Plea Agreemenr is

hereby rejected bl the llnited States.
'l'his Plea Agreement
applies onl1., to the crirninal

violations described and does not appl)' to any civil matler or any civil lbrl'citure

proceeding cxcept as specificalll' sot lbrth. This Plca Agreement binds onlv the l.lnited

States nttomey's Ofllcc for the Western District oi'Oklahoma and does not bind anv other

federal. state, or local prosecuting, adnr inistrative. or regulatory authoriry. If Del'cndant

does not accept the tcrms of this Plca Agreement by December 29,2021,lhe oll'er is

u,ithilrarvn.
Case 5:22-cr-00009-JD Document 8 Filed 01/20/22 Page 2 of 15

Guilty Plea

2. Defendant agrees to enter a plea of guilty to a two-count lnformation

charging: ( I ) bank fraud, a violation of Title 18. United States Code, Section 1344(2); and

(2) money laundering. a violation ofTitle 18, United States Code, Section 1957(a).

To be found guilty of violating Count I (bank fraud), as charged in the Information,

Defendant must admit. and does admit. that liom on or about September 11.2020. through

on or aboul November 5,2020, in the Westem District of Oklahoma, Defendant: (l)

knolingly executed a scheme or artifice to obtain money under the custody and control of

a financial institution by means of materially false and fiaudulent pretenses.
representations. or promises: (2) the financial institution u,as insured by the Federal

Deposit Insurance Corporation; (3) Defendant acted rvith the intent to defraud: and (4) the

false or liaudulent pretenses. representations. or promises made by Defendant were

material, meaning that the), rvould naturally tend to influence. or \\,ere capable of

influencing the decision ofthe financial institution.

To be lbund guilty of violaring count 2 (monev laundering). as charged in the

Information. Defendant must admit. and does admit, that on or about october 23,2020, in

the western District of oklahorna. Defendant: ( I ) engaged (or attempred to engage
) in a
monetary transaction: (2) the monetary transaction involved crirninalll,, derived properlvl

(3) Defendant knerv that the property was derived from bank fraud; (4) the property
was,

in fact, derivcd from bank fraud: (5) the monetary transaction u,as ofa yalue grealcr than

$10,000; and (6) the monetary transaction took place within the United Srates.

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Case 5:22-cr-00009-JD Document 8 Filed 01/20/22 Page 3 of 15

Maximum Pcnaltt,, Restitution, and Special Assessment

3. The maximum penalty that could be imposed as a result of this plea as to

Count I (bank fraud) is no more than thirty years of imprisonment or a fine ol'

$ 1,000.000.00. or both such fine and imprisonment. as well as a mandatory special

assessment of $100.00 and a term of supervised release ofno more than five years.

The maximum penalq, that could be imposed as a result of this plea as to Count 2

(money laundering) is no more than ten years of irnprisonment or a fine of $250,000.00, or

both such fine and imprisonment. as well as a mandatory special assessment of $100.00

and a term ofsupervised release ofno more than three years.

Defendant is pleading guilty to rnultiple counts ol' convicrion. and Defendant

understands that the Court may impose the sentence as to each count to run consecutively

to one another. so that the total imprisonment that Defendant may face is greater than the

maximum punishment for any one offense.

4. In addition to the punishment described above. a plea of guilty can affect

immigration status. If Defendant is not a citizen of the United States. a guilt_v plea may

result in deportation and removal from the l-lnited States. mav prevent Defendant from ever

lawfully reentering or remaining in the united States. and may result in the deniat of

naturalization. Il Defendant is a naturalized citizen of the llnited states. a guilt1,.plca may

result in denaturalization.

5. In addition. the court nrust order thc payrnent ofrestitution to any
'ictim(s)
of the ofrensc. Pursuanr to l8 U.S.C. g$ 3663(a)(3) and 36634. thc parties further agrce

J
Case 5:22-cr-00009-JD Document 8 Filed 01/20/22 Page 4 of 15

that, as parl of the sentence resulting from Defendant's plea, the Court rrvill enter an order

of restitution as follows:

a. $241,543.35 to Citizens Bank of Edmond, Attention: Whitney Randall, I
East lst Street, Edmond, Oklahoma 73034: and

b. $10,600 to the U.S. Small Business Administration, Denver Finance Office.
721 l9'h Street, 3'd Floor Room 301 , Denver, Colorado 80202. All paynrents

should reference loan number is 74808670-05.

6. Defendant agrees to pay the special assessment due the United States to the

Office of the United States Court Clerk immediately following sentencing. Defendant

understands that any fine or restitution ordered by the Court is immediatelS' due unless the

Court provides for payment on a date certain or in installments. If the Cou( imposes a

schedule for pal,ment of restitution. Defendant agrees that such a schedule represents a

minimum payment obligation and does not preclude the United States Attorney's Office

from pursuing other means by rvhich to satis$r Defeldant's full and immediately

enforceable financial obligations. Defendant accepts a continuing obligation to pay in full.

as soon as possible, any financial obligation imposed by the court. Defendant further

understands that a failurc to abide b)'the terms ofany restitution schedule imposed by the

Court may result in lurther action by thc Court.

7. For certain statutory of'lbnses, the Court must also impose a term of

supen,ised release. rvhich Defendant rvill begin to sen/e after being released from custody.

For all olhcr offenses, the Court ma1, impose a tenn of supervised release to be sen,ed

following release fi'om custody. During the term oi'supervised release, Defendant will be

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Case 5:22-cr-00009-JD Document 8 Filed 01/20/22 Page 5 of 15

subject to conditions that will include prohibitions against violating local, state, or I'ederal

larv. reporting requirements. restrictions on travel and residence. and possible testing for

controlled substance use. If Defendant violates the conditions of supcrvised release, the

Court may revoke De1'endant's supervised release and sentence Def'endant to an additional

term ol imprisonment. This additional term of imprisonment rvould be sened without

credit for the time Defendant successfully spent on supervised release. When combined,

the original term of imprisonment and anl. subsequent term of imprisonment the Court

imposes may exceed the statutory maximum prison tenn allowable for the offense.

Financial Disclosures

8. Defendant agrees to disclose all assets in u,hich Defendant has an). interest

or over which Defendant exercises control, directly or indirectly, including those held by a

spouse. nominee, or an), other third party. Upon requcst b1' the tJnited States. Dcl'endant

agrees ( I ) to complete truthfully and sign under penalty of perjurl, a F inancial Statement

ofDebtor by the change-of-plea hearing, or a date othcrwise agreed to by the United States,

and (2) to provide updates with any material changes in circumstanccs. as described in 18

U.S.C. $ 3664(k), within seven days ol'the evenr giving rise to the changes. Defendant

understands that the lJnited slates u,ill take Defendanl's compliancc u,ith these rcquests

into account u,hen it nlakes a reconrmendation lo the courl rcearding Dcfendant's

acceptancc of responsibility.

9. Defendant also expressll, authorizes thc Ljnited Stalcs n ttomey.s Olllce to

obtain a credit repofl on Defendant. in order to evaluare Defendanl's abiliry to satisly any

financial obligations irnposed by the court. Finally. Defendant agrees to notify the
Case 5:22-cr-00009-JD Document 8 Filed 01/20/22 Page 6 of 15

Irinancial I-itigation Program ("FLt'''; of the lJnited Statcs Attorney's Olllcc and to obtain

permission lrom FLP before Delendant transfers any interest in property rvith a value

cxceeding $1,000, orvned directly, indirectly, individually, or jointly by Defendant.

including any interest held or orvned under any name. including trusls. partnerships. or

corporalions. Del'endant acknorvledges a continuing obligation to notily and obtain

permission liom FLP for any lransl'ers ol' the above-described propert) until full

satisl'action ol any restitution. fine, special assessrnent. or other financial obligations

imposcd by the ('outt.

Forfeiturc

10. Dclbndant agrccs to lbrfeit to thr: United States volunlarill, and imrrediately
all ofl)cfcndant's right. titlc. and interest in and to all asscls u,hich are subjcct to lbri'eiture

pursuarrt to'l'itle 18, United States Code. Sections 9{12(a)( l) and (a)(2) and'l'itle 28, United

States Code. Section 2461, including but not limited to a mont;y judgment in the amount

ol$252.143.35. which represcnts the amount o{'proceeds obtaincd by Defcndant as a result

of thc offenses.

a. Defendant understands and agrees that the tbrfeiture will takc the form ofa
moncy judgment against her for that amounl.

b. Defcndant knou'ingly and voluntarilv agrecs to the amount olthe forfeiture
money judgment imposed against her by thc Courl.

c. Defbndant agrees to the forfeiture ol'substilute assets as authorized hercin
and pursuant to 2l U.S.c. $ 853. Defendanr agrees that thc elenrents lor

forlciting subsritute assets as set forth in 2l LJ.S.C.
$ g53(p) ha'e been

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Case 5:22-cr-00009-JD Document 8 Filed 01/20/22 Page 7 of 15

satisfied. Defendant agrees that the forfeiture olsubstitute assets pursuant to

2l tl.S.C. S 853(p) shall not be deemed an alteration of Defendant's
sentence. l-he value ofeach forfeited substitute asset, less costs and expenses

in forfeiting and disposing of the asset, shall be oflset against the balance of

Defendanl's forfeiture monel' judgment.

I l. Defendant knowingly and voluntarill, rvaives Defendant's right to ajurl' trial

on the lorfeiture ofassets. Defendant knorvingll,and r,oluntarilv waives all constitutional.

legal, and equitable defenses to the forfeiture ofthese assets in any proceeding. and further

u,aives any claim or defense under the Eighth Amendment to the United States

Constitution, including any claim ofcxcessive fine. to the forfeiture or disposition ofassets

b1'the [)nited States, the State of Oklahoma. or its subdivisions. Defendant knorvingly and

volunlarily consents to the entry of a final order of lorfciture before sentencing as to

Defendant's interest in the assets. Forfeiture ofDefendanl's assets shall not be treated as

satisfaction of any fine. restitution. cost of imprisonment, or any other penalty the Court

may impose upon Defendant in addition to forfeiture.

12. Defendant knorvingly and voluntarily rvaivcs an1, right to appeal or
collaterally attack an), rratter in connection with the forfciturc provided for herein.

Defendant rvaives l)efendant's right to notice ofany forfeiture proceeding and agrees not

to file a claim to any of the above-listed property or propertv involved in thc underlying

criminal conduct. or other$'ise to contest forfeiture in an1'civil. adrninistrativc. orjudicial

proceeding that may be initiated. Delbndant further agrees not to assisl others in
filing a
claim in a forlbiture proceeding or otherwise assist others who challcnge a forfeiture
aclion

7
Case 5:22-cr-00009-JD Document 8 Filed 01/20/22 Page 8 of 15

involving the abovc-listed property or property involved in the underll,ing crirrinal

conduct. [)efcndant also voluntarilv and immediatell' u'aives all right. title. and intcrcsr irr

and 1o the above-listed propcrt)' in order that appropriate disposition mav be rnade bv lhe

appropriate ledcral or slate lau' enlbrcement agency

Sentencins Guidelines

13. The parties acknou,ledge that l8 U.S.C. $ 3553(a) directs thc Court ro
consider ccrtain lirctors in irnposing scntence. including the Guidelincs prornulgaled b1, lhe

United Stalcs Scnlcrrcing Cornrtrission. Consequentll'. although thc parlies recognizc lhal

the Guidelines arc only'advisory,. thcy have entered into certain stipulations and agrccmcnts

u,ith respecl to the Guidelincs. IJased upon the information knorvn 1o the partics on thc

date that this l)lca Agrccmcnt is cxecuted. they expect to take, but are not limiled to, the

follorving positions at scntencing:

a. Thc parties agree the loss for purposes of U.S.S.G. g 281.l(bxl) is more
than $250.000 but less than $550,000, resulting in an increase of l2 levels;

b. 1'he parties agree the 2-level enhancement in U.S.S.G. g2Bl.l(bX12)
(related to offense conduct described in 18 U.S.C. 0 I040) does not apply:

c. 'l'he parties agrec that the 2-level enhancement under ll.S.S.G.
A 28 l.l(b)(gXB) (related ro a misrepresentation or other fraudulenl acrion in

a bankruplc), proceeding) applies.

d. 'l'he parries agree Delendant should receive a nvo-level downward
adjustrnent lor l)efbndant's acceptance of responsibilit)-, pursuanl to

tl.S.S.G. g 3l) L I (a), if Defendant commits no further crimes. doe s nor

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Case 5:22-cr-00009-JD Document 8 Filed 01/20/22 Page 9 of 15

falsely deny or lrivolously contest relevant conduct, and full1'complies with

all other terms of this Plea Agreement. Further. to the extent the Court finds

I)el'endant qualifies for that trvo-level dorvnrvard adjustment and U.S.S.G.

$ 3E I . I (b) is applicable, the United States agrees to move for the additional

one-level dorvnrvard ad.justment of $ 3E 1 .l (b) if Defendant accepts the terms

of'this Plea Agreemenl by the deadline established in Paragraph l.

Apart lrom anv expressed agreements and stipulations. the parties reserve the right

to advocate for, and present evidence relevant to, other Guidelines adjustments and

sentencing factors lbr consideration by the United States Probation Office and the Court.

14. The partics have entered into this Plea Agreement under the provisions of
Rule I l(c)(l)(A) & (B). Defendant acknowledges and understands that the Cou( is not

bound by, nor obligated to accept. these stipulations, agreements, or recommendations of

the United States or Defendant. And. even if the Court rejects one or more of these

stipulations. agrecments. or recommendations. that fact alone lvould not allow Defendant

to withdrarv Delendant's plea olguilty. Upon Defendant's signing of this PIea Agreement.

the United States intends to end its investigation ofthe allegations in the Infonnation. as to

Defendant. excepl insofar as required lo prepare for further hearings in this case. including

but not Iimited to sentencing. and to prosecute others. if any. involved in Defendant's

conduct. l'he [Jnited States agrees to end any investigation directed specilically at the

foregoing stipulations, agreements, or recommendations as to Defendant. I lorvever.

subject to the lenns and conditions ofthis Plea Agreement and plea Supplernent, thc Ilnited

States expressly reserves the right to take positions that deviate from thc loregoing

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Case 5:22-cr-00009-JD Document 8 Filed 01/20/22 Page 10 of 15

stipulations. agreemcnts. or rocomulcndations in tlro cvenl that malcrial crcdible evidence

requiring such a dcviation is discovcred during thc course ol its invcstigation alter the

signing of this PIea Agreemcrlt or arises from sourccs indepcndent of'the ljnited States.

including thc [Jnited States Probation Olfice

Waivcr of Righl to Appeal and Bring Collalcral Challenec

I 5. Defendant understands that the Court will consider the factors set forth in I 8
U.S.C. $ 3553(a) in determining Defendant's sentence. Defendant also understands that

the Court has jurisdiction and authority to impose any sentence within the statutory

maximum for the offense(s) to which Defendant is pleading guilty. Defendant further

understands that 28 U.S.C. $ I 291 and I 8 tl.S.C. g 3742 give Defendant the right to appeal

the judgment and sentence imposed b1, the Court. Acknorvledging all of'this. and in

exchange for the prornises and concessions made by the United States in this Plea

Agreement, Defendant knowingly and voluntarily waives the following rights:

a. Defendant waives the right to appeal Defendant's guiltl,plea. and any

other aspect of Defendant's conviction. including but not limited to any rulings on pretrial

suppression motions or any other pretrial dispositions of motions and issues:

b. [ixcept as stated immediately below. Defendant waives the right to

appeal Defendant's sentence as imposed by the court. including any reslitution. and the

manner in which the sentence is determined. If the sentence is above thc advisory

Guidelines range determined by the court to apply to Defendant's case, this waiver does

not include Defendanl's right to appeal specifically the substantive reasonableness of

Defendant's sentence;

l0
Case 5:22-cr-00009-JD Document 8 Filed 01/20/22 Page 11 of 15

Defendant waives the right to collatcrally challenge or nrovc to

modill,(undcr28 U.S.C. $ 2255. l8 U.S.C. $ 3582(cl(2). oran,v- otherground) f)efcndant's

conr.iction or sentence, including an1, reslitution. excepl u,ith re'spect to claims of

ineffective assistance of counsel.

Dcl'endant acknou,ledges that thcse u aivcrs remain in lull eflbct and are

enforceable, even if thc Court rejects one or morc olthe positions ol-thc United Statcs or

l)efendant set lbrth in paragraph 13.

16. Exccpt as stated imnrediatel;- belou,, the [Jnited Statcs agrees Io q,aivc its
right undor l8 U.S.C. s\ 37.12 to appeal the scntcncc inrposed bv the ('ourt and thc manner

in which lhe scntcncc u,as determined. II'lhe senlcncc is belou thc advison, Guidelines

range detcnnined hl the ('oul'l to applv to this casc. this rvaiver does not includc thc risht

oI'the United States to appcal specilicalll,the substantive reasonablcness of the sentence.

Waiver of Claim to Prevailins Partv Status

1'1 . Defendant expressly acknowledges that Defendant is not a "prevailing party"

within the meaning of l8 U.S.C. $ 30064 with respect to the count of conviction or any

other count or charge that may be dismissed pursuant to this Plea Agreement. If Defendant

is represented by retained counsel. Dcf'endanr voluntarily. knou,ingly. and intelligentll,

waives any rights Defendant may have lo seek reasonable attomey's fees and other

litigation cxpenses under l8 U.S.C. $ 3006A.

Waiver of FOIA and Priva c1' Act Riehls

18. Defendant wait'es all righls. whether asserted directly or by a represcntative.
to request ofor receive from an1, department or agenc), of the tjnited States any records

il
Case 5:22-cr-00009-JD Document 8 Filed 01/20/22 Page 12 of 15

perlaining to the investigation or pnrseculion of lhis casc. including hut not linrilccl to

records that Delbndant may seck under the l"reedom of Inlbrmation Ac1. 5 U.S.C. $ 552.

or the Privac-,- Acl of 1974. 5 l.t.S.C. $ 522a

Oblisations of Defendant

19. Defendant shall commit no further crimes. Should Defendant commit an),
further crimes. kno*'ingly givc false. incomplete. or rnisleading testimony or information.

or othenvise violate any provision ol- this Plea Agreemcnt, the United States rvill be

released from any obligations. agreements. or restrictions imposed on it under this Plea

Agreement, and the United States may prosecute Delbndant for any and all of Defendant's

federal criminal violations, including perjury and obstruction of justice. Any prosecution

within the scope of this investigation that is not time-barred by the applicable statute of

Iimitations on the date of the signing of this Plea Agreement ma), be brought aeainsr

Defendant, nonvithstanding the expiration ofthe statute of limitations betrveen thc signing

of this Plea Agreement and the commencement of that prosecution. Defendant hereby

waives all defenses based on the slatute of lirnitations with respect to any prosecution that

is not time-barred on the date that this Plea Agreement is signed.

20. Thc partics also recosnize that if the Court detennines Del'endant has
violated anv provision ol'this l)lea Agreement or authorizes Defcndant to u,ithdrarv from

Defendant's knowing and voluntary guilty plea entered pursuant to this plea Agreement:

(a) all written or oral statements made by Defendanl to the Court or to I'ederal or other

designated lavv enforcement agenls, any testimony given by Defendant belbre a grand.jury

or other tribunal, whether before or aller tre signing olthis plea Agreement, and any leads

t2
Case 5:22-cr-00009-JD Document 8 Filed 01/20/22 Page 13 of 15

fronr those statcnrenls tlr testirtronr'. shall be admissiblc in evidencc irr anr criminal

proceeding brought against Dcl'endant: and (b) Defendant shall assert no clairn under the

llnited States Conslitution. an-v statute. liederal Rulc of C'rirninal Procedure I l(l). Fcdcral

Rule ofEvidencc 410. or any other lederal rule or la*'that thosc statemcnts or anv leads

fiom thosc statements should he supprcssed. Defendant knouingly and voluntarill,u'aives

Del-endant's rights described in this paragraph as ol'the time I)cf'endant siens this Plea

Agreement

Oblieations of the United Stalcs

21. If Defendant enters a plea of guilty as described above and fully meets all
obligations under this Plea Agreement, the llnited States Attomey's Office lor the Westem

District of Oklahoma rvill not further prosecute Del'endant lbr any crimes relatcd to: (l)

Defendant's participalion in a schernc to defraud Citizens Bank of Edmond. Mid|irst Bank.

the U.S. SmallBusiness Administration. and the Federal Reserve Board in connection rvith

loans issued pursuant to the Paycheck Protection Program. the Economic lnjury Disaster

Loan program, and the Main Street l,ending Prograrn during the period from January l,

2020, through the datc of this I'lea Agreement: (2) Del'endant's false and lraudulent

statements to MidFirst Bank in conncction with a rnortgage loan application for the

properb' located ar 16813 I-ittle Leaf l.ane. Edrnond. oklahoma as of thc date ol.this plea

Agreement: and (3) misreprescntalions and fhlse statements made in the hankruptcy

proccedings In re oliver and olivia ('hildren's Apparel, /nc.. (w.D. okla.
Case No. 2l-

10572) and ln re Tre l-ord ond Jill For d (W.D. Okla. Casc No. 2 l _ 10574
) as ol.the dare

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Case 5:22-cr-00009-JD Document 8 Filed 01/20/22 Page 14 of 15

ol'this PIea ngreement. 'l'his Plea Agreement does no1 provide any protection againsl

prosecution lbr any crime not spccillcally described above

22. [)efendant understands that the sentence to be inrposed upon l)efendant is

rvithin the sole discretion of the (loun. The tlnited States does not make anv promise or

representation as to what sentence l)efendant s,ill receive. The tJnited States reserves the

right to inlonn the United States l)robation Olllce and the Court ol'the nature and extenl

of Def'endant's activities s'ith rcspect to this case and all other activities of Del'endanl that

the United States deems relevant to sentencing.

Sisnat u res

23. By signing this Plea Agreement. Defendant acknou,lcdges that Defendant
has discusscd the terms of the Plca Agreement rvith Del'endant's afiorne1, and understands

and accepls those tenns. Further. I)et'endant acknou'lcdges that this Plea Asreernent. in

coniunction u.'ith the I'lea Supplemcnt filed contemporaneously under seal, contains the

only terms ol'the agrecrncnt conccrning Dcl'cndant's plca of guilty in this casc. and thal

there are no other deals. bargains, agreements, or understandings which modi{y or alter

these tenrts.

l.{
Case 5:22-cr-00009-JD Document 8 Filed 01/20/22 Page 15 of 15

I)ated this ] aay ot' .202L-

ROBhR f J. 'I'ROIISTIIR
API'ROVIiD: Unilcd States Attomev

-42
snfwDbN uar.p JII L. PLRRY
Depury Chiefl Criminal Division As I Unite Slates Au
Wcstcrn District ol' Oklahoma
2 I 0 I'ark Avenue. Ste. 400
Oklahoma Ciq'. Oklahoma 73102
(40s) s53-8743 (Officc)
(40s) ss3-8888 (FAX)

.llLt. NICOLL FORI) J. PA CK QIJII,LIAN
I)efendant Atlorne)' for Delendant

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