Information — United States v. Jill Nicole Ford, Western District of Oklahoma (Document 1)

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An Information filed by the United States Attorney in United States v. Jill Nicole Ford, No. CR-22-9-JD, in the U.S. District Court for the Western District of Oklahoma, filed 01/07/22 as Document 1. Count 1 charges bank fraud under Title 18, United States Code, Section 1344(2) and Count 2 charges money laundering under Section 1957(a). It alleges that the defendant, owner of Oliver and Olivia Apparel, Inc., obtained a Main Street Lending Program loan through Citizens Bank of Edmond, with $405,686.84 in proceeds deposited on or about September 28, 2020, after agreeing the funds would be used for working capital and payroll only. It alleges transfers from the loan account to personal accounts to pay for construction of a personal home and a down payment on a Cadillac Escalade ESV, including a $73,632.58 check. Forfeiture allegations seek a money judgment of $252,143.35.

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“Information — United States v. Jill Nicole Ford, Western District of Oklahoma (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-no-5-22-cr-00009-dkt-1-d37c5fb7fd/, SHA-256 ebce44f53db4e7a345b5257c7ab621dae5ba49b29f1159c318acc5c29e563251.

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Case 5:22-cr-00009-JD Document 1 Filed 01/07/22 Page 1 of 6

IN THE TINITED STATES DISTRICT COURT FOR THE

WESTERN DISTRICT OF OKLAHOMA

UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
-vs- ) No. CR-22-9-JD
)
JILL NICOLE FORD, ) Violations: l8 U.S.C. S 1344(2)
) 18 U.S.C. $ l9s7(a)
) l8 U.S.C. $ 982(a)(l)
) 18 U.S.c. $ 982(a)(2)
Defendant. ) 28 U.S.C. $ 2461

INFORMATION
The United States Attomey charges:

Introduction

At all times relevant to this Information:

1. JILL NICOLE FORD ("FORD"), the defendant, was a resident of the

Westem District of Oklahoma.

2. Oliver and Olivia Apparel, Inc., ("O & O") was an Intemet clothing retailer

located in the Westem District of Oklahoma that was owned by FORD.

3. Citizens Bank of Edmond ("Citizens Bank") was a financial institution in

the western District of oklahoma, the deposits of which were insured by the Federal

Deposit Insurance Corporation ('FDIC").

4. MidFirst Bank was a financial institution in the Westem District of

Oklahoma, the deposits of which were insured by the FDIC.
Case 5:22-cr-00009-JD Document 1 Filed 01/07/22 Page 2 of 6

5. On or about March21,2020. Congress passed the Coronavirus Aid, Relief,

and Economic Security Act (CARES Act), that provided more than $2 trillion in relief lbr

individuals and businesses adversely affected by the coronavirus pandemic. Pursuant to

the CARES Act, the Secretary of the Treasury and the Federal Reserve Board created the

Main Street Lending Program (MSLP) to promote lending to small- and medium-sized

businesses affected by the coronavirus pandemic. As part olthe MSLP, the Secretary ol

the Treasury and the Federal Reserve Board created a government-owned facility to

purchase 95 percent participations in loans made by private lenders that conformed to the

MSLP's terms while the lenders retained five percent of each loan they originated.

6. In or about August 2020, FORD, on behalf of O & O, submitted an

application to Citizens Bank for a5424,168loan pursuant to the MSLP

7. On or about September 11,2020, FORD. on behalfolO & O. executed a

loan agreement with Citizens Bank in which she agreed that: (a) O & O would use the

proceeds of the MSLP loan for working capital and payroll only; and (b) no distributions

would be made to any owner of O & O from the loan proceeds. Citizens Bank executed a

participation agreement with MSLP on or about September 11,2020.

8. On or about September 28, 2020, O & O received loan proceeds in the

amount of $405,686.84 in its bank account (Account No. XXX3394) at Citizens Bank

(the "MSLP Account"). The balance of the MSLP Account prior to the deposit was

$ 100.09.

2
Case 5:22-cr-00009-JD Document 1 Filed 01/07/22 Page 3 of 6

COUNT I
(Bank Fraud)

9. The United States Attomey incorporates paragraphs l-8 by ref-erence.

The Scheme to Defraud

10. It was part ofthe scheme that on or about September I l, 2020, FORI)
signed a loan agreement with Citizens Bank falsely representing that she would use

MSLP funds for working capital and payroll only, and that she would not make

distributions to herself as the owner of O & O.

1 1. It was part ofthe scheme that on or about September 29, 2020, FORI)
deposited a $5,000 cashiers checks drawn on the MSLP Account into an O & O account

at MidFirst Bank.

12. It was part ofthe scheme that on or about September 29, 2020, FORI)
withdrew $5,000 in cash from the MSLP Account and deposited it into an O & O account

at MidFirst Bank.

13. It was part ofthe scheme that on or about September 30, 2020, FORI)
wired $35,000.00 from the MSLP Account to an O & O account at MidFirst Bank.

Thereafter, also on or about September 30,2020, FORD made two transfers in a total

amount of $40,500.00 from the O & O account at MidFirst Bank, to her personal

MidFirst Bank account. FORD used these funds to make a payment for the construction

of her personal home.

J
Case 5:22-cr-00009-JD Document 1 Filed 01/07/22 Page 4 of 6

14. It was also part ofthe scheme that on or about October 23. 2020, FORD
wired $73,000.00 from the MSLP Account to an O & O account at MidFirst Bank. The

same day, FORD transferred $74,000.00 from O & O's MidFirst Bank account to her

personal MidFirst Bank account. FORD used those funds to pay for the construction ol'

her personal home

15. It was also part of the scheme that on or about November 5, 2020, FORD
transf'erred $10,000.00 from the MSLP Account to her personal account at Citizens Bank.

The same day, FORD wrote a $10,000.00 check from her personal account at Citizens

Bank as a down payment on a Cadillac Escalade ESV tbr her personal use.

Execution of the Scheme

16. From on or about September 1I,2020. through on or about November 5.
2020. in the Westem District of Oklahoma.

JILL NICOLE FORD-

with the intent to defraud, willfully and knowingly executed and attempted to execute a

scheme and artifice to defraud Citizens Bank and to obtain monies and funds owned by,

and under the custody and control of, Citizens Bank by means of materially false and

fraudulent pretenses, representations, and promises by making false representations in a

loan agreement and converting proceeds of an MSLP loan she obtained on behalfofO &

O to her personal use.

All in violation of Title 18, United States Code, Section 1344(2).

4
Case 5:22-cr-00009-JD Document 1 Filed 01/07/22 Page 5 of 6

COUNT 2
(Money Laundering)

17. The United States Attomey incorporates paragraphs l-16 by reference.
18. On or about October 23,2020, in the Westem District of Oklahoma,
JILL NICOLE FORD

knowingly engaged in a monetary transaction by, through, and to a financial institution,

affecting interstate commerce, in criminally derived property ofa value greater than

$ 10.000.00. ln particular. FORD ivrote a check drarm on her personal bank account at

MidFirst Bank in the amount of $73,632.58 to pay fbr the construction of her personal

home, after those lunds had been derived from bank fraud, a specified unlawlul activity

pursuant to Title 18, United States Code, Sections 1956(c)(7)(A) and 1961(1).

All in violation of Title 18. United States Code. Section 1957(a).

FORFEITURE ALLEGATIONS

The allegations contained in this Information are hereby realleged and incorporated

for the purpose of alleging forfeiture.

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

NICOLE FORD shall forfeit to the United States any property constituting, or derived

from, proceeds obtained directly or indirectly, as a result ofsuch offense.

Likewise, upon conviction ofthe offense alleged in Count 2 of this Information,

JILL NICOLE FORD shall forfeit to the United States any properfy, real or personal,

involved in such offense, or any property traceable to such property.

5
Case 5:22-cr-00009-JD Document 1 Filed 01/07/22 Page 6 of 6

The property to be forfeited includes. but is not limited to, a money judgment in

the amount of $252,143.35, which represents the proceeds obtained as a result of the

offenses.

Pursuant to Title 21, United States Code, Section 853(p), as adopted by Title 28,

United Stated Code, Section 2461(c), JILL NICOLE FORD shall fbrfeit substitute

property. up to the value ofthe property described above if. by any act or omission of

defendant, the property described above, or any portion thereof, cannot be located upon

the exercise ofdue diligence; has been transferred or sold to, or deposited with, a third

person; has been placed beyond the jurisdiction ofthe Courl: has been substantially

diminished in value; or has been commingled with other propefty that cannot be

subdivided without ditfi culty

All pursuant to Title 18, United States Code, Sections 982(a)(1) and (a)(2), and
'fitle 28, Llnited States Code. Section 2461.

ROBEI{T J.-I ROESTER
United Statcs Attorney

?"ySry*r
rdsSrca L. PERRY t)
Assistant United States Attomev

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