Mikel Jones Bar

7/31/2019 Mikel Jones Bar

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IN THE SUPREME COURT OF FLORIDA

THE FLORIDA BAR,Complainant, The Florida Bar FileNo. 2012-50,854(15G)

v.MIKEL DAVID JONES

Respondent.

NOTICE OF DETERMINATION OR JUDGMENT OF GUILTCOMES NOW, The Florida Bar, an d files this Notice of Determination or

Judgment of Guilt, pursuant to Rule 3-7.2(f), Rules of Discipline of The Florida Barand says:

1. Respondent is a member of The Florida Bar, admitted on November 12,1999.

2. On or about November 7,2011 in the case styled United State of Americav. Mikel Jones an d Don a Nichols Jones, Case No. 11 -261, in the United S tates DistrictCourt for the Eastern District of Pennsylvania, the jury found respondent gu ilty of1 count of Conspiracy in violation of 18 United S tates Code, Section 371,14 counts ofW ire Fraud in violation of 18 United States Code, Sections 1 343 and 2; 14 Counts ofMail Fraud in violation of 18 United States Code, Sections 1341 and 2; and 1 count ofMoney Laundering in violation of 18 United S tates Code, Sections 1956(a)(l)(B)(i)


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and 2 .A certified copy of the Jury Verdict Form is attached hereto as Exhibit A and acopy of the Second Superseding Indictment is attached hereto as Exhibit B.

3. The jury verdict constitutes a "determination of guilt" under R. RegulatingFla. Bar 3-7.2(a)(2), and pursuant to R. Regulating Fla. Bar 3 -7.2(b), it is conclusiveproof of guilt.

4. Conspiracy, Mail Fraud, Wire Fraud and Money Laundering are feloniesunder federal law.

WHEREFORE, The Florida Bar respectfully requests that this Court enter anorder:

1. Finding Respondent guilty of violating Rule 3-4.3 [The commission by alawyer of any act that is unlawful or contrary to honesty and justice, whether the ac t iscommitted in the course of the attorney's relations as an attorney or otherwise, whethercommitted within or outside the state of Florida, and whether or not the act is a felonyor misdemeanor, may constitutea cause for discipline.]; Rule 4-8.4(b) [A lawyer shallno t commit a criminal act that reflects adversely on the lawyer's honesty,trustworthiness or fitness as a lawyer in other respects.]; and Rule 4-8.4(c) [A lawyershall not engage in conduct involvin g dishonesty, fraud, deceit, or misrepresentation...] of the Rules Regulating The Florida Bar;

2. Suspending Respondent pursuant to Rule 3-7.2(f), Rules of Discipline ofThe Florida Bar;


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3. Ordering Respondent to furnish a copy of the suspension order to allclients, opposing counsel and courts befo re which he is counsel of record as requiredby Rule 3-5. l(g) of the Rules of Discipline of The Florida Bar and to furnish staffcounsel with the requisite affidavit listing all clients, counsel and courts so inform edwithin 30 days after receipt of the court's order; and

4. Appointing or directing the appointment of a referee to conduct a hearingon sanctions pursu ant to R ule 3-7.2(h), Rules of D iscipline of The Florida B ar.

Respectfully submitted

llONNA FRIEDMAN^6lJNG, #563129Bar Counsel, The Florida Bar1300 Concord Terrace, Suite 130Sunrise, Florida 33323(954) 835-0233CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing Noticeof Determination or Judgment of Guilt regarding The Florida Bar File No. 2012-50,854(15G ) has been furnished by U.S. certified mail no. 7009 1680 0001 10901140,return receipt requested, to Mikel David Jones, Respondent, at PMB 109,4781 NorthCongress Avenue, Boynton Beach, Florida 33426-7941, on this 1 3 f K day of~ \ .2012

RONNA F E M A N YOUNG, B a r CounselCopy provided to:K enneth Lawrence Marvin, Staff Counsel


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IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA,v.

MIKEL JONES ANDDONA NICHOLS JONES

CRIMINAL ACTION

No. 11-261

JURY VERDICT FORMOn Count 1 of the Second Superseding Indictment, charging Mikel Jones withmail fraud on or about May 9,2006, we, the jury, unanimously find theDefendant, Mikel Jones:

NOT GUILTY GUILTYOn Count 3 of the Second Superseding Indictment, charging Mikel Jones withwire fraud on or about March 26, 2006, we, the jury, unanimously find theDefendant, Mikel Jones:X NOT GUILTY GUILTY

On Count 4 of the Second Superseding Indictment, charging Mikel Jones withwire fraud on or about May 25, 2006, we, the jury, unanimously find theDefendant, Mikel Jones:

NOT GUILTY GUILTYOn Count 5 of the Second Superseding Indictment, charging Mikel Jones withconspiracy from in or about January of 2008 until in or about April of 2009, we,the jury, unanimously find the Defendant, Mikel Jones:

NOT GUILTY GUILTYOn Count 5 of the Second Superseding Indictment, charging Dona Nichols Joneswith conspiracy from in or about January of 2008 until in or about April of 2009,we, the jury, unanimously find the Defendant, Dona Nichols Jones:

NOT GUILTY GUILTYOn Counts 6-19 of the Second Superseding Indictment, charging Mikel Jones withwire fraud, we, the jury, unanimously find the Defendant, Mikel Jones (You mustaddress each individual count of wire fraud against Mikel Jones separately):

THE FLORIDA BAEXHIBIT


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Count 6: Wire Fraud o n or about January 9, 2008, against Mikel Jon es:NOT GUILTY ^ GUILTY

Count 7: Wire Fraud on or about January 30, 2008, against Mikel Jones:NOT GUILTY X GUILTY

Count 8: Wire Fraud on or about January 30, 2008, against Mikel Jones:NOT GUILTY X GUILTY

Count 9: Wire Fraud o n o r about February 25, 2008, against Mikel Jones:NOT GUILTY * GUILTY

Count 10: Wire Fraud o n or about March 13, 2008, against Mikel Jones:NOT GUILTY ^ GUILTY

Count 11: Wire Fraud on or about April 24, 2008, against Mikel Jones:NOT GUILTY X GUILTY

Count 12: Wire Fraud on or about April 25, 2008, against Mikel Jones:_ NOTGUILTY A GUILTYCount 13: Wire Fraud on or about June 19, 2008, against Mikel Jones:_ NOT GUILTY XGUILTYCount 14: Wire Fraud o n o r about July 11, 2008, against Mikel Jones:_ NOTGUILTY XGUILTYCount 15: Wire Fraud o n o r about August 27, 2008, against M ikel Jones:

NOT GUILTY < GUILTY


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Count 16: Wire Fraud o n o r about September 18, 2008, against Mikel Jones:NOT GUILTY V GUILTY

Count 17: Wire Fraud o n o r about September 22, 2008, against Mikel Jones:NOT GUILTY ^ GUILTY

Count 18: Wire Fraud o n o r about October 13, 2008, against Mikel Jones:VNOT GUILTY A GUILTY

Count 19: Wire Fraud on or about October 13, 2008, against Mikel Jones:NOT GUILTY X GUILTY

7. On Counts 6-19 of the Second Superseding Indictment, charging Dona NicholsJones with wire fraud, we, the jury, unanimously find the Defendant, DonaNichols Jones (You must address each individual count of wire fraud againstDona Nichols Jones separately):Count 6: Wire Fraud on or about January 9, 2008, against Do na Nichols Jones:

NOT GUILTY ^ GUILTYCount 7: Wire Fraud on or about January 30, 2008, against Dona Nichols Jones:vNOT GUILTY r GUILTYCount 8: Wire Fraud on o r about January 30, 2008, against Dona Nichols Jones:

NOT GUILTY X GUILTYCount 9: Wire Fraud o n or abo ut February 25, 2008, against Dona NicholsJones:

NOT GUILTY ^ GUILTYCount 10: Wire Fraud o n o r about M arch 13, 2008, against Dona Nichols Jones:

NOT GUILTY )( GUILTY


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Count 11: Wire Fraud o n or about April 24, 2008, against Dona Nichols Jo nes:NOT GUILTY *GUILTY

Count 12: Wire Fraud on o r about April 25, 2008, against Dona Nichols Jo nes:NOT GUILTY X GUILTY

Count 13: Wire Fraud on o r about June 19, 2008, against Dona Nichols Jone s:NOT GUILTY _X GUILTY

Count 14: Wire Fraud on or about July 11, 2008, against Dona N ichols Jones:NOT GUILTY X GUILTY

Count 15: Wire Fraud on or about August 27, 2008, against Dona Nichols Jone s:NOT GUILTY X GUILTY

Count 16: Wire Fraud on o r about September 18, 2008, against Dona NicholsJones:NOT GUILTY ^ GUILTY

Count 17: Wire Fraud o n or about September 22, 2008, against Don a NicholsJones:NOT GUILTY GUILTY

Count 18: Wire Fraud on or about October 13, 2008, against Don a NicholsJones:NOT GUILTY X GUILTY

Count 19: Wire Fraud on o r about October 13, 2008, against Don a NicholsJones:NOT GUILTY X GUILTY

8. On Counts 20-33 of the Second Superseding Indictment, charging Mikel Joneswith mail fraud, we, the jury, unanimously find the Defendant, Mikel Jones (Youmust address each individual count of mail fraud against Mikel Jones


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separately):Co unt 20: Mail Fraud o n or about February 1, 2008, against Mikel Jones:

NOT GUILTY X GUILTYCo unt 21: Mail Fraud on o r about July 23, 2008, against Mikel Jon es:

NOT GUILTY J* GUILTYCount 22: Mail Fraud on or about September 23, 2008, against Mikel Jones:

NOT GUILTY *GUILTYCoun t 23: Mail Fraud on o r about October 16, 2008, against Mikel Jones:

NOT GUILTY _X GUILTYCo unt 24: Mail Fraud on or about Octob er 21, 2008, against Mikel Jone s:

NOT GUILTY ^ GUILTYCo unt 25: Mail Fraud on or about Octob er 29, 2008, against Mikel Jon es:

NOT GUILTY GUILTYC ou n t 26: Mail Fraud o n o r about November 7, 2008, against Mikel Jones:

NOT GUILTY "* GUILTYCoun t 27: Mail Fraud on o r about November 24, 2008, against Mikel Jones:

NOT GUILTY X GUILTYCoun t 28: Mail Fraud on o r about December 8, 2008, against Mikel Jones:

NOT GUILTY X GUILTYC ou n t 29: Mail Fraud on o r about December 16, 2008, against Mikel Jones:

NOT GUILTY \GUILTY


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C o u n t 30: Mail Fraud o n o r about December 22, 2008, against Mikel Jones:NOT GUILTY *GUILTY

C o u n t 31: Mail Fraud on or about December 30, 2008, against MikelJones:NOT GUILTY ^ GUILTY

Coun t 32: Mail Fraud o n or about January 6, 2009, against Mikel Jone s:NOT GUILTY _* GUILTY

Co unt 33: Mail Fraud o n or about January 19, 2009, against Mikel Jone s:NOT GUILTY _* GUILTY

9. On Counts 20-33 of the Second Superseding Indictment, charging Dona NicholsJones with mail fraud, we, the jury, unanimously find the Defendant, DonaNichols Jones (You must address each individual count of mail fraud againstDona Nichols Jones separately):Coun t 20: Mail Fraud on o r about February 1, 2008, against Dona NicholsJones:

NOT GUILTY GUILTYC o u n t 21: Mail Fraud on or about July 23, 2008, against Dona Nichols Jones:* NOT GUILTY GUILTY

C o u n t 22: Mail Fraud on or about September 23, 2008, against Do na NicholsJones:*NOT GUILTY GUILTY

Coun t 23: Mail Fraud o n or about October 16, 2008, against Dona NicholsJones:

*NOT GUILTY GUILTY


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Coun t 24: Mail Fraud on o r about October 21, 2008, against Dona NicholsJones:* NOT GUILTY GUILTY

Count 25: Mail Fraud on or about October 29, 2008, against Dona NicholsJones:*NOT GUILTY GUILTY

C ou n t 26: Mail Fraud on or about November 7, 2008, against Dona NicholsJones:x NOT GUILTY GUILTY

Count 27: Mail Fraud on o r about November 24, 2008, against Dona NicholsJones:y NOTGUILTY GUILTY

Coun t 28: Mail Fraud on o r about December 8, 2008, against Dona NicholsJones:NOEXHJILTY GUILTY

Coun t 29: Mail Fraud on o r about December 16, 2008, against Don a NicholsJones:^ NOT GUILTY GUILTY

Count 30: Mail Fraud on o r about December 22, 2008, against Dona NicholsJones:X NOT GUILTY GUILTY

Coun t 31: Mail Fraud on o r about December 30, 2008, against Dona NicholsJones:X NOT GUILTY GUILTY

Coun t 32: Mail Fraud on or about January 6, 2009, against Dona Nichols Jones:X NOT GUILTY GUILTY


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Count 33: Mail Fraud on or about January 19, 2009, against Dona NicholsJones:*NOT GUILTY GUILTY

10. On Count 34 of the Second Superseding Indictment, charging Mikel Jones withmoney laundering, between on or about March 6,2009, through on or aboutDecember 29, 2009, we, the jury, unanimously find the Defendant, Mikel Jones:

NOT GUILTY *GUILTY11. On Count 34 of the Second Superseding Indictment, charging Dona Nichols Joneswith money laundering, between on or about March 6,2009, through on or aboutDecember 29,2009, we, the jury, unanimously find the Defendant, Dona NicholsJones:

XOT GUILTY *GUILTY

i 1 .Dated: "7 /W 1 1 Foreperson: ** *


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Case 2:ll-cr-00261-BMS Document 31 Filed 09/13/11 Page1of 27

IN THE UNITED STATES DISTRICT COURTFOR THE EASTERN DISTRICT OF PENNSYLVANIAUNITED STATES OF AMERICA : CRIMINAL NO. 11-261

v. : DATE FILED: September 13,2011MIKEL D. JONES : VIOLATIONS:DONA NICHOLS JONES 18 U.S.C. 371 (conspiracy - 1 count)18 U.S.C. 1341 (mail fraud - 16 counts)18 U.S.C. 1343 and 1349(wire fraud -: 16counts)18 U.S.C. 1956(a)(l)(B)(i) (money

: laundering - 1 count)18 U.S.C. 2 (aiding and abetting): Notice of forfeiture

S E C ON D S U P E R S E D I N G I N D I C T M E N TCOUNTS ONE AND TWO

THE GRAND JURY CHARGES THAT:BACKGROUND

At all times material to this Second Superseding Indictment:1. Defendant MIKEL D. JONES owned and operated a law firm called the

Mikel Jones Law Firm, LLC, ("the law firm"), which was located at 1831 Chestnut Street, 4thFloor, Philadelphia, Pennsylvania 19103. The law firm specialized in personal injury, wrongfuldeath, and medical negligence cases. Defendant JONES employed between four to sixindividuals at the law firm and was licensed to practice law in, among other places, Pennsylvaniaand Florida. Defendant JONES had a law degree from Nova Southeastern University LawSchool.

2. The Philadelphia Commercial Development Corporation ("PCDC") was anonprofit corporation that promoted commercial development in the Philadelphia area. PCDC

THE FLORIDA BAR'SEXHIBIT

B


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Case 2:ll-cr-00261-BMS Document 31 Filed 09/13/11 Page 2 of 27

was funded by the Commonwealth of Pennsylvania, the City of Philadelphia, and various othersources.

3. Minority Venture Partners Ltd. ("MVP") was a venture capital fundfinanced entirely by more than $1.6 million from the Commonwealth of Pennsylvania. Thepurpose of MVP was to make investments in and loans to promising minority businesses in thePhiladelphia area. The managers of MVP were also the operators of PCDC.

THE SCHEME TO DEFRAUD4. From in or about September 2005 to in or about September 2009,

defendantMIKEL D. JONES

devised and intended to devise a scheme to defraud and to obtain money and property by meansof false and fraudulent pretenses, representations and promises.

MANNER AND MEANSIt was part of the scheme that:5. In early 2006, defendant MIKEL D. JONES applied for funds from MVP

to expand the Mikel Jones Law Firm and to fund working capital. In the application for theinvestment, defendant JONES provided various financial information about his law firm,including tax returns, information about his success as an attorney, and information about hiscases.

6. Based on information supplied by defendant MIKEL D. JONES, MVPagreed to make an investment of approximately $150,000 in the Mikel Jones Law Firm.


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7. On or about January 27, 2006, defendant MIKEL D. JONES and MVPentered into an agreement in which defendant JONES agreed to use the $150,000 to expand hisbusiness and to fund working capital. Defendant JONES agreed to repay the funds in 48 months.He also agreed to deposit two months principal payments into a bank account, and to deposit fivepercent of his gross sales each day into the bank account to use to repay the $150,000. Inconversations with officials of MVP and PCDC, defendant JONES represented that he would us ethe $150,000 to expand and operate his law firm and for no other purpose.

8. In three separate transactions, MVP wire transferred the funds to a bankaccount defendant MIKEL D. JONES established in January 2006 to maintain the MVP funds.Specifically, on or about January 30, 2006, defendant JONES received by wire transfer $75,000from MVP. On or about March 26, 2006, JONES received a $37,000 wire transfer fromMVP.On or about May 9, 2006, defendant JONES sent to MVP by United States Mail a request for theremaining MVP funds. On or about May 25, 2006, MVP wire transferred $35,000 to defendantJONES.

9. Defendant MIKEL D. JONES lied to MVP and its operators and did notuse the MVP funds as required. Defendant JONES did not deposit principal payments into thebank account and did not deposit a portion of the receipts of his law firm into the account so thatMVP could recoup its investment, as he agreed to do. Instead, defendant JONES concealed histheft of MVP funds by transferring the funds to his and his wife's personal bank accounts, fromwhich he used the funds to pay personal expenses, including groceries, personal trips, credit cardbills, and various sports tickets. Defendant JONES falsely told MVP representatives that he wasusing the funds to operate his law firm and did not disclose that he had diverted the funds to his


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personal bank accounts. Also, defendant JONES did not file tax returns reporting that he hadreceived the funds from MVP.

10. In or about July 2009, representatives of MVP contacted defendantMJJKEL D. JONES regarding his repaying MVP for the $150,000 investment. To avoid hisobligation of repaying MVP's investment in his law firm, defendant JONES lied about hisfinances and falsely claimed that he did not have the funds to repay MVP. Defendant JONESinitially offered to pay $5,000, but later agreed to pay $20,000 to settle his obligation. At thetime defendant JONES was claiming he did not have sufficient funds to repay MVP, he hadsubstantial funds and was spending tens of thousands of dollars on sports tickets and other luxuryitems, including a Hawaiian vacation. Indeed, just months before being contacted by MVP, andwithin months after being contacted by MVP, defendant JONES had told lenders that he earned$470,000 to $500,000 yearly from the practice of law. By making these false statements abouthis finances, defendant JONES convinced MVP to accept just $20,000 to satisfy his debt. On orabout July 28, 2009, defendant JONES mailed a check in the amount of $20,000 to MVP.


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THE MAILINGS11 . On or about the dates listed below, in the Eastern District of Pennsylvania,

and elsewhere, defendantMIKEL D. JONES,

for the purpose of executing the scheme described above, and attempting to do so, and aiding andabetting its execution, knowingly caused to be sent by United States Mail, the following items:Count Date Description1 May 9, 2006 A request by defendant JONES fo r $37,500 in MVPfunds to be wire transferred to him.2 July 28, 2009 A check in the amount of $20,000 sent fromdefendant JONES to PCDC in repayment of the

$150,000 investment in defendant JONES' lawfirm.hi violation of Title 18,United States Code, Sections 1341 and 2.


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COUNTS THREE AND FOURTHE GRAND JURY FURTHER CHARGES THAT:

1. Paragraphs 1 through 3 and 5 through 10 of Counts One and Two areincorporated here.

2. On or about the dates listed below, in the Eastern District of Pennsylvania,and elsewhere, defendant

MIKEL D.JONES,for the purpose of executing the scheme described above, attempting to do so, and aiding andabetting its execution, knowingly caused to be transmitted by means of wire communication ininterstate commerce, certain signals and sounds, as described below:Count Date Description3 March 26, 2006 A $37,000 wire transfer from MVP's bank accountto theLaw Firm.4 May 25, 2006 A $35,000 wire transfer from MVP's bank account

to the Commerce Bank account of the Mikel JonesLaw Firm.In violation of Title 18, United States Code, Sections 1343and 2.


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COUNT FIVETHE GRAND JURY FURTHER CHARGES THAT:

At all times relevant to this Second Superseding Indictment:1. Paragraph 1 of Counts One and Two is incorporated here.2. In or about February 2006, defendant MIKEL D. JONES obtained a

business line of credit from a lender in New York, referred to here as "Lender No. 1." The limitsof this business line of credit were increased in July 2007, and in January 2008, and allowed thelaw firm to borrow up to $1,750,000 to operate the law firm. Defendant JONES agreed that hewould use the proceeds of the line of credit to discharge certain tax hens and for working capitalrelated to the operation of his law firm and other approved expenses. Defendant JONES andLender No. 1 agreed that defendant JONES would receive payments of $10,000 per month fromthe line of credit, called the draw, which defendant JONES would be permitted to use to paypersonal expenses.

3. Defendant DONA NICHOLS JONES is defendant MIKEL D. JONES'swife. Defendant NICHOLS JONES was involved in the administration of the Mikel Jones LawFirm, including preparing proposed budgets containing law firm expenses and coordinating thepayment of those expenses with a representative of Lender No. 1. Defendant NICHOLS JONESwas aware that the business line of credit funds were to be used to support the operation of thelaw firm.

4. hi addition to operating his law firm, defendant MIKEL D. JONES ownedand controlled shell companies, including Strata Tech, Inc. ("Strata Tech") and Visions 21stDemocratic Club. Defendants JONES and DONA NICHOLS JONES used these shell


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companies, a media corporation located in the Philadelphia area ("Company No. 1"), and thename of their daughter, referred to here as "K.M.," to steal hundreds of thous ands of dollars fromLender No. 1 under false pretenses.

THE CONSPIRACY5. From in or about January 2008 to in or about April, 200 9, defendants

MIKEL D. JONES andDONA NICHOLS JONESconspired and agreed, with each other, and with others know n and unknown to the grand jury, tocommit an offense against the United States, that is, they devised and intend to devise a schemeto defraud Lender No. 1 and to obtain mo ney and property by means of false and fraudulentpretenses, representations and promises. In conspiring to do so, they knowingly caused the useof the United States mails and commercial interstate carriers, and the transmission of certainsignals and sounds by means of wire communications in inlerslale commerce, irrviolatioirofTitle 18, United States Code, Sections 1341, 1343 and 2.

MANNER AND MEANS6. Defendants MIK EL D. JONES and DONA NICHOLS JONES submitted

budgets to Lender No. 1 of the expected expenses of the law firm and agreed to submit invoicesfrom vendors who supplied goods and services to the law firm. Lender No. 1 agreed to pay thesevendors upon Lender No. 1 's receipt of the invoices. Defendants JONES and NICHOLS JONESagreed that they w ould subm it the invoices to a representative of Lender No. 1, an accountantwho would review the invoices and disburse the funds on behalf of Lender No. 1. Thedefendants sent messages and invoices to Lender No. 1 's representative by telephone, fax and e --mail.

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7. Defendants MIKEL D. JONES and DONA NICHOLS JONES wantedmore funds fo r personal us e than Lender No. 1 was willing to furnish. To sidestep Lender No. 1and to obtain more funds fo r personal use, the defendants used the name of Strata Tech and thename of Company No. 1 to steal money from Lender No. 1 under false pretenses. Specifically,the defendants created, and caused the creation of , fraudulent check requests and invoicespurportedly on the letterhead of Strata Tech and Company No. 1 which falsely claimed that thesecompanies had provided business-related services to defendant JONES' law firm, hi fact, thesecompanies had supplied no services to the law firm whatsoever. The defendants then suppliedthe false invoices to the representative of Lender No. 1 to cause payment on the invoices to thelaw firm and to Strata Tech. Once the defendants received payment on the invoices, theytransferred the fraudu lently-received funds to their ow n bank accounts and used them to paypersonal expenses.

8. The bogus invoices which defendants MIKEL D. JONES and DONANICHOLS JONES supplied to the representative of Lender No. 1 seeking payment from the lawfirm stated that Strata Tech was in the business of, among other things, "event management,""strategic marketing," "speaker placement," "corporate identity," and "advertising." hi reality, atthe time Strata Tech was a shell corporation that had no real operations and used the address of amail drop in Florida as its business address. Strata Tech did not supply any services to the lawfirm.

9. The check requests and bogus invoices which defendants MIKEL D.JONES and DONA NICHOLS JONES supplied to the representative of Lender No. 1 seekingpayment from the law firm claimed, falsely, that Company No. 1 had done advertising for the lawfirm in four separate media markets in Pennsylvania, New Jersey, Florida, and the District of

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Columbia. Once the defendants received payment on these invoices, defendant JONES used theproceeds to pay for his season tickets to Philadelphia 76ers basketball games.

10. Defendants MIKEL D. JONES and DONA NICHOLS JONES also usedthe name of their daughter, K.M., to defraud Lender No. 1 of funds. The defendants intimated toLender No. 1 that they could be harmed if they did not pay off a debt they had taken out withanother source. Once Lender No. 1 approved the payment, the defendants laundered the fundsthey received from Lender No. 1 through an account jointly held by K.M. an d defendantNICHOLS JONES, then used the funds to pay personal expenses and to replenish client fundsdefendant JONES ha d previously taken from his law firm account.

11 . Defendant MIKEL D. JONES also received funds from Lender No. 1 aftertelling Lender No. 1 that the funds would be used for a political donation which could improvethe law firm's litigation efforts. After the funds were furnished to defendant JONES's Visions21 st Democratic Club, defendant JONES took the funds by writing checks to cash and to himself.

12. Defendant MIKEL D. JONES convinced a representative of Lender No. 1to furnish funds to him by telling the representative that he had to "repay my nephew" or he was"looking at a very bad situation." Later, after defendant JONES told the representative "mynephew is in danger" and that he needed money right away, Lender No. 1 furnished $52,000 todefendant JONES. Defendant JONES had the funds deposited to his personal account, afterwhich they were used fo r personal expenses.

OVERT ACTSIn furtherance of the conspiracy, defendants MIKEL D. JONES and DONA

NICHOLS JONES, together with others known and unknown to the grand jury, committed thefollowing overt acts, among others, in the Eastern District of Pennsylvania and elsewhere:

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1. In or about late 2007 or January 200 8, the Mikel Jones Law Firmsubmitted a proposed 2 008 law firm budget to a representative of Lender No. 1 which containedfraudulent payments to be made to Strata Tech and Company No. 1. Defendants MIK EL D.JONES and DON A NICHO LS JONE S told the representative that the payments were to be madefor law firm advertising to be done by Strata Tech and Company No. 1.

2. In or about early 2008, defendant DON A NICHOLS JONES, a paid"Human Resource Consultant" to the law firm, told a representative of Lender No. 1 that shewould be coordinating the payment of law firm expenses w ith the representative, including thepayment of Company No. 1 and Strata Tech invoices. Thereafter, defendant NICHOLS JONEScaused checks made p ayable to Co mpany No. 1 to be sent by the New York representative to thelaw firm, and caused checks made payable to Strata Tech to be sent by the representative todefendant NICHOLS JONES at her Florida home and to Strata Tech in Florida.

3. On or about January 9, 2008 , defendant MIKE L D. JONES directed anemployee of his law firm to include monthly line items totaling m ore than $20 ,000 in paymentsto Strata Tech and Com pany No. 1 on the firm budget so that defendan t JONES could submitbogus invoices to Lender No. 1.

4. On or about January 22, 2008, defendant MIK EL D. JONES wrote to arepresentative of Lender No. 1 that "I really need that $52,000 wired today," and "my nephew isin danger. I need to resolve this today."

5. On or about January 28, 2008, defendant MIK EL D. JONES wrote torepresentative of L ender No. 1 and asked them to hold off paying other bills and to rearrangeStrata Tech and Company No. 1 as "priorities."

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6. On or about January 30, 2008, defendant MIK EL D. JONES directed anemployee of his law firm to prepare invoices to submit to a representative of Lender No. 1seeking paym ent of a total of $20,000 for Strata Tech and Company No. 1. Defendant JONESinstructed his employee to inform the representative of Lender No. 1 not to contact Strata Tech orCompany No. 1 because of "personal & political relationships that exist between Mikel and bothentities. Should there be any need to negotiate, Mikel will handle."

7. On or about January 30, 2008, defendants MIK EL D. JONES and DONANICHO LS JON ES caused the Mikel Jones Law Firm to fax a check request seeking payment foradvertising and a purported Strata Tech invoice dated January 28, 20 08, to a representative ofLender No. 1 in New York.

8. On or about January 30, 2008 , defendants MIKEL D. JONES and DONANICHOLS JONES caused the Mikel Jones Law Firm to fax a check request seeking paym ent foradvertising and a purported Company No. 1 invoice dated January 1, 2008, to a representative ofLender No. 1 in New Y ork.

9. On or about February 25 , 2008 defendants MIK EL D. JONES and DONANICHOLS JONES caused the Mikel Jones Law Firm to f ax a check request s eeking payment foradvertising and a purported S trata Tech invoice dated February 22, 2008, to a representative ofLender No. 1 in New York.

10. On or about March 13, 2008, defendant MIK EL D. JONES wrote to arepresentative of Lender No. 1 that he paid $10,000 in Com pany No. 1 expenses from his ownfunds an d that he needed to be reimbursed.

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11 . On or about March 13, 2008 , defendants MIK EL D. JONES and DONANICHOLS JONE S caused the Mikel Jones Law Firm to fax a check request for a $10,000reimbuirsement to defendant MIKEL D. JONES and a copy of a $10,000 check made payable toCompany No. 1 from Beneficial Bank.

12. On or about March 31 , 2008, defendant MIK EL D. JONES wrote to arepresentative of Lender No. 1 identifying items needing to be addressed , included the remainingbalance for Company No. 1 and a past due balance of $35,000 for S trata Tech. Defen dantJONES wrote that he had used his Am erican Express card the week before to make a $14,000payment to Company No. 1.

13. On or about April 24, 2008, defendant MIKE L D. JONE S instructed anemployee of his law firm to prepare invoices in the name of Company No. 1 showing that$38,000 had been paid and that there was a balance due of $20,000. Defend ant JONES alsoinstructed his employee to create a Strata Tech invoice showing paym ents of $15,000 and abalance due of $40,000.

14. On or about April 25, 2008 , defendants MIK EL D. JONES and DONANICHOLS JONES caused the Mikel Jones L aw Firm to fax a check request and a purportedStrata Tech invoice dated April 23, 2008, to a representative of Lender No. 1 in New York.

15. On or about April 25 , 2008, defendants MIK EL D. JONES and DONANICHOL S JO NES caused the Mikel Jones Law Firm to fax a check request seeking paymentfrom Company No. 1 for reimbursement of expenses and a purported Company No. 1 invoicedated A pril 21, 200 8, to a representative of Lender No. 1 in New Y ork.

16. On or about April 26, 2008 , in an effort to convince Lender No. 1 torelease funds to him, defendant MIKE L D. JONE S wrote to a representative of Lender No. 1

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that, "because of my personal and political relationships, both [Company No. 1 and Strata Tech]have been good with not coming after me for non-payment over the past 4/6 months."

17. On or about June 6, 2008, defendant MIK EL D. JONES wrote to arepresentative of Lender No. 1 that he owed Strata Tech $10,00 0 and requested p ayment of thatamount.

18. On or about June 19, 2008, defendants MIKEL D. JONES and DONANICHOL S JON ES caused the Mikel Jones Law Firm to fax a check request and purportedCompany No. 1 invoices dated May 1, 2008 and June 1, 2008 to a representative of Lender No. 1in New York.

19. On or about June 19, 2008, defendants M IKEL D. JONES and DONANICHOLS JONES caused the Mikel Jones Law Firm to fax a check request and purported StrataTech invoices dated April 23, 20 08, May 1, 2008, and June 1, 200 8 to a representative of LenderNo. 1 in New York.

20. On or about June 19, 2008, defendants MIK EL D. JONES and DONANICHO LS JONE S caused the Mikel Jones Law Firm to fax a check request seeking a $14,000reimbursement for a payment made to Company No. 1 on "Amex." The f ax noted that back upfor the request was attached. Attached to the check request was an American Express cardstatement on an account held by defendant NICHOLS JONES for the time period March 28,2008 through April 27, 2008. The statement had been altered to mask the fact that the AmericanExpress card had been used to m ake a total of $14,000 in purchases of Philadelphia 7 6ers ticketson March 28, 200 8 and March 31 , 2008. In response to this request, and in reliance on thealtered American Express card statement, the representative sent a check drawn on the law firm

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operating account and m ade payable to defendant JONES in the amount of $14 ,000 to thedefendants' home.

21 . On or about July 9, 2008, defendant MIK EL D. JONES w rote to arepresentative of Lender No. 1 requesting DV D copies of a commercial and claiming thatCompany No. 1 will run it on the East Coast. Defen dant JONES also wrote "they need mypolitical m uscle and we're already paying them $10,000 per month."

22 . On or about July 11, 2008, defendants MIK EL D. JONES and DONANICHOL S JON ES caused the Mikel Jones Law Firm to fax a check request and purported StrataTech invoice dated July 9, 200 8, to a representative of Lender No. 1 in New York.

23. On or about July 11, 2008, defendants MIK EL D. JONES and DONANICHOLS JONES caused the Mikel Jones Law Firm to send a fax containing an updated invoicefor Company. No. 1 to a representative of Lender No. 1 hi New York.

24. On or about August 12, 2008, defendant MIK EL D. JONES requested thatLender No. 1 make a $25,000 payment to defendant JONES' corporation, Visions 21stDemocratic Club, to fund a political donation w hich could benefit the law firm's litigationefforts. Once he received the funds, defendant JONES us ed them to pay personal expenses.

25. On or about August 27 , 2008, defendants MIK EL D. JONES and DONANICHO LS JON ES caused the Mikel Jones Law Firm to fax a check request and purportedCompany No. 1 invoice dated August 1, 200 8, to a representative of Lender No. 1 in New York.Defendant NICHOLS JONES told the representative to overnight the invoice payment check toPhiladelphia.

26 . On or about August 27, 2008, defendants MIK EL D. JONES and DONANICHOLS JONE S caused the Mikel Jones Law Firm to fax a check request and purported Strata

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Tech invoice dated A ugust 1, 200 8, to a representative of Lender No. 1 in New York. DefendantNICH OLS JONES told the representative to ov ernight the invoice paym ent check to Florida.

27. On or about September 18, 2008, defendants MIKEL D. JONES andDONA NICHOLS JONES caused the Mikel Jones Law Firm to fax a check request andpurported Company No. 1 invoice dated September 1, 200 8, to a representative of Lender No. 1in New Y ork. Defend ant NICHO LS JONES told the representative to overnight the invoicepayment check to Philadelphia.

28. On or about September 18, 2008, defendants MIKEL D. JONES andDO NA NICH OLS JON ES caused the Mikel Jones Law Firm to fax a check request andpurported Strata Tech invoice dated September 1, 2008 , to a representative of Lender No. 1 inNew Y ork.

29. On or about September 22, 2008, defendants MIK EL D. JONES andDONA NICHOLS JONES caused the Mikel Jones Law Firm to fax a check request for paymentto Strata Tech to a representative of Lender No. 1 hi New York. Defendant NICHOLS JONEStold the representative to overnight the paym ent check to Florida.

30. On or about October 13, 200 8, defendants MIK EL D. JONES and DONANICHO LS JON ES caused an employee of the Mikel Jones Law Firm to e-mail a request to haveadvertising bills for Com pany No. 1 and Strata Tech, among others, paid w eekly. Defend antNICHOL S JONES told the representative to s end the Strata Tech check overnight to Florida andthe Com pany No. 1 and other checks overnight to Philadelphia.

31 . On or about October 13 , 200 8, defendants MIK EL D. JONES and DONANICH OLS JONES caused the Mikel Jones Law Firm to fax a check request for advertising and

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purported invoices fo r Company No. 1 and Strata Tech dated October I , 2008, to a representativeof Lender No. 1 in New York. The fax noted that it was "to follow e-mail sent."

32. On or about November 25, 2008, defendant MKEL D. JONES w rote to arepresentative of Lender No. 1 and requested the representative to m ail a check for $5,000 todefendant DON A NICHOL S JONES along with a letter acknowledging her "valuable part inmoving ou r venture forward." hi respons e to the request, the representative sent a Mikel JonesLaw Firm Operating A ccount check m ade payable to defendant NICHOLS JONES in the amountof $5,000 overnight to defendant NICHOL S JONES in Florida.

33. In or about January 2009, defendants MQCEL D. JONES and DONANICHOLS JONES told Lender No. 1 that they needed approximately $160,000 to repay a debtand requested that Lender No. 1 issue a check to K .M., who, unbeknownst to Lender No . 1, wasthe defendants' daughter. After Lender No. 1 issued the $160,000 check, defendant NICHOLSJONES w rote a $132,000 check from the proceeds of the $160,000 check to purchase a cashier'scheck. Defen dant JONES then deposited the cashier's check to a law firm trust account toreplenish client funds defendant JONES had previously taken. Defendan t NICH OLS JONESused remaining proceeds from the $160 ,000 check to pay her American Express credit card bills.

34. In total, between approximately January 200 8 and approximately April2009, defendants MJJCEL D. JONES and DONA NICHOLS JONES obtained m ore than$456,000 from Lender No. 1 by subm itting bogus invoices to Lender No. 1 and by making falserepresentations to Lender No. 1.

All in violation of Title 18, United States Code, Section 37 1.

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COUNTS SIX THROUGH NINETEENTHE GRAND JURYFURTHER CHARGES THAT:

1. Paragraph 1 of Counts One and Two and Paragraphs 2, 3, 4, and 6 through12 of Count Five are incorporated here.

2. On or about the dates listed below, in the Eastern District of Pennsylvania,and elsewhere, defendants

MIKEL D. JONES andDONA NICHOLS JONES,for the purpose of executing the scheme described above, attempting to do so, and aiding andabetting its execution, knowingly caused to be transmitted by means of wire communication ininterstate commerce, the folio whig signals and sounds:

THE WIRESDate~January 9, 2008

January 30, 2008

-DescriptionAn email message from defendant MIKEL D. JONES to anemployee at defendant JONES' law firm in Philadelphiadirecting the employee to include fraudulent line items fo rStrata Tech and Company No. 1 on the budget submitted tothe representative of Lender No. 1.An email message from defendant MIKEL D. JONES to anemployee at defendant JONES' law firm in Philadelphiadirecting the employee to draft requests fo r payment tosubmit to a representative of Lender No. 1 for Strata Techand Company No. 1. The e-mail message directed theemployee to include the following comment:"Melanie, please mail [Company No. 1] check to Mikel inthe Philly office (Mikel will personally deliver to hiscontact) and Strata-Tech check directly to them. Pleaserefrain from direct contact due to the personal & politicalrelationships that exist between Mikel and both entities.Should there be any need to negotiate, Mikel will handle."

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January 30,2008 A faxed check request from the Mikel Jones Law Firm inPhiladelphia to a representative of Lender No. 1 containingan invoice for Company No. 1 dated January 1, 2008, forlaw firm advertising, and a Strata Tech invoice datedJanuary 28, 200 8, for advertising, and the followingmessage:"Mikel wanted me to forward to you the attached.1. He asked that you mail to him here in Philadelphiathe check payable to [Company No. 1] and he willpersonally deliver to his contact.2. He asked that you mail the check directly to Strata-Tech;3. He also asked that for the foreseeable future thatyou not contact either company directly due to hispersonal and political relationships with the twocompanies.4. Should there be any need to negotiate he said hewould negotiate;..."

February 25, 200 8

10 March 13, 2008

11 April 24, 2008

12 April 25 , 2008

A faxed check request from the Mikel Jones L aw Firm inPhiladelphia to a representative of Lender No. 1 in NewYork containing a Strata Tech invoice dated February 2 2,2008.A faxed check request from the Mikel Jones Law F irm inPhiladelphia to a representative of Lender No. 1 in NewYo rk seeking reimbursem ent for expenses and containing acopy of a $10,000 check made payable to C ompan y No. 1.An e-mail message from defendant MIKEL D. JONES toan employee at JONES' law firm in Philadelphia directingthe employee to prepare invoices to s ubmit to Lender No. 1for Strata Tech and Company No. 1.Faxed check requests from the Mikel Jones Law Firm inPhiladelphia to a representative of Lender No. 1 in NewYork seeking reimbursement of Company No. 1 expensesand payment for Strata Tech and containing a Strata Techinvoice dated April 23 , 2008 and a Company No. 1 invoicedated April 21,2008.

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13 June 19, 2008

14 July 11, 2008

15 August 27, 2008

16 September 18, 2008

17

18

September 22, 2008

October 13, 2008

19 October 13, 2008

Faxed check requests from the Mikel Jones Law Firm inPhiladelphia to a representative of Lender No. 1 in NewYork seeking reimbursement for a payment made toComp any No. 1 and payments to Strata Tech and C ompanyNo. 1. The faxes included an altered American Expressstatement justifying the reimbursement, and Strata Techinvoices dated April 23, 2008, May 1, 200 8, and June 1,2008 and Company No. 1 invoices dated May 1 , 200 8, andJune 1,2008.Faxed check requests from the Mikel Jones Law Firm inPhiladelphia to a representative of Lender No. 1 in NewYork seeking paym ent to Strata Tech and containing aStrata Tech invoice dated July 9, 2008 and a CompanyNo . 1 invoice dated July 9, 20 08.Faxed check requests from the Mikel Jones Law Firm inPhiladelphia to a representative of Lender No. 1 in NewYork seeking payments to Strata Tech and Com pany No. 1and containing a Company No. 1 invoice dated A ugust 1,200 8 and a Strata Tech invoice dated August 1, 2008 .Faxed check requests from the Mikel Jones Law Firm in^Philadelphia to a-represeittetive^fHbenderisfo. 1 inNewYork seeking payments to Strata Tech and Company. No.land containing a Strata Tech invoice dated September 1,200 8 and a Company No. 1 invoice dated September 1 ,2008.A faxed check request from the M ikel Jones L aw firm inPhiladelphia to a representative of Lender No. 1 in NewYork requesting payment to Strata Tech.An email message from an employee of defendant JONES'law firm in Philadelphia to a representative of Lender No. 1in New York requesting that they pay advertising bills fo rStrata Tech and Co mpany No. 1 weekly.A faxed check request from the Mikel Jones Law Firm inPhiladelphia to a representative of Lender No. 1 in NewYork containing Strata Tech and Company No. 1 invoicesdated October 1,2008.

All in violation of Title 18 , United States Code, Sections 1343 and 2.

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COUNTS TWENTY THROUGH THIRTY-THREETHE GRAND JURY FURTHER CHARGES THAT:

1. Paragraph 1 of Counts One and Two and Paragraphs 2,3,4, and 6 through12 of Count Five are incorporated by reference.

2. For the purposes of executing the scheme described above, defendantsMIKEL D. JONES and DONA NICHOLS JONES caused approximately 27 checks generatedunder false pretenses totaling approximately $138,000 and created by the representative ofLender No. 1 made payable to Strata Tech, to be sent by United States Mail and commercialcarrier from New York to the defendants' home in Boynton Beach, Florida, and to Strata Tech,Inc. at a mail box drop located at 4781 N. Congress Avenue, Boynton Beach, Florida.

THE MAILINGS3. On or about the dates listed below, in the Eastern District of Pennsylvania,

and elsewhere, defendantsMIKEL D. JONES and

DONA NICHOLS JONES,for the purpose of executing the scheme described above, and attempting to do so, and aiding andabetting its execution, knowingly caused to be sent by United States Mail and commercialinterstate carrier, from New York to the Mikel Jones Law Firm, 1831 Chestnut Street, 4th Floor,Philadelphia, Pennsylvania, the following items:Count Date Description20 February 1, 2008 A Double D Associates check dated 2/1/2008 and

made payable to Company No. 1 in the amount of$7,500.

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Case 2:ll-cr-00261-BMS Document 31 Filed 09/13/11 Page 22 o f 27

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July 23, 2008

September 23, 2008

October 16, 2008

October 21 ,2008

October 29, 2008

November 7, 2008

November 24, 2008

December 8, 2008

December 1 6, 2008

December 22, 2008

A Mikel Jones Law Firm Operating Account checkdated 7/23/2008 and made payable to CompanyNo. 1 in the amount of $7,500.Mikel Jones Law Firm O perating Account checksmade payable to Company No. land dated8/12/2008 in the amount of $7,500, and 9/23/2008in the amount of $7,000.A Mikel Jones Law Firm Operating Account checkdated 10/16/2008 and made payable to CompanyNo. 1 in the amount of $9,166.50.A Mikel Jones Law Firm O perating A ccount checkdated 10/21/2008 and made payable to CompanyNo. 1 in the amount of $4,583.25.A Mikel Jones Law Firm Operating A ccount checkdated 10/28/20 08 and made payable to CompanyNo. 1 in the amount of $4,583.25.A Mikel Jones Law Firm Operating Account checkdated 11/7/2008 and made payable to Company

A Mikel Jones Law Firm O perating Account checkdated 11/24/2008 and made payable to CompanyNo. 1 in the amount of $9,166.50.A Mikel Jones L aw Firm Operating Account checkdated 12/8/2008 and made payable to CompanyNo. 1 in the amount of $9,166.50.A Mikel Jones Law Firm Operating Account checkdated 12/16/2008 and made payable to CompanyNo. 1 in the amount of $4,583.25.A Mikel Jones Law Firm Operating Account checkdated 12/22/2008 and made payable to CompanyNo. 1 in the amount of $4,583.25.

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31 December 30, 2008 A Mikel Jones Law Firm Operating Account checkdated 12/26/2008 and made payable to CompanyNo. 1 in the amount of $4,583.25.32 January 6, 20 09 A Mikel Jones Law Firm Operating Account check

dated 1/6/2009 and made payable to Company No. 1in the amount of $4,583.25.33 January 19, 200 9 A Mikel Jones Law Firm Operating Account checkdated 1/19/2009 and made payable to Com pany No.1 in the amount of $4,583.25.

All in violation of Title 18, United States Code, Sections 1341 and 2.

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COUNT THIRTY -FOURTHE GRAND JURY FURTHER CHARGES THAT:

1. Paragraphs 1 of Counts One and Two and Paragraphs 2, 3, 4, and 6through 12 of Count Five are incorporated here.

2. Between on or about March 6, 2009, through on or about December 29,2009, in the Eastern District of Pennsylvania, and elsewhere, defendants

MIKEL D. JONES andDONA NICHOLS JONESknowingly conducted, and attempted to conduct, and aided, abetted, and willfully causedfinancial transactions affecting interstate commerce, namely, the defendants lied to Lender No. 1to cause the lender to issue a $160,000 check made payable to their daughter, K.M., which wasdeposited to an account in Florida controlled by K.M. and defendant NICHOLS JONES.

rrcheck was funded by the $160,000 check made payable to their daughter, hi April 2009defendant JONES deposited this $132,000 check into his attorney trust account at BeneficialSavings Bank in Philadelphia to replenish client funds he had previously taken from a law firmtrust account. Defendant NICHOLS JONES used remaining funds from the $160,000 check topay personal expenses, hi December 2009, defendant JONES paid from bis law firm trustaccount the clients whose funds he had previously taken.

3. When conducting, aiding, abetting, and willfully causing, the financialtransactions described in paragraph 2 above, defendants MIKEL D. JONES and DONANICHOLS JONES knew that the property involved in those financial transactions represented theproceeds of some form of unlawful activity.

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4. The financial transactions described in paragraph 2 above involved theproceeds of specified unlawful activities, that is, mail fraud and wire fraud, in violation of Title18 , United States Code, Sections 1341 and 1343, and defendants MIKEL D. JONES and DONANICHOLS JONES acted with the knowledge that the transactions were designed, in whole and inpart, to conceal and disguise the nature, location, source, ownership and control of the proceedsof the specified unlawful activities.

All in violation of Title 18 , United States Code, Sections 1956 (a)(l)(B)(i) and 2.

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NOTICE OF FORFEITURETHE GRAND JURY FURTHER CHARGES THAT:

1. As a result of the violations of Title 18, United States Code, Sections1341, 1343, 1349,and 1956, se t forth in this Second Superseding Indictment defendants

MIKEL D. JONES andDONA NICHOLS JONESshall forfeit to the United States of America: (a) any property, real or personal, that constitutes oris derived from proceeds traceable to the commission of such offenses; and (b) any property, realor personal, that was involved in the commission of such offense, including, but not limited to,approximately $584,000.

2. If any of the property subject to forfeiture, as a result of any act oromission of the defendant:

lotbe^ecated(b) has been transferred or sold to, or deposited with, a third party;(c) has been placed beyond the jurisdiction of the Court;(d) has been substantially diminished in value; or(e) has been commingled with other property which cannot be divided

without difficulty;it is the intent of the United States, pursuant to Title 28, United States Code, Section 246 l(c),incorporating Title 21, United States Code, Section 853(p), to seek forfeiture of any otherproperty of the defendants up to the value of the property subject to forfeiture.

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Case 2:ll-cr-00261-BMS Documen t 31 Filed 09/13/11 Page 27 of 27

All pursu ant to Title 28, United States Code, Section 246l(c), and Title 18,United States Code, Section 981(a)(l)(C).

A TRUE B ILL:

ZANE DAVID MEMEGERUnited States Attorney

GRAND JURY FOREPERSON

Documents

Mikel Jones Bar