Case 4:23-cv-00218-CVE-SH Document 2 Filed in USDC ND/OK on 05/26/23 Page 1 of 6

IN THE I.INITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRTCT OF OKLAHOMA

I. UNITED STATES OF AMERICA,

Plaintiff,

Y Civil No.

1. $111,328.18 rN UMTED STATES

CURRENCY,

2. fi104,782.77 rN UNTTED STATES

CURRENCY,

Defendants

United States Yerified Civil Complaint for Forfeiture In Rem

Plaintiff, United States of America, by and through Reagan V. Reininger,

Assistant United States Afforney, brings this complaint and alleges as follows in

accordance with Rule G(2) of the Supplemental Rules for Admiralty or Maritime

Claims and Asset Forfeiture Actions:

Nature of The Action

1. This is a civil forfeiture action against United States Currency that is proceeds or

property facilitating violations of wire fraud, 18 U.S.C. $ 1343, that is subject to

forfeiture pursuant to 18 U.S.C. $ 981(aX1XC).

The United States Curency In Rem

2. The defendant properties are $111,328.18 seized from Wel1s Fargo account

5068242055 on April 4, 2023, by Seizure Warrant issued in 23-MJ-209-JFJ and

Case 4:23-cv-00218-CVE-SH Document 2 Filed in USDC ND/OK on 05/26/23 Page 2 of 6

$L04,782.77 seizedfromWells Fargo account 9298379907 onApril 3,2023,by Seizure

Warrant issued rn 23 -MJ -2 1 0-JFJ.

3. The defendant properties are presently in the custody of the United States

Marshal's Service for the Northem District of Oklahoma. Pursuant to Supplemental

Rule G(3Xb)(i), "the clerk must issue a waffant to arrest the properry if it is in the

government's possession, custody, or control."

Jurisdiction and Venue

4. The United States brings this action in rem in its own right to forfeit and condemn

the defendant properties. This Court has jurisdiction over an action commenced by

the United States under 28 U.S.C. $ 1345, and over an action for forfeiture under 28

U.S.C. $ 13ss(a)

5. This Court has in remjurisdiction over the defendant properties under 28 U.S.C.

$135s(b)

6. Venue is proper in this district pursuant to 28 U.S.C. $ 1355(bX1) because the acts

or omissions giving rise to the forfeiture occulred in this district, and pursuant to 28

U.S.C. $ 1395, because the defendant properties are located in this district.

Basis for Forfeiture

7. The defendant properties are subject to forfeiture pursuant to l8 U.S.C. $

981(aX1)(C) which states that any propeffy, real or personal, involved in a transaction

or attempted transaction in violation of 18 U.S.C. $ 1343 of this title, or any properry

traceable to such property is subject to forfeiture to the United States.

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Facts

8. The facts and circumstances supporting the seizure and forfeiture ofthe defendant

properties are set forth in the Affidavit of Special Agent Steven J. Leippert, attached

hereto and incorporated herein by reference

9. Tulsa Public Schools (TPS) is an independent school district located in Tulsa,

Oklahoma, within the Northern District of Oklahoma, and conducts business

activities and maintains bank accounts within the Northern District of Oklahoma.

10. The Foundation for Tulsa Schools is a public charity recogntzed by the Internal

Revenue Service (IRS) as a 501(c)(3) organrzatron with a stated mission to build a

better communiry through the support of TPS by providing education resources via

donated funds. The foundation maintains an office at the TPS Education Service

Center, located at3027 S New Haven Ave, Tulsa, OK 74714, and maintains abank

account at Bank of Oklahoma in Tulsa, Oklahoma, within the Northern District of

Oklahoma.

11. In August 2016, Devin D. Fletcher (Fletcher) was hired by TPS as the Chief

Learnrng Officer

72. Fletcher resigned from TPS in or around June of 2022

13. S. Monee Kemp, Shanequa Monee Kemp, is a half-sister of Fletcher.

14. S. Monee Kemp, Shanequa Monee Kemp, maintained Wells Fargo bank

account number 3000 1 88908

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15. From 2018 through May 2021, S. Monee Kemp, also known as Shanequa

Monee Kemp, received approximately $343,125 from TPS.

16. From 2018 through May 2021, S. Monee Kemp, also known as Shanequa

Monee Kemp, received approximately $105,000 from the Foundation for Tulsa

Schools

17. Goldie Fletcher Kemp is the mother of Fletcher.

18. Goldie Fletcher Kemp opened Wells Fargo account number 9298319907 tn

2017.

19. On or about April 8,2022, S. Monee Kemp, also known as Shanequa Monee

Kemp, withdrew 5245,250.64from the Wells Fargo account 9298319907 by cashier's

check number 685400 1 355

20. On or about April 11,2022, S. Monee Kemp, also known as Shanequa Monee

Kemp, deposit the cashier's check number 6854001355 into Wells Fargo account

9298319907.

21. Wells Fargo bank account 5068242055 is held in the name of Devin D.

Fletcher

22. On or about April L2,2022, $144,687.87 was transferred from Wells Fargo

account 9298319907 to Wells Fargo account 5068242055

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Conclusion

WHEREFORE, the United States requests that the Clerk of the Court issue an

arrest warrant in rem pursuant to Supplemental Rule G(3)(b), which the United States

will execute upon the defendant properties pursuant to 28 U.S.C. $ 1355(d) and
Supplemental Rule G(3)(c)

The United States further requests that the defendant properties be forfeited to the

United States for disposal according to law, and the United States be awarded its costs

and disbursements in this action and all other relief to which it is entitled.

Respectfully submitted,

CLINTON J. JOHNSON
LTNITED STATES ATTORNEY

REAGAN V. GER, OBA # 22326

Assistant United States Attorney
110 West Seventh Street, Suite 300
Tulsa, OK74l79
Telephone: (91 8) 382-2700
Email : reagan. reininger@usdoj. gov

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Case 4:23-cv-00218-CVE-SH Document 2 Filed in USDC ND/OK on 05/26/23 Page 6 of 6

VERIFICATION

I, Steven J. Leippert, hereby veriff and declare under penalty of perjury that I am a

Special Agent with the Federal Bureau of Investigation, that I have read the foregoing

Verified Cornplaint In Rem and know the contents thereof, and that the matters contained

in the Verified Complaint are true to rry own knowledge, except those matters herein stated

to be alleged on infonnation and belief and as to those matters I believe thern to be true.

The sources of my knowledge and information and the grounds of my belief are the

official files and records of the United States, information supplied to me by other law

enforcement officers, as well as my investigation of this case, together with others.

I hereby verify and declare under penalty ofperjury that the foregoing is true and correct

to the best of my knowledge and belief.

Executed at Tulsa, Oklahoma , this 3,{ day of May ,2023

.ffi"*/eML
STEVEN J. LEIPPi,ft.T, Special Agent
Federal Bureau of Investigation
Case 4:23-cv-00218-CVE-SH Document 2-1 Filed in USDC ND/OK on 05/26/23 Page 1 of 9

SUPPORTING AFFIDAVIT

STATE OF OKLAHOMA )
) SS

COLINTY OF TULSA )

I, Steven J. Leippert, duly sworn, state the following

1. I am a Special Agent with the Federal Bureau of Investigation (FBI). I have been

employed in this capacity since January of 2002, and am currently assigned to the
Oklahoma City Field Office, Tulsa Resident Agency. During the past 2l years,I have
worked in the Washington DC, Kansas Ciry, Oklahoma City, and Tampa Field Offices,

in which I have conducted a wide variefy of investigations, specifically complex White

Collar Crime investigations

2. Since becoming a Special Agent, I have become familiar with, and have participated in

a wide range of methods of investigation, including but not limited to, use of physical

surveillance, witness interviews, search warrants, arrest warrants, debriefings and operational

use of informants, pen registers, surveillance of undercover transactions, consensually

monitored and recorded conversations and phone calls, and reviews of recorded conversations.

Additionally, I have participated in investigations that utilized the interception of wire and
electronic comtnunications (Title III) and have monitored/minimized nurlerous calls during

these investigations. Through training, education, and experience, I have become familiar with

the manner in which criminal enterprises function and have received numerous hours in

training from various federal, state, and local law enforcement agencies. I also spoke on
Case 4:23-cv-00218-CVE-SH Document 2-1 Filed in USDC ND/OK on 05/26/23 Page 2 of 9

numerous occasions with other experienced investigators concerning the methods and

practices of criminal enterprises and money launderers.

3. As a Special Agent with FBI, I am vested with the authority to investigate violations of

Federal laws including Title 18 of the United States Code. The facts contained in this affidavit

were discovered by me or relayed to me by other Law Enforcement Officers named herein

Propertv Sought for Forfeiture

4. This affidavit is submitted in support of a Civil Complaint for Forfeiture against the

following property:

a. $104,782.77 in funds seized from Wells Fargo bank account9298319907 in

the name of Fletcher Kemp; and

b. $111,323.18 in funds seized from Wells Fargo bank account 5068242055 in

the name of Devin Fletcher.

5. The asset listed above is subject to forfeiture pursuant to 18 U.S.C. $ 981(a)(1)(C).

The information described in these paragraphs below, furnished in support of this affidavit,

is derived from rny own observations and investigation, information, and communications to

me from other agents, law enforcement officers and investigators. This affidavit will show

Devin D. Fletcher (Fletcher), Shanequa Monee Kemp (Kemp), and Goldie Fletcher Kernp

engaged in monetary transactions in property derived from a specified unlawful activity

(wire fraud, in violation of Title 1 8, United States Code, Section 1343) and the proceeds

generated from the below described violations of federal laws were deposited into the

financial accounts described below.

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Facts and Circumstances

6. Tulsa Public Schools (TPS) is an independent school district located in Tulsa,

Oklahoma, within the Northern District of Oklahoma, and conducts business activities and

maintains bank accounts within the Northern District of Oklahoma.

7. The Foundation for Tulsa Schools is a public charity recognized by the Internal

Revenue Service (IRS) as a 501(c)(3) organization with a stated mission to build a better

community through the support of TPS by providing education resources via donated funds.

The foundation maintains an office at the TPS Education Service Center, located at 3027 S

New Haven Ave, Tulsa, OK 74114, and maintains a bank account at Bank of Oklahoma in

Tulsa, Oklahoma, within the Northern District of Oklahoma.

8. Biographical information from the website "finalsite.net" indicates Fletcher graduated

from the University of Texas with a Bachelor of Business Administration and a Master of

Business Administration in 2007. Fletcher was hired in August 2016 by TPS as the Chief

Learning Officer, and he previously served as the executive director at Denver Public Schools

from 2013 -2016. On July 8,2022, TPD Detective R. Shaw interviewed TPS Superintendent

Dr. Deborah Gist who described Fletcher's employment as the "Chief Talent Officer" and that

he was essentially in charge of human resources and recruiting. During his employment with

TPS, Fletcher maintained a residence at 107 N. Detroit Ave, APT 300, Tulsa, Oklahoma and

maintained bank accounts in Tulsa, Oklahoma, within the Northern District of Oklahoma

during the tirne frame of the alleged violations

9. On or about July 2,2022, an attorney representing TPS contacted the Tulsa Police

Department (TPD) indicating they were made aware of possible violations of school policy.

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After further investigation the attorney identified evidence that Fletcher may have

misappropriated funds from TPS. One ofthe alleged methods of misappropriating funds is still

under investigation and involved Fletcher inflating the costs of expenses for which he was

reimbursed via a third-parfy vendor, a violation of school policy. Another of the alleged

methods of rnisappropriating funds involved Fletcher allegedly facilitating andlor approving

payments from TPS to another individual, S. Monee Kemp, pursuant to contracts and purchase

orders submitted to TPS for consulting services with no detailed documentation of provided

servlces

10. A representative for TPS told TPD Detective Shaw the relationship with S. Monee

Kemp began in20l8 and that Kernp was paid $343,125 from TPS through May 2021 and was

paid an additional $105,000 from the Foundation for Tulsa Schools. TPS learned after the

allegations that S. Monee Kemp was Shanequa Monee Kemp, the half-sister of Fletcher who

had shared a past address with Fletcher.

11. On or about on May 22,2020, Kemp forwarded an email to Fletcher, detailing

contractual obligations to be completed by Kemp which included in part:

a Development and consultation of goals, strategic direction, and project plans

o Ongoing Project management.

a Recruitment and interview support.

a Coaching, strategic planning sessions, and support for Talent Management Team

a Virtual and on-site support of Talent Management teams

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Case 4:23-cv-00218-CVE-SH Document 2-1 Filed in USDC ND/OK on 05/26/23 Page 5 of 9

o Liaison with other departments and teams to ensure that Talent Management best

practices are seamlessly integrated throughout the district

12. TPS only identified twelve emails between Kemp and TPS over the four-year span

of the relationship and none of the emails contain any work product or communication

about any services provided by Kemp, and TPS has not been able to document any work

completed by Kemp to support the payments since the allegations. The emails focused on

the payment process and her correct address. Kemp was doing business under the entity

name of Talented 10*'during her interactions with TPS. Upon receipt of an invoice from

Kemp, TPS would initiate an electronic payment to Kemp's bank account which was

maintained at Wells Fargo. Kemp emailed herbank account routing number and account

number to TPS and provided an address as 2323 Misty Ridge Circle, Arlington, Texas.

13. The TPS representative indicated the metadata for one of the invoices dated May

26 , 2020 , for $49 ,7 50, provided by Kemp showed the author was Fletcher. An Augu st 29 ,

2018, email from Fletcher's TPS email account to Kemp stated "Thanks for agreeing to

send an updated invoice. Will sign and process upon receipt."

14. Fletcher resigned from TPS in or around lune 2022.

15. Investigators and agents have reviewed bank account records pertaining to

Fletcher, Kemp, and Goldie Fletcher also known as Goldie Fletcher Kemp as well as

records from TPS and open-source datato conduct the financial investigation.

16. Goldie Fletcher Kemp is the mother of Fletcher, and public source datareported a

common address as of February 2023 at 7214 West 14th Street, Littlefield, Texas. The

apparent purpose of the conspiracy was for the conspirators to unlawfully enrich
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Case 4:23-cv-00218-CVE-SH Document 2-1 Filed in USDC ND/OK on 05/26/23 Page 6 of 9

themselves by misappropriating funds from TPS within the Northern District of

Oklahoma and elsewhere. The financial investigation is ongoing.

17. Investigators were not able to identifii an entity operating as Talented 10tr in the

name of Kemp through open-source data searches such as the Texas Secretary of State

Investigators did not identify any deposits to Kemp's bank accounts from entities similar

to TPS from a review of bank records from October 2017 through June 2022. Kemp had

regular payroll deposits from May 201,8 through May 2022 yua a payroll service

18. Kemp maintained Wel1s Fargo bank account number 3000188908 as the sole

signatory on the account to which deposits were made representing proceeds of wire fraud

based on electronic payments from TPS totaling $Sal ,125 and payments from the

Foundation for Tulsa Schools totaling $105,000 as follows:

o8l08/18 S18,7oo.oo TULSA PUBLIC SCH TPS 180807 57699 TALENTED1OTH

08/27 /1.8 S15,4oo.oo TULSA PUBLIC SCH TPS 180824 57699 TALENTED1OTH
oe/10/1.8 s10,900.00 TULSA PUBLIC SCH TPS 180907 57699 TALENTED1OTH
07/o1./Ie s49,375.00 TULSA PUBLIC SCH TPS 190628 57699 S MONEE KEMP
06/ls/20 S48,750.00 TULSA PUBLIC SCH TPS 200618 57699 S MONEE KEMP
01./08121 $65,ooo.oo TULSA PUBLIC SCH TPS 210107 57699 S MONEE KEMP
01./Lsl21. s25,ooo.oo TULSA PUBLIC SCH TPS 2TO7T4 57699 S MONEE KEMP
02126/2t s40,000.00 TULSA PUBLIC SCH TPS 210225 57699 S MONEE KEMP
04/os/21. S3o,ooo.oo TULSA PUBLIC SCH TPS 2TO4O8 57699 S MONEE KEMP
04/30/21 s3o,ooo.oo TULSA PUBLIC SCH TPS 210429 57699 S MONEE KEMP
06/28/2L s10,000.00 TULSA PUBLIC SCH TPS 210625 57699 S MONEE KEMP
TOTAL s343,125.00

01.131./22 S75,ooo.oo Foundation For Tulsa Schools

03/31./22 S:o,ooo.oo Foundation for Tulsa Schools
TOTAL $1o5,ooo.oo

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19. Kemp also maintained Wells Fargo account 2404681633 as the sole signatory.

Account information dated January 2020 lists her occupation as a teacher at Destiny

Learntng Center. The account was opened with an initial transfer datedlanvary 24,2020,

of $25 followed by a transfer dated January 27, 2020, of $26,000, both from account

3000188908 consisting of proceeds from wire fraud. An additional $280,061.41 consisting

of proceeds from wire fraud were transferred to the account from account 3000188908

through April 8,2022. Cashier's check number 6854001355 was purchased April 8,2022,

for $245,250.641eaving a minimal balance in the account. The check was payable to

Shanequa Kemp.

20. TPD executed a state search wafiant at the residence of Fletcher in Tulsa,

Oklahoma, on July 14, 2022, during which a copy of cashier's check number 6854001355

was recovered by officers.

a. Wells Fargo Bank Account Number 9298319907

21. Goldie Fletcher Kemp opened account number 9298319907 n 2011 as the sole
signatory listing an address in Levelland, Texas. The account was styled as Fletcher Kemp

from 2017 through March 2022. Beginning with a monthly statement dated April 8 , 2022 ,

the account was styled in the name of Fletcher Kemp and Devin Fletcher even though a

signature card was not provided by the bank addtngDevin Fletcher as a signatory.

22. The account had a negative balance as of April 8, 2022. Cashier's check number

68540013 55 payable to Shanequa Kemp for $245,250.64was deposited to the account on

April 17, 2022, representing proceeds from wire fraud. On April 12, 2022, $144,687.87

was transferred from this account to Wells Fargo account number 5068242055 which was

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Case 4:23-cv-00218-CVE-SH Document 2-1 Filed in USDC ND/OK on 05/26/23 Page 8 of 9

held in the name of Fletcher. The remaining balance in this account after the transfer was

$100,833.77, and the account balance was maintained above this amount through March

7, 2023, at which time the ending balance was $105,282.77. A seizure warrant was

executed on April 3, 2023, and $104,782.77 was seized from the account.

b. Wells Fargo Bank Account Number 5068242055

23. Wells Fargo did not produce a signature card for account number 5068242055, but

the monthly account statements are styled Devin D. Fletcher with an address of 107 N.

Detroit Ave, APT 300, Tulsa, Oklahoma. On April 12, 2022, $144,687.87 representing

proceeds from wire fraud was transferred from account number 9298319907 to this

account. The account balance on November 30, 2022, was $110,091.43. A seizure

warrant was executed on April 3, 2023, and $111,328.18 was seized from the account.

24. Kemp met with investigators on April 17, 2023. Kemp stated she did not operate

a business named Talented 10th and did not perform any type of services for TPS or for

the Foundation for Tulsa Schools. Kemp stated that Fletcher indicated that TPS would

be reaching out to her for information and that Fletcher would tell her what to say in

response. Fletcher told Kemp not to respond to emails until he had first been notified.

Kemp provided her bank account information to TPS. Kemp stated that Fletcher

directed her to keep any funds she received in her account. In April 2022 Fletcher and

Goldie Fletcher Kemp showed up at her residence and Fletcher directed Kemp to

obtain a cashiers check from Wells Fargo for all the funds in the account which was

approximately $245,000. The three of them went to the bank and Kemp obtained

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and signed the cashier's check which was deposited to an account in the name of Goldie

Fletcher Kemp

Conclusion

25. Based upon the information set forth herein, as well as training, experience, and

knowledge of this investigation, Affiant has sufficient probable cause to believe Devin D

Fletcher, Shanequa Monee Kemp, and Goldie Fletcher Kemp conspired to violate 18

U.S.C. $$ 1956(aXlXBXi), 1956(h), 1957(a), and 1343, and that this activiry generated

proceeds traceableto, and/or used to facilitate the illegal activity listed in this Affidavit.

bfr,,rr-r/fu-
Steven J. Leippert, Special Agent
Federal Bureau of Investigation

Subscribed and sworn to before rne this ai day of 2023

? 5M
PUBLIC, State of Oklahoma
# 01011541
EXP. o7t11D5
(seal) a
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