IN THE DISTRICT COURT OF TULSA COUNTY

STATE OF OKLAHOMA

STATE OF OKLAHOMA, )

Plaintiff, ) CF 20 18 297 9vs. ) Case No. CF-201$-

McDougal, Jeff DavidW/M, DOB: 1965 )SSN: XXX-XX-9689 )

T I’T cJTDefendant. )

-

JUL 132018COUNTYOFTULSA )—.-—ri

Ii:rin ,SS.STA OF TL3A _NTYSTATE OF OKLAHOMA

AFFIDAVIT OF PROBABLE CAUSE

I, Robert L. Fisher, do attest that the following is true and factual to the best of my knowledge inregards to the following information. I have been employed as an Agent for the State ofOklahoma, Office of Attorney General, for over two years and the majority of those years havebeen spent in the Consumer Protection Unit. Previously, I was employed with the Bethany PoliceDepartment for over nine (9) years with my last assignment being a Field Training Officer inPatrol. I am currently assigned to investigate fraud complaints received by the ConsumerProtection Unit of the State of Oklahoma, Office of Attorney General.

On April 24, 2018, I was assigned to investigate potential criminal wrongdoing involvingviolations of the Oklahoma Solicitation of Charitable Contributions Act. Jeff David McDougaland his professional fundraiser, Cornerstone Oklahoma, are operating in Tulsa, Oklahoma, underthe ownership and management of McDougal. Since August 2017, the Consumer Protection Unithas received numerous complaints against McDougal, stating that he is soliciting donationsthrough Cornerstone Oklahoma on behalf of a veterans charity that has a name similar to anotherveterans charity so as to deceive the public when soliciting contributions. Over the course of thisinvestigation, this agent has reviewed various documents and interviewed several witnessesregarding the allegations against McDougal. The following information was obtained during theinvestigation.

On April 24, 2018, this agent searched filings that McDougal made with the Oklahoma Secretaryof State relating to Cornerstone Oklahoma and found that Cornerstone Oklahoma solicitscontributions for the following three charitable organizations: Broken Arrow Jaycees, AmericanOklahoma Veterans of Green Country and Students Against Drugs Association. In addition toowning Cornerstone Oklahoma, McDougal is also associated with the three charitable

organizations that Cornerstone Oklahoma solicits for. According to the organizations’ charitableorganization registrations that they filed with the Oklahoma Secretary of State, McDougal servesas the President/Director and/or Secretary for American Oklahoma Veterans of Green Country, thePi-esident for Student Against Drugs Association, and the Secretary of Compliance for the BrokenArrow Jaycees Organization.

While reviewing the charitable organization registration for American Oklahoma Veterans ofGreen Country, this agent observed that McDougal executed the document on behalc of AmericanOklahoma Veterans of Green Country as the organization’s Director/President on May 10, 2017.However, elsewhere on the registration McDougal provides that he serves as the Secretary ofAmerican Oklahoma Veterans of Green Country and Charles Grimes serves as the President of theorganization. McDougal also asserts on that registration that American Oklahoma Veterans ofGreen Country will solicit or accept contributions for the purpose of providing track chairs andmany benevolent programs for military veterans.

On April 30, 201$, this agent requested from Arvest Bank, located at P.O. Box 11110, Fort Smith,Arkansas 72917, through a Multi County Grand Jury Subpoena, the bank records/accountinformation belonging to McDougal and his professional fundraiser, Cornerstone Oklahoma. OnMay 11, 2018, this Agent received bank records/account information belonging to AmericanOklahoma Veterans of Green Country in response to that request. After later reviewing the bankrecords/account information for American Oklahoma Veterans of Green Country, this agentobserved that most of the funds in the account were paid to McDougal or another account that wascontrolled by him. This agent did not find that any of the funds were used to assist veterans.

On June 5, 2018, this agent interviewed witness, Charles Grimes at the Oklahoma AttorneyGeneral’s Office, located at 15 West 6th Street, Suite 1000, Tulsa, Oklahoma 74119. Thisinterview was recorded. Grimes resides in the City of Bixby, Oklahoma(l7215 South 92’ EastAvenue), County of Tulsa, Oklahoma. This agent asked Grimes if he knew Jeff McDougal.Grimes stated to this agent that he is married to McDougal’s sister, Vera. This agent asked Grimesif he was familiar with American Oklahoma Veterans of Green Country. Grimes stated to thisagent that he was not aware of the charity. This agent asked Grimes if he served on the board forthe charity, and Grimes stated to this agent that he does not serve on the board of AmericanOklahoma Veterans of Green Country.

On June 26, 2018, this agent interviewed two professional solicitors who were identified asworking for Cornerstone Oklahoma according to the Oklahoma Secretary of State’s website.This agent first interviewed witness, Alana Marie Landon (Berry) via phone at the OklahomaAttorney General Office, located at 15 West 6th Street, Suite 1000, Tulsa, Oklahoma 74119. Theinterview was recorded. Landon (Berry) resides in the City of Owasso, Oklahoma (10925 North172nd East Avenue). This agent explained Landon (Berry) the reason for the interview, inreference to this investigation. This agent asked Alana Marie Landon (Berry) if she knew JeffMcDougal. Landon (Berry) stated to this agent that she was employed by McDougal from Augustof 2017 until October/November 2017 as a telemarketer/customer service for the followingcharity: American Oklahoma Veterans of Green Country. Landon (Berry) stated to this agent thatshe was not aware of the other two charities (Broken Arrow Jaycees, and Students against Drugs

—c)—

and Alcohol) that were run by McDougal. Landon (Berry) stated to this agent that McDougal paidher approximately $8.00 per hour to collect donations for him through telemarketing. This agentasked Landon (Berry) what her job description was when she worked for McDougal. LandontBerrv) stated to this agent that she would call citizens and businesses for donations for militaryveterans. Landon (Berry) stated to this agent that upon contacting the citizens or businesses, shewas rcqciired to verify their correct addresses and ask them whether they would be paying with adebit/credit card or if they would need to send cash for their donations. This Agent asked LandontBerrv) if she was aware of where the money, that was collected, went. Landon (Berry) stated tothis agent that McDougal told her the money collected was used to buy veterans Christmaspresents. This agent asked Landon (Berry) of how they knew who to call for donations. LandontBerrv) stated to this agent that a list of names and addresses are generated from the compctter, andso much of the money collected went towards helping veterans, payroll and the process itself.Landon (Berry) stated to this agent that she was aware of the fact that McDougal previouslyworked for Green Country Veterans Association Charity in the past as well, due to the fact that hetold her that she would be collecting donations for a similar named organization. Landon (Berry)stated to this agent that McDougal called her in January of 2018 and offered her $10.00! hour tocome hack to work for him.

This agent next interviewed witness, Ashley Faye Wooden via phone at the Oklahoma AttorneyGeneral Office, located at 15 West 6th Street, Suite 1000, Tulsa, Oklahoma 74119. The interviewwas recorded. Wooden resides in the City of Tulsa, Oklahoma (8173 East 3l Place South). Thisagent explained to Wooden the reason for the interview in reference to this investigation. Thisagent asked Wooden if she knew Jeff McDougal. Wooden stated to this agent that she wasemployed by McDougal from September of 2017 until end of May! beginning of June2018 as atelemarketer for the following charities: American Oklahoma Veterans of Green Country andBroken Arrow Jaycees. Wooden stated to this agent that these were the only two charities that shecollected donations from for McDougal. Wooden stated to this agent that McDougal would giveher leads of people and businesses that she needed to contact. Wooden stated to this agent that shewould also use an online parrot dialer, and this is where McDougal got the list from of who sheneeded to contact. This agent asked Wooden what her job description was when she worked forMcDougal. Wooden stated to this agent that she would call citizens and businesses for donationsfor military veterans by using a script. Wooden stated to this agent that upon contacting thecitizens or businesses, she was required to verify the correct addresses for them and to ask themwhether they would be paying with a debit!credit card or if they would need to send cash for theirdonations. Wooden stated to this agent that some people were not comfortable with using theirdebit/credit card over the phone, so someone in the organization wocild send them a card, so thattheir information and amount donated, could be put on it. This Agent asked Wooden if she wasaware of where the money, that was collected, went. Wooden stated to this agent that McDougaltold her that the money collected, was used for Veteran Track Chairs.

After speaking with Landon (Berry) and Wooden, this agent interviewed several witnesses thatthis agent believed donated to American Oklahoma Veterans of Green Country based on theorganization’s bank records or a complaint that the Oklahoma Attorney General’s office received.In all, this agent interviewed 18 witnesses. Each witness, whose separate interviews are notedbelow, stated that he or she was contacted by American Oklahoma Veterans of Green Country via

—3—

phone or a direct mailer and asked to donate money to the veterans organization. With theexception of one of the witnesses, all of the interviewed donors also stated that they had given tothe cinrelated veterans charity Green Country Veterans Association in the past and assumed whenthey were contacted by American Oklahoma Veterans of Green Country that the two differentorganizations were the same or related.

On June 25, 2018, this agent interviewed the complainant, Helen Cauble via phone at theOklahoma Attorney General Office, located at 15 West 6th Street, Suite 1000, Tulsa,Oklahoma 74119. The interview was recorded. Cauble resides in the City of Henryetta,Oklahoma (18945 Cedar Road, 74437) and County of Okmulgee, Oklahoma. Caublestated to this agent that she has been donating money twice a year (May/November, lateDecember) to the Green Country Veterans Association (Claremore). Cauble stated to thisagent that she always donates $30-$35 twice year. Cauble stated to this agent that shereceived a call, while at her residence, from the American Oklahoma Veterans of GreenCountry requesting a donation on November 6, 2017. Cauble stated to this agent that sheassumed that the American Oklahoma Veterans of Green Country was the sameorganization as the Green Country Veterans Association (Claremore) that she had beendonating to previously, so she wrote them a check for $30 and sent it to them (AmericanOklahoma Veterans of Green Country).

On June 29, 2018, this agent interviewed the witness, Lisa Presley via phone at theOklahoma Attorney General Office, located at 15 West 6ih Street, Suite 1000, Tulsa,Oklahoma 74119. The interview was recorded. Presley resides in the City of Claremore,Oklahoma (14651 East 430 Road) and County of Rogers. Oklahoma. This agent explainedthe situation to Presley, in reference to this investigation. Presley stated to this agent thatshe has been donating money twice a year to the Green Country Veterans Association(Claremore). Presley stated to this agent that she always donates S30-$50 each time.Presley stated to this agent that she received a call, while at her residence, from theAmerican Oklahoma Veterans of Green Country requesting a donation in December of2017, around Christmas time. Presley stated to this agent that she was told that they(American Oklahoma Veterans of Green Country was doing a Christmas Fundraiser.Presley stated that the representative from American Oklahoma Veterans of Gi-een Countryrequested her credit card information and she refused to give them it over the phone.Presley stated to this agent that she had them send something to her via mail and once itarrived, she believe that she sent a check for approximately $30 or $50, but she was unsure.Presley stated to this agent that she assumed that the American Oklahoma Veterans ofGreen Country was the same organization as the Green Country Veterans Association(Clarernore) that she had been giving to, so that is why she wrote the check and sent it tothem (American Oklahoma Veterans of Green Country).

• On June 29, 2018, this agent interviewed the witness, Kathy Little via phone at theOklahoma Attorney General Office, located at 15 West 6th Street, Suite 1000, Tulsa,Oklahoma 74119. The interview was recorded. Little resides in the City of Claremore,Oklahoma (14651 East 430 Road), County of Rogers, Oklahoma. This agent explained thesituation to Little, in reference to this investigation. Little stated to this agent that on

—4—

November 10, 2017, she received a call, while at her residence, from American OklahomaVeterans of Green Country requesting a donation to help veterans for Christmas at theVeterans Home of Claremore Oklahoma. Little stated to this agent that she assumed thatthe call was Green Country Veterans Association (Claremore), due to the fact that she hasbeen donating to them, twice a year, for severaL years. Little stated to this agent that shealways donates $50, so she sent American Veterans of Green Country a check for $50.Little stated to the agent that she later received a call from Green Country VeteransAssociation (Claremore), and they were requesting a donation. Little stated to this agentthat she advised them that she had already sent a check to their organization. Little stated tothis agent that she always kept her receipts from Green Country Veterans Association(Claremore), and when she realized that the American Oklahoma Veterans of GreenCountry wasn’t the same as Green Country Veterans Association (Claremore). she didn’tsend any more money to them (American Oklahoma Veterans of Green Country).

• On June 29, 2018, this agent interviewed the witness, Kim Gourd via phone at theOklahoma Attorney General Office, located at 15 West 6th Street, Suite 1000, Tulsa,Oklahoma 74119. The interview was recorded. Gourd resides in the City of Owasso,Oklahoma (19740 E 72nd Street North). and County of Tulsa, Oklahoma. This agentexplained the situation to Gourd, in reference to this investigation. Gourd stated to thisagent that she has been donating money in the amount of $50 to the Green CountryVeterans Association in Claremore Oklahoma on the following dates: 12-17-15, 06-14-16,05-22-17, and 11-24-17. Gourd stated to this agent that she always sent the money usingthe electronic funds transfer (EFT) system though her financial institution (Arvest Bank).Gourd stated to this agent that, while at her residence, she received a caLl from theAmerican Oklahoma Veterans of Green Country requesting a donation around the end ofNovember of 2017. Gourd stated to this agent that she was told that they (AmericanOklahoma Veterans of Green Country) were doing a FLindraiser to help the veterans ofgreen country. Gourd stated to this agent that she assumed that the American OklahomaVeterans of Green Country was the same organization as Green Country VeteransAssociation (Claremore) that she had been donating to, so she donated $50 to them usingthe electronic funds transfer (EFT) system though her financial institution (Arvest Bank)on the following dates: 11-21-17, and 02-05-18. Gourd stated to this agent that she thoughtsomething was strange about this, hut she never looked into it.

• On June 29, 2018, this agent interviewed the witness, Cinda Lou Wilson via phone (at theOklahoma Attorney General Office, located at 15 West 6th Street, Suite 1000, Tulsa,Oklahoma 74119. The interview was recorded. Wilson resides in the City of Wagoner,Oklahoma (70211 South 340 Avenue), County of Wagoner, Oklahmna. This agentexplained the situation to Wilson, in reference to this investigation. Wilson stated to thisagent that she has been donating money in the amount of $30 to the Green CountryVeterans Association in Claremore Oklahoma for approximately four to five (4-5) years.Wilson stated to this agent that she always sent the money via mail and that she neverwould pay using he debit/credit card via phone. Wilson stated to this agent that shereceived a call, while at her residence, from the American Oklahoma Veterans of GreenCountry requesting a donation in November of 2017, claiming that the money would go to

—5—

help veterans of Oklahoma. Wilson stated to this agent that she assumed that they(American Oklahoma Veterans of Green Country) were from Green Country VeteransAssociation in Claremore Oklahoma since she had been donating to them.

On July 2, 2018, this agent interviewed the witness, Brent Hopkins via phone at theOklahoma Attorney General Office, located at 15 West 6tti Street, Suite 1000, Tulsa,Oklahoma 74119. The interview was recorded. Hopkins resides in the City of Tulsa,Oklahoma (3470 South Gary Avenue), County of Tulsa, Oklahoma. This agent explainedthe situation to Hopkins, in reference to this investigation. Hopkins stated to this agent thathe has been donating money in the amount of $50 to the Green Country VeteransAssociation in Claremore Oklahoma for approximately ten (10) years. Hopkins stated tothis agent that he received a call, while at his residence, from the American OklahomaVeterans of Green Country requesting a donation in October of 2017. Hopkins stated tothis agent that he was told that they (American Oklahoma Veterans of Green Country)were doing a fundraiser to help the veterans of green country. Hopkins stated to this agentthat he assumed that the American Oklahoma Veterans of Green Country was the sameorganization as Green Country Veterans Association (Claremore), so he donated $50 tothem.

On July 2, 2018, this agent interviewed the witness, Sharon Guterman via phone at theOklahoma Attorney General Office, located at 15 West 6th Street, Suite 1000, Tulsa,Oklahoma 74119. The interview was recorded. Guterman resides in the City of Jenks,Oklahoma (10708 South Holley Street), County of Tulsa, Oklahoma. This agent explainedthe situation to Gciterman, in reference to this investigation. Guterman stated to this agentthat she received a call, while at her residence, from the American Oklahoma Veterans ofGreen Country, requesting a donation in December of 2017, and in February of 2018.Guterman stated to this agent that she donated money in the amount of S50 to the AmericanOklahoma Veterans of Green Country both times. Guterman stated to this agent that shealso received a call from Green Country Veterans Association (Claremore), requesting adonation in November of 2017 and she donated $50 to them. Guterman stated to this agentthat she was told by the American Oklahoma Veterans of Green Country that they weredoing a fundraiser to help local veterans in the Tulsa area. Guterman stated to this agentthat she assumed that both the American Oklahoma Veterans of Green Country and theGreen Country Veterans Association (Claremore) were the same organization.

On July 2, 2018, this agent interviewed the witness, Sally Asberry via phone at theOklahoma Attorney General Office, located at 15 West 6th Street, Suite 1000, Tulsa,Oklahoma 74119. The interview was recorded. Asberry resides in the City of Tulsa,Oklahoma (3112 North Troost Avenue) County of Tulsa, Oklahoma. This agent explainedthe situation to Asberry, in reference to this investigation. Asberry stated to this agent thatshe received a call, while at her residence, from the American Oklahoma Veterans ofGreen Cocintry requesting a donation in July of 2017. Asberry stated to this agent that shedonated money in the amount of $15 (one-time payment) to the American OklahomaVeterans of Green Country. Asberry stated to this agent that her husband is a veteran (U.S.Army) and she always tries to help out veterans as much as she can. Asberry stated to this

—6—

agent that she was told that they (American Oklahoma Veterans of Green Country) wereasking for donations to help the veterans of green country.

On July 5, 2018, this agent interviewed the witness, Barbara Weaver via phone at theOklahoma Attorney General Office, located at 15 West 6th Street, Suite 1000, Tulsa,Oklahoma 74119. The interview was recorded. Weaver resides in the City of Owasso,Oklahoma ($400 North 100th East Avenue), County of Tulsa, Oklahoma. This agentexplained the situation to Weaver, in reference to this investigation. Weaver stated to thisagent that she has been donating money to the Green Country Veterans Association inClaremore Oklahoma in the past years. Weaver stated to this agent that she received acall, while at her residence, from the American Oklahoma Veterans of Green Countryrequesting a donation in October of 2017. Weaver stated to this agent that she was told thatthey (American Oklahoma Veterans of Green Cocintry) were asking for donations to helpthe veterans in Oklahoma. Weaver stated to this agent that she assumed that the AmericanOklahoma Veterans of Green Country was the same organization as Green CountryVeterans Association (Claremore) that she previously donated to, so she donated $325.00to them. Weaver stated to this agent that she received another phone call from someone atGreen Country Veterans Association (Claremore) requesting a donation. Weaver stated tothis agent that she explained to them that she had already sent a $325.00 donation to them.Weaver stated to this agent that she told them that American Oklahoma Veterans of GreenCountry contacted her and that she assumed that they were the same organization as GreenCountry Veterans Association (Claremore) because she had given to them before. Weaverstated that a representative from Oklahoma Veterans of Green Country Associationadvised her that American Oklahoma Veterans of Green Country was not a legitimateorganization and that it was a scam.

On July 6, 2018, this agent interviewed the witness, Joe Lane via phone at the OklahomaAttorney General Office, located at 15 West 6th Street, Suite 1000, Tulsa, Oklahoma74119. The interview was recorded. Lane resides in the City of Big Cabin, Oklahoma(6724 South 4300 Road), County of Craig, Oklahoma. This agent explained the situation toLane, in reference to this investigation. Lane stated to this agent that he has been donatingmoney in the amount of S200-$300 to the Green Country Veterans Association inClaremore Oklahoma for approximately fifteen (15) years. Lane stated to this agent thathe received a call, while at his residence, from the American Oklahoma Veterans of GreenCountry requesting a donation at the end of November or beginning of December of 2017.Lane stated to this agent that he was told that they (American Oklahoma Veterans of GreenCountry) were accepting donations to help veterans. Lane stated to this agent that he toldAmerican Oklahoma Veterans of Green Country that if they sent him something in themail, so that he can make sure they are really helping veterans, he would send them acheck. Joe Lane stated to this agent that he received an invoice in the mail from AmericanOklahoma Veterans of Green Country. Lane stated to this agent that he assumed that theAmerican Oklahoma Veterans of Green Country was the same organization as GreenCountry Veterans Association (Claremore), so he donated S200 (Check #5554) toAmerican Oklahoma Veterans of Green Country because he had donated to them in thepast.

—7—

• On July 5, 2018, this agent interviewed the witness, Clint Baker of Alpha Insulation &Maintenance via phone at the Oklahoma Attorney General Office, located at 15 West 6th

Street, Suite 1000, Tulsa, Oklahoma 74119. The interview was recorded. Baker resides inthe City of Bixby, Oklahoma (18690 South Joplin Avenue), County of Tulsa, Oklahoma.This agent explained the situation to Baker, in reference to this investigation. Baker statedto this agent that he has been donating money in the amount of $300 to $500 per year to theGreen Country Veterans Association in Claremore Oklahoma for approximately five (5) toten (10) years. Baker stated to this agent that he received a call, while at Alpha Insulationand maintenance, from the American Oklahoma Veterans of Green Country requesting adonation in October of 2017. Baker stated to this agent that he was told that they (AmericanOklahoma Veterans of Green Country) were helping veterans with the money received.Baker stated to this agent that he assumed that the American Oklahoma Veterans of GreenCountry was the same organization as Green Country Veterans Association (Claremore)since he had donated to Green Country Veterans Association in the past.

• On July 5, 2018, this agent interviewed the witness, Julie Lacy of Stress Con via phone atthe Oklahoma Attorney General Office, located at 15 West 6th Street, Suite 1000, Tulsa,Oklahoma 74119. The interview was recorded. Lacy resides in the City of Tulsa,Oklahoma (6533 East 1 1th Street), County of Tulsa, Oklahoma. This agent explained thesituation to Lacy, in reference to this investigation. Lacy stated to this agent that she hasbeen donating money one (1) to two (2) times a year, for approximately sixteen (16) years(since 2002), on behalf of Stress Con, in the amount of $300, to the Green CountryVeterans Association in Claremore Oklahoma. Lacy stated to this agent that she received acall, while at Stress Con, from the American Oklahoma Veterans of Green Countryrequesting a donation at the end of January 20 18/ beginning of February of 2018. Lacystated to this agent that she was told that they (American Oklahoma Veterans of GreenCountry) were asking for donation to help the veterans of green country. Lacy stated to thisagent that she assumed that the American Oklahoma Veterans of Green Country was thesame organization as the Green Country Veterans Association (Claremore) that she hadbeen donating to, so she donated $300, just like normal.

• On July 12, 2018, , this agent interviewed the witness, Rick Stuber, owner of StuherArchitecture mc, via phone at the Oklahoma Attorney General Office, located at 15 West6th1 Street, Suite 1000, Tulsa, Oklahoma 74119. The interview was recorded. Stuber residesin the City of Tulsa, Oklahoma (2642 East 21st Street, Suite #195), County of Tulsa,Oklahoma. This agent explained the situation to Stuher, in reference to this investigation.Stuber stated to this agent that he has donated money in the amount of $150 to the GreenCountry Veterans Association in Claremore Oklahoma, sometime in the year of 2017.Stuber stated to this agent that he received a call, while at his business, from the AmericanOklahoma Veterans of Green Country requesting a donation sometime in the year of 2017and 2018 (Unsure of the month). Stuber stated to this agent that he donated $150 toAmerican Oklahoma Veterans of Green Country. Stuber stated to this agent that he wastold that they (American Oklahoma Veterans of Green Country) were using the donationsto help the veterans of Oklahoma with medical expenses, to help purchase “track chairs”,

—8—

and to help pay for organized trips (fishing etc.) for the veterans. Stciber stated to this agentthat he assumed that the American Oklahoma Veterans of Green Country was the sameorganization as Green Country Veterans Association (Claremore).

On July 12, 2018, this agent interviewed the witness, Mike Meece, owner of Clif’sPharmacy via phone at the Oklahoma Attorney General Office, located at 15 West 61h

Street, Suite 1000, Tulsa, Oklahoma 74119. The interview was recorded. Meece resides inthe City of Sallisaw, Oklahoma (505 East Redwood), and County of Sequoyah, Oklahoma.This agent explained the situation to Meece, in reference to this investigation. Meece statedto this agent that he has been donating money in the amount of $150 (Decemeber-2015,June-20 16) to the Green Country Veterans Association in Claremore Oklahoma for a fewyears. Meece stated to this agent that he received a call while, at his pharmacy, from theAmerican Oklahoma Veterans of Green Country requesting a donation, both in Novemberof 2017 and February of 2018. Meece stated to this agent that he donated $150 to them inNovember of 2017 and $100 to them in February of 2018. Meece stated to this agent that hewas told that they (American Oklahoma Veterans of Green Country) were taking donationsto help veterans of Oklahoma. Meece stated to this agent that he assumed that theAmerican Oklahoma Veterans of Green Country was the same organization as GreenCountry Veterans Association (Claremore) that he had given to in the past.

• On July 12, 2018, this agent interviewed the witness. Tony McIntosh, owner of McIntoshFlooring via phone at the Oklahoma Attorney General Office, located at 15 West 6 Street,Suite 1000, Tulsa, Oklahoma 74119. The interview was recorded. McIntosh resides in theCity of Tulsa, Oklahoma (10909-C East 56th Street) County of Tulsa, Oklahoma. Thisagent explained the situation to Mcintosh, in reference to this investigation. McIntoshstated to this agent that he donated money in the past (Decemeber-2014) to the GreenCountry Veterans Association in Claremore Oklahoma. McIntosh stated to this agent thathe received a call, while at McIntosh Flooring, from the American Oklahoma Veterans ofGreen Country) requesting a donation in December of 2017. McIntosh stated to this agentthat he donated $150 to the American Oklahoma Veterans of Green Country. Mcintoshstated to this agent that he assumed that the donations would go to help the veterans ofOklahoma. McIntosh stated to this agent that he assumed that the American OklahomaVeterans of Green Country was the same organization as Green Country VeteransAssociation (Claremore), so he donated to them.

On July 12, 2018, this agent interviewed the witness, Lavonne Blanco of Pathway Servicesvia phone at the Oklahoma Attorney General Office located at 15 West 6th Street, Suite1000, Tulsa, Oklahoma 74119. The interview was recorded. Blanco resides in the City ofBroken Arrow, Oklahoma 74012 (2701 North Hemlock Court), County of TulsaOklahoma. This agent explained the situation to Blanco, in reference to this investigation.Blanco stated to this agent that she has been donating money, on behalf of PathwayServices, to the Green Country Veterans Association in Claremore Oklahoma forapproximately five (5) years. Blanco stated to this agent that she donated to GreenCountry Veterans Association as follows: 11-14-16 $750, 05-03-17 $200, 11-08-17 $500,05-23-18 $300. Blanco stated to this agent that she received a call, while at Pathways

—9—

Services, from the American Oklahoma Veterans of Green Country requesting a donationon May 15, 2017 and she donated $200 to them. Blanco stated to this agent that she wastold that they (American Oklahoma Veterans of Green Country) were collecting donationsto help the veterans. Blanco stated to this agent that she assumed that the AmericanOklahoma Veterans of Green Country was the same organization as Green CountryVeterans Association (Claremore), so that’s why she donated to them the first time.

On July 16, 2018, at approximately 12:22 pm, this agent interviewed the witness, SarahAbles of Heritage Flooring via phone at the Oklahoma Attorney General Office, located at15 West 6th Street, Suite 1000, Tulsa, Oklahoma 74119. The interview was recorded.Sarah Ables resides in the City of Pryor, Oklahoma (31 South Adair St), County of Mayes,Oklahoma. This agent explained the situation to Ables, in reference to this investigation.Ables stated to this agent that she has been donating money, on the behalf of Heritageflooring in the amount to the Green Country Veterans Association in ClaremoreOklahoma one to two times a year for approximately ten (10) years. Ables stated to thisagent that she has donated to Green Country Veterans Association the following: April2018 $150, May 2017 $500, May 2016 $750, May 2015 $300, and December 2015 $600.Ables stated to this agent that she received a call from the American Oklahoma Veterans ofGreen Country (2464 South Sheridan, Tulsa Oklahoma) requesting a donation in July of2014. Ables stated to this agent that she sent American Oklahoma Veterans of GreenCountry a check for $250. Ables stated to this agent that she was told that they (AmericanOklahoma Veterans of Green Country) were accepting donations to help the veterans at theClaremore senior citizens place for veterans. Ables stated to this agent that she assumedthat the American Oklahoma Veterans of Green Country was the same organization asGreen Country Veterans Association (Claremore).

On July 16, 2018, at approximately 12:40 pm, this agent interviewed the witness, GeorgeHighland of Achievers Marketing Group Inc. via phone at the Oklahoma Attorney GeneralOffice, located at 15 West 6th Street, Suite 1000, Tulsa, Oklahoma 74119. The interviewwas recorded. George Highland resides in the City of Bixby, Oklahoma 74008 (8 EastDawes Aye), County of Tulsa, Oklahoma. This agent explained the situation to Highland,in reference to this investigation. Highland stated to this agent that he has been donatingmoney, on behalf of Achievers Marketing Group, in the amount of $50-s 100 to the GreenCountry Veterans Association in Claremore Oklahoma for approximately five (5) years.Highland stated to this agent that he received a call from the American Oklahoma Veteransof Green Country (2464 South Sheridan, Tulsa Oklahoma) requesting a donation in Marchof 2018. Highland stated to this agent that he donated $150 to American OklahomaVeterans of Green Country on March 20, 2018.Highland stated to this agent that heassumed that the American Oklahoma Veterans of Green Country was the sameorganization as Green Country Veterans Association (Claremore), so he donated $150 tothem. Highland stated to this agent that apparently American Oklahoma Veterans of GreenCountry convinced him to donate $150 considering that he had always donated $50-$ 100to Green Country Veterans Association. Highland stated to this agent that he was caughtoff guard when he donated to American Oklahoma Veterans of Green Country.

—10—

After completing the above interviews and reviewing relevant documents, your affiant believesprobable cause exists to show that the Defendant, McDougal committed eighteen (1$) felonycounts of obtaining signature or property for charitable purposes by false pretenses, Title 21-1543;one U) felony count of knowingly making any false material statement or representation on aregistration application, Title ls-552A4A.1; and one (1) felony count of knowingly using, inconnection with solicitation of contributions for the purpose of deceiving the public, a namesimilar to other charitable organizations, professional fundraiser, professional solicitor orgovernment agency or political subdivision Title 18-552. 14A.3.

The undersigned asks this Court to issue a finding of fact that there is probable cause to believe theabove-name Defendant committed these crimes in the City of Tulsa, Tulsa County, Oklahoma, andissue a warrant for the arrest of Jeff David McDougal.

Further affiant sayeth not.

Oklahoma Office of the Attorney General

By:__________Robert L. Fisher, AgentConsumer Protection Unit

SUBSCRIBED AND SWORN to before me this

Commission Expires:Commission Number:ISc(

4”otary Public]

J1uiUIIk,,,4

% o,

—11—

FINDING OF PROBABLE CAUSE

On this

___

day of

_____________,

2018, the above-styled and numbered causecame before me, the undersigned Judge of thDistrict Court of Tulsa County, Oklahoma, upon theAffidavit of Robert L. Fisher, Agent with the Consumer Protection Unit of State of OklahomaOffice of Attorney General, requesting that a warrant of arrest be issued for the within namedDefendant, that he might be arrested and held to answer for the said offenses. Based upon the saidAffidavit, I am satisfied and do hereby find that the said offenses have been committed, and thatthere is probable cause to believe the within named Defendant has committed these said offenses,and that a warrant of arrest should be issued.

Dated this

___

day of, 2018.

ftheDistriourt

—12—