Jerry D. Criner - Page 7

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          against condominiums allegedly owned by petitioner in New Jersey            
          and were still pending and that a request for a nominee NFTL with           
          respect to the Claremore property had not been completed.                   
               On December 11, 2001, Mr. Baustert submitted a memorandum              
          requesting authorization to file a nominee NFTL against the                 
          Claremore property to the Office of District Counsel in Oklahoma            
          City, Oklahoma (Counsel).  The memorandum request was sent                  
          through Dale Spannagel, group manager.  In the memorandum, Mr.              
          Baustert outlined the facts that formed the basis for his belief            
          that petitioner was the equitable owner of the Claremore                    
          property:  (1) No mortgage was recorded when the Claremore                  
          property was ostensibly purchased by Alice Criner, indicating a             
          cash purchase; (2) petitioner had a long history of placing real            
          and personal property in nominee names of his family members and            
          the Wesley Brown Society; (3) on April 26, 1990, petitioner’s ex-           
          wife recorded a quitclaim deed divesting herself of any interest            
          that she had in the Claremore property; (4) Rogers County                   
          Treasurer’s records indicate that petitioner, his wife, and their           
          children have paid the ad valorem property taxes on the Claremore           
          property; and (5) petitioner claimed to have “an arrangement”               
          with his siblings to watch after the home, but he did not produce           
          any affidavits from them when asked to do so by the revenue                 
          officer.  The memorandum also noted that the Claremore property             
          was listed for sale with Peck Realty for an asking price of                 






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