Federal Criminal Complaint and Civil Rights Violation Report

18 U.S.C. §§ 241, 242 — Civil Rights Conspiracy and Deprivation Under Color of Law

18 U.S.C. §§ 1343, 1349 — Wire Fraud and Conspiracy

18 U.S.C. §§ 1512, 1519 — Obstruction and Evidence Fabrication

18 U.S.C. § 1028 — Identity Theft

18 U.S.C. § 1001 — False Statements

42 U.S.C. §§ 3604, 3605 — Fair Housing Act

42 U.S.C. § 12182 — Americans with Disabilities Act

A. About the Complainant

Warrant Officer One Aaron K. Shugard (Retired), U.S. Army, is a 100% service-connected disabled combat veteran. He served the United States in uniform and was honorably discharged. He is currently homeless as a direct result of the crimes documented in this complaint. His 13-year-old daughter resides in the custody of his ex-wife pursuant to a default judgment in which fabricated government records—specifically, a false mental health diagnosis entered into the Lawton Police Department's CAD system by Lt. Steven Schulte on June 4, 2024, without medical evaluation or professional consultation—were available to the court. The origin and fraudulent nature of that record is documented in this complaint.

B. What This Complaint Documents

This complaint presents documented evidence of a coordinated conspiracy involving state law enforcement officials, a former VA employee, and a private insurance company to deprive a disabled combat veteran of his civil rights, suppress criminal reporting, fabricate official government records, commit insurance fraud, and obstruct justice. The conspiracy began on May 30, 2024, when Jessica Carter, the City of Lawton's Director of Emergency Response and wife of Assistant Chief Eric Carter, texted precise instructions to Theleka Williams scripting a fraudulent 911 call to provide cover for an unlawful entry into WO1 Shugard's home A-1 . What followed was a pattern of residential burglaries, evidence suppression, fabricated mental health records, a seven-month obstruction of formal police reporting, and an insurance claim denial built on provably false statements submitted to a state regulator.

C. Key Parties Identified in This Complaint

State Actors (Lawton Police Department)

Primary Suspect

Theleka Williams — APRN-CNP (nurse practitioner) with prescribing authority. Former VA employee at Reynolds Army Community Hospital. Positively identified on surveillance video exiting the complainant's residence during the burglary A-158 . Co-parent of Captain Henderson's child. Author of self-incriminating letters containing verified insider knowledge of the crimes F-1 .

American National Insurance Company (ANI)

ANI held the homeowner's policy on WO1 Shugard's property (Claim #35-T-4TF849). ANI's Special Investigations Unit adopted, relied upon, and amplified the same fabricated evidence created by LPD officers to deny the complainant's legitimate insurance claim. ANI employees made provably false statements to the Oklahoma Insurance Department, produced a backdated letter referencing an email domain that did not exist on the purported date of authorship, and—after executive management reviewed the full scope of the fraud evidence—chose to maintain the fraudulent position rather than investigate or correct it.

D. Why Multiple Federal Agencies Receive This Complaint Simultaneously

This complaint is submitted simultaneously to the Federal Bureau of Investigation (FBI Dallas Field Office), the U.S. Department of Justice Civil Rights Division, the VA Office of Inspector General, and the Department of Housing and Urban Development Office of Fair Housing. Each agency receives the identical, complete evidentiary record.

The alleged conduct spans overlapping federal jurisdictions: state actors conspiring with a private entity to deprive civil rights (DOJ Civil Rights Division, FBI); a former VA employee targeting a veteran and submitting forged documents to VA agencies (VA OIG); housing-related insurance discrimination based on fabricated disability (HUD Fair Housing); and interstate wire fraud by a private insurer (FBI, U.S. Attorney). No single agency has sole jurisdiction over the totality of the conduct.

E. Exhaustion of State and Local Remedies

Before seeking federal intervention, the complainant exhausted every reasonably available state and local remedy. Each attempt was either ignored, inadequate, or structurally compromised by the same conflicts of interest documented in this complaint:

Federal jurisdiction is not a preference. It is the only remaining pathway.

F. Selection of FBI Dallas Field Office

This complaint is directed to the FBI Dallas Field Office rather than the Oklahoma City Field Office. The documented relationships between Lawton Police Department command staff and local institutions, combined with the demonstrated pattern of information leaks, create a reasonable concern that routing this complaint through Oklahoma-based federal personnel could compromise the investigation before it begins. The complainant currently resides in Lubbock, Texas, which falls within the FBI Dallas Field Office's area of responsibility.

G. How to Read This Document

This complaint is structured to allow multiple reading approaches. Investigators who need the full narrative should read sequentially from Part 0 through Part XI. Those seeking specific evidentiary analysis can navigate directly to the relevant Part using the sidebar navigation.

Certain critical evidence pieces are cited across multiple categories to maintain organizational integrity. The intentional duplication ensures that the complete evidentiary foundation for a specific claim is contained within its respective section.

H. Complainant's Standard of Evidence

The complainant has constructed this complaint so that every material claim can be independently verified by the receiving investigators without reliance on the complainant's testimony. Where a claim rests on documentary evidence, the exhibit is cited. Where a claim rests on inference, the underlying documented facts and the logical basis for the inference are stated explicitly. The complainant has deliberately separated proven facts from investigative recommendations, and has identified unverified claims as such. The complainant does not ask any receiving agency to take his word. He asks that they examine the evidence and reach their own conclusions.

A. The First 72 Hours — When Everything Could Have Been Stopped

On the night of May 30, 2024, Theleka Williams executed a script. Hours earlier, Jessica Carter, the City of Lawton's Director of Emergency Response and wife of Assistant Chief Eric Carter, texted Williams precise instructions: call the dispatch number 30 minutes before arrival, request a "standby," claim you're "watching" the house because there were "people in there the night before" A-1 .

Williams followed the script exactly. At 22:20 PM, she called dispatch and recited Carter's words almost verbatim A-150 . Three LPD units responded—A2, A3, and E8—and cleared the scene as "Secured" at 22:48 PM. No one questioned why a woman with no keys was "watching" a house she didn't own. No one asked for proof of authorization. The pretext worked.

What the officers missed: Security cameras had already captured two unidentified individuals loitering on the back porch at 21:40 PM A-2 , forty minutes before Williams made her scripted call. About an hour later at 23:40, a camera caught 3–4 people entering through the garage A-156 . One of them was positively identified as Theleka Williams A-158 .

B. The Burglary Reports That Weren't — Dispatch Classified Correctly; Investigation Failed

June 1, 2024, 03:35 AM (Incident #2024-00036237) Exhibit A-151 : Warrant Officer Shugard, monitoring his security system away from his home, called LPD to report active intruders. Dispatch classified this call correctly: RESIDENTIAL BURGLARY (Code 110D02, Priority 1-Delta, In Progress). Officers Noel, Harrelson, and Bordelon responded. They cleared the scene at 04:04 AM—24 minutes after the call—stating all windows were locked and no signs of forced entry were found. They did not treat the residence as a crime scene, did not request the video evidence, did not generate a police report, and provided no guidance on how to submit evidence.

June 1, 2024, 06:26 AM (Incident #2024-00036251) Exhibit A-152 : Less than three hours later, Shugard called again. Dispatch again classified correctly: RESIDENTIAL BURGLARY (Code 110D02, Priority 1-Delta, In Progress). This is the second independent dispatch classification of burglary at the same address in under three hours. Officers conducted only a superficial external check. They entered a "law/medical narrative" into the call log—the first pivot to recharacterize a residential burglary as a mental health issue. No report was generated. No evidence was collected.

C. Admission — June 3, 2024

Exhibit A-153 At 01:05 AM on June 3, 2024, Theleka Williams called LPD dispatch to request a welfare check on Aaron Shugard. The dispatcher recorded two critical admissions directly from Williams:

"No key or remote access is available at present time."

The resident "does not have any physical/medical/mental conditions."

These statements were made by Williams herself, a licensed APRN-CNP who had previously provided medical care to Shugard. This June 3rd CAD log became the "Truth Baseline." Williams admitted she had no legal right to enter the home. Williams confirmed Shugard had no mental illness. Both facts would be reversed within 37 hours.

D. The June 4th Confrontation — Where the Cover-Up Became Official

Exhibit A-154 Warrant Officer Shugard returned to his residence on June 4, 2024, and discovered extensive damage and called police. Before police could arrive, Williams pulled into his driveway and forced her way inside. When officers arrived, Shugard explicitly informed them he had video footage of the residential burglary and wanted to give it to the officer.

At 14:51 PM, Lieutenant Steven Schulte manually added an entry to the CAD system: "male caller has PTSD and mental health issues"—specifically citing schizophrenia. No medical evaluation was conducted. No medical professional was consulted. In 37 hours and 46 minutes, Aaron Shugard's official status flipped from "does not have any mental conditions" to "mentally unstable." The only thing that happened between those two entries was that Shugard tried to report a crime with video evidence.

E. The Five Points of Proof — All Ignored

Every single piece of this evidence was either refused, ignored, or suppressed.

F. July 2024 — The Escalation, the Government Notification Chain, and the Information Leak

July 3, 2024 Exhibit E-1 : Shugard sent a formal email to Robert Whittington with Mark Mason copied, reporting the break-in, stating that video evidence showed individuals breaking in, that police had been dismissive, and offering to submit security footage. Within hours of this email being sent, Shugard received harassing calls from Williams—a sequence consistent with an information leak from within the notification chain.

July 5, 2024 (Incident #2024-00045347) Exhibit A-155 : Williams approached the residence again. This incident is significant because it documents the consequences of police intimidation. Shugard did not call 911 himself. A third party called, stating: "Her cousin is scared to call PD due to this female's threats to him." Dispatch again classified correctly: RESIDENTIAL BURGLARY. This is the fourth dispatch classification of residential burglary at this address. Four classifications, zero investigations.

G. Detective Adamson — The Courier

The Obstruction and Rejection Loop (June 2024 – January 2025)

For approximately seven months, WO1 Shugard was repeatedly denied the right to file a formal criminal report. Despite providing video evidence of a felony burglary, patrol officers refused to generate a report. When Shugard attempted to bypass the in-person obstruction by filing online reports through LPD's Coplogic system, both submissions were systematically rejected Exhibits C-1 through C-7 .

March 2025 — The Courier Act: Adamson's only visit to Shugard's residence was not to investigate. It was to deliver paperwork from the suspect. Among the documents Adamson hand-delivered was a response from the Oklahoma Bar Association to Williams F-3 . The investigation was functioning as Williams' mail service.

H. The Protection Mechanism Exposed

The Circular Logic of Obstruction: Officers refuse to collect video evidence → No evidence = no formal report → No report = DA declines due to "insufficient evidence" → Chief Smith cites DA declination as validation → Officers who created the evidence void use that void to justify their refusal. This is not incompetence. This is architecture.

I. Why Federal Jurisdiction Is the Only Option

The local system did not fail Aaron Shugard. The local system worked exactly as designed—to protect a suspect with command-level connections. Every checkpoint that should have stopped this instead facilitated it. Federal jurisdiction is not a choice. It is a mathematical necessity.

A. Death of Chief James T. Smith — Loss of Key Witness

Chief James T. Smith of the Lawton Police Department died on January 22, 2026. His cause of death has not been publicly disclosed. Chief Smith was a critical witness: he signed the false exoneration letter dated February 27, 2025, containing provable false statements. His death means these false statements can no longer be challenged through his testimony. However, the claims against all surviving defendants stand on independent, documented evidence.

The "Two Times" Claim vs. Documented Record

Chief Smith's exoneration letter stated: "There was a response to your residence two times around June of 2024." The CAD system documents at least seven incidents:

B. Victim Safety and Status

Complainant WO1 Aaron K. Shugard (Ret.) is currently homeless as a direct result of the crimes detailed in this complaint. Primary suspect Theleka Williams remains at large despite proven forgeries, burglary, and admitted poisoning. Williams is a former VA employee with APRN-CNP credentials and prescribing authority. LPD cannot provide protection—they are a threat.

C. Evidence Preservation Emergency

Evidence destruction is ongoing. Body camera footage requests have returned "no responsive records" despite multiple officers responding to incidents B-6 . Eric Carter (Assistant Chief) controls the Records and Evidence Division.

Restricted Law/Medical Narrative Pattern

A. The Command Relationships That Make Local Investigation Impossible

Relationship #1: The Carters (Married) — Jessica Carter scripted the May 30 crime. Eric Carter controls Records Division, BWC footage, evidence, and the online reporting system.

Relationship #2: Williams and Henderson (Co-Parents) — Theleka Williams shares a child with LPD Captain Henderson. They are NOT married, meaning no spousal privilege applies—both can be compelled to testify.

B. The Mental Health Fabrication Chain

The following twelve key findings are proven by the defendants' own records—not the victim's allegations.

The critical distinction in this case is not whether a crime occurred. The LPD's own dispatch classification system determined that a crime occurred on June 1, 2024. Twice. The distinction is between what the 911 system recognized as criminal and what the investigative system refused to treat as criminal. This gap is itself evidence of organizational misconduct.

A. What Standard Investigative Protocol Required

For a RESIDENTIAL BURGLARY call with live camera feed and real-time suspect descriptions, standard protocol requires: immediate scene entry to secure premises; body-camera activation; evidence collection protocol initiation; contact with homeowner for evidence; burglary report generation; chain-of-custody documentation; follow-up contact within 24 hours; and supervisory review within 72 hours.

B. What Actually Happened

C. Why This Gap Cannot Be Explained by Incompetence

This is not a case of unsolved crimes. It is a case of uninvestigated crimes. The dispatch system functioned properly four times. Supervisors and officers made deliberate choices not to investigate. An organization cannot claim insufficient evidence for a crime its own system officially classified as burglary.

The designation "civil matter" is not a legal conclusion. It is an administrative deflection. Criminal conduct does not have a civil-dispute exemption.

A. The Actual Legal Standard

C. The Coplogic Rejection Chain Exhibits C-1 through C-7

Over a 70-day period (September 21 – November 30, 2024), WO1 Shugard made two formal attempts to file online police reports. Both were rejected through contradictory reasoning that created a closed loop:

First Report (T24000203, September 21, 2024): Filed with 182 individually itemized property entries including military uniforms, electronics, a Suzuki GSX250R motorcycle ($4,700), HVAC damages ($24,000), and electrical damages ($15,000). Rejected September 23: "burglary of residence" "can not be completed on line."

Second Report (T24000430, November 11, 2024): Modified approach referencing list already provided to Detective Adamson. Rejected November 30: "there is already an original report."

109 days of active reporting effort (September 21 through January 7) produced a four-sentence case report with a blank evidence section. The 182-item property inventory was never incorporated. The forgeries reported on January 3, 2025 were omitted entirely.

D. From Deflection to Architecture

The "civil matter" label was not a classification error corrected over time. It was the first layer of a multi-layered obstruction architecture. Each barrier reinforced the others: the label avoided creating a report; the absence of a report justified the DA's declination; the declination justified Chief Smith's exoneration letter; and the Coplogic rejections ensured the victim's own attempts to create a record were systematically blocked. This is not a failure of classification. It is architecture.

Two entirely separate entities—the Lawton Police Department (state actors) and American National Insurance Company (private entity)—independently relied on the same falsified evidence to reach the same result: denial of the victim's rights. This convergence demonstrates cooperation, shared reliance, and mutual reinforcement.

A–C. Shared Fabrications

D. The Chief Smith–Cathcart Timing: Direct Coordination

On February 27, 2025, ANI attorney Bill Cathcart had an EUO scheduled for 10:00 AM H-1 . At 10:20 AM—20 minutes later—Chief Smith sent his exoneration email B-8 . The alignment demonstrates coordination between a state law enforcement agency and a private insurance company's legal representative.

F. Government Notification Chain

Between July 3 and late 2024, WO1 Shugard escalated his complaint through four distinct government touchpoints spanning three separate government functions. None produced a criminal investigation. Four government touchpoints across four months—combined with zero investigative action—constitutes evidence of deliberate institutional choice rather than administrative error.

A. Chief Smith's Exoneration Email (February 27, 2025, 10:20 AM)

Contradiction #1 — "Conflicting Stories": Chief Smith claimed no report was generated due to "conflicting stories." Williams herself admitted "No key or remote access" 37 hours before the June 4 incident. There was no conflict.

Contradiction #2 — "Two Times": Chief Smith claimed two responses. CAD records show at least six incidents.

Contradiction #3 — "No Evidence of Cover Up": Chief Smith ignored the mental health fabrication, officers' refusal of video evidence, the 7-month obstruction, BWC returning "no responsive records," and Eric Carter's wife's involvement.

Contradiction #4 — Circular Logic: Officers refused evidence → DA declined for "insufficient evidence" → Chief cites DA declination → Officers who created the void use it to justify their refusal.

Contradiction #5 — Wrong Dates: Claims first online report was in August. The first was September.

B. Broyles' OID Letter (December 13, 2024)

False Statement #1: "The nurse advised the police that Mr. Shugard had mental health issues." The CAD logs prove the opposite.

False Statement #2: Dismissed video evidence using the fabricated psychiatric diagnosis.

False Statement #3: Characterized damage as "hard living" despite admitting ANI knew 4 people broke in and identified Williams.

Critical Omission: Broyles acknowledged the adjuster could not determine whether damage was vandalism or construction because areas were never fully inspected. ANI admitted incomplete inspection yet used the incomplete results to deny the claim.

C. Sisco's OID Letter (December 30, 2025)

False Statement #1: Sisco claimed a police report was "issued on July 30, 2024" and "no knowledge" of the January 7, 2025 report. Both false—CAD logs were printed on July 30; no formal report existed until January 7, 2025.

False Statement #2 — "Misprinted Date": A "misprint" does not explain how the August 22 letter references "several emails over the past month" from a non-existent domain.

D. The Broyles-Smithson Backdating Trap

Scenario A: If the August 22, 2024 date is accurate, the letter references a domain that didn't exist. THIS PROVES FABRICATION.

Scenario B: If the "misprint" is true (letter written December 2025), then SIU was NOT involved in August 2024, and ANI made material misrepresentations to OID. THIS PROVES FRAUD.

E. CAD Log Comparison (June 3 vs June 4, 2024)

Time elapsed: 37 hours, 46 minutes. Medical evaluation conducted: ZERO.

F. Jessica Carter Text Messages (May 30, 2024) A-1

09:59 AM — Carter to Williams: "Just call 581-3272 about 30 minutes before you head over in case officers are tied up. Let the dispatcher know you would like a standby for a house you are watching because there were people in there the night before."

Williams' response: "Ok.. just don't want 'him' all in the biz"

Carter's offer: "Gotcha. I can give the supervisor a heads up if you want."

At 22:20 PM, Williams called dispatch and used the exact script A-150 . A city official used her knowledge of emergency dispatch systems to script a fraudulent 911 call.

G. Cathcart C&D Letter (January 14, 2026) — Executive Ratification G-3

Upper management reviewed: the backdating proof, CAD log contradictions, video evidence, civil rights analysis, evidence of child endangerment, and all fraud allegations. They did NOT investigate the fraud, did NOT correct false statements to OID, did NOT remedy the claim denial. Instead: told the victim to stop contacting executives and referred the matter back to SIU—the unit that produced the backdated letter. When corporate executives have knowledge of subordinates' fraud and choose to maintain the fraudulent position, the entire corporation becomes liable.

H. Williams' Letter — Insider Knowledge and Fabricated Motive

The Oklahoma Insurance Department was engaged twice. Both times, David Kalbert served as the assigned reviewer. Both times, ANI's responses contained provably false statements. Both times, Kalbert accepted those responses without scrutiny, effectively functioning as a mail-forwarding service rather than a regulatory body.

The Contradictions Kalbert Ignored

Broyles (Dec 2024) claimed the nurse told police about Shugard's mental health. The CAD logs prove the nurse said the opposite. Sisco (Dec 2025) claimed a police report was issued July 30, 2024. No formal report existed until January 7, 2025. The Smithson letter referenced a domain registered November 2025 but was dated August 2024.

The Cosigning Scheme

Lt. Schulte fabricated a mental health diagnosis. Broyles then told OID that "the nurse" reported it—swapping the source to give it clinical credibility. Broyles further stated that "the police dismissed the vandalism"—but the police "dismissal" was itself based on the fabricated diagnosis. ANI did not passively receive bad information from LPD. They laundered it: misattributed who said what to give the fabrication medical authority, then pointed to the police "dismissal" as independent validation. This is a coordinated scheme to use a perceived disability to deny housing-related insurance services.

Category A — The Crime

Category B — Police Records

Category C — Coplogic Report Rejection Chain

Category D — Insurance Fraud

Category E — Government Notification / Escalation

Category F — Forgery Evidence

Category G — Executive Ratification

Category H — Additional Evidence

To the Federal Bureau of Investigation

Investigation into potential violations of 18 U.S.C. §§ 241, 242 involving named LPD personnel. Investigation into wire fraud conspiracy between LPD officials and ANI. Preservation of all electronic communications between named defendants. Interviews of all named officers regarding disposition decisions on dispatch-classified burglary calls. ANI's email transmission logs for the August 22, 2024 letter. Chief Smith's phone records and communications. Investigation into the systematic rejection of formal crime reports documented in Exhibits C-1 through C-7.

To the U.S. Attorney's Office

Review of evidence for potential federal prosecution. Subpoenas for ANI internal communications regarding Claim #35-T-4TF849. Subpoena of ANI's claim diary entries showing SIU referral date and reason code. Subpoena of document-generation metadata for the Smithson letter.

To the U.S. Department of Justice — Civil Rights Division

Investigation into potential violations of 42 U.S.C. § 14141 based on the documented pattern of systematic obstruction of crime reporting by LPD, including four dispatch-classified burglary calls producing zero investigations, fabrication of a mental health record, seven-month obstruction, and the 70-day Coplogic rejection chain. Coordination with FBI's investigation to establish both individual criminal liability and institutional pattern or practice.

To the VA Office of Inspector General

Investigation into former VA employee Theleka Williams. Determination of whether Williams accessed victim's VA medical records without authorization. Investigation into Williams' submission of forged documents to VA (ORMDI). Coordination with FBI regarding criminal charges.

To HUD Office of Fair Housing

Fair Housing Act investigation into ANI's denial of housing-related insurance services based on perceived disability. Investigation into discrimination based on fabricated mental health diagnosis. Consideration of pattern-or-practice investigation of ANI's claims handling.

Request for Expedited Intake Processing

Based on three documented exigencies: (1) Active evidence destruction risk — Eric Carter controls Records Division; BWC requests return "no responsive records"; Chief Smith's records at risk of routine destruction. (2) Ongoing threat from named defendants — Williams remains at large with prescribing authority and demonstrated pattern of identity theft. (3) Federal defendants on notice — ANI executive management formally notified of fraud evidence and chose to maintain position.

Assertion of Crime Victim Rights (18 U.S.C. § 3771)

Right to Reasonable Protection (§ 3771(a)(1)): The complainant requests procedural protection — that the opening of a federal investigation be communicated to LPD and ANI, establishing that contact with or retaliation against the complainant constitutes potential obstruction.

Right to Proceedings Free from Unreasonable Delay (§ 3771(a)(7)): Evidence preservation concerns and the death of a key witness establish that delay directly prejudices the evidentiary record.

Right to Information and Notification (§ 3771(a)(2)): Upon case initiation, registration in the Victim Notification System (VNS).