1 DISTRICT COURT, CITY AND COUNTY OF DENVER, COLORADO 1437 Bannock Street Denver, CO 80202 THE PEOPLE OF THE STATE OF COLORADO, v. DANIEL GALVAN ANTHONY HARV EY STUART KNOWLES LEOBARDO LOYA ABDON LOYA-SA NCHEZ ALEXANDER O RAM FRANCISCO VALENCIA JOSEPH VITTUM DEREK DURICA MATTHEW BEKKERUS BRIAN BUTLER ANTHONY EMBRY CARL HAYES ANDRE ISLER GERALD LAMASTER GARY LIHUDIS MICHAEL MCCAIN BERNARDINO MENDOZA MARIA MORENO RONALD MUNGUIA-MARTIN JEROME NELSON KAMAL PATTERSON TONY ROMERO QUENTIN WALLACE ADRIAN HE RNANDEZ ALEJANDRO URIB E ALAN JOHNSON JIMMIE JOE MONTGOMERY KENNETH WEST HORACIO BUGARIN MARK FRALEIGH MITCHELL MORRIS SHAWN BLEA Defendants. COURT USE ONLY
Transcript
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
JOHN W. SUTHERS, Attorney GeneralANNEMARIE L. BRAUN*Senior Assistant Attorney General1525 Sherman Street, 7th FloorDenver, CO 80203
303-866-5738Registration Number: 39877*Counsel of Record
Case No.:
GJ Case No.: 11CR01
Ctrm: 209
COLORADO STATE GRAND JURY SECOND SUPERSEDING INDICTMENT
Of the 2011-2012 term of the Denver District Court in the year 2011; the2011-2012 Colorado State Grand Jurors, chosen, selected and sworn in the nameand by the authority of the People of the State of Colorado, upon their oaths, presentthe following:
COUNT ONE:37284
COCCA – Pattern of Racketeering – Participation in an Enterprise,§ 18-17-104(3), C.R.S., (F2)
Daniel Galvan, Anthony Harvey,Stuart Knowles, Leobardo Loya, Abdon Loya-Sanchez, Alexander Oram, Francisco Valencia,Joseph Vittum , Derek Durica, Alan Johnson,Jimmie Joe Montgomery, Kenneth West, andHoracio Bugarin
COUNT TWO:37284
COCCA – Conspiracy,§ 18-17-104(4), C.R.S., (F2)
Daniel Galvan, Anthony Harvey,Stuart Knowles, Leobardo Loya, Abdon Loya-Sanchez, Alexander Oram, Francisco Valencia,Joseph Vittum, Derek Durica, Alan Johnson,Jimmie Joe Montgomery, Kenneth West, andHoracio Bugarin
COUNT THREE:82021
Distribution of a Schedule II ControlledSubstance,§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3)
Francisco Valencia
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
VIOLATION OF THE COLORADO ORGANIZED CRIME CONTROL ACT —PATTERN OF RACKETEERING—PARTICIPATION IN AN ENTERPRISE, C.R.S.18-17-104(3) and 18-17-105 (F2)
COUNT ONE
Between the dates of January 1, 2009 and September 29, 2011, in the State ofColorado, Daniel Galvan, Anthony Harvey, Stuart Knowles, Leobardo Loya,Abdon Loya-Sanchez, Alexander Oram, Francisco Valencia, Joseph Vittum,Derek Durica, Alan Johnson, Jimmie Joe Montgomery, Kenneth West, andHoracio Bugarin and others both known and unknown, while employed by orassociated with an enterprise, unlawfully, feloniously, and knowingly conducted orparticipated, directly or indirectly, in the enterprise through a pattern of racketeeringactivity: in violation of sections 18-17-104(3) and 18-17-105, C.R.S.
COUNT TWO
VIOLATION OF THE COLORADO ORGANIZED CRIME CONTROL ACT —CONSPIRACY/ENDEAVORING, C.R.S. 18-17-104(4) (F2)
Between the dates of January 1, 2009 and September 29, 2011, in the State ofColorado, Daniel Galvan, Anthony Harvey, Stuart Knowles, Leobardo Loya,Abdon Loya-Sanchez, Alexander Oram, Francisco Valencia, Joseph Vittum,Derek Durica, Alan Johnson, Jimmie Joe Montgomery, Kenneth West, andHoracio Bugarin and others both known and unknown, did unlawfully, knowingly,and feloniously conspire and endeavor to conduct and participate, directly orindirectly, in an enterprise, through a pattern of racketeering activity in violation of
C.R.S. § 18-17-104(4) and § 18-17-104(3), C.R.S.
The offenses alleged in Counts One and Two were committed in the followingmanner:
The Enterprise
The enterprise alleged in counts one and two was primarily a group of individuals,associated in fact, although not a legal entity. The enterprise included, but was notlimited to, the following associated in fact individuals and/or legal entities: DanielGalvan, Anthony Harvey, Stuart Knowles, Leobardo Loya, Abdon Loya-
Sanchez, Alexander Oram, Francisco Valencia, Joseph Vittum, Derek Durica,Alan Johnson, Jimmie Joe Montgomery, Kenneth West, and Horacio Bugarinand others both known and unknown to the Grand Jury. The individuals associatedwith the enterprise had a primary objective and a common purpose to distributelarge quantities of illegal controlled substances, including cocaine andmethamphetamine, both Schedule II Controlled Substances, and marijuana,throughout the Northern Colorado area to various customers. Both Anthony Harveyand Daniel Galvan supplied their respective dealers with these illegal controlled
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
substances. These dealers included Stuart Knowles, Leobardo Loya, AlexanderOram, Francisco Valencia, Joseph Vittum, Derek Durica, and Alan Johnson. AlanJohnson, in turn, supplied his runners, Alexander Oram, Kenneth West, and JimmieJoe Montgomery with cocaine and methamphetamine for further distribution.
Anthony Harvey, Daniel Galvan, and Alan Johnson, together with their respectivedealers including Stuart Knowles, Leobardo Loya, Alexander Oram, FranciscoValencia, Joseph Vittum, Derek Durica, Kenneth West and Jimmie Joe Montgomeryrelied upon and utilized a system of cellular telephones and othertelecommunications facilities to arrange and execute the distribution of these illegalcontrolled substances throughout Northern Colorado.
Further, Anthony Harvey, Daniel Galvan, and Alan Johnson used these cellulartelephones to communicate with their various sources of supply for these illegalcontrolled substances, including Abdon Loya-Sanchez and Horacio Bugarin.Because the members of the criminal enterprise used cellular telephones soextensively to conduct the business and operations of the enterprise, the membersoften utilized coded terminology when speaking to each other on the telephone inorder to conceal their criminal activities.
Pattern of Racketeering Activity
Daniel Galvan, Anthony Harvey, Stuart Knowles, Leobardo Loya, Abdon Loya-Sanchez, Alexander Oram, Francisco Valencia, Joseph Vittum, Derek Durica,Alan Johnson, Jimmie Joe Montgomery, Kenneth West, and Horacio Bugarin directly and in concert, engaged in, attempted to engage in, conspired to engage in,
or solicited another to engage in at least two predicate acts, including any lesseroffenses, related to the conduct of the enterprise, with at least one of which tookplace in the State of Colorado after July 1, 1981 and the last of the acts ofracketeering activity occurring within ten years after a prior act of racketeeringactivity and include:
Distribution of a Controlled Substance – Schedule IIPossession with Intent to Distribute a Controlled Substance – Schedule IIConspiracy to Distribute a Controlled Substance – Schedule IIUnlawful Use of a Telecommunications Facility
Racketeering Activity
The acts of racketeering activity that the above named persons committed,attempted to commit, conspired to commit, or solicited, coerced, or intimidatedanother person to commit, consist of the following predicate acts, including anylesser included offenses:
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Distribution of a Controlled Substance – Schedule II –PREDICATE ACT ONE
25 to 450 Grams, (F3)
On or about July 2, 2009, in the State of Colorado, Daniel Galvan unlawfully,
feloniously, and knowingly sold or distributed cocaine, a schedule II controlledsubstance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
The offense alleged in Predicate Act One was committed in the following manner:
On July 2nd, 2009, a confidential informant working in cooperation with and at thedirection of law enforcement officers drove to THE SHOP, a business located at1925 S. Timberline Road in Fort Collins. Daniel GALVAN and an individualidentifiable only as “Andy” LNU came out and met the CI in his/her car. While DanielGALVAN was standing there, taking an active role in the deal, Andy LNU handedthe CI one ounce of cocaine and the CS paid Andy LNU $475.00.
Distribution of a Controlled Substance – Schedule II –PREDICATE ACT TWO
25 to 450 Grams, (F3)
On or about July 10, 2010, in the State of Colorado, Stuart Knowles unlawfully,feloniously, and knowingly sold or distributed cocaine, a schedule II controlledsubstance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
The offense alleged in Predicate Act Two was committed in the following manner:
On or about July 10, 2010, Stuart Knowles sold a nine-ounce quantity of cocaine toa confidential source, who is fully identifiable to Northern Colorado Drug Task Forcedetectives.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Distribution of a Controlled Substance – Schedule II, (F3)PREDICATE ACT THREE
On or about June 24, 2011, in the State of Colorado, Francisco Valenciaunlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II
controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Predicate Act Three was committed in the following manner:
On June 24, 2011, Francisco Valencia sold a quantity of cocaine to RonaldMunguia-Martin in the parking lot at 2519 S. Shields St. in Fort Collins.
Distribution of a Controlled Substance – Schedule II –PREDICATE ACT FOUR
25 to 450 Grams, (F3)
On or about August 10, 2011, in the State of Colorado, Leobardo Loya unlawfully,feloniously, and knowingly sold or distributed cocaine, a schedule II controlledsubstance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
Unlawful Use of a Communication Facility
PREDICATE ACT FIVE
On or about August 10, 2011, in the State of Colorado, Leobardo Loya didknowingly or intentionally use a communications facility, namely, a telephone, tofacilitate the commission of a felony, namely, distribution of a controlled substance,in violation of 21 U.S.C. §§ 841 and 846, such use of a commmunications facilitybeing unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Four and Five were committed in thefollowing manner:
On August 10, 2011, Leobardo Loya sold a one-ounce quantity of cocaine to aconfidential informant in the parking lot of the King Soopers parking lot located atWillox and College Ave in Fort Collins. Leobardo Loya utilized his cellular telephone(970) 412-9227 to arrange and coordinate the delivery of the cocaine.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Distribution of a Controlled Substance – Schedule II –PREDICATE ACT SIX
25 to 450 Grams, (F3)
On or about August 12, 2011, in the State of Colorado, Leobardo Loya unlawfully,
feloniously, and knowingly sold or distributed cocaine, a schedule II controlledsubstance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT SEVEN
On or about August 12, 2011, in the State of Colorado, Leobardo Loya, didknowingly or intentionally use a communications facility, namely, a telephone, tofacilitate the commission of a felony, namely, distribution of a controlled substance,in violation of 21 U.S.C. §§ 841 and 846, such use of a commmunications facilitybeing unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Six and Seven were committed in thefollowing manner:
On August 12, 2011, Leobardo Loya sold a one-ounce quantity of cocaine to a
confidential informant in the parking lot of Sports Authority parking lot, at 425 SCollege Ave. in Fort Collins. Leobardo Loya utilized his cellular telephone (970)213-3222 to arrange and coordinate the delivery of the cocaine.
Distribution of a Controlled Substance – Schedule II –PREDICATE ACT EIGHT
25 to 450 Grams, (F3)
On or about September 14, 2011, in the State of Colorado, Leobardo Loyaunlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule IIcontrolled substance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Unlawful Use of a Communication FacilityPREDICATE ACT NINE
On or about September 14, 2011, in the State of Colorado, Leobardo Loya, didknowingly or intentionally use a communications facility, namely, a telephone, to
facilitate the commission of a felony, namely, distribution of a controlled substance,in violation of 21 U.S.C. §§ 841 and 846, such use of a commmunications facilitybeing unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Eight and Nine were committed in thefollowing manner:
On September 14, 2011, Leobardo Loya sold a three-ounce quantity of cocaine to aconfidential informant in the parking lot of the King Soopers parking lot located atWillox and College Ave in Fort Collins. Leobardo Loya utilized his cellular telephone(970) 213-3222 to arrange and coordinate the delivery of the cocaine.
Distribution of a Controlled Substance – Schedule II –PREDICATE ACT TEN
25 to 450 Grams, (F3)
On or about August 4, 2011, in the State of Colorado, Alan Johnson and Alexander Oram unlawfully, feloniously, and knowingly sold or distributed cocaine,a schedule II controlled substance.
Further, the amount was or had been represented to be at least twenty-five grams
but not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT ELEVEN
On or about August 4, 2011, in the State of Colorado, Alan Johnson and Alexander Oram did knowingly or intentionally use a communications facility,namely, a telephone, to facilitate the commission of a felony, namely, distribution ofa controlled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of a
commmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Ten and Eleven were committed in thefollowing manner:
On August 4, 2011, Alan Johnson directed Alexander Oram to sell a three-ouncequantity of cocaine to a confidential informant. Alexander Oram then sold a three-ounce quantity of cocaine to the confidential informant from his residence at 1025
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Cunningham Drive, apartment C-6 in Fort Collins. Alan Johnson utilized his cellulartelephone 970-308-1614 and Alexander Oram utilized his cellular telephone number970-690-9788 to arrange and coordinate this delivery of the cocaine.
Distribution of a Controlled Substance – Schedule II –
PREDICATE ACT TWELVE
25 to 450 Grams, (F3)
On or about August 16, 2011, in the State of Colorado, Alan Johnson and Alexander Oram unlawfully, feloniously, and knowingly sold or distributed cocaine,a schedule II controlled substance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT THIRTEEN
On or about August 16, 2011, in the State of Colorado, Alan Johnson and Alexander Oram did knowingly or intentionally use a communications facility,namely, a telephone, to facilitate the commission of a felony, namely, distribution ofa controlled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Twelve and Thirteen were committed in thefollowing manner:
On or about August 16, 2011, Alan Johnson directed Alexander Oram to sell a five-ounce quantity of cocaine to a confidential informant. On that date, Oram, based onAlan Johnson’s express direction to Oram, delivered the five-ounce quantity ofcocaine to the confidential informant from Oram’s residence at 1025 CunninghamDrive, apartment C-6 in Fort Collins. Alan Johnson utilized his cellular telephonenumber to arrange and coordinate the delivery of the cocaine with both AlexanderOram and the confidential informant. Alexander Oram utilized his cellular telephonenumber 970-690-9788 to arrange and coordinate the delivery of the cocaine.
Distribution of a Controlled Substance – Schedule II, (F3)PREDICATE ACT FOURTEEN
On or about August 24, 2011, in the State of Colorado, Anthony Harvey unlawfully,feloniously, and knowingly sold or distributed cocaine, a schedule II controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Possession with Intent to Distribute a Controlled Substance, (F3)PREDICATE ACT FIFTEEN
On or about August 24, 2011, in the State of Colorado, Alan Johnson and Alexander Oram unlawfully, feloniously, and knowingly possessed with intent to
distribute a material, compound, mixture, or preparation that contained cocaine, aschedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A),(3),C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT SIXTEEN
On or about August 24, 2011, in the State of Colorado, Anthony Harvey, AlanJohnson and Alexander Oram did knowingly or intentionally use a communicationsfacility, namely, a telephone, to facilitate the commission of a felony, namely,distribution of a controlled substance, in violation of 21 U.S.C. §§ 841 and 846, suchuse of a commmunications facility being unlawful, and in violation of 21 U.S.C.§ 843.
The offenses alleged in Predicate Acts Fourteen through Sixteen were committed inthe following manner:
On August 24, 2011, Alan Johnson, Alexander Oram and Anthony Harvey agreedthat Harvey would distribute a quantity of cocaine to Alan Johnson by delivering thecocaine to Johnson’s runner, Alexander Oram, who would pick up the cocaine fromHarvey at Harvey’s shop. Alexander Oram went to Anthony Harvey’s shop located
at 200 Commerce Drive Unit #G in Fort Collins, CO. There, Harvey gave Oram aquantity of cocaine. Oram took the quantity of cocaine and then purchased a cuttingagent, in order to process the cocaine for further distribution. Johnson utilized hiscellular telephone 970-308-1614, Harvey utilized his cellular telephone 970-388-2208 and Oram utilized his cellular telephone number 970-690-9788 to arrange andcoordinate this delivery of the cocaine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT SEVENTEEN
On or about August 26, 2011, in the State of Colorado, Anthony Harvey and
Abdon Loya-Sanchez unlawfully, feloniously, and knowingly conspired with eachother, to sell or distribute cocaine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Unlawful Use of a Communication FacilityPREDICATE ACT EIGHTEEN
On or about August 26, 2011, in the State of Colorado, Anthony Harvey andAbdon Loya-Sanchez did knowingly or intentionally use a communications facility,
namely, a telephone, to facilitate the commission of a felony, namely, distribution ofa controlled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Seventeen and Eighteen were committed inthe following manner:
On August 26, 2011, Anthony Harvey and Abdon Loya-Sanchez agreed that Loya-Sanchez would distribute a quantity of cocaine to Harvey in exchange for money. Infurtherance of this agreement, Harvey then went to meet Loya- Sanchez in theparking lot in the 900 block of E. Harmony Road in Fort Collins, CO. There, Harveygave Loya-Sanchez money that comprised proceeds from the sale of cocaine andreceived a quantity of cocaine from Loya-Sanchez. Harvey utilized his cellulartelephone 970-388-2208 and Loya-Sanchez utilized his cellular telephone number307-215-4762 to arrange and coordinate this meeting in reference to the delivery ofthe cocaine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT NINETEEN
On or about August 27, 2011, in the State of Colorado, Anthony Harvey, Alan
Johnson and Alexander Oram unlawfully, feloniously, and knowingly conspiredwith each other, to sell or distribute cocaine, a schedule II controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT TWENTY
On or about August 27, 2011, in the State of Colorado, Anthony Harvey, AlanJohnson and Alexander Oram did knowingly or intentionally use a communicationsfacility, namely, a telephone, to facilitate the commission of a felony, namely,distribution of a controlled substance, in violation of 21 U.S.C. §§ 841 and 846, such
use of a commmunications facility being unlawful, and in violation of 21 U.S.C.§ 843.
The offenses alleged in Predicate Acts Nineteen and Twenty were committed in thefollowing manner:
On August 27, 2011, Alan Johnson and Anthony Harvey agreed that Harvey woulddistribute a quantity of cocaine to Alan Johnson and that Johnson would have his
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
runner, Alexander Oram, pick up the cocaine from Harvey. Alexander Oram andAnthony Harvey agreed that Harvey would distribute a quantity of cocaine to Oramin exchange for money. In furtherance of this agreement, Oram then went toAnthony Harvey’s shop located at 200 Commerce Drive Unit #G in Fort Collins, CO.There, Harvey gave Oram a quantity of cocaine. Harvey utilized his cellular
telephone 970-388-2208 and Oram utilized his cellular telephone number 970-690-9788 and 404-908-7309 to arrange and coordinate this delivery of the cocaine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT TWENTY-ONE
On or about September 3, 2011, in the State of Colorado, Anthony Harvey andAlexander Oram unlawfully, feloniously, and knowingly conspired with each other,to sell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT TWENTY-TWO
On or about September 3, 2011, in the State of Colorado, Anthony Harvey andAlexander Oram did knowingly or intentionally use a communications facility,namely, a telephone, to facilitate the commission of a felony, namely, distribution ofa controlled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Twenty-One and Twenty-Two werecommitted in the following manner:
On September 3, Alexander Oram and Anthony Harvey agreed that Harvey woulddistribute a quantity of cocaine to Oram in exchange for money. In furtherance ofthis agreement, Oram then went to Anthony Harvey’s home located at 2420Manchester Drive in Fort Collins, CO. Harvey utilized his cellular telephone 970-388-2208 and Oram utilized his cellular telephone number 970-690-9788 to arrangeand coordinate this conspiracy to distribute cocaine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT TWENTY-THREE
On or about September 6, 2011, in the State of Colorado, Anthony Harvey andStuart Knowles unlawfully, feloniously, and knowingly conspired with each other, tosell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Unlawful Use of a Communication FacilityPREDICATE ACT TWENTY-FOUR
On or about September 6, 2011, in the State of Colorado, Anthony Harvey andStuart Knowles did knowingly or intentionally use a communications facility,
namely, a telephone, to facilitate the commission of a felony, namely, distribution ofa controlled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Twenty-Three and Twenty-Four werecommitted in the following manner:On September 6, 2011, Anthony Harvey and Stuart Knowles agreed that Harveywould distribute a quantity of cocaine to Knowles in exchange for money. Infurtherance of this agreement, Knowles then went to Anthony Harvey’s homelocated at 2040 Manchester Drive in Fort Collins, CO. Harvey utilized his cellulartelephone 970-388-2208 and Knowles utilized his cellular telephone number 970-481-8858 to arrange and coordinate this conspiracy to distribute cocaine.
Distribution of a Controlled Substance – Schedule II, (F3)PREDICATE ACT TWENTY-FIVE
On or about September 8, 2011, in the State of Colorado, Francisco Valenciaunlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Distribution of a Controlled Substance – Schedule II –
PREDICATE ACT TWENTY-SIX
25 to 450 Grams, (F3)
On or about September 8, 2011, in the State of Colorado, Joseph Vittumunlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule IIcontrolled substance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
The offenses alleged in Predicate Acts Twenty-Five and Twenty-Six were committedin the following manner:
On September 8, 2011, Francisco Valencia distributed a quantity of cocaine toJoseph Vittum at Valencia’s residence located 1007 Whalers Way in Fort Collins.From Valencia’s residence, Vittum then traveled to 3657 S. College Ave. in Fort
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Collins. There, Vittum distributed a one-ounce quantity of cocaine to a confidentialinformant who was working in cooperation with and at the direction of law enforcement.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)
PREDICATE ACT TWENTY-SEVEN
Between the dates of September 8 through September 13, 2011, in the State ofColorado, Daniel Galvan and Francisco Valencia unlawfully, feloniously, andknowingly conspired with each other, to sell or distribute cocaine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT TWENTY-EIGHT
Between the dates of September 8, 2011 through September 13, 2011, in the Stateof Colorado, Daniel Galvan and Francisco Valencia did knowingly or intentionallyuse a communications facility, namely, a telephone, to facilitate the commission of afelony, namely, distribution of a controlled substance, in violation of 21 U.S.C.§§ 841 and 846, such use of a commmunications facility being unlawful, and inviolation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Twenty-Seven and Twenty-Eight werecommitted in the following manner:
Beginning on September 8, 2011, and continuing through September 13, 2011,
Daniel Galvan and Francisco Valencia had a series of telephone conversations andultimately agreed that Galvan would distribute a quantity of cocaine to Valencia inexchange for money. In furtherance of this agreement, Galvan then traveled toValencia’s residence at 1007 Whaler’s Way in Fort Collins, CO. There, Galvandelivered a quantity of cocaine to Valencia. Galvan utilized his cellular telephone970-682-8515 and Valencia utilized his cellular telephone number 970-488-9294 toarrange and coordinate this delivery of cocaine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT TWENTY-NINE
Between the dates of September 19, 2011, through September 20, 2011, in theState of Colorado, Daniel Galvan and Stuart Knowles unlawfully, feloniously, andknowingly conspired with each other, to sell or distribute cocaine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Distribution of a Controlled Substance – Schedule II, (F3)PREDICATE ACT THIRTY
On or about September 20, 2011, in the State of Colorado, Daniel Galvanunlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II
controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Possession with Intent to Distribute a Controlled Substance, (F3)PREDICATE ACT THIRTY-ONE
On or about September 20, 2011, in the State of Colorado, Stuart Knowlesunlawfully, feloniously, and knowingly possessed with intent to distribute a material,compound, mixture, or preparation that contained cocaine, a schedule II controlledsubstance, in violation of section 18-18-405(1),(2)(a)(I)(A),(3), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT THIRTY TWO
Between the dates of September 19, 2011, through September 20, 2011, in theState of Colorado, Daniel Galvan and Stuart Knowles did knowingly orintentionally use a communications facility, namely, a telephone, to facilitate thecommission of a felony, namely, distribution of a controlled substance, in violation of21 U.S.C. §§ 841 and 846, such use of a commmunications facility being unlawful,and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Twenty-Nine, Thirty, Thirty-One, and Thirty
Two were committed in the following manner:
On September 20, 2011, Daniel Galvan and Stuart Knowles agreed that Galvanwould distribute a quantity of cocaine to Knowles in exchange for money. Infurtherance of this agreement, Knowles then met Galvan at the 7-11 conveniencestore located at 970 W. Horsetooth in Fort Collins, CO. There, Galvan delivered aquantity of cocaine to Knowles. Galvan utilized his cellular telephone 970-682-8515and Knowles utilized his cellular telephone number 970-481-8858 to arrange andcoordinate this delivery of cocaine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)
PREDICATE ACT THIRTY-THREE
On or about September 24, 2011, in the State of Colorado, Anthony Harvey andAbdon Loya-Sanchez unlawfully, feloniously, and knowingly conspired with eachother, to sell or distribute cocaine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Distribution of a Controlled Substance – Schedule II, (F3)PREDICATE ACT THIRTY-FOUR
On or about September 24, 2011, in the State of Colorado, Abdon Loya-Sanchez unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II
controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Possession with Intent to Distribute a Controlled Substance, (F3)PREDICATE ACT THIRTY-FIVE
On or about September 24, 2011, in the State of Colorado, Anthony Harveyunlawfully, feloniously, and knowingly possessed with intent to distribute a material,compound, mixture, or preparation that contained cocaine, a schedule II controlledsubstance, in violation of section 18-18-405(1),(2)(a)(I)(A),(3), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT THIRTY-SIX
On or about September 24, 2011, in the State of Colorado, Anthony Harvey andAbdon Loya-Sanchez did knowingly or intentionally use a communications facility,namely, a telephone, to facilitate the commission of a felony, namely, distribution ofa controlled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Thirty-Three, Thirty-Four, Thirty-Five and
Thirty-Six were committed in the following manner:
On September 24, 2011, Abdon Loya-Sanchez and Anthony Harvey agreed thatLoya-Sanchez would distribute a quantity of cocaine to Harvey in exchange formoney. In furtherance of this agreement, Loya-Sanchez then met Harvey atHarvey’s shop located at 204 Commerce Drive Unit #D and #E in Fort Collins, CO.There, Loya-Sanchez delivered a quantity of cocaine to Harvey. Loya-Sanchezutilized his cellular telephone 307-215-4672 and Harvey utilized his cellulartelephone number 970-388-2208 to arrange and coordinate this delivery of cocaine.
Unlawful Use of a Communication Facility
PREDICATE ACT THIRTY-SEVEN
On or about September 8, 2011, in the State of Colorado, Joseph Vittum didknowingly or intentionally use a communications facility, namely, a telephone, tofacilitate the commission of a felony, namely, distribution of a controlled substance,in violation of 21 U.S.C. §§ 841 and 846, such use of a commmunications facilitybeing unlawful, and in violation of 21 U.S.C. § 843.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
The offenses alleged in Predicate Acts Thirty-Seven and Thirty- Eight werecommitted in the following manner:
On September 8, 2011, Vittum distributed a one-ounce quantity of cocaine to aconfidential informant who was working in cooperation with and at the direction of law
enforcement. Vittum utilized his cellular telephone to arrange and coordinate thisdelivery of cocaine to the confidential informant.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT THIRTY-EIGHT
On or about August 24, 2011, in the State of Colorado, Anthony Harvey and DerekDurica unlawfully, feloniously, and knowingly conspired with each other, to sell ordistribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT THIRTY-NINE
On or about August 24, 2011, in the State of Colorado, Anthony Harvey and DerekDurica did knowingly or intentionally use a communications facility, namely, atelephone, to facilitate the commission of a felony, namely, distribution of acontrolled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Thirty-Eight and Thirty-Nine were committed
in the following manner:
On August 24, 2011, Derek Durica and Anthony Harvey agreed that Harvey woulddistribute a quantity of cocaine to Durica in exchange for money. In furtherance ofthis agreement, Durica then went to Anthony Harvey’s shop located at 200Commerce Drive Unit #G in Fort Collins, CO. There, Harvey gave Durica a quantityof cocaine. Harvey utilized his cellular telephone 970-388-2208 and Durica utilizedhis cellular telephone number 970-217-7744 to arrange and coordinate this deliveryof the cocaine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)
PREDICATE ACT FORTY
On or about August 24, 2011, in the State of Colorado, Anthony Harvey and CarlHayes unlawfully, feloniously, and knowingly conspired with each other, to sell ordistribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Unlawful Use of a Communication FacilityPREDICATE ACT FORTY-ONE
On or about August 24, 2011, in the State of Colorado, Anthony Harvey didknowingly or intentionally use a communications facility, namely, a telephone, to
facilitate the commission of a felony, namely, distribution of a controlled substance,in violation of 21 U.S.C. §§ 841 and 846, such use of a commmunications facilitybeing unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Forty and Forty-One were committed in thefollowing manner:
On August 24, 2011, Carl Hayes and Anthony Harvey agreed that Harvey woulddistribute a quantity of cocaine to Hayes in exchange for money. In furtherance ofthis agreement, Hayes then went to Anthony Harvey’s shop located at 200Commerce Drive Unit #G in Fort Collins, CO. There, Harvey gave Hayes a quantityof cocaine. Harvey utilized his cellular telephone 970-388-2208 and Hayes utilizedhis cellular telephone number 832-279-7728 to arrange and coordinate this deliveryof the cocaine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT FORTY-TWO
On or about August 24, 2011, in the State of Colorado, Anthony Harvey and KamalPatterson unlawfully, feloniously, and knowingly conspired with each other, to sellor distribute cocaine, a schedule II controlled substance; in violation of section 18-
18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT FORTY-THREE
On or about August 24, 2011, in the State of Colorado, Anthony Harvey didknowingly or intentionally use a communications facility, namely, a telephone, tofacilitate the commission of a felony, namely, distribution of a controlled substance,in violation of 21 U.S.C. §§ 841 and 846, such use of a commmunications facilitybeing unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Forty-Two and Forty-Three were committedin the following manner:
On or about August 24, 2011, Kamal Patterson and Anthony Harvey agreed thatHarvey would distribute a quantity of cocaine to Patterson in exchange for money.In furtherance of this agreement, Patterson then went to Anthony Harvey’s shoplocated at 200 Commerce Drive Unit #G in Fort Collins, CO. There, Patterson gaveHarvey a quantity of US currency so that Harvey could use that money to ultimately
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
acquire a quantity of cocaine from Harvey’s source of supply. Harvey utilized hiscellular telephone 970-388-2208 and Patterson utilized his cellular telephonenumber 719-388-6449 to arrange and coordinate this delivery of cash towards thepurchase of cocaine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT FORTY-FOUR
On or about August 26, 2011, in the State of Colorado, Anthony Harvey and DerekDurica unlawfully, feloniously, and knowingly conspired with each other, to sell ordistribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT FORTY-FIVE
On or about August 26, 2011, in the State of Colorado, Anthony Harvey and DerekDurica did knowingly or intentionally use a communications facility, namely, atelephone, to facilitate the commission of a felony, namely, distribution of acontrolled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Forty-Four and Forty-Five were committed inthe following manner:
On August 26, 2011, Derek Durica and Anthony Harvey agreed that Harvey would
distribute a quantity of cocaine to Durica in exchange for money. In furtherance ofthis agreement, Durica then went to Anthony Harvey’s shop located at 200Commerce Drive Unit #G in Fort Collins, CO. There, Harvey gave Durica a quantityof cocaine. Harvey utilized his cellular telephone 970-388-2208 and Durica utilizedhis cellular telephone number 970-217-7744 to arrange and coordinate this deliveryof the cocaine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT FORTY-SIX
On or about September 2, 2011, in the State of Colorado, Anthony Harvey and
Derek Durica unlawfully, feloniously, and knowingly conspired with each other, tosell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Unlawful Use of a Communication FacilityPREDICATE ACT FORTY-SEVEN
On or about September 2, 2011, in the State of Colorado, Anthony Harvey andDerek Durica did knowingly or intentionally use a communications facility, namely, a
telephone, to facilitate the commission of a felony, namely, distribution of acontrolled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Forty-Six and Forty-Seven were committed inthe following manner:
On September 2, 2011, Derek Durica and Anthony Harvey agreed that Harveywould distribute a quantity of cocaine to Durica in exchange for money. Infurtherance of this agreement, Durica then met Anthony Harvey at a parking lot 200Linden Street in Fort Collins, CO. There, Durica gave Harvey a quantity of UScurrency so that Harvey could use that money to ultimately acquire a quantity ofcocaine from Harvey’s source of supply. Harvey utilized his cellular telephone 970-388-2208 and Durica utilized his cellular telephone number 970-217-7744 to arrangeand coordinate this delivery of cash towards the purchase of cocaine.
Distribution of a Controlled Substance – Schedule II, (F3)PREDICATE ACT FORTY-EIGHT
On or about September 3, 2011, in the State of Colorado, Anthony Harveyunlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II
controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Predicate Act Forty-Eight was committed in the followingmanner:
On September 3, 2011, Anthony Harvey delivered a quantity of cocaine to MatthewBekkerus at Anthony Harvey’s residence located at 2040 Manchester in Fort Collins,CO.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT FORTY-NINE
On or about September 3, 2011, in the State of Colorado, Anthony Harvey andGary Lihudis unlawfully, feloniously, and knowingly conspired with each other, tosell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Unlawful Use of a Communication FacilityPREDICATE ACT FIFTY
On or about September 3, 2011, in the State of Colorado, Anthony Harvey didknowingly or intentionally use a communications facility, namely, a telephone, to
facilitate the commission of a felony, namely, distribution of a controlled substance,in violation of 21 U.S.C. §§ 841 and 846, such use of a commmunications facilitybeing unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Forty-Nine and Fifty were committed in thefollowing manner:
On September 3, 2011, Gary Lihudis and Anthony Harvey agreed that Harvey woulddistribute a quantity of cocaine to Lihudis in exchange for money. In furtherance ofthis agreement, Lihudis then went to Anthony Harvey’s residence located at 2040Manchester in Fort Collins, CO. There, Harvey gave Lihudis a quantity of cocaine.Harvey utilized his cellular telephone 970-388-2208 and Lihudis utilized his cellulartelephone number 970-231-8105 to arrange and coordinate this delivery of thecocaine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT FIFTY-ONE
Between the dates of September 3, 2011, and September 10, 2011, in the State ofColorado, Anthony Harvey and Maria Moreno unlawfully, feloniously, and
knowingly conspired with each other, to sell or distribute cocaine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT FIFTY-TWO
Between the dates of September 3, 2011, and September 10, 2011, in the State ofColorado, Anthony Harvey did knowingly or intentionally use a communicationsfacility, namely, a telephone, to facilitate the commission of a felony, namely,distribution of a controlled substance, in violation of 21 U.S.C. §§ 841 and 846, suchuse of a commmunications facility being unlawful, and in violation of 21 U.S.C.
§ 843.
The offenses alleged in Predicate Acts Fifty-One and Fifty-Two were committed inthe following manner:
Beginning on September 3, 2011, Maria Moreno and Anthony Harvey agreed thatHarvey would distribute a quantity of cocaine to Moreno in exchange for money. Infurtherance of this agreement, on September 3, 2011, Moreno then went to Anthony
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Harvey’s shop located at 200 Commerce Drive, Unit #G in Fort Collins, CO. There,Moreno gave Harvey a quantity of US currency so that Harvey could use that moneyto ultimately acquire a quantity of cocaine from Harvey’s source of supply. Harveyutilized his cellular telephone 970-388-2208 and Moreno utilized her cellulartelephone number 970-286-9717 to arrange and coordinate this delivery of the
cocaine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT FIFTY-THREE
On or about September 7, 2011, in the State of Colorado, Anthony Harvey andJerome Nelson unlawfully, feloniously, and knowingly conspired with each other, tosell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT FIFTY-FOUR
On or about September 7, 2011, in the State of Colorado, Anthony Harvey didknowingly or intentionally use a communications facility, namely, a telephone, tofacilitate the commission of a felony, namely, distribution of a controlled substance,in violation of 21 U.S.C. §§ 841 and 846, such use of a commmunications facilitybeing unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Fifty-Three and Fifty-Four were committed inthe following manner:
On September 7, 2011, Jerome Nelson and Anthony Harvey agreed that Harveywould distribute a quantity of cocaine to Nelson in exchange for money. Infurtherance of this agreement, Nelson then went to Anthony Harvey’s shop locatedat 204 Commerce Drive, Unit #D in Fort Collins, CO. There, Nelson received aquantity of cocaine that Harvey had designated for Nelson at Harvey’s shop. Harveyutilized his cellular telephone 970-388-2208 and Nelson utilized his cellulartelephone number 970-213-1503 to arrange and coordinate this delivery of cocaine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT FIFTY-FIVE
On or about September 7, 2011, in the State of Colorado, Anthony Harvey andQuentin Wallace unlawfully, feloniously, and knowingly conspired with each other,to sell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Distribution of a Controlled Substance – Schedule II, (F3)PREDICATE ACT FIFTY-SIX
On or about September 7, 2011, in the State of Colorado, Anthony Harveyunlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II
controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT FIFTY-SEVEN
On or about September 7, 2011, in the State of Colorado, Anthony Harvey didknowingly or intentionally use a communications facility, namely, a telephone, tofacilitate the commission of a felony, namely, distribution of a controlled substance,in violation of 21 U.S.C. §§ 841 and 846, such use of a commmunications facilitybeing unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Fifty-Five through Fifty-Seven werecommitted in the following manner:
On September 7, 2011, Anthony Harvey and Quentin Wallace agreed that Harveywould distribute a quantity of cocaine to Wallace in exchange for money. Infurtherance of this agreement, Wallace then met Harvey at his residence, 2040Manchester in Fort Collins, CO. There, Harvey delivered a quantity of cocaine toWallace. Harvey utilized his cellular telephone 970-388-2208 and Wallace utilizedhis cellular telephone number 970-599-8451 to arrange and coordinate this delivery
of cocaine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT FIFTY-EIGHT
On or about September 9, 2011, in the State of Colorado, Anthony Harvey andGary Lihudis unlawfully, feloniously, and knowingly conspired with each other, tosell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication Facility
PREDICATE ACT FIFTY-NINE
On or about September 9, 2011, in the State of Colorado, Anthony Harvey didknowingly or intentionally use a communications facility, namely, a telephone, tofacilitate the commission of a felony, namely, distribution of a controlled substance,in violation of 21 U.S.C. §§ 841 and 846, such use of a commmunications facilitybeing unlawful, and in violation of 21 U.S.C. § 843.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
The offenses alleged in Predicate Acts Fifty-Eight and Fifty-Nine were committed inthe following manner:
On September 9, 2011, Gary Lihudis and Anthony Harvey agreed that Harvey woulddistribute a quantity of cocaine to Lihudis in exchange for money. In furtherance of
this agreement, Lihudis met Harvey at Lihudis’ residence at 7348 S. College Ave. inFort Collins, CO. There, Lihudis gave Harvey a quantity of US currency so thatHarvey could use that money to ultimately acquire a quantity of cocaine fromHarvey’s source of supply. Harvey utilized his cellular telephone 970-388-2208 andLihudis utilized his cellular telephone number to arrange and coordinate this deliveryof cash towards the purchase of cocaine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT SIXTY
On or about September 9, 2011, in the State of Colorado, Anthony Harvey andMichael McCain unlawfully, feloniously, and knowingly conspired with each other, tosell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT SIXTY-ONE
On or about September 9, 2011, in the State of Colorado, Anthony Harvey didknowingly or intentionally use a communications facility, namely, a telephone, tofacilitate the commission of a felony, namely, distribution of a controlled substance,
in violation of 21 U.S.C. §§ 841 and 846, such use of a commmunications facilitybeing unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Sixty and Sixty-One were committed in thefollowing manner:
On September 9, 2011, Michael McCain and Anthony Harvey agreed that Harveywould distribute a quantity of cocaine to McCain in exchange for money. Infurtherance of this agreement, McCain met Harvey at the intersection of CollegeAve. and Harmony Road in Fort Collins, CO. There, McCain gave Harvey a quantityof US currency so that Harvey could use that money to ultimately acquire a quantity
of cocaine from Harvey’s source of supply. Harvey utilized his cellular telephone970-388-2208 and McCain utilized his cellular telephone number 720- 648- 0628 toarrange and coordinate this delivery of cash towards the purchase of cocaine.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT SIXTY-TWO
On or about September 14, 2011, in the State of Colorado, Anthony Harvey andDerek Durica unlawfully, feloniously, and knowingly conspired with each other, to
sell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT SIXTY-THREE
On or about September 14, 2011, in the State of Colorado, Anthony Harvey andDerek Durica did knowingly or intentionally use a communications facility, namely, atelephone, to facilitate the commission of a felony, namely, distribution of acontrolled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Sixty-Two and Sixty-Three were committedin the following manner:
On September 14, 2011, Derek Durica and Anthony Harvey agreed that Harveywould distribute a quantity of cocaine to Durica in exchange for money. Infurtherance of this agreement, Durica then went to Anthony Harvey’s shop located at204 Commerce Drive Unit #D in Fort Collins, CO. There, Durica gave Harvey aquantity of US currency so that Harvey could use that money to ultimately acquire aquantity of cocaine from Harvey’s source of supply. Harvey utilized his cellular
telephone 970-388-2208 and Durica utilized his cellular telephone number 970-217-7744 to arrange and coordinate this delivery of cash towards the purchase ofcocaine.
Distribution of Marijuana – Between 5 and 100 Pounds, (F4)PREDICATE ACT SIXTY-FOUR
On or about September 20, 2011, in the State of Colorado, Abdon Loya-Sanchezand Anthony Harvey, unlawfully, feloniously, and knowingly sold or distributed, orattempted to sell or distribute, marijuana or marijuana concentrate.
Further, the amount was at least five pounds but not more than one hundred poundsof marijuana; in violation of section 18-18-406(6)(b)(I), (III)(B), C.R.S.
The offense alleged in Predicate Act Sixty-Four was committed in the followingmanner:
On September 20, 2011, Abdon Loya-Sanchez and Anthony Harvey distributedapproximately 10 pounds of marijuana, packaged in single-pound increments to
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Brian Butler at Harvey’s residence, 2040 Manchester in Fort Collins, CO. Shortlythereafter, at Mile Marker 351 on Hwy 287, law enforcement officers recovered 10pounds of marijuana from Brian Butler.
Possession with Intent to Distribute a Controlled Substance –
PREDICATE ACT SIXTY-FIVE
25 to 450 Grams, (F3)
On or about September 30, 2011, in the State of Colorado, Leobardo Loyaunlawfully, feloniously, and knowingly possessed with intent to distribute a material,compound, mixture, or preparation that contained cocaine, a schedule II controlledsubstance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
The offense charged in Predicate Act Sixty-FIve was committed in the followingmanner:
On September 30, 2011, law enforcement officers recovered 336.7 grams ofcocaine from Leobardo Loya’s residence at 2025 N. College Ave., #225, FortCollins, CO.
Possession with Intent to Distribute a Controlled Substance, (F3)
PREDICATE ACT SIXTY-SIX
On or about September 30, 2011, in the State of Colorado, Leobardo Loyaunlawfully, feloniously, and knowingly possessed with intent to distribute a material,compound, mixture, or preparation that contained methamphetamine, a schedule IIcontrolled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense charged in Predicate Act Sixty-Six was committed in the followingmanner:
On September 30, 2011, law enforcement officers recovered 14 grams of
methamphetamine from Leobardo Loya’s residence at 2025 N. College Ave., #225,Fort Collins, CO.
Possession with Intent to Distribute a Controlled Substance, (F3)PREDICATE ACT SIXTY-SEVEN
On or about September 30, 2011, in the State of Colorado, Abdon Loya-Sanchezunlawfully, feloniously, and knowingly possessed with intent to distribute a material,
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
compound, mixture, or preparation that contained cocaine, a schedule II controlledsubstance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense charged in Predicate Act Sixty-Seven was committed in the followingmanner:
On September 30, 2011, law enforcement officers recovered 10.7 grams of cocainefrom the residence of Abdon Loya-Sanchez at 3717 S. Taft Hill, #268, Fort Collins,CO.
Possession with Intent to Distribute Marijuana –PREDICATE ACT SIXTY-EIGHT
Between 5 and 100 Pounds, (F4)
On or about September 30, 2011, in the State of Colorado, Abdon Loya-Sanchez, unlawfully, feloniously, and knowingly possessed or attempted to possess, withintent to sell or distribute marijuana or marijuana concentrate.
Further, the amount was at least five pounds but not more than one hundred poundsof marijuana; in violation of section 18-18-406(6)(b)(I), (III)(B), C.R.S.
The offense charged in Predicate Act Sixty-Eight was committed in the followingmanner:
On September 30, 2011, law enforcement officers recovered 2536.7 grams(approximately 5 pounds) of marijuana from the residence of Abdon Loya-Sanchez
at 3717 S. Taft Hill, #268, Fort Collins, CO. Law enforcement officers recovered3939.6 grams (approximately 8 pounds) of marijuana from the storage facility rentedby Abdon Loya-Sanchez at 3702 Manhattan, #E-6, Fort Collins, CO.
Possession with Intent to Distribute a Controlled Substance –PREDICATE ACT SIXTY-NINE
450 to 1000 Grams, (F3)
On or about September 30, 2011, in the State of Colorado, Alexander Oramunlawfully, feloniously, and knowingly possessed with intent to distribute a material,compound, mixture, or preparation that contained cocaine, a schedule II controlled
substance.
Further, the amount was or had been represented to be at least four hundred-fiftygrams but not more than one thousand grams or one kilogram of a material,compound, mixture, or preparation that contained the controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
The offense charged in Predicate Act Sixty-Nine was committed in the followingmanner:
On September 30, 2011, law enforcement officers recovered 477.4 grams ofcocaine from the residence of Alexander Oram at 1025 Cunningham, #C-6, Fort
Collins, CO.
Possession with Intent to Distribute a Controlled Substance –PREDICATE ACT SEVENTY
450 to 1000 Grams, (F3)
On or about September 30, 2011, in the State of Colorado, Francisco Valenciaunlawfully, feloniously, and knowingly possessed with intent to distribute a material,compound, mixture, or preparation that contained cocaine, a schedule II controlledsubstance.
Further, the amount was or had been represented to be at least four hundred-fiftygrams but not more than one thousand grams or one kilogram of a material,compound, mixture, or preparation that contained the controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S.
The offense charged in Predicate Act Seventy was committed in the followingmanner:
On September 30, 2011, law enforcement officers recovered 686 grams of cocainefrom Francisco Valencia’s bedroom in his residence at 1007 Whalers Way, Fort
Collins, CO.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT SEVENTY-ONE
On or about September 24, 2011, in the State of Colorado, Anthony Harvey andTony Romero unlawfully, feloniously, and knowingly conspired with each other, to
sell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT SEVENTY-TWO
On or about September 24, 2011, in the State of Colorado, Anthony Harvey andStuart Knowles unlawfully, feloniously, and knowingly conspired with each other, tosell or distribute cocaine and oxycodonoe, both schedule II controlled substances; inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT SEVENTY-THREE
On or about September 24, 2011, in the State of Colorado, Anthony Harvey andStuart Knowles did knowingly or intentionally use a communications facility,namely, a telephone, to facilitate the commission of a felony, namely, distribution ofa controlled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses charged in Predicate Acts Seventy-One through Seventy-Three were
committed in the following manner:
On September 24, 2011, Anthony Harvey and Tony Romero agreed that Harveywas going to distribute a quantity of cocaine and that Romero would assist Harvey inprocessing the cocaine for distribution. In furtherance of this agreement, Harveydirected Romero to purchase a cutting agent for the cocaine, which Romero did andbrought to Harvey’s shop.
Also on that date, Anthony Harvey and Stuart Knowles agreed that Harvey woulddistribute quantities of cocaine and oxycodonoe to Knowles in exchange for money.In furtherance of this agreement, Knowles went to Harvey’s shop at 204 Commerce
Drive, Units #D/E, Fort Collins, CO, in order to pick up a quantity of oxycodone fromHarvey. Harvey utilized his cellular telephone and Knowles utilized his cellulartelephone to arrange and coordinate this deal.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT SEVENTY-FOUR
On or about September 24, 2011, in the State of Colorado, Abdon Loya-Sanchezand Adrian Hernandez unlawfully, feloniously, and knowingly conspired with each
other, to sell or distribute cocaine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
Distribution of a Controlled Substance – Schedule II –PREDICATE ACT SEVENTY-FIVE
25 to 450 Grams, (F3)
On or about September 24, 2011, in the State of Colorado, Abdon Loya-Sanchezunlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule IIcontrolled substance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
Possession with Intent to Distribute a Controlled Substance – Schedule II –PREDICATE ACT SEVENTY-SIX
25 to 450 Grams, (F3)
On or about September 24, 2011, in the State of Colorado, Adrian Hernandez
unlawfully, feloniously, and knowingly possessed with intent to distribute cocaine, aschedule II controlled substance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT SEVENTY-SEVEN
On or about September 24, 2011, in the State of Colorado, Abdon Loya-Sanchezdid knowingly or intentionally use a communications facility, namely, a telephone, tofacilitate the commission of a felony, namely, distribution of a controlled substance,in violation of 21 U.S.C. §§ 841 and 846, such use of a commmunications facilitybeing unlawful, and in violation of 21 U.S.C. § 843.
The offenses charged in Predicate Acts Seventy-Four through Seventy-Seven werecommitted in the following manner:
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
On September 24, 2011, Abdon Loya-Sanchez and Adrian Hernandez agreed thatLoya-Sanchez would deliver a quantity of cocaine to Hernandez in exchange formoney. In furtherance of this agreement, Hernandez met Loya-Sanchez in aparking lot located at Taft Hill Road and Harmony Road, Fort Collins, CO. At thatlocation, Loya-Sanchez distributed approximately a one-pound quantity of cocaine to
Adrian Hernandez. Hernandez accepted the cocaine and then left the area.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT SEVENTY-EIGHT
On or about September 23, 2011, in the State of Colorado, Abdon Loya-Sanchezand Alejandro Uribe unlawfully, feloniously, and knowingly conspired with eachother, to sell or distribute cocaine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT SEVENTY-NINE
On or about September 23, 2011, in the State of Colorado, Abdon Loya-Sanchezdid knowingly or intentionally use a communications facility, namely, a telephone, tofacilitate the commission of a felony, namely, distribution of a controlled substance,in violation of 21 U.S.C. §§ 841 and 846, such use of a commmunications facilitybeing unlawful, and in violation of 21 U.S.C. § 843.
The offenses charged in Predicate Acts Seventy-Eight and Seventy-Nine werecommitted in the following manner:
On September 23, 2011, Abdon Loya-Sanchez and Alejandro Uribe agreed thatUribe would deliver an amount of money to Loya-Sanchez as payment for a pastpurchase of cocaine and towards a future purchase of cocaine. In furtherance ofthis agreement, Uribe went to Loya-Sanchez’s residence at 3717 Taft Hill, #268,Fort Collins, CO. At that location, Uribe delivered a quantity of money as paymentfor past drug transactions. Loya-Sanchez utilized his cellular telephone 307-215-4762 to arrange this meeting.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Distribution of a Controlled Substance – Schedule II –PREDICATE ACT EIGHTY
25 to 450 Grams, (F3)
On or about May 3, 2011, in the State of Colorado, Alan Johnson unlawfully,
feloniously, and knowingly sold or distributed cocaine, a schedule II controlledsubstance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT EIGHTY-ONE
On or about May 3, 2011, in the State of Colorado, Alan Johnson did knowingly orintentionally use a communications facility, namely, a telephone, to facilitate thecommission of a felony, namely, distribution of a controlled substance, in violation of21 U.S.C. §§ 841 and 846, such use of a commmunications facility being unlawful,and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Eighty and Eighty-One were committed in thefollowing manner:
On May 3, 2011, Alan Johnson sold a five-ounce quantity of cocaine to a
confidential informant in the parking lot of the Albertson’s grocery store at 3657 S.Mason in Fort Collins, CO. Alan Johnson utilized his cellular telephone 970-308-1614 to arrange and coordinate the delivery of the cocaine.
Distribution of a Controlled Substance – Schedule II –PREDICATE ACT EIGHTY-TWO
25 to 450 Grams, (F3)
On or about June 17, 2011, in the State of Colorado, Alan Johnson unlawfully,feloniously, and knowingly sold or distributed cocaine, a schedule II controlledsubstance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Unlawful Use of a Communication FacilityPREDICATE ACT EIGHTY-THREE
On or about June 17, 2011, in the State of Colorado, Alan Johnson did knowinglyor intentionally use a communications facility, namely, a telephone, to facilitate the
commission of a felony, namely, distribution of a controlled substance, in violation of21 U.S.C. §§ 841 and 846, such use of a commmunications facility being unlawful,and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Eighty-Two and Eighty-Three werecommitted in the following manner:
On June 17, 2011, Alan Johnson sold a three-ounce quantity of cocaine to aconfidential informant in the parking lot of American Furniture Warehouse store at625 SW Frontage Road in Fort Collins, CO. Alan Johnson utilized his cellulartelephone 970-308-1614 to arrange and coordinate the delivery of the cocaine.
Distribution of a Controlled Substance – Schedule II, (F3)PREDICATE ACT EIGHTY-FOUR
On or about August 3, 2011, in the State of Colorado, Alan Johnson unlawfully,feloniously, and knowingly sold or distributed methamphetamine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Distribution of a Controlled Substance – Schedule II, (F3)PREDICATE ACT EIGHTY-FIVE
On or about August 3, 2011, in the State of Colorado, Jimmie Joe Montgomeryunlawfully, feloniously, and knowingly sold or distributed methamphetamine, aschedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),C.R.S.
The offenses alleged in Predicate Acts Eighty-Four and Eighty-Five were committedin the following manner:
On August 3, 2011, Alan Johnson delivered a quantity of methamphetamine toJimmie Joe Montgomery at Johnson’s residence on Cleveland Avenue, Loveland,
CO. Montgomery then took the methamphetamine from Johnson and delivered 4.3grams of methamphetamine to Kevin Caldwell in the 1400 block of Remington Streetin Fort Collins, CO.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT EIGHTY-SIX
Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado,Alan Johnson and Kenneth West unlawfully, feloniously, and knowingly conspired
with each other, to sell or distribute cocaine, a schedule II controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Distribution of a Controlled Substance – Schedule II, (F3)PREDICATE ACT EIGHTY-SEVEN
Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado,Alan Johnson unlawfully, feloniously, and knowingly sold or distributed cocaine, aschedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),C.R.S.
Possession with Intent to Distribute a Controlled Substance, (F3)PREDICATE ACT EIGHTY-EIGHT
Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado,Kenneth West unlawfully, feloniously, and knowingly possessed with intent todistribute a material, compound, mixture, or preparation that contained cocaine, aschedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A),C.R.S.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)
PREDICATE ACT EIGHTY-NINE
Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado,Alan Johnson and Mark Fraleigh unlawfully, feloniously, and knowingly conspiredwith each other, to sell or distribute cocaine, a schedule II controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT NINETY
Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado,
Alan Johnson and Mitchell Morris unlawfully, feloniously, and knowingly conspiredwith each other, to sell or distribute cocaine, a schedule II controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Unlawful Use of a Communication FacilityPREDICATE ACT NINETY-ONE
Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado,Alan Johnson and Kenneth West did knowingly or intentionally use a
communications facility, namely, a telephone, to facilitate the commission of afelony, namely, distribution of a controlled substance, in violation of 21 U.S.C.§§ 841 and 846, such use of a commmunications facility being unlawful, and inviolation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Eighty-Six through Ninety-One werecommitted in the following manner:
Between the dates of August 8, 2011 and August 12, 2011, Alan Johnson delivereda quantity of cocaine to Kenneth West. West and Johnson then agreed that Westwould travel to Montana and distribute a quantity of cocaine to each of Johnson’scustomers, Mark Fraleigh and Mitchell Morris. In furtherance of this agreement,West traveled to Montana and delivered a quantity of cocaine to both Mark Fraleighand Mitchell Morris. Johnson utilized his cellular telephone 970-308-1614 and Westutilized his cellular telephone 970-301-5777 to arrange and coordinate this deliveryof the cocaine.
At approximately the same time, Johnson agreed with Mark Fraleigh that Johnsonwould deliver a quantity of cocaine to Fraleigh. In furtherance of this agreement,Johnson gave a quantity of cocaine to Kenneth West who then transported thecocaine to Fraleigh in Montana. Fraleigh then coordinated with Johnson through the
use of cellular telephones to send the proceeds from the sale of cocaine back toJohnson.
Similarly, Johnson agreed with Mitchell Morris that Johnson would deliver a quantityof cocaine to Morris. In furtherance of this agreement, Johnson gave a quantity ofcocaine to Kenneth West who then transported the cocaine to Morris in Montana.Morris then coordinated with Johnson through the use of cellular telephones toreturn the proceeds from the sale of the cocaine back to Johnson.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT NINETY-TWO
On or about August 12, 2011, in the State of Colorado, Alan Johnson and HoracioBugarin unlawfully, feloniously, and knowingly conspired with each other, to sell ordistribute methamphetamine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Unlawful Use of a Communication FacilityPREDICATE ACT NINETY-THREE
On or about August 12, 2011, in the State of Colorado, Alan Johnson and HoracioBugarin did knowingly or intentionally use a communications facility, namely, a
telephone, to facilitate the commission of a felony, namely, distribution of acontrolled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Ninety-Two and Ninety-Three werecommitted in the following manner:
On August 12, 2011, Alan Johnson and Horacio Bugarin agreed that Bugarin woulddistribute a quantity of methamphetamine to Johnson in exchange for money. Infurtherance of this agreement, Bugarin picked up Alan Johnson from his residenceon Cleveland Street in Loveland, CO. Bugarin then traveled with Johnson toGreeley, CO. Johnson utilized his cellular telephone 970-308-1614 and Bugarinutilized his cellular telephone to arrange and coordinate this meeting in reference tothe conspiracy to distribute the methamphetamine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT NINETY-FOUR
On or about August 14, 2011, in the State of Colorado, Alan Johnson and ShawnBlea unlawfully, feloniously, and knowingly conspired with each other, to sell ordistribute methamphetamine, a schedule II controlled substance; in violation of
section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT NINETY-FIVE
On or about August 14, 2011, in the State of Colorado, Alan Johnson did knowinglyor intentionally use a communications facility, namely, a telephone, to facilitate thecommission of a felony, namely, distribution of a controlled substance, in violation of21 U.S.C. §§ 841 and 846, such use of a commmunications facility being unlawful,and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Ninety-Four and Ninety-Five were committedin the following manner:
On August 14, 2011, Alan Johnson and Shawn Blea agreed that Johnson woulddistribute a quantity of methamphetamine to Blea in exchange for money. Infurtherance of this agreement, Blea went to Johnson’s residence on ClevelandStreet, Loveland, CO. At that location, Blea received a quantity ofmethamphetamine from Johnson.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT NINETY-SIX
On or about August 15, 2011, in the State of Colorado, Alan Johnson and AnthonyHarvey unlawfully, feloniously, and knowingly conspired with each other, to sell or
distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT NINETY-SEVEN
On or about August 15, 2011, in the State of Colorado, Alan Johnson and AnthonyHarvey did knowingly or intentionally use a communications facility, namely, atelephone, to facilitate the commission of a felony, namely, distribution of acontrolled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts Ninety-Six and Ninety-Seven werecommitted in the following manner:
On August 15, 2011, Alan Johnson and Anthony Harvey agreed that Johnson wouldpay an amount of US currency to Harvey as payment both for previous deliveries ofcocaine and also for future delivery of cocaine. In furtherance of this agreement,Johnson and Harvey met at 5000 Boardwalk, Fort Collins, CO. At that location,Johnson paid Harvey an amount of US currency towards the future purchase ofcocaine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT NINETY-EIGHT
On or about August 16, 2011, in the State of Colorado, Alan Johnson and JimmieJoe Montgomery unlawfully, feloniously, and knowingly conspired with each other,to sell or distribute methamphetamine, a schedule II controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT NINETY-NINE
On or about August 16, 2011, in the State of Colorado, Alan Johnson and JimmieJoe Montgomery did knowingly or intentionally use a communications facility,namely, a telephone, to facilitate the commission of a felony, namely, distribution ofa controlled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
The offenses alleged in Predicate Acts Ninety-Eight and Ninety-Nine werecommitted in the following manner:
On August 16, 2011, Alan Johnson and Jimmie Joe Montgomery agreed thatJohnson would distribute a quantity of methamphetamine to Montgomery in
exchange for money. In furtherance of this agreement, Johnson directedMontgomery to go to Johnson’s residence on Cleveland Ave, Loveland, CO.Montgomery then traveled to Johnson’s residence to pick up the quantity ofmethamphetamine. Johnson utilized his cellular telephone 970-308-1614 andMontgomery utilized his cellular telephone 970-400-0105 to arrange and coordinatethis delivery of the methamphetamine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT ONE HUNDRED
On or about August 16, 2011, in the State of Colorado, Alan Johnson and HoracioBugarin unlawfully, feloniously, and knowingly conspired with each other, to sell ordistribute methamphetamine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT ONE HUNDRED-ONE
On or about August 16, 2011, in the State of Colorado, Alan Johnson and HoracioBugarin did knowingly or intentionally use a communications facility, namely, atelephone, to facilitate the commission of a felony, namely, distribution of a
controlled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts One Hundred and One Hundred-One werecommitted in the following manner:
On August 16, 2011, Alan Johnson and Horacio Bugarin agreed that Johnson wouldpay an amount of US currency to Bugarin as payment both for previous deliveries ofmethamphetamine and also for future delivery of methamphetamine. In furtheranceof this agreement, Johnson and Bugarin met at the gas station at 1st and Taft,Loveland, CO. At that location, Johnson paid Bugarin an amount of US currency
towards the future purchase of methamphetamine.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT ONE HUNDRED-TWO
On or about August 21, 2011, in the State of Colorado, Alan Johnson and HoracioBugarin unlawfully, feloniously, and knowingly conspired with each other, to sell or
distribute methamphetamine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT ONE HUNDRED-THREE
On or about August 21, 2011, in the State of Colorado, Alan Johnson and HoracioBugarin did knowingly or intentionally use a communications facility, namely, atelephone, to facilitate the commission of a felony, namely, distribution of acontrolled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts One Hundred-Two and One Hundred-Threewere committed in the following manner:
On August 21, 2011, Alan Johnson and Horacio Bugarin agreed that Johnson wouldpay an amount of US currency to Bugarin as payment both for previous deliveries ofmethamphetamine and also for future delivery of methamphetamine. In furtheranceof this agreement, Johnson and Bugarin met at Bugarin’s residence at 139 Juniper#B, Loveland, CO. At that location, Johnson paid Bugarin an amount of UScurrency towards the future purchase of methamphetamine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT ONE HUNDRED-FOUR
On or about August 24, 2011, in the State of Colorado, Alan Johnson and HoracioBugarin unlawfully, feloniously, and knowingly conspired with each other, to sell ordistribute methamphetamine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
Distribution of a Controlled Substance – Schedule II, (F3)PREDICATE ACT ONE HUNDRED-FIVE
On or about August 24, 2011, in the State of Colorado, Horacio Bugarin unlawfully,feloniously, and knowingly sold or distributed methamphetamine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Possession with Intent to Distribute a Controlled Substance, (F3)PREDICATE ACT ONE HUNDRED-SIX
On or about August 24, 2011, in the State of Colorado, Alan Johnson unlawfully,feloniously, and knowingly possessed with intent to distribute a material, compound,
mixture, or preparation that contained methamphetamine, a schedule II controlledsubstance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT ONE HUNDRED-SEVEN
On or about August 24, 2011, in the State of Colorado, Alan Johnson and HoracioBugarin did knowingly or intentionally use a communications facility, namely, atelephone, to facilitate the commission of a felony, namely, distribution of acontrolled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts One Hundred-Four though One Hundred-Seven were committed in the following manner:
On August 24, 2011, Alan Johnson and Horacio Bugarin agreed that Bugarin woulddeliver a quantity of methamphetamine to Johnson. In furtherance of thisagreement, Johnson and Bugarin met at Johnson’s residence at Cleveland Ave.,Loveland, CO. At that location, Bugarin delivered a quantity of methamphetamine toJohnson.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT ONE HUNDRED-EIGHT
On or about August 26, 2011, in the State of Colorado, Alan Johnson and AnthonyHarvey unlawfully, feloniously, and knowingly conspired with each other, to sell ordistribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Distribution of a Controlled Substance – Schedule II, (F3)PREDICATE ACT ONE HUNDRED-NINE
On or about August 26, 2011, in the State of Colorado, Anthony Harvey unlawfully,feloniously, and knowingly sold or distributed cocaine, a schedule II controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Possession with Intent to Distribute a Controlled Substance, (F3)PREDICATE ACT ONE HUNDRED-TEN
On or about August 26, 2011, in the State of Colorado, Alan Johnson unlawfully,feloniously, and knowingly possessed with intent to distribute a material, compound,
mixture, or preparation that contained cocaine, a schedule II controlled substance, inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Unlawful Use of a Communication FacilityPREDICATE ACT ONE HUNDRED-ELEVEN
On or about August 26, 2011, in the State of Colorado, Alan Johnson and AnthonyHarvey did knowingly or intentionally use a communications facility, namely, atelephone, to facilitate the commission of a felony, namely, distribution of acontrolled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts One Hundred-Eight through One Hundred-Eleven were committed in the following manner:
On August 26, 2011, Alan Johnson and Anthony Harvey agreed that Harvey woulddeliver a quantity of cocaine to Johnson. In furtherance of this agreement, Johnsonand Harvey met at 5000 Boardwalk, Fort Collins, CO. At that location, Harveydelivered a quantity of cocaine to Johnson, who accepted the delivery.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)
PREDICATE ACT ONE HUNDRED-TWELVE
On or about September 19, 2011, in the State of Colorado, Alan Johnson and Anthony Harvey unlawfully, feloniously, and knowingly conspired with each other,to sell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Unlawful Use of a Communication FacilityPREDICATE ACT ONE HUNDRED-THIRTEEN
On or about September 19, 2011, in the State of Colorado, Anthony Harvey andAlan Johnson did knowingly or intentionally use a communications facility, namely,
a telephone, to facilitate the commission of a felony, namely, distribution of acontrolled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843.
The offenses alleged in Predicate Acts One Hundred-Twelve and One Hundred-Thirteen were committed in the following manner:
On September 19, 2011, Alan Johnson and Anthony Harvey agreed that Harveywould distribute a quantity of cocaine to Alan Johnson and that Johnson would payHarvey. In furtherance of this agreement, they met at the Inca Restaurant, at 2413S. College, Fort Collins, CO. Harvey utilized his cellular telephone 970-388-2208and Johnson utilized his cellular telephone number 970-308-1614 to arrange andcoordinate this conspiracy to distribute cocaine.
Distribution of a Schedule II Controlled Substance –PREDICATE ACT ONE HUNDRED-FOURTEEN
450 to 1000 Grams, (F3)
On or about September 29, 2011, in the State of Colorado, Alan Johnsonunlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule IIcontrolled substance.
Further, the amount was or had been represented to be at least four hundred-fiftygrams but not more than one thousand grams or one kilogram of a material,compound, mixture, or preparation that contained the controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S.
The offense charged in Predicate Act One Hundred-Fourteen was committed in thefollowing manner:
On September 29, 2011, Alan Johnson delivered approximately 477.4 grams ofcocaine to Alexander Oram at Oram’s residence on 1025 Cunningham, #C-6, Fort
Collins, CO. Johnson directed Oram to store the cocaine for future distribution.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Possession with Intent to Distribute a Controlled Substance –PREDICATE ACT ONE HUNDRED-FIFTEEN
Schedule II – 450 to 1000 Grams, (F3)
On or about September 30, 2011, in the State of Colorado, Horacio Bugarin
unlawfully, feloniously, and knowingly possessed with intent to distributemethamphetamine, a schedule II controlled substance.
Further, the amount was or had been represented to be at least four hundred-fiftygrams but not more than one thousand grams or one kilogram of a material,compound, mixture, or preparation that contained the controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S.
Possession with Intent to Distribute a Controlled Substance –PREDICATE ACT ONE HUNDRED-SIXTEEN
Schedule II – 25 to 450 Grams, (F3)
On or about September 30, 2011, in the State of Colorado, Horacio Bugarinunlawfully, feloniously, and knowingly possessed with intent to distribute cocaine, aschedule II controlled substance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
The offenses charged in Predicate Acts One Hundred-Fifteen and One Hundred-Sixteen were committed in the following manner:
On September 30, 2011, law enforcement officers recovered 26.6 grams of cocaineand 466.25 grams of methamphetamine from Horacio Bugarin’s residence atJuniper Place, Loveland, CO.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)PREDICATE ACT ONE HUNDRED SEVENTEEN
On or about September 13, 2011, in the State of Colorado, Abdon Loya-Sanchez
and Alejandro Uribe unlawfully, feloniously, and knowingly conspired with eachother, to sell or distribute cocaine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Unlawful Use of a Communication FacilityPREDICATE ACT ONE HUNDRED EIGHTEEN
On or about September 13, 2011, in the State of Colorado, Abdon Loya-Sanchezdid knowingly or intentionally use a communications facility, namely, a telephone, to
facilitate the commission of a felony, namely, distribution of a controlled substance,in violation of 21 U.S.C. §§ 841 and 846, such use of a commmunications facilitybeing unlawful, and in violation of 21 U.S.C. § 843.
The offenses charged in Predicate Acts One Hundred-Seventeen and One Hundred-Eighteen were committed in the following manner:
On September 13, 2011, Abdon Loya-Sanchez and Alejandro Uribe agreed thatLoya-Sanchez would deliver approximately two ounces of cocaine to Uribe. Infurtherance of this agreement, Loya-Sanchez went to Uribe’s residence on W.Laurel Street, Fort Collins, CO. At that location, Loya-Sanchez distributed a quantityof cocaine to Alejandro Uribe. Loya-Sanchez utilized his cellular telephone 307-215-4762 to arrange this meeting.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Distribution of a Controlled Substance – Schedule II, (F3)COUNT THREE
On or about June 24, 2011, in the State of Colorado, Francisco Valenciaunlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II
controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Three was committed in the manner described inPredicate Act Three.
Distribution of a Controlled Substance – Schedule II –COUNT FOUR
25 to 450 Grams, (F3)
On or about August 10, 2011, in the State of Colorado, Leobardo Loya unlawfully,feloniously, and knowingly sold or distributed cocaine, a schedule II controlledsubstance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
The offense alleged in Count Four was committed in the manner described inPredicate Acts Four and Five.
Distribution of a Controlled Substance – Schedule II –COUNT FIVE
25 to 450 Grams, (F3)
On or about August 12, 2011, in the State of Colorado, Leobardo Loya unlawfully,feloniously, and knowingly sold or distributed cocaine, a schedule II controlledsubstance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation of
Distribution of a Controlled Substance – Schedule II –COUNT SIX
25 to 450 Grams, (F3)
On or about September 14, 2011, in the State of Colorado, Leobardo Loya
unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule IIcontrolled substance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
The offense alleged in Count Six was committed in the manner described inPredicate Acts Eight and Nine.
Distribution of a Controlled Substance – Schedule II –COUNT SEVEN
25 to 450 Grams, (F3)
On or about August 4, 2011, in the State of Colorado, Alan Johnson and Alexander Oram unlawfully, feloniously, and knowingly sold or distributed cocaine,a schedule II controlled substance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,
mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
The offense alleged in Count Seven was committed in the manner described inPredicate Acts Ten and Eleven.
Distribution of a Controlled Substance – Schedule II –COUNT EIGHT
25 to 450 Grams, (F3)
On or about August 16, 2011, in the State of Colorado, Alan Johnson and
Alexander Oram unlawfully, feloniously, and knowingly sold or distributed cocaine,a schedule II controlled substance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
The offense alleged in Count Eight was committed in the manner described inPredicate Acts Twelve and Thirteen.
Distribution of a Controlled Substance – Schedule II, (F3)COUNT NINE
On or about August 24, 2011, in the State of Colorado, Anthony Harvey unlawfully,feloniously, and knowingly sold or distributed cocaine, a schedule II controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Possession with Intent to Distribute a Controlled Substance, (F3)COUNT TEN
On or about August 24, 2011, in the State of Colorado, Alan Johnson and Alexander Oram unlawfully, feloniously, and knowingly possessed with intent todistribute a material, compound, mixture, or preparation that contained cocaine, aschedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A),(3),C.R.S.
The offenses alleged in Counts Nine and Ten were committed in the mannerdescribed in Predicate Acts Fourteen through Sixteen.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT ELEVEN
On or about August 26, 2011, in the State of Colorado, Anthony Harvey and
Abdon Loya-Sanchez unlawfully, feloniously, and knowingly conspired with eachother, to sell or distribute cocaine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Eleven was committed in the manner described inPredicate Acts Seventeen and Eighteen.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT TWELVE
On or about August 27, 2011, in the State of Colorado, Anthony Harvey, Alan
Johnson and Alexander Oram unlawfully, feloniously, and knowingly conspiredwith each other, to sell or distribute cocaine, a schedule II controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Twelve was committed in the manner described inPredicate Acts Nineteen and Twenty.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT THIRTEEN
On or about September 3, 2011, in the State of Colorado, Anthony Harvey andAlexander Oram unlawfully, feloniously, and knowingly conspired with each other,
to sell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Thirteen was committed in the manner described inPredicate Acts Twenty-One and Twenty-Two.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT FOURTEEN
On or about September 6, 2011, in the State of Colorado, Anthony Harvey andStuart Knowles unlawfully, feloniously, and knowingly conspired with each other, tosell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Fourteen was committed in the manner described inPredicate Acts Twenty-Three and Twenty-Four.
COUNT FIFTEENDistribution of a Controlled Substance – Schedule II, (F3)
On or about September 8, 2011, in the State of Colorado, Francisco Valencia
unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Distribution of a Controlled Substance – Schedule II –COUNT SIXTEEN
25 to 450 Grams, (F3)
On or about September 8, 2011, in the State of Colorado, Joseph Vittumunlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule IIcontrolled substance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
The offenses alleged in Counts Fifteen and Sixteen were committed in the mannerdescribed in Twenty-Five and Twenty-Six.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT SEVENTEEN
Between the dates of September 8 through September 13, 2011, in the State ofColorado, Daniel Galvan and Francisco Valencia unlawfully, feloniously, and
knowingly conspired with each other, to sell or distribute cocaine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Seventeen was committed in the manner described inPredicate Acts Twenty-Seven and Twenty-Eight.
COUNT EIGHTEENConspiracy to Distribute a Controlled Substance – Schedule II, (F3)
Between the dates of September 19 through September 20, 2011, in the State ofColorado, Daniel Galvan and Stuart Knowles unlawfully, feloniously, andknowingly conspired with each other, to sell or distribute cocaine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
COUNT NINETEENDistribution of a Controlled Substance – Schedule II, (F3)
On or about September 20, 2011, in the State of Colorado, Daniel Galvanunlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Possession with Intent to Distribute a Controlled Substance, (F3)COUNT TWENTY
On or about September 20, 2011, in the State of Colorado, Stuart Knowlesunlawfully, feloniously, and knowingly possessed with intent to distribute a material,compound, mixture, or preparation that contained cocaine, a schedule II controlledsubstance, in violation of section 18-18-405(1),(2)(a)(I)(A),(3), C.R.S.
The offenses alleged in Counts Eighteen, Nineteen, and Twenty were committed inthe manner described in Predicate Acts Twenty-Nine, Thirty, Thirty-One, and Thirty
Two.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT TWENTY-ONE
On or about September 24, 2011, in the State of Colorado, Anthony Harvey andAbdon Loya-Sanchez unlawfully, feloniously, and knowingly conspired with each
other, to sell or distribute cocaine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
Distribution of a Controlled Substance – Schedule II, (F3)COUNT TWENTY-TWO
On or about September 24, 2011, in the State of Colorado, Abdon Loya-Sanchez unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Possession with Intent to Distribute a Controlled Substance, (F3)COUNT TWENTY-THREE
On or about September 24, 2011, in the State of Colorado, Anthony Harveyunlawfully, feloniously, and knowingly possessed with intent to distribute a material,compound, mixture, or preparation that contained cocaine, a schedule II controlledsubstance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offenses alleged in Counts Twenty-One, Twenty-Two, and Twenty-Three werecommitted in the manner described in Predicate Acts Thirty-Three, Thirty-Four,Thirty-Five and Thirty-Six.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Distribution of a Controlled Substance – Schedule II, (F3)COUNT TWENTY-FOUR
On or about May 12, 2011, in the State of Colorado, Anthony Embry unlawfully,feloniously, and knowingly sold or distributed cocaine, a schedule II controlled
substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Twenty-Four was committed in the following manner:
On May 12, 2011, Anthony Embry sold 3.6 grams of cocaine to an undercoverofficer at 3035 W. Prospect Road in Fort Collins.
Distribution of a Controlled Substance – Schedule II, (F3)COUNT TWENTY-FIVE
On or about May 26, 2011, in the State of Colorado, Quentin Wallace unlawfully,feloniously, and knowingly sold or distributed cocaine, a schedule II controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Distribution of a Controlled Substance – Schedule II, (F3)COUNT TWENTY-SIX
On or about May 26, 2011, in the State of Colorado, Anthony Embry unlawfully,feloniously, and knowingly sold or distributed cocaine, a schedule II controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offenses alleged in Count Twenty-Five and Twenty-Six were committed in thefollowing manner:
On May 26, 2011, Quentin Wallace delivered a quantity of cocaine to AnthonyEmbry at 3035 W. Prospect Road in Fort Collins. Then, Anthony Embry sold 4.3grams of cocaine to an undercover officer.
Distribution of a Controlled Substance – Schedule II, (F3)COUNT TWENTY-SEVEN
On or about June 3, 2011, in the State of Colorado, Andre Isler unlawfully,
feloniously, and knowingly sold or distributed cocaine, a schedule II controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Distribution of a Controlled Substance – Schedule II, (F3)COUNT TWENTY-EIGHT
On or about June 3, 2011, in the State of Colorado, Anthony Embry unlawfully,feloniously, and knowingly sold or distributed cocaine, a schedule II controlled
substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offenses alleged in Counts Twenty-Seven and Twenty-EIght were committed inthe following manner:
On June 3, 2011, Andre Isler delivered a quantity of cocaine to Anthony Embry at1957 Pecan Street, Fort Collins. Then, Anthony Embry sold 7.7 grams of cocaine toan undercover officer at 3035 W. Prospect Road in Fort Collins.
Distribution of a Controlled Substance – Schedule II, (F3)COUNT TWENTY-NINE
On or about June 24, 2011, in the State of Colorado, Ronald Munguia-Martin unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Possession with Intent to Distribute a Controlled Substance, (F3)COUNT THIRTY
On or about June 24, 2011, in the State of Colorado, Gerald Lamaster unlawfully,feloniously, and knowingly possessed with intent to distribute a material, compound,
mixture, or preparation that contained cocaine, a schedule II controlled substance, inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Possession of a Controlled Substance – Schedule II, (F6)COUNT THIRTY-ONE
On or about June 24, 2011, in the State of Colorado, Gerald Lamaster unlawfully,feloniously, and knowingly possessed a material, compound, mixture, or preparationthat contained oxycodone, a schedule II controlled substance, in violation of section18-18-403.5(1),(2)(a)(I), C.R.S.
The offenses alleged in Counts Twenty-Nine through Thirty-One were committed inthe following manner:
On June 24, 2011, Ronald Munguia-Martin sold a quantity of cocaine to GeraldLamaster in the parking lot of Safeway at 860 Cleveland Ave. in Loveland. Shortlythereafter, law enforcement officers recovered a quarter-ounce of cocaine and 14Oxycodone pills from Gerald Lamaster.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT THIRTY-TWO
On or about August 24, 2011, in the State of Colorado, Anthony Harvey and DerekDurica unlawfully, feloniously, and knowingly conspired with each other, to sell or
distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Thirty-Two was committed in the manner described inPredicate Acts Thirty-Eight and Thirty-Nine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT THIRTY-THREE
On or about August 24, 2011, in the State of Colorado, Anthony Harvey and CarlHayes unlawfully, feloniously, and knowingly conspired with each other, to sell ordistribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Thirty-Three was committed in the manner describedin Predicate Acts Forty and Forty-One.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT THIRTY-FOUR
On or about August 24, 2011, in the State of Colorado, Anthony Harvey and Kamal
Patterson unlawfully, feloniously, and knowingly conspired with each other, to sellor distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Thirty-Four was committed in the manner described inPredicate Acts Forty-Two and Forty-Three.
COUNT THIRTY-FIVEConspiracy to Distribute a Controlled Substance – Schedule II, (F3)
On or about August 26, 2011, in the State of Colorado, Anthony Harvey and Derek
Durica unlawfully, feloniously, and knowingly conspired with each other, to sell ordistribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Thirty-Five was committed in the manner described inPredicate Acts Forty-Four and Forty-Five.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Possession of a Dangerous Weapon, (F5)COUNT THIRTY-SIX
On or about September 1, 2011, in the State of Colorado, Jerome Nelsonunlawfully, feloniously, and knowingly possessed a dangerous weapon, namely: aWinchester 12-gauge pump short shotgun; in violation of section 18-12-102(3),
C.R.S.
The offense alleged in Count Thirty-Six was committed in the following manner:
On or about September 1, 2011, Jerome Nelson possessed a Winchester shortshotgun that he ultimately concealed in the frame of a vehicle located at 200Commerce Drive, Unit #G, Fort Collins, CO.
COUNT THIRTY-SEVENConspiracy to Distribute a Controlled Substance – Schedule II, (F3)
On or about September 2, 2011, in the State of Colorado, Anthony Harvey andDerek Durica unlawfully, feloniously, and knowingly conspired with each other, tosell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Thirty-Seven was committed in the manner describedin Predicate Acts Forty-Six and Forty-Seven.
Distribution of a Controlled Substance – Schedule II, (F3)COUNT THIRTY-EIGHT
On or about September 3, 2011, in the State of Colorado, Anthony Harveyunlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Possession of a Controlled Substance – Schedule II, (F6)COUNT THIRTY-NINE
On or about September 3, 2011, in the State of Colorado, Matthew Bekkerusunlawfully, feloniously, and knowingly possessed a material, compound, mixture, orpreparation that contained cocaine, a schedule II controlled substance, in violation of
section 18-18-403.5(1),(2)(a)(I), C.R.S.
The offenses alleged in Counts Thirty-Eight and Thirty-Nine were committed in themanner described in Predicate Act Forty-Eight.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT FORTY
On or about September 3, 2011, in the State of Colorado, Anthony Harvey andGary Lihudis unlawfully, feloniously, and knowingly conspired with each other, to
sell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Forty was committed in the manner described inPredicate Acts Forty-Nine and Fifty.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT FORTY-ONE
Between the dates of September 3, 2011, and September 10, 2011, in the State ofColorado, Anthony Harvey and Maria Moreno unlawfully, feloniously, andknowingly conspired with each other, to sell or distribute cocaine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Forty-One was committed in the manner described inPredicate Acts Fifty-One and Fifty-Two.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT FORTY-TWO
On or about September 7, 2011, in the State of Colorado, Anthony Harvey and
Jerome Nelson unlawfully, feloniously, and knowingly conspired with each other, tosell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Forty-Two was committed in the manner described inPredicate Acts Fifty-Three and Fifty-Four
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT FORTY-THREE
On or about September 7, 2011, in the State of Colorado, Anthony Harvey and
Quentin Wallace unlawfully, feloniously, and knowingly conspired with each other,to sell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Distribution of a Controlled Substance – Schedule II, (F3)COUNT FORTY-FOUR
On or about September 7, 2011, in the State of Colorado, Anthony Harveyunlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II
controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Possession with Intent to Distribute a Controlled Substance, (F3)COUNT FORTY-FIVE
On or about September 7, 2011, in the State of Colorado, Quentin Wallaceunlawfully, feloniously, and knowingly possessed with intent to distribute a material,compound, mixture, or preparation that contained cocaine, a schedule II controlledsubstance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offenses alleged in Counts Forty-Three through Forty-Five were committed inthe manner described in Predicate Acts Fifty-Five through Fifty-Seven.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT FORTY-SIX
On or about September 9, 2011, in the State of Colorado, Anthony Harvey andGary Lihudis unlawfully, feloniously, and knowingly conspired with each other, tosell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Forty-Six was committed in the manner described inPredicate Acts Fifty-Eight and Fifty-Nine.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT FORTY-SEVEN
On or about September 9, 2011, in the State of Colorado, Anthony Harvey andMichael McCain unlawfully, feloniously, and knowingly conspired with each other, tosell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Forty-Seven was committed in the manner describedin Predicate Acts Sixty and Sixty-One.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT FORTY-EIGHT
On or about September 14, 2011, in the State of Colorado, Anthony Harvey andDerek Durica unlawfully, feloniously, and knowingly conspired with each other, to
sell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Forty-Eight was committed in the manner described inPredicate Acts Sixty-Two and Sixty-Three.
Distribution of Marijuana – Between 5 and 100 Pounds, (F4)COUNT FORTY-NINE
On or about September 20, 2011, in the State of Colorado, Abdon Loya-Sanchezand Anthony Harvey, unlawfully, feloniously, and knowingly sold or distributed, orattempted to sell or distribute, marijuana or marijuana concentrate.
Further, the amount was at least five pounds but not more than one hundred poundsof marijuana; in violation of section 18-18-406(6)(b)(I), (III)(B), C.R.S
Possession with Intent to Distribute Marijuana –COUNT FIFTY
Between 5 and 100 Pounds, (F4)
On or about September 20, 2011, in the State of Colorado, Brian Butler, unlawfully,
feloniously, and knowingly possessed or attempted to possess, with intent to sell ordistribute marijuana or marijuana concentrate.
Further, the amount was at least five pounds but not more than one hundred poundsof marijuana; in violation of section 18-18-406(6)(b)(I), (III)(B), C.R.S
The offenses alleged in Counts Forty-Nine and Fifty were committed in the mannerdescribed in Predicate Act Sixty-Four.
Possession with Intent to Distribute a Controlled Substance –COUNT FIFTY-ONE
25 to 450 Grams, (F3)
On or about September 30, 2011, in the State of Colorado, Leobardo Loyaunlawfully, feloniously, and knowingly possessed with intent to distribute a material,compound, mixture, or preparation that contained cocaine, a schedule II controlledsubstance.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
Possession with Intent to Distribute a Controlled Substance, (F3)COUNT FIFTY-TWO
On or about September 30, 2011, in the State of Colorado, Leobardo Loyaunlawfully, feloniously, and knowingly possessed with intent to distribute a material,compound, mixture, or preparation that contained methamphetamine, a schedule IIcontrolled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offenses alleged in Counts Fity-One and Fifty-Two were committed in themanner described in Predicate Acts Sixty-Five and Sixty-Six.
Possession with Intent to Distribute a Controlled Substance, (F3)COUNT FIFTY-THREE
On or about September 30, 2011, in the State of Colorado, Abdon Loya-Sanchezunlawfully, feloniously, and knowingly possessed with intent to distribute a material,compound, mixture, or preparation that contained cocaine, a schedule II controlledsubstance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Fifty-Three was committed in the manner described inPredicate Act Sixty-Seven.
Possession with Intent to Distribute Marijuana –COUNT FIFTY-FOUR
Between 5 and 100 Pounds, (F4)
On or about September 30, 2011, in the State of Colorado, Abdon Loya-Sanchez, unlawfully, feloniously, and knowingly possessed or attempted to possess, withintent to sell or distribute marijuana or marijuana concentrate.
Further, the amount was at least five pounds but not more than one hundred poundsof marijuana; in violation of section 18-18-406(6)(b)(I), (III)(B), C.R.S
The offense alleged in Count Fifty-Four was committed in the manner described inPredicate Act Sixty-Eight.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Distribution of a Controlled Substance – Schedule II –COUNT FIFTY-FIVE
25 to 450 Grams, (F3)
On or about September 29, 2011, in the State of Colorado, Tony Romero
unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule IIcontrolled substance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
The offense alleged in Count Fifty-Five was committed in the following manner:
On or about September 29, 2011, Tony Romero delivered approximately 477.4grams of cocaine to Alexander Oram at Anthony Harvey’s shop located at 204Commerce Drive, Unit D/E, Fort Collins, CO.
Possession with Intent to Distribute a Controlled Substance –COUNT FIFTY-SIX
450 to 1000 Grams, (F3)
On or about September 30, 2011, in the State of Colorado, Alexander Oramunlawfully, feloniously, and knowingly possessed with intent to distribute a material,compound, mixture, or preparation that contained cocaine, a schedule II controlled
substance.
Further, the amount was or had been represented to be at least four hundred-fiftygrams but not more than one thousand grams or one kilogram of a material,compound, mixture, or preparation that contained the controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S.
The offense alleged in Count Fifty-Six was committed in the manner described inPredicate Act Sixty-Nine.
Special Offender – Deadly Weapon
COUNT FIFTY-SEVEN
On or about September 30, 2011, in the State of Colorado, Alexander Oramcommitted the felony offense charged in Count Fifty-Six and used, displayed,possessed on his person or within his immediate reach, a deadly weapon, namely: aKel-Tec .380 caliber pistol; in violation of section 18-18-407(1)(f)(I), C.R.S.
The offense charged in Count Fifty-Seven was committed in the following manner:
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
On September 30, 2011, law enforcement officers recovered a Kel-Tec .380 caliberpistol within close proximity of 477.4 grams of cocaine from the residence ofAlexander Oram at 1025 Cunningham, #C-6, Fort Collins, CO.
COUNT FIFTY-EIGHT
Possession with Intent to Distribute a Controlled Substance –450 to 1000 Grams, (F3)
On or about September 30, 2011, in the State of Colorado, Francisco Valenciaunlawfully, feloniously, and knowingly possessed with intent to distribute a material,compound, mixture, or preparation that contained cocaine, a schedule II controlledsubstance.
Further, the amount was or had been represented to be at least four hundred-fiftygrams but not more than one thousand grams or one kilogram of a material,compound, mixture, or preparation that contained the controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S.
The offense alleged in Count Fifty-Eight was committed in the manner described inPredicate Act Seventy.
Special Offender – Deadly WeaponCOUNT FIFTY-NINE
On or about September 30, 2011, in the State of Colorado, Francisco Valenciacommitted the felony offense charged in Count Fifty-Eight and used, displayed,
possessed on his person or within his immediate reach, a deadly weapon, namely: a.40 caliber pistol; in violation of section 18-18-407(1)(f)(I), C.R.S.
The offense charged in Count Fifty-Nine was committed in the following manner:
On September 30, 2011, law enforcement officers recovered a .40 caliber pistol fromFrancisco Valencia’s bedroom in his residence at 1007 Whalers Way, Fort Collins,CO, within close proximity of 686 grams of cocaine that Valencia possessed in orderto distribute to his customers.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Possession of a Weapon by a Previous Offender (F6)COUNT SIXTY
On or about September 30, 2011, in the State of Colorado, Bernardino Mendozaunlawfully, feloniously, and knowingly possessed, used, or carried upon [his] person
a firearm or other weapon, namely: Tech 9 handgun, and Bernardino Mendoza waspreviously convicted of a felony, namely: First Degree Criminal Trespass, on July15, 2008; in violation of section 18-12-108(1), C.R.S.
The offense alleged in Count Sixty was committed in the following manner:
On September 30, 2011, law enforcement officers recovered a Tech 9 handgun fromBernardino Mendoza’s bedroom in his residence at 1007 Whalers Way, Fort Collins,CO. Mendoza was previously convicted of a felony, namely: First Degree CriminalTrespass, on July 15, 2008, in Larimer County Case No. 08 CR 867.
Cultivation of Marijuana, (F4)COUNT SIXTY-ONE
On or about September 30, 2011, in the State of Colorado, Daniel Galvan, unlawfully, knowingly, and feloniously cultivated, grew, produced, processed, ormanufactured marijuana or marijuana concentrate, or allowed marijuana ormarijuana concentrate to be cultivated, grown, produced, processed, ormanufactured on land owned, occupied, or controlled by the defendant; in violationof section 18-18-406(7.5)(c), C.R.S.
The offense alleged in Count Sixty-One was committed in the following manner:
On September 30, 2011, law enforcement officers located a marijuana growconsisting of 58 plants in the residence of Daniel Galvan at 2430 Leghorn, FortCollins, CO.
Distribution of a Controlled Substance – Schedule II, (F3)COUNT SIXTY-TWO
On or about June 23, 2011, in the State of Colorado, Andre Isler and AnthonyEmbry unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule
II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Sixty-Two was committed in the following manner:
On June 23, 2011, Andre Isler delivered a quantity of cocaine to Anthony who thensold 7.6 grams of cocaine to an undercover officer at 3035 W. Prospect Road in FortCollins.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT SIXTY-THREE
On or about September 24, 2011, in the State of Colorado, Anthony Harvey andTony Romero unlawfully, feloniously, and knowingly conspired with each other, to
sell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT SIXTY-FOUR
On or about September 24, 2011, in the State of Colorado, Anthony Harvey andStuart Knowles unlawfully, feloniously, and knowingly conspired with each other, tosell or distribute cocaine and oxycodone, both schedule II controlled substances; inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offenses charged in Counts Sixty-Three and Sixty-Four were committed in themanner described in Predicate Acts Seventy-One through Seventy-Three.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT SIXTY-FIVE
On or about September 24, 2011, in the State of Colorado, Abdon Loya-Sanchezand Adrian Hernandez unlawfully, feloniously, and knowingly conspired with eachother, to sell or distribute cocaine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
Distribution of a Controlled Substance – Schedule II –COUNT SIXTY-SIX
25 to 450 Grams, (F3)
On or about September 24, 2011, in the State of Colorado, Abdon Loya-Sanchezunlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule IIcontrolled substance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,
mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Possession with Intent to Distribute a Controlled Substance – Schedule II –COUNT SIXTY-SEVEN
25 to 450 Grams, (F3)
On or about September 24, 2011, in the State of Colorado, Adrian Hernandez
unlawfully, feloniously, and knowingly possessed with intent to distribute cocaine, aschedule II controlled substance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
The offenses charged in Counts Sixty-Five through Sixty-Seven were committed inthe manner described in Predicate Acts Seventy-Four through Seventy-Seven.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT SIXTY-EIGHT
On or about September 23, 2011, in the State of Colorado, Abdon Loya-Sanchezand Alejandro Uribe unlawfully, feloniously, and knowingly conspired with eachother, to sell or distribute cocaine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense charged in Count Sixty-Eight was committed in the manner described inPredicate Acts Seventy-Eight and Seventy-Nine.
Distribution of a Controlled Substance – Schedule II –COUNT SIXTY-NINE
25 to 450 Grams, (F3)
On or about May 3, 2011, in the State of Colorado, Alan Johnson unlawfully,feloniously, and knowingly sold or distributed cocaine, a schedule II controlledsubstance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,
mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
The offense alleged in Count Sixty-Nine was committed in the manner described inPredicate Acts Eighty and Eighty-One.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Distribution of a Controlled Substance – Schedule II –COUNT SEVENTY
25 to 450 Grams, (F3)
On or about June 17, 2011, in the State of Colorado, Alan Johnson unlawfully,
feloniously, and knowingly sold or distributed cocaine, a schedule II controlledsubstance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
The offense alleged in Count Seventy was committed in the manner described inPredicate Acts Eighty-Two and Eighty-Three.
Distribution of a Controlled Substance – Schedule II, (F3)COUNT SEVENTY-ONE
On or about August 3, 2011, in the State of Colorado, Alan Johnson unlawfully,feloniously, and knowingly sold or distributed methamphetamine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Distribution of a Controlled Substance – Schedule II, (F3)COUNT SEVENTY-TWO
On or about August 3, 2011, in the State of Colorado, Jimmie Joe Montgomeryunlawfully, feloniously, and knowingly sold or distributed methamphetamine, aschedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),C.R.S.
The offenses alleged in Counts Seventy-One and Seventy-Two were committed inthe manner described in Predicate Acts Eighty-Four and Eighty-Five.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT SEVENTY-THREE
Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado,Alan Johnson and Kenneth West unlawfully, feloniously, and knowingly conspiredwith each other, to sell or distribute cocaine, a schedule II controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Distribution of a Controlled Substance – Schedule II, (F3)COUNT SEVENTY-FOUR
Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado,Alan Johnson unlawfully, feloniously, and knowingly sold or distributed cocaine, a
schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),C.R.S.
Possession with Intent to Distribute a Controlled Substance, (F3)COUNT SEVENTY-FIVE
Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado,Kenneth West unlawfully, feloniously, and knowingly possessed with intent todistribute a material, compound, mixture, or preparation that contained cocaine, aschedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A),C.R.S.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT SEVENTY-SIX
Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado,Alan Johnson and Mark Fraleigh unlawfully, feloniously, and knowingly conspiredwith each other, to sell or distribute cocaine, a schedule II controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)
COUNT SEVENTY-SEVEN
Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado,Alan Johnson and Mitchell Morris unlawfully, feloniously, and knowingly conspiredwith each other, to sell or distribute cocaine, a schedule II controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offenses alleged in Counts Seventy-Three through Seventy-Seven werecommitted in the manner described in Predicate Acts Eighty-Six through Ninety-One.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT SEVENTY-EIGHT
On or about August 12, 2011, in the State of Colorado, Alan Johnson and HoracioBugarin unlawfully, feloniously, and knowingly conspired with each other, to sell or
distribute methamphetamine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Seventy-Eight was committed in the manner describedin Predicate Acts Ninety-Two and Ninety-Three.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT SEVENTY-NINE
On or about August 14, 2011, in the State of Colorado, Alan Johnson and ShawnBlea unlawfully, feloniously, and knowingly conspired with each other, to sell ordistribute methamphetamine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Seventy-Nine was committed in the manner describedin Predicate Acts Ninety-Four and Ninety-Five.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT EIGHTY
On or about August 15, 2011, in the State of Colorado, Alan Johnson and Anthony
Harvey unlawfully, feloniously, and knowingly conspired with each other, to sell ordistribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Eighty was committed in the manner described inPredicate Acts Ninety-Six and Ninety-Seven.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT EIGHTY-ONE
On or about August 16, 2011, in the State of Colorado, Alan Johnson and Jimmie
Joe Montgomery unlawfully, feloniously, and knowingly conspired with each other,to sell or distribute methamphetamine, a schedule II controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged Count Eighty-One was committed in the manner described inPredicate Acts Ninety-Eight and Ninety-Nine.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT EIGHTY-TWO
On or about August 16, 2011, in the State of Colorado, Alan Johnson and HoracioBugarin unlawfully, feloniously, and knowingly conspired with each other, to sell or
distribute methamphetamine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in County Eighty-Two was committed in the manner describedin Predicate Acts One Hundred and One Hundred-One.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT EIGHTY-THREE
On or about August 21, 2011, in the State of Colorado, Alan Johnson and HoracioBugarin unlawfully, feloniously, and knowingly conspired with each other, to sell ordistribute methamphetamine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Eighty-Three was committed in the manner describedin Predicate Acts One Hundred-Two and One Hundred-Three.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT EIGHTY-FOUR
On or about August 24, 2011, in the State of Colorado, Alan Johnson and Horacio
Bugarin unlawfully, feloniously, and knowingly conspired with each other, to sell ordistribute methamphetamine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
Distribution of a Controlled Substance – Schedule II, (F3)COUNT EIGHTY-FIVE
On or about August 24, 2011, in the State of Colorado, Horacio Bugarin unlawfully,feloniously, and knowingly sold or distributed methamphetamine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Possession with Intent to Distribute a Controlled Substance, (F3)COUNT EIGHTY-SIX
On or about August 24, 2011, in the State of Colorado, Alan Johnson unlawfully,feloniously, and knowingly possessed with intent to distribute a material, compound,
mixture, or preparation that contained methamphetamine, a schedule II controlledsubstance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offenses alleged in Counts Eighty-Four through Eighty-Six were committed inthe manner described in Predicate Acts One Hundred-Four though One Hundred-Seven.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT EIGHTY-SEVEN
On or about August 26, 2011, in the State of Colorado, Alan Johnson and AnthonyHarvey unlawfully, feloniously, and knowingly conspired with each other, to sell ordistribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Distribution of a Controlled Substance – Schedule II, (F3)COUNT EIGHTY-EIGHT
On or about August 26, 2011, in the State of Colorado, Anthony Harvey unlawfully,feloniously, and knowingly sold or distributed cocaine, a schedule II controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
Possession with Intent to Distribute a Controlled Substance, (F3)COUNT EIGHTY-NINE
On or about August 26, 2011, in the State of Colorado, Alan Johnson unlawfully,feloniously, and knowingly possessed with intent to distribute a material, compound,mixture, or preparation that contained cocaine, a schedule II controlled substance, inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offenses alleged in Counts Eighty-Seven through Eighty-Nine were committedin the manner described in Predicate Acts One Hundred-Eight through One
Hundred-Eleven.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT NINETY
On or about September 19, 2011, in the State of Colorado, Alan Johnson and Anthony Harvey unlawfully, feloniously, and knowingly conspired with each other,
to sell or distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense alleged in Count Ninety was committed in the manner described inPredicate Acts One Hundred-Twelve and One Hundred-Thirteen.
Distribution of a Schedule II Controlled Substance –COUNT NINETY-ONE
450 to 1000 Grams, (F3)
On or about September 29, 2011, in the State of Colorado, Alan Johnson
unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule IIcontrolled substance.
Further, the amount was or had been represented to be at least four hundred-fiftygrams but not more than one thousand grams or one kilogram of a material,compound, mixture, or preparation that contained the controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S.
The offense charged in Count Ninety-One was committed in the manner describedin Predicate Act One Hundred-Fourteen.
Possession with Intent to Distribute a Controlled Substance –COUNT NINETY-TWO
Schedule II – 450 to 1000 Grams, (F3)
On or about September 30, 2011, in the State of Colorado, Horacio Bugarinunlawfully, feloniously, and knowingly possessed with intent to distributemethamphetamine, a schedule II controlled substance.
Further, the amount was or had been represented to be at least four hundred-fiftygrams but not more than one thousand grams or one kilogram of a material,
compound, mixture, or preparation that contained the controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S.
5/10/2018 Northern Colo Drug Ring Indictment - slidepdf.com
Possession with Intent to Distribute a Controlled Substance –COUNT NINETY-THREE
Schedule II – 25 to 450 Grams, (F3)
On or about September 30, 2011, in the State of Colorado, Horacio Bugarin
unlawfully, feloniously, and knowingly possessed with intent to distribute cocaine, aschedule II controlled substance.
Further, the amount was or had been represented to be at least twenty-five gramsbut not more than four hundred-fifty grams or one pound of a material, compound,mixture, or preparation that contained the controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.
The offenses charged in Counts Ninety-Two and Ninety-Three was committed in themanner described in Predicate Acts One Hundred-Fifteen and One Hundred-Sixteen.
Special Offender – Deadly WeaponCOUNT NINETY-FOUR
On or about September 30, 2011, in the State of Colorado, Horacio Bugarincommitted the felony offenses charged in Counts Thirty and Thirty-One and used,displayed, possessed on his person or within his immediate reach, a deadlyweapon, namely: a Glock 27 .40 caliber pistol; in violation of section 18-18-407(1)(f)(I), C.R.S.
The offense charged in Count Ninety-Four was committed in the following manner:
On September 30, 2011, law enforcement officers recovered a .40 caliber pistol inclose proximity to a large quantity of methamphetamine and cocaine from HoracioBugarin’s residence at Juniper Place, Loveland, CO.
Conspiracy to Distribute a Controlled Substance – Schedule II, (F3)COUNT NINETY-FIVE
On or about September 13, 2011, in the State of Colorado, Abdon Loya-Sanchezand Alejandro Uribe unlawfully, feloniously, and knowingly conspired with each
other, to sell or distribute cocaine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.
The offense charged in Count Ninety-Five was committed in the manner describedin Predicate Acts One Hundred-Seventeen and One Hundred-Eighteen.
