Mewbourn et al. indictment - Colorado Attorney General

Centennial, Colorado 80112Plaintiff,THE PEOPLE OF THE STATE OF COLORADO,7325 South Potomac Street_____________COLORADO STATE GRAND JURY INDICTMENTDefendants.JODY PILMER,Assistant Attorneys General* Ctrm.:Registration Numbers:JOHN W. SUTHERS, Attorney GeneralSTEVEN FRITZ,Denver, CO 80203Jody Pi!mer 31347(303) 866-4500Steven Fritz 41074*Counsel of Record1525 Sherman Street, 7th FloorCase No.:COURT USE ONLYAKA: Vesse W. Sellers; Jessie Sellers; Debbye SellersJESSE WAYNE SELLERS D.O.B. 10/11/84AKA:JOHN LEVI SMITH D.O.B. 12/23/83AKA: Jim EsquibelJAMES ALBERT ESQUIBEL D.O.B. 5/30/59AKA: Walts Smith; Bruce SmithWALTER BRUCE SMITH D.O.B. 3/15/60Johnson; Melissa Ann GillespieAKA: Melissa Ann Frost; Stacy Hoffman; Melissa AnnMELISSA ANN GILLISPIE D.O.B. 1/23/77Troy Mickel; Mike! Troy MewbourneAKA: Mikel Troy Jameson; Mikel Troy Jamison; MikelMIKEL TROY MEWBOURN D.O.B. 03/10/70V.DISTRICT COURT,ARAPAHOE COUNTY, COLORADO

Mikel MewbournCOUNT TWO: THEFT § 18-4-401(1), (2)(d) C.R.S. (F-3) 10801 VIMikel Mewbourn, Melissa Gillispie, Walter Smith1372841Mike! Mewbourn, Melissa GillispieICON 0801 VI§ 18-4-401(1 ),(2)(d); 18-2-201 C.R.S. (F4)COUNT TWELVE: CONSPIRACY TO COMMIT THEFTMikel Mewbourn, Melissa GillispieCOUNT ELEVEN: THEFT § 18-4-401(1),(2)(d) C.R.S. (F3) 10801 VIMikel Mewbourn§ 18-8-707 C.R.S (F4) 1261211COUNT TEN: TAMPERING WITH A WITNESS OR VICTIMMikel Mewbourn§ 18-8-610(1)(a) C.R.S. (F6) 1260621COUNT NINE: TAMPERING WITH PHYSICAL EVIDENCEMikel MewbournOFFENDER § 18-12-108(1) C.R.S. (F6) 13007A1COUNT EIGHT: POSSESSION OF A WEAPON BY A PREVIOUSMikel Mewbourn, Walter SmithTHE FIRST DEGREE §18-4-409(2),(3)(b) C.R.S.COUNT SEVEN: AGGRAVATED MOTOR VEHICLE THEFT IN(F3) 10804B1Mike! MewbournSERVANT § 18-8-306 C.R.S. (F-4) 1240511COUNT SIX: ATTEMPT TO INFLUENCE A PUBLICMikel MewboumCOUNT FIVE: THEFT § 18-4-401(1),(2)(c), C.R.S. (F-4) 10801U1Mikel Mewbourn§18-5.5-102(1)(d) C.R.S. (F4) 1150A1 ICOUNT FOUR: COMPUTER CRIME - COMMIT THEFTMikel MewbournCOUNT THREE: THEFT § 18-4-401(1),(2)(c) C.R.S. (F-4) 10801 UICRIME CONTROL ACT § 18-17-104(3) C.R.S. (F2)COUNT ONE: VIOLATION OF COLORADO ORGANIZED

Mikel MewbournIATT 0801U1SERVANT, § 18-8-306 C.R.S. (F4) [240511COUNT TWENTY-THREE: ATTEMPT TO INFLUENCE A PUBLICMikel Mewboum, Melissa Gillispie, Jesse Sellers[0901E1COUNT TWENTY-TWO: CRIMINAL MISCHIEF § 18-4-501 C.R.S. (F4)Mikel Mewbourn, Melissa Gillispie, Jesse Sellers[CON 0801 VI§ 18-4-401(1), (2)(d);18-2-201 C.R.S. (F4)COUNT TWENTY-ONE: CONSPIRACY TO COMMIT THEFTMikel Mewbourn, Melissa Gillispie, Jesse Sellers[ATT 0801 VI§ 18-4-401(1)(a), (2)(d);18-2-101 C.R.S. (F4)COUNT TWENTY: CRIMINAL ATTEMPT TO COMMIT THEFTMikel Mewboum, John SmithCOUNT NINETEEN: FORGERY § 18-5-102(1)(c) C.R.S. (F5) [IOO1CJMikel Mewbourn, Walter Smith, John Smith[CON 0801U1§ 18-4-401(1), (2)(d);18-2-201 C.R.S. (F5)COUNT EIGHTEEN: CONSPIRACY TO COMMIT THEFTMikel Mewboum, Walter Smith, John Smith[ATT 0801U1§ 18-4-401(1),(2)(c); 18-2-101 C.R.S. (F5)COUNT SEVENTEEN: CRIMINAL ATTEMPT TO COMMIT THEFTMikel MewbournCOUNT SIXTEEN: THEFT § 18-4-401(1),(2)(d) C.R.S. (F3) [0801 VI§ 18-4-401(1), (2)(d);18-2-201 C.R.S. (F4)COUNT FIFTEEN: CONSPIRACY TO COMMIT THEFTMikel Mewboum, James Esquibel, Melissa GillispieICON 0801 VIMikel Mewbourn, James Esquibel, Melissa GillispieCOUNT FOURTEEN: THEFT § 18-4-401(1),(2)(d) C.R.S. (F3) [0801 VI§ 18-4-401(1), (2)(c); 18-2-101 C.R.S. (F5)COUNT THIRTEEN: CRIMINAL ATTEMPT TO COMMIT THEFT

Mike! Mewbourn, Jesse SellersCOUNT TWENTY-FOUR:VIOLATION OF BAIL BOND CONDITIONS§ 18-8-212(1) C.R.S. (F6) 1231421Mike! Mewbourri

1437 Bannock Street_____________1COLORADO STATE GRAND JURY INDICTMENTof RecordSteven Fritz 41074Assistant Attorneys General* Ctrm.:Jody Pilmer 31347JOHN W. SUTHERS, Attorney GeneralJODY PILMER,Registration Numbers:Defendants.STEVEN FRITZ,Denver, CO 80203(303) 866-45001525 Sherman Street, 7th FloorCase No•COURT USE ONLY AAKA: Vesse W. Sellers; Jessie Sellers; Debbye SellersJESSE WAYNE SELLERS D.O.B. 10/11/84AKA:JOHN LEVI SMITH D.O.B. 12/23/83AKA: Jim EsquibelJAMES ALBERT ESQUIBEL D.O.B. 5/30/59AKA: Waits Smith; Bruce SmithWALTER BRUCE SMITH D.O.B. 3/15/60Johnson; Melissa Ann GillespieAKA: Melissa Ann Frost; Stacy Hoffman; Melissa AnnMELISSA ANN GILLISPIE D.O.B. 1/23/77Troy Mickel; Mikel Troy MewbourneAKA: Mikel Troy Jameson; Mikel Troy Jamison; Mike!MIKEL TROY MEWBOURN D.O.B. 03/10/70V.Plaintiff,THE PEOPLE OF THE STATE OF COLORADO,Denver, CO 80202OF DENVER, COLORADODISTRICT COURT, CITY AND COUNTY

COUNT ONE2although not a legal entity. The enterprise included, but was not limited to, the following:WALTER SMITH, JESSE SELLERS, and other persons known or unknown, who wereassociated from time to time in racketeering activity that was related to the conduct of theMIKEL MEWBOURN, MELISSA GILLISPIE, JAMES ESQUIBEL, JOHN LEVI SMITH,enterprise.The enterprise consists of the people identified above working in concert with each otherThe enterprise alleged in this count was a group of individuals, associated in fact,filing fraudulent claims against insurance companies to obtain settlement proceeds. Thewas typically the owner, responsible party, or insured party related to a particular fraudulentwere either based upon damage to automobiles and other property that was intentionally causedMikel Mewbourn and asserted by him and other parties involved in a particular claim. The falsethe damage claims and pay money for the damaged or allegedly stolen property.fraudulent claims included damage claims from staged automobile accidents, staged automobilethefts, staged automobile hail-damage, and staged property damage. Through the course of thecriminal conduct charged in this case, the fraudulent insurance claims were not all made inidentical fashion, but had common elements including the involvement of Mikel Mewbourn andparties that he recruited in order to commit the various criminal acts required to accomplish theultimate goal of obtaining insurance proceeds for fraudulent damage claims. Mikel Mewbournclaim of damage to property and Melissa Gillispie, Walter Smith, or other named and unnamedparties assisted in the endeavor by either helping damage property, helping conceal property, orproviding false statements to investigators regarding the insurance claims. The insurance claimsor on staged thefts of property covered by insurance policies secured by Mike! Mewbourn orother participants at his urging. Each claim involved false reports and statements made byparticipants to insurance company representatives and investigators that were formulated bystatements were made by participants with the intent to cause the insurance companies to settleby the participants in the enterprise and claimed to have been the result of accidental occurencesand, from time to time, with other parties of known and unknown identity for the purpose ofThe Enterprise104(3) and § 18-17-105, C.R.S.legal entity, unlawfully, feloniously, and knowingly conducted or participated, directly orBetween and including September 1, 2007 and March 31, 2011, in the State of Colorado,MIKEL MEWBOURN, MELISSA GILLISPIE, and WALTER SMITH while employed by orassociated with an enterprise, namely: a group of individuals associated in fact, although not aindirectly, in the enterprise through a pattern of racketeering activity; in violation of § 18-17-(F2)VIOLATION OF COLORADO ORGANIZED CRIME CONTROL ACT, C.R.S. 18-17-104(3)State Grand Jurors, chosen, selected and sworn in the name and by the authority of the People ofthe State of Colorado, upon their oaths, present the following:Of the 2010-2011 term of the Denver District Court in the year of 2011, the 2010-2011

15, 16, 17, 18, 19, 20, 21, 22, 23enterprise, including:For purposes of this count, the defendants engaged in acts related to the conduct of theAs to MIKEL MEWBOURN, the acts described in counts 2, 3, 4, 5, 6, 7, 9, 10, 11, 12, 13, 14,3Between and including June 2, 2010 and July 9, 2010, in the State of Colorado, MIKELthan twenty thousand dollars; in violation of § 18-5.5-102(1 )(d), C .R.S.or thing of value taken, or cost of restoration or repair was one thousand dollars or more but lessor computer system, or any part thereof to commit theft, and the loss, damage, value of services,MEWBOURN unlawfully, feloniously, and knowingly accessed a computer, computer network,COMPUTER CRIME -COMMITTHEFT §18-5.5-102(1)(d), C.R.S. (F4)COUNT FOURBetween and including June 2, 2010 and July 9, 2010, in the State of Colorado, MIKELthing of value, namely: United States Currency, of Duram Plummer, with the value of onethousanddollars or more but less than twenty thousand dollars, without authorization, or bythreat or deception, and intended to deprive Duram Plummer permanently of its use or benefit; inviolation of § 18-4-401(1 )(a),(2)(c), C.R.S.MEWBOURN, unlawfully, feloniously, and knowingly obtained or exercised control over aTHEFT § 18-4-401(1),(2)(c), C.R.S. (F-4)COUNT THREEover a thing of value, namely: United States Currency, of State Farm Mutual InsuranceCompany, with the value of over twenty thousand dollars, without authorization, or by threat ordeception, and intended to deprive State Farm Mutual Insurance Company permanently of its useMIKEL MEWBOURN, unlawfully, feloniously, and knowingly obtained or exercised controlBetween and including September 14, 2007 and April 2, 2008, in the State of Colorado,or benefit; in violation of 18-4-401(1), (2)(d) and § 10-1-129 C.R.S,THEFT § 18-4-401(1), (2)(d), C.R.S. (F-3)COUNT TWOAs to WALTER SMITH, the acts described in counts 7, 17, 18As to MELISSA GILLISPIE, the acts described in counts 11, 12, 14, 15, 20, 21, 22Pattern of Racketeering Activity

Between and including July 10, 2010 and October 5, 2010, in the State of Colorado,over a thing of value, namely: United States Currency, of Duram Plummet, with the value ofMIKEL MEWBOURN, unlawfully, feloniously, and knowingly obtained or exercised control4unlawfully, feloniously, and knowingly possessed, used, or carried upon his person a firearm orother weapon, namely: 357 Magnum Revolver handgun and .40 caliber semiautomatic handgun,Colorado statute § 18-4-401, C.R.S., on May 10, 1990; in violation of 18-12-108(1), C.R.S.On or about October 5, 2010, in the State of Colorado, MIKEL MEWBOURNand MIKEL MEWBOURN was previously convicted of a felony, namely: Theft, as defined byPOSSESSION OF A WEAPON BY A PREVIOUS OFFENDER, § 18-12-108(1), C.R.S. (F6)COUNT EIGHTBetween and including March 27, 2008 and March 31, 2011, in the State of Colorado,obtained or exercised control over the motor vehicle of State Farm Mutual Insurance Company,vehicle for more than twenty-four hours and attempted to alter or disguise or altered or disguisedwithout authorization, or by threat or deception and retained possession or control over the motorthousand dollars; in violation of § 1 8-4-409(2),(3 )(b) and § 10-1-129 C. R. S.the appearance of the motor vehicle, and the value of the motor vehicle was more than twentyMIKEL MEWBOURN and WALTER SMITH unlawfully, feloniously, and knowinglyAGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, C.R.S. 18-4-409(2),(3)(b) (F3)COUNT SEVENBinh Tran, a public servant, by means of deceit, with the intent thereby to alter or affect thepublic servant’s decision, vote, opinion, or action concerning a matter which was to bewas a member; in violation of 18-8-306 and § 10-1-129 C.R.S.Colorado, MIKEL MEWBOURN unlawfully and feloniously attempted to influence Detectiveconsidered or performed by the public servant or the agency or body of which the public servantBetween and including September 14, 2007 and October 16. 2007, in the State ofATTEMPT TO INFLUENCE A PUBLIC SERVANT § 18-8-306, C.R.S. (F-4)COUNT SIXone-thousand dollars or more but less than twenty thousand dollars, without authorization, or bythreat or deception, and intended to deprive Duram Plummer permanently of its use or benefit; inviolation of § 18-4-401(1 )(a),(2)(c), C.R.S.THEFT § 18-4-401(l),(2)(c), C.RS. (F-4)COUNT FIVE

On September 14, 2007, Mikel Mewboum reported to the Denver Police Department thatreference.The facts supporting all other counts in this indictment are incorporated herein byhis 2000 Ferrari 550 Maranello automobile was stolen while he was dining at a restaurant at the5550 Maranello at a warehouse so that he could sell individual parts for profit. Smith was awarelate June or early July, 2010. In addition, Mewbourn gave Mr. Plummer other Ferrari parts,In June, 2010, Mewbourn used an eBay account under the name “wsmithracing” toIn November, 2009, Mewboum recruited Walter Smith to help disassemble the FerrariIran, Mewbourn reported that his car was taken without his knowledge or permission whilePolice investigation led by Detective Binh Tran. Through the course of that investigation,car was alleged by Mewbourn to have been stolen. Through his several statements to DetectiveHyatt Hotel in South Denver with Michaela Taylor. Mewbourn’s report resulted in a DenverDetective Tran spoke with Mewboum by telephone and personally, visited the scene of thereported crime, and interviewed several parties who were working at the Hyatt Hotel when theparked and secured at the Hyatt Hotel. He further reported that he had personally parked thefrom the same valet on that evening, but that his car was not in the space where he left it.that he gave him and that someone had switched keys. That key was collected and retained as$38,764.91 for his equity in the vehicle. The lienholder was paid $76,216.29. State Farmthe theft.automobile and given his key to a valet working at the hotel. He stated that he retrieved a keyMewbourn later reported that he believed the key that he was given by the valet was not the keyevidence by Detective Tran. Detective Tran reviewed surveillance tape from the Hyatt from thenight of the incident with Mewboum. The video showed a silver Ferrari that matched thedescription of Mewbourn’s car leaving the area on the evening of the reported theft whileMewbourn was still dining at the hotel restaurant. Detective Iran was never able to recover thevehicle and it has remained listed as a stolen vehicle in the police database.Mewbourn’s Ferrari 550 Maranello was insured by State Farm. Sometime afterMewbourn reported the vehicle stolen to the police, he made the same report to State Farm, whobegan investigating the claim. Through the course of that investigation, Mewboum’s statementsregarding the theft of his Ferrari remained consistent with his initial report to police. Mewboumbecame the title holder to the Ferrari after paying Mewboum’s insurance claim as the result ofthat Mewbourn had claimed that the Ferrari had been stolen and accepted insurance proceeds forOver the course of a week, Smith and Mewbourn cut the Ferrari into smaller pieces.the loss. Mewbourn offered and Smith agreed to accept $10,000 in exchange for his assistance.Bend Oregon, agreed to purchase the engine. Plummer agreed to pay $10,000 for the engine andprovided State Farm with his other key to the vehicle. At the conclusion of the State FarmInvestigation on March 28, 2008, Mewboum’s claim was honored and State Farm paid himadvertise a used Ferrari engine for sale. As the result of the advertisement, Duram Plummer ofother parts and Mewbourn personally delivered the engine to Mr. Plummer in Bend, Oregon inincluding a steering column with the ignition intact. Subsequently, Mr. Plummer agreed topurchase a Ferrari transmission from Mewbourn and paid him $2,800 on July 10, 2010 usingMewbourn’s Paypal account. That transmission has never been shipped to Mr. Plummer and aFerrari transmission matching its description was recovered by investigators when Mewboum ‘Shome was searched.Inspection of the engine that was sold to Mr. Plummer by Mewbourn revealed an engineThe facts supporting counts TWO through EIGHT are as follows:

that Mewbourn’s key operated the ignition.inspected by investigators. The materials documented the listing of several Ferrari 550Maranello parts for sale around September, 2010. The listings included a hood, a passengerEBay and Paypal account records linked to Mewboum and his wife were obtained and6reference.The facts supporting all other counts in this indictment are incorporated herein byStorage facility in Arapahoe County, Colorado. On October 5, 2010 investigators used a padlockissued by the management of the storage unit to secure Mewboum’s unit pending the applicationIn October, 2010, Mikel Mewbourn was the leaseholder of a storage unit at a PublicThe facts supporting count NINE are as follows:believing that an official proceeding was pending or about to be instituted, and acting withoutaltered physical evidence with intent to impair its verity or availability in the pending orprospective official proceeding; in violation of 18-8-6l0(1)(a) and § 10-1-129 C.RS.On or about October 7, 2010, in the State of Colorado, MIKEL MEWBOURN,legal right or authority, unlawfully and feloniously destroyed, mutilated, concealed, removed, orTAMPERING WITH PHYSICAL EVIDENCE § 18-8-610(1)(a), C.R.S. (F6)COUNT NINEOn October 7, 2010, a storage unit in Arapahoe County, Colorado that was leased bydoor, and a driver’s side fender. The parts were consistent in appearance and color to the vehiclethat Mewbourn reported stolen in 2007.Mewbourn’s home was searched on October 5, 2010. During that search investigatorsrecovered several vehicle parts that were later confirmed to be consistent with parts from aFerrari 550 Maranello of the same make as that which Mewbourn reported stolen. Among theparts found in Mewbourn’s garage was a transmission with identifying numbers on it that arepresentative from Ferrari North America confirmed was originally installed in the Ferrari thatMewbourn reported stolen. During the search, investigators located a .357 Magnum Revolverhandgun and .40 caliber semiautomatic handgun in a bedside table in the bedroom thatMewbourn’s wife, Michaela Jameson, confirmed that they shared. She further stated that thebedside table in which the guns were located was Mewbourn’s and that the guns and propertyinformation provided by Grand County Court in Colorado that Mewboum has been previouslyconvicted of three counts of class four felony theft in two cases. Those convictions occurred onMewbourn was searched. Within the unit, investigators located and recovered numerous vehiclelocated therein, were his property. Investigators confirmed through a criminal history andMay 10, 1990.parts that were later inspected and confirmed to be consistent with parts from a Ferrari 5502010, investigators located and impounded additional Ferrari parts under a bridge in ruraland the key previously provided to investigators by Mewboum fit the door locks.Maranello of the same make as that which Mewbourn reported stolen in 2007. On December 1,Arapahoe County approximately 40 miles from Mewbourn’s storage facility. The parts wereconsistent with those which had been advertised for sale on eBay through Mewbourn’s accountsteering column that Mewbourn sold Duram Plummer was examined by a locksmith who foundnumber that corresponded to the vehicle that Mewbourn had reported stolen in 2007. The

On October 7, 2010, Mewbourn gained entry to the storage facility at 6:07 a.m.,that his access was restricted, at which point Mewbourn acknowledged that police had previouslybeen to his home.7Between and including October 5, 2010 and November 16, 2010, in the State ofColorado, MIKEL MEWBOURN unlawfully, feloniously, and intentionally attempted, withoutbribery or threats, to induce Michaela Jameson, a witness, a victim, or a person the defendantbelieved might be called to testify as a witness or victim in any crime to testify falsely orunlawfully withhold any testimony in violation of 18-8-707 and § 10-1-129 C.R.S.TAMPER1I’JG WITH A WITNESS OR VICTIM, C.R.S. I 8-8-707 (F4)COUNT TENcargo area that were not readily identifiable on the video. Mewbourn returned to the storage unitfacility almost two hours later and was contacted by Aurora Police officers and taken intocustody.be a cart in the cargo area and leaving the facility approximately 9 minutes later with items in thebeen removed. The search of the unit revealed a cart consistent in appearance to the one that wasalso found numerous vehicle parts that were later inspected and confirmed to be consistent with2007. Among the parts were front and rear pieces of the vehicle’s body. No vehicle partsparts from a Ferrari 550 Maranello of the same make as that which Mewbourn reported stolen inhad hidden parts from the storage unit under a bridge on a dirt road fifty miles away.in the cargo area of Mewbourn’s truck in the aforementioned surveillance video. Investigatorsaccording to records and surveillance video provided by management of the facility.Mewbourn’s truck was captured on surveillance video entering the facility with what appeared toWhen investigators from the Attorney General’s office arrived to search Mewbourn’smatching the description of those which had been advertised for sale on eBay through an accountconsistent in appearance to the Ferrari that Mewbourn reported stolen. The parts include a hoodof Mewbourn’s storage facility. The parts collected consist of various body panels that areOn December 1, 2010, investigators located and collected a number of Ferrari parts thatstorage unit, they discovered that the lock that had been placed on the unit at their request hadlinked to Mewboum were located. Mewboum’s wife later stated that Mewbourn told her that heThe truck that Mewbourn had driven to the facility was impounded and found to containhad been placed under a bridge in rural Arapahoe County, Colorado approximately 40 miles eastthe lock that had been placed on Mewbourn’s unit by management of the facility and equipmentthat could be used to cut a lock.and two doors identical to parts that had been advertised for sale on eBay through Mewbourn’saccount.storage unit had been secured without his knowledge and contacted management, who explainedfor and execution of a search warrant. On October 6, 2010, Mewbourn discovered that his

The facts supporting all other counts in this indictment are incorporated herein by8reference.motorcycle and a 2006 Harley-Davidson motorcycle, both of which were owned by MikelMewbourn and subject to liens as the result of having been financed by Mewbourn. On anunknown date prior to May 26, 2009 at an unknown location, Mewbourn intentionally causedThe facts supporting all other counts in this indictment are incorporated herein byOn May 25, 2009, State Farm was the insurance provider for a 2005 Bourget customThe facts supporting counts ELEVEN and TWELVE are as follows:Between and including May 25, 2009 and July 31, 2009, in the State of Colorado,commission of the crime of THEFT, unlawfully and feloniously agreed with each other and aperson or persons to the Attorney General unknown that one or more of them would engage inconduct which constituted that crime or an attempt to commit that crime, or agreed to aid theother person or persons in the planning or commission or attempted commission of that crime,conspirators; in violation of 18-4-401(l)(2)(d), § 18-2-201 and § 10-1-129 C.R.S.and an overt act in pursuance of the conspiracy was committed by one or more of theMIKEL MEWBOURN and MELISSA GILLISPIE, with the intent to promote or facilitate theCONSPIRACY TO COMMIT THEFT, C.R.S. l8-4-401(1),(2)(d);18-2-201 (F4)COUNT TWELVEby threat or deception, and intended to deprive State Farm Mutual Insurance CompanyMIKEL MEWBOURN and MELISSA GILLISPIE unlawfully, feloniously, and knowinglyBetween and including May 25, 2009 and July 31, 2009, in the State of Colorado,obtained or exercised control over a thing of value, namely: Money, of State Farm MutualInsurance Company, with the value of twenty thousand dollars or more, without authorization, orpermanently of its use or benefit; in violation of. 18-4-401(l)(a),(2)(d) and § 10-1-129 C.R.S.THEFT - $20,000 OR MORE, C.R.S. I 8-4-401(1),(2)(d) (F3)COUNT ELEVENto know what he did.with his wife, Michaela Jameson, during which he asked her to make statements to authoritiesregarding his Ferrari if asked. Specifically, Mewbourn asked that she state that Mewbourn wasthat he had made some “little” changes to the car, but that she does not know enough about carsreference.Between October 5, 2010, when investigators located and confiscated Ferrari parts andweapons from his home, and November 16, 2010, Mewbourn had one or more conversationsalways working on the Ferrari and that he installed a new transmission and paddle shifters.Mewbourn made vague promises to Jameson in return, suggesting that he would pay her, that hewould ‘make it worth her while,” and that it would be financially beneficial for her to make suchstatements, though he did not specify an amount of money. Jameson stated that she was awareThe facts supporting count TEN are as follows:

May 25, 2009. Mewbourn stated, through the course of the claim and investigation resultingfrom the claim, that he had been hauling the two motorcycles in an enclosed aluminum trailer onmotorcycles had sustained damage during a highway accident in which he had been involved onand made an insurance claim for damage to the two motorcycles, reporting that the two9of its use or benefit; in violation of 18-4-401(1),(2)(c), § 18-2-101 and § 10-1-129 C.R.S.Between and including June 7, 2009 and July 30, 2010, in the State of Colorado, MIKELTheft, unlawfully, feloniously, and knowingly attempted to obtain or exercise control over athing of value, namely: Money of State Farm Mutual Insurance Company, with the value of onethreat or deception, and intended to deprive State Farm Mutual Insurance Company permanentlythousand dollars or more but less than twenty thousand dollars, without authorization, or byMEWBOURN, by engaging in conduct constituting a substantial step toward the commission ofCRIMINAL ATTEMPT TO COMMIT THEFT, C.R.S. 18-4-401(1), (2)(c);18-2-lOl (F5)COUNT THIRTEENDavidson Credit$1 1,892.94 payment to Lien Holder, Harley-Harley-Davidson Claim: $ 6,514.19 payment to Mikel MewbournBourget Motorcycle Claim: $28,501.80 payment to Mike! Mewbourn$13,683.28 payment to Lien Holder, Harley-Davidson Crediteach. Through the course of the claim and the investigation that resulted from the claim,his location after he had already been able to load the motorcycles into the bed of his truck withtruck. He stated that Gillispie then took the trailer to her home in Trinidad.the assistance of passers-by and that Gillispie then helped him load the trailer into the bed of herfor inspection, as it had been stolen from Gillispie’s home within a few days of her removing itfrom her truck bed and parking it. State Farm paid Mewbourn’s damage claims as followsnorthbound Interstate-25 in Colorado. He reported that the trailer detached from his truck inhazardous road conditions and rolled, ejecting the motorcycles and causing significant damage toMewbourn further reported that immediately after the wreck, he called Melissa Gillispie at herhome in Trinidad, Colorado and requested that she help him. He reported that Melissa arrived atMewbourn contacted Gillispie around the time he made the damage claim to State FarmInsurance and told her that she would be getting a call from an insurance investigator.Mewbourn told Gillispie to tell the investigator the same fabricated facts that he reported.Mewbourn further explained to her that he had damaged the motorcycles intentionally bydragging them from a chain behind his truck.Through the course of the investigation, Gillispie generally confirmed Mewbourn’sreport in a statement to the State Farm investigator. When the investigator requested that thearound July 31, 2009:trailer be made available for inspection, Gillispie and Mewbourn reported that it was unavailablesignificant damage to the two motorcycles by chaining and dragging them from the rear of histruck and driving them around a parking lot. On May 26, 2009, Mewbourn contacted State Farm

10Between and including October 1, 2009 and May 25, 2010, in the State of Colorado,with each other and a person or persons to the Attorney General unknown that one or more ofpromote or facilitate the commission of the crime of THEFT, unlawfully and feloniously agreedMIKEL MEWBOURN, JAMES ESQUIBEL, and MELISSA GILLISPIE, with the intent toCONSPIRACY TO COMMIT THEFT, C.R.S. 18-4-401(1), (2)(d);18-2-201 (F4)COUNT FIFTEENor by threat or deception, and intended to deprive Farmers Insurance permanently of its use orbenefit; in violation of 18-4-401(1)(a),(2)(d) and § 10-1-129 C.R.S.of Farmers Insurance, with the value of twenty thousand dollars or more, without authorization,Between and including October 1, 2009 and May 25, 2010, in the State of Colorado,feloniously, and knowingly obtained or exercised control over a thing of value, namely: Money,MIKEL MEWBOURN, JAMES ESQUIBEL, and MELISSA GILLISPIE unlawfully,THEFT, C.R.S. 18-4-401(1 ),(2)(d) (F3)COUNT FOURTEENMewboum was one of the drivers and which is the subject of the charges set forth in countsinsurance company investigation and through the course of the investigation persisted with theirfor each vehicle as follows: GMC truck $4,917.07; Volvo $8,625.08. The claim for damages2009. Inspections of the two vehicles on that date and later inspection by a hail damage experthail damage claims, Mewbourn’s GMC was wrecked in a staged accident in which Mewboumhailstorm on June 7, 2009, Jameson and Mewbourn made hail damage claims associated withtheir respective vehicles and had them inspected by State Farm Insurance adjusters on June 16,revealed that the damage to the Volvo and the GMC truck was inconsistent with naturallyoccurring hail damage and had likely been mechanically generated. Both Michaela Jameson andclaim that the damage to the vehicles was caused by hail. Adjusters estimated the cost of repairTwenty through Twenty-Three.to a lien as the result of having been financed and Jameson’s Volvo was leased. After ato the Volvo was denied by State Farm after investigation.On October 9, 2009, prior to the completion of the insurance investigation regarding thewas one of the drivers and which is the subject of the charges set forth in counts Fourteen andreference.Mikel Mewboum communicated with an investigator from State Farm Insurance throughout theThe facts supporting all other counts in this indictment are incorporated herein byOn June 7, 2009, State Farm Insurance was the insurance provider for Mike! Mewboum’s2007 GMC truck and his wife Michaela Jameson’s 2006 Volvo. Mewboum’s truck was subjectFifteen. On July 30, 2010, Jameson’s Volvo was wrecked in a staged accident in whichThe facts supporting count THIRTEEN are as follows:

C.R.S.or more of the conspirators; in violation of 18-4-401(1)(2)(d), § 18-2-201 and § 10-1-12911reference.The facts supporting all other counts in this indictment are incorporated herein bydamaged. He told her that the owner of the truck that she was driving was a man she had met,keep up the appearance that she knew Esquibel. Mewbourn also instructed her to “be frantic”Mewbourn and Gillispie staged the accident as planned at the intersection of WatkinsRoad and Yale Avenue in Arapahoe County, Colorado. The collision resulted when Gillispieimpact, Gillispie reversed the truck she was driving and then drove into Mewbourn’s truck again,staged accident. During their interactions with the emergency personnel, Mewbourn andsince Gillispie was a child. Gillispie was issued a citation for failing to stop at a traffic controlshort distance from the staged accident because his truck was no longer operable. The threedrove together to Mewbourn’s home. Mewboum later drove Esquibel’s truck, while Gillispierode along, back to the location from which it they had originally picked it up. GillispieMewbourn subsequently paid the court fines and costs associated with the citation issuedEsquibel’s truck was insured by Farmer’s Insurance at the time of the collision. Claimsto Gillispie as the result of the collision.location where Esquibel’s truck was parked. During the drive, Mewbourn explained thesubstance of the plan to Gillispie, telling her that they would drive the two trucks to a secludedlocation and that she would drive Esquibel’s Ford truck into Mewbourn’s GMC truck. Heexplained how and where the impact needed to occur to ensure that the frame of his truck wasdrove Esquibel’s truck east on Yale Avenue into a three way intersection where Mewbourn hadstepped out of his truck and left it to slowly idle through the intersection. After the initialforcing both trucks onto the shoulder of the road and down an incline. Both trucks weredamaged.device and for failing to provide proof of insurance on the vehicle she was driving. Gillispierefused transport from the scene by ambulance and called James Esquibel, in accordance withMewbourn’s instruction, to pick her up at the scene. Mewbourn drove his truck from the scene.Esquibel and Gillispie left the scene in Esquibel’s damaged truck and picked Mewbourn up aobserved as Mewbourn repeatedly drove the truck into a concrete barrier and hit it with a sledgehammer. He had previously told Gillispie that he was concerned that Esquibel’s truck did notsustain enough damage to be a total loss.accident involving his 2007 GMC pick-up truck and a 2005 Ford pick-up truck owned by JamesEsquibel. On October 23, 2009, Mewbourn picked Gillispie up in his truck, gave her onethousanddollars in cash for her participation in what was about to occur, and drove her to athat the wreck had been planned, and that she was to call the truck’s owner after the wreck towhen police arrived to investigate the collision and to refuse medical care.Gillispie acted as if they did not know each other, despite the fact that they had been acquaintedIn October, 2009, Mike! Mewbourn recruited Melissa Gillispie to participate in a stagedA Colorado State Trooper and an ambulance ultimately responded to the scene of theThe facts supporting counts FOURTEEN and FIFTEEN are as follows:commission of that crime, and an overt act in pursuance of the conspiracy was committed by onethem would engage in conduct which constituted that crime or an attempt to commit that crime,or agreed to aid the other person or persons in the planning or commission or attempted

distributed by Farmer’s Insurance as follows:Total settlement proceeds related to the collision in the amount of $48,485.91 were12constituting a substantial step toward the commission of theft, unlawfully, feloniously, andBetween and including April 3, 2010 and March 31, 2011, in the State of Colorado,knowingly attempted to obtain or exercise control over a thing of value, namely: money, ofMIKEL MEWBOURN, WALTER SMITH, and JOHN SMITH by engaging in conductCRIMINAL ATTEMPT TO COMMIT THEFT, C.R.S. 18-4-40l(1),(2)(c); 18-2-101 (F5)COUNT SEVENTEENGolden, Colorado. During the course of his construction of the home, Mewbourn intentionallyresponsible for the construction of a fraternity house located at 1701 West Campus Road indetached a water supply line within the home around December 28, 2009. The flooding whichinsurance settlement, Mewboum intentionally exacerbated the water damage by later forcingresulted caused extensive water damage to the home. In order to increase the amount of anyrunning water from a washing machine fixture located within the home into the internal structureclaim through the building’s owner and negotiated a settlement amount with Willis of Northproceeds exceeding $40,000. The proceeds of the insurance settlement were then used toreimburse Mewbourn and M & B Contracting for repairing the damage.America for the cost of repairs. Willis of North America paid the owner of the home settlementof a nearby wall. As the result of the flooding and damage, Mewbourn submitted an insuranceMike! Mewbourn, doing business as M&B Contracting, was the general contractorThe facts supporting count SIXTEEN are as follows:to deprive Willis of North America permanently of its use or benefit; in violation of § 18-4-Between and including December 28, 2009 and February 28, 2010, in the State ofColorado, MIKEL MEWBOURN unlawfully, feloniously, and knowingly obtained or exercisedcontrol over a thing of value, namely: Money, of Willis of North America, with the value oftwenty thousand dollars or more, without authorization, or by threat or deception, and intended401(1)(a),(2)(d) and § 10-1-129 C.R.S.THEFT, C.R.S. 18-4-401(1 ),(2)(d) (F3)COUNT SIXTEENJerry Standers Collision Works- $521.80 (paid 05/25/10)Ford Motor Credit (lien holder on Esquibel’s truck) -Mikel Mewboum - $400.00 (paid 11/05/09)GMAC Vault Trust (lien holder on Mewbourn’s truck)- $32,411.54 (paidJames Esquibel -$2,086.4111/17/09)(paid 01/25/10)$13,066.16(paid 01/25/10)Farmer’s Insurance after a brief investigation during which Gillispie and Mewbourn were bothinterviewed by a Farmer’s investigator and remained consistent in their false narrativeconcerning the collision.for the damage to the two vehicles resulting from this accident were made and ultimately paid by

CONSPIRACY TO COMMIT THEFT, C.R.S. 18-4-401(1), (2)(c); 18-2-201 (F5)COUNT EIGHTEENof its use or benefit; in violation of 18-4-401(1),(2)(c), § 18-2-101 and § 10-1-129 C.R.S.13reference.Between January 1 and April 3, 2010. Mikel Mewbourn. Walter Smith, and John Smithdiscussed and agreed upon a plan to insure Mikel Mewbourn’s 2006 Toyota Tundra in JohnSmith’s name and then conceal and falsely report the truck stolen in order to collect insuranceproceeds. It was further agreed that the parties would report that John Smith was in the processMewbourn insured the Toyota Tundra on March 18, 2010 in John Smith’s name throughThe facts supporting all other counts in this indictment are incorporated herein byMikel Mewbourn. Mewbourn was contacted around the time of the reported theft and stated thatthe truck was a single cab truck with no added features, that he was being paid for the truck, andToyota Tundra truck had been stolen from its parking place in front of his home. In his report topolice, Mr. Smith stated that he had been in possession of the truck for approximately twomonths prior to the theft and that he was in the process of purchasing it from a friend namedin a storage unit leased by Mewbourn. On April 4, 2010, John Smith reported to police that thea policy issued by Esurance. On April 3, 2010, Walter Smith and Mewbourn concealed the truckto Mewbourn’s insurance claim history.of purchasing the truck from Mewbourn at the time of the staged theft to avoid suspicion relatedThe facts supporting counts SEVENTEEN through NINETEEN are as follows:was calculated to become or to represent if completed, an instrument which document did or mayhave evidenced, created, transferred, terminated, or otherwise affected a legal right, interest,10-1-129 C.R.S.completed, altered, or uttered a written instrument which was or which purported to be, or whichobligation, or status, namely: Affidavit of Vehicle Theft; in violation of § 18-5-102(1 )(c) and §SMITH, with the intent to defraud Esurance, unlawfully, feloniously, and falsely made,On or about May 13, 2010, in the State of Colorado, MIKEL MEWBOURN and JOHNFORGERY C.R.S. 18-5-102(1 )(c) (F5)COUNT NINETEENother and a person or persons to the Attorney General unknown that one or more of them wouldMIKEL MEWBOURN, WALTER SMITH, and JOHN SMITH, with the intent to promote orBetween and including January 1, 2010 and March 31, 2011, in the State of Colorado,aid the other person or persons in the planning or commission or attempted commission of thatfacilitate the commission of the crime of THEFT, unlawfully and feloniously agreed with eachengage in conduct which constituted that crime or an attempt to commit that crime, or agreed tocrime, and an overt act in pursuance of the conspiracy was committed by one or more of theconspirators; in violation of 18-4-401(1)(2)(d), § 18-2-201 and § 10-1-129 C.R.S.Esurance. with the value of one thousand dollars or more but less than twenty thousand dollars,without authorization, or by threat or deception, and intended to deprive Esurance permanently

of the reported theft, Mewbourn owed $7,000 on the truck.14conduct constituting a substantial step toward the commission of Theft, attempted to unlawfully,feloniously, and knowingly obtain or exercise control over a thing of value, namely: Money, ofBudget Rental Company, Continental Casualty Company, ACE Group and State Farm MutualInsurance Company, with the value of twenty thousand dollars or more, without authorization, orCompany, ACE Group and State Farm Mutual Insurance Company permanently of its use orBetween and including July 29, 2010 and March 31, 2011, in the State of Colorado,benefit; in violationof I8-4-401(1)(a),(2)(d), § 18-2-101 and § 10-1-129 C.R.S.by threat or deception, and intended to deprive Budget Rental Company, Continental CasualtyMIKEL MEWBOURN, MELISSA GILLISPIE, and JESSE SELLERS, by engaging inCRIMINAL ATTEMPT TO COMMIT THEFT, C.R.S. 18-4-401(1), (2)(d); 18-2-101 (F4)COUNT TWENTYOn November 9, 2010, the Toyota Tundra was recovered approximately twenty feetprior to its reported theft and was making payments but that he had not put the truck in his name.to apply for insurance through Esurance and paid for it using his credit card. He reported that hereimbursed Mewboum for the cost of the insurance. Mewbourn completed an Affidavit ofJohn Smith made an insurance claim on the truck shortly after reporting it stolen and toldan insurance investigator that he had purchased the truck from Mewbourn about two monthsHe further reported that he had gone to Mewbourn’s house, where Mewboum used his computerSmith, who signed the document and had it notarized on May 13, 2010. Mewboum subsequentlyto resolve the claim. A day later, Smith reinitiated contact with Esurance and agreed to provide alate June, 2010. Mewboum was interviewed on July 6, 2010. During their interviews withVehicle Theft with false information on a form provided by Esurance and provided it to Johnsubmitted that form to Esurance.After the initial theft claim, the insurance investigator for Esurance had difficultyreaching Smith at his listed phone numbers and eventually closed the claim on May 21, 2010.Approximately two weeks later, Mewboum called Esurance and asked what Smith needed to dorecorded statement for the investigator the following week. That recorded interview occurred ininvestigators for Esurance after the reported theft, both Smith and Mewboum stated that SmithMewbourn stated that there was a written contract and Smith stated there was no writtenevidence of the agreement. Mewbourn stated that he gave the only key he had to the truck tohad agreed to purchase the Toyota Tundra from Mewboum and that he was making payments.his possession after the reported theft.down an embankment on a road in Gilpin County. The truck was recovered with the key in theagainst the gas pedal and there was a rope tied to the gear shifter on the truck’s steering column.Smith. Smith stated that he received only one key to the truck from Mewboum and that it was inignition. In addition, at the time of recovery, there was a shovel in the cab of the truck wedgedtheft. The truck was being financed by Mewbourn through Toyota Motor Company. At the timethat he does not have access to the vehicle any longer. Mewbourn further estimated that thetruck was worth $14,000. The Toyota was registered and titled to Mewboum at the time of thereported theft. The title and registration have remained in Mewbourn’s name since the reported

COUNT TWENTY-ONECONSPIRACY TO COMMIT THEFT, C.R.S. 18-4-401(1)(a), (2)(d);18-2-201 (F4)Between and including July 29, 2010 and March 31, 2011, in the State of Colorado,MIKEL MEWBOURN, MELISSA GILLESPIE, and JESSE SELLERS, with the intent topromote or facilitate the commission of the crime of Theft, unlawfully and feloniously agreedwith each other and a person or persons to the Attorney General unknown that one or more ofthem would engage in conduct which constituted that crime or an attempt to commit that crime,or agreed to aid the other person or persons in the planning or commission or attemptedcommission of that crime, and an overt act in pursuance of the conspiracy was committed by oneor more of the conspirators; in violation of § 18-4-401(1 )(a),(2)(d), § 1 8-2-201 and § 10-1-129C.R.S.COUNT TWENTY-TWOCRIMINAL MISCHIEF - $1,000 -$20,000, C.R.S. 18-4-501 (F4)On or about July 30, 2010, in the State of Colorado, MIKEL MEWBOURN, MELISSAGILLISPIE, and JESSE SELLERS, in the course of a single criminal episode, unlawfully,feloniously, and knowingly damaged the real or personal property of Budget Truck Rental, theaggregate damage being one thousand dollars or more but less than twenty thousand dollars; inviolation of § 18-4-501 and § 10-1-129 C.R.S.COUNT TWENTY-THREEATTEMPT TO INFLUENCE A PUBLIC SERVANT, C.R.S. 18-8-306 (F4)Between and including July 29, 2010 and January 13, 2011, in the State of Colorado,MIKEL MEWBOURN and JESSE SELLERS unlawfully and feloniously attempted toinfluence Donna Schneider, a public servant, by means of deceit, with the intent thereby to alteror affect the public servanCs decision, vote, opinion, or action concerning a matter which was tobe considered or performed by the public servant or the agency or body of which the publicservant was a member; in violation of 18-8-306 and § 10-1-129 C.R.S.The facts supporting counts TWENTY through TWENTY-THREE are as follows:The facts supporting all other counts in this indictment are incorporated herein byreference.On July 29, 2010, Mikel Mewbourn and Jesse Sellers rented a Budget moving truck inthe name of Jesse Sellers and purchased an optional supplemental liability insurance policy withcoverage up to one-million dollars. Mewbourn paid the deposit on the truck and Jesse Sellerswas listed as the authorized driver. Between July 29 and July 30, 2010, Sellers and MelissaGillispie loaded the Budget truck with belongings that Gillispie was planning to move from herapartment in Denver, Colorado to a storage unit that had been previously rented by Gillispie withMewbourn’ s assistance.On July 30, 2010, Mewbourn arrived at Gillispie’s residence driving his wife’s 2006Volvo, insured by State Farm Insurance and the subject of a previous hail damage claim15

After the Budget truck and Volvo were loaded with belongings, Mewbourn, Gillispie,the cones.Gillispie that the speakers were worth $12,000 and that he had damaged them by poking holes inrental truck, asking if he could store the speakers in Gillispie’s storage unit. Mewbourn later told16belongings. Sellers was driving the Budget truck, Mewbourn was driving the Volvo, andGillispie was driving a 2002 Saturn that she had recently purchased and financed. The threeparties stopped prior to reaching the storage unit. Mewbourn then drained brake fluid from theBudget truck with Seller’s assistance and the three returned to their vehicles and staged a threedriven by Sellers. The accident occurred when Gillispie stopped at a stop sign in her Saturn withand Sellers drove to a location near the storage unit in which Gillispie was planning to store hercar accident involving Gillispie’s Saturn, the Volvo driven by Mewbourn, and the Budget truckaccident. Gillispie and Sellers remained on scene while a Wheat Ridge Police OfficerAfter the collision, Mewbourn was transported by ambulance to a hospital, where he wasMewbourn behind her driving the Volvo. As Gillispie accelerated into the intersection atMewbourn’s instruction, Sellers drove the Budget truck into the rear of the Volvo, causing it tocollide with the Saturn. All three vehicles were damaged.Failure to Comply with Compulsory Insurance. The Saturn and Budget truck were left on scenein a nearby parking lot.parties. Damages claimed were for property damage to the Volvo owned by Mewbourn’s wife into the Saturn by repeatedly reversing it into a wall such that the body of the vehicle rubbedtreated for a pre-existing herniated belly-button that he claimed was the result of the three-carinvestigated the collision, had the Volvo towed, and cited Sellers for Careless Driving andAfter the collision, Sellers and Gillispie returned to the scene and caused further damageagainst its rear tire.Mewbourn and Gillispie submitted damage claims to Budget and to State Farm, theinsurance provider for the Volvo being driven by Mewbourn, for the damages incurred by theamount of approximately $5,000, medical bills and future surgical costs associated withMewbourn’s pre-existing herniated bellybutton in an amount of approximately $ 7,800, the costproperty damage associated with personal property belonging to Gillispie and Mewbourn thatinvestigation that occurred immediately following the collision and the insurance companyinvestigations, Gillispie, Mewbourn, and Sellers provided statements designed to convinceinvestigators that the collision was accidental.January 13, 2011. On at least one occasion, Mewbourn and Gillispie accompanied Sellers tosignificant mechanical experience and that he agreed with Sellers that the cause of the collisionDriving charge and allowed Sellers to plead guilty to a less significant offense.of rental vehicles for Mewbourn’s wife and Gillispie, and a heretofore unknown amount ofan estimated amount exceeding $ 8,000, property damage to Gillispie’s Saturn in an estimatedwas alleged to have been damaged in the collision. Through the course of the accidentAs the result of the traftic citations related to the collision, Sellers appeared in Wheatthe case. Through discussions with the prosecuting attorney, Mewbourn told her that he hadRidge Municipal Court on approximately four occasions between the date of the collision andcourt, at which time Mewbourn represented himself to the prosecuting attorney as the victim inwas the failure of the Budget truck’s brakes. Based upon the statements by Mewbourn andSellers and a review of the accident report, the prosecutor dismissed the original Carelessdescribed and set forth in count Thirteen. Some of Gillispie’s belongings were loaded by theparties into the Volvo. Mewbourn loaded two large speakers that he owned into the Budget

VIOLATION OF BAIL BOND CONDITIONS, FELONY §18-8-212(1), C.R.S. (F6)Between and including July 14, 2010 and January 11, 2011, in the State of Colorado,COUNT TWENTY-FOURh17reference.which he was facing charges of Defrauding a Secured Creditor and Conspiracy to Defraud aConditions of the bond posted by Mewbourn include the following Order: “You shall notcommit any new offenses.” As set forth in the preceding paragraphs and counts of thisSecured Creditor. The charges in that case were ultimately dismissed in January, 2011.indictment, Mewboum has violated those conditions by committing the criminal acts since hisrelease on bond.The facts supporting all other counts in this indictment are incorporated herein byOn July 14, 2010, Mewbourn posted a bond in Arapahoe County Case no. 10CR 1294 inThe facts supporting count TWENTY-FOUR are as follows:§ 18-8-212(1), C.R.S.Defrauding a Secured Creditor § 18-5-206(1 )(d), arising from the conduct for which he wasarrested, unlawfully, feloniously, and knowingly violated a condition of the bond; in violation ofIOCRI 294 in which he was accused by complaint of the commission of two felony counts ofMIKEL MEWBOURN, having been released on bail bond, in Arapahoe County Case

JOHN W. SUTHERSAttoIj___JUDY MER No. 31347Seq)ssistant Attorney GeneralFinancial Fraud UnitCriminal Justice SectionThe 2010-2011 Colorado Statewide Grand Jury presents the wit n Indictment, and thesame is hereby ORDERED FILED this day of204.0. Z( I3/Pursuant to § 13-73-107, C R S, the Court designates County,Colorado as the county of venueDated this Yi of I 1%Denver District Court23