The facts supporting <strong>al</strong>l other counts in this <strong>indictment</strong> are incorporated herein by8reference.motorcycle and a 2006 Harley-Davidson motorcycle, both of which were owned by Mikel<strong>Mewbourn</strong> and subject to liens as the result of having been financed by <strong>Mewbourn</strong>. On anunknown date prior to May 26, 2009 at an unknown location, <strong>Mewbourn</strong> intention<strong>al</strong>ly causedThe facts supporting <strong>al</strong>l other counts in this <strong>indictment</strong> are incorporated herein byOn May 25, 2009, State Farm was the insurance provider for a 2005 Bourg<strong>et</strong> customThe facts supporting counts ELEVEN and TWELVE are as follows:B<strong>et</strong>ween and including May 25, 2009 and July 31, 2009, in the State of <strong>Colorado</strong>,commission of the crime of THEFT, unlawfully and feloniously agreed with each other and aperson or persons to the <strong>Attorney</strong> Gener<strong>al</strong> 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 Mutu<strong>al</strong> Insurance CompanyMIKEL MEWBOURN and MELISSA GILLISPIE unlawfully, feloniously, and knowinglyB<strong>et</strong>ween and including May 25, 2009 and July 31, 2009, in the State of <strong>Colorado</strong>,obtained or exercised control over a thing of v<strong>al</strong>ue, namely: Money, of State Farm Mutu<strong>al</strong>Insurance Company, with the v<strong>al</strong>ue 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. Specific<strong>al</strong>ly, <strong>Mewbourn</strong> asked that she state that <strong>Mewbourn</strong> wasthat he had made some “little” changes to the car, but that she does not know enough about carsreference.B<strong>et</strong>ween October 5, 2010, when investigators located and confiscated Ferrari parts andweapons from his home, and November 16, 2010, <strong>Mewbourn</strong> had one or more conversations<strong>al</strong>ways working on the Ferrari and that he inst<strong>al</strong>led a new transmission and paddle shifters.<strong>Mewbourn</strong> made vague promises to Jameson in r<strong>et</strong>urn, suggesting that he would pay her, that hewould ‘make it worth her while,” and that it would be financi<strong>al</strong>ly benefici<strong>al</strong> 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. <strong>Mewbourn</strong> stated, through the course of the claim and investigation resultingfrom the claim, that he had been hauling the two motorcycles in an enclosed <strong>al</strong>uminum 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.B<strong>et</strong>ween and including June 7, 2009 and July 30, 2010, in the State of <strong>Colorado</strong>, MIKELTheft, unlawfully, feloniously, and knowingly attempted to obtain or exercise control over athing of v<strong>al</strong>ue, namely: Money of State Farm Mutu<strong>al</strong> Insurance Company, with the v<strong>al</strong>ue of on<strong>et</strong>hreat or deception, and intended to deprive State Farm Mutu<strong>al</strong> Insurance Company permanentlythousand dollars or more but less than twenty thousand dollars, without authorization, or byMEWBOURN, by engaging in conduct constituting a substanti<strong>al</strong> 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 <strong>Mewbourn</strong>Bourg<strong>et</strong> Motorcycle Claim: $28,501.80 payment to Mike! <strong>Mewbourn</strong>$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 <strong>al</strong>ready 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 <strong>Mewbourn</strong>’s damage claims as followsnorthbound Interstate-25 in <strong>Colorado</strong>. He reported that the trailer d<strong>et</strong>ached from his truck inhazardous road conditions and rolled, ejecting the motorcycles and causing significant damage to<strong>Mewbourn</strong> further reported that immediately after the wreck, he c<strong>al</strong>led Melissa Gillispie at herhome in Trinidad, <strong>Colorado</strong> and requested that she help him. He reported that Melissa arrived at<strong>Mewbourn</strong> contacted Gillispie around the time he made the damage claim to State FarmInsurance and told her that she would be g<strong>et</strong>ting a c<strong>al</strong>l from an insurance investigator.<strong>Mewbourn</strong> told Gillispie to tell the investigator the same fabricated facts that he reported.<strong>Mewbourn</strong> further explained to her that he had damaged the motorcycles intention<strong>al</strong>ly bydragging them from a chain behind his truck.Through the course of the investigation, Gillispie gener<strong>al</strong>ly confirmed <strong>Mewbourn</strong>’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 <strong>Mewbourn</strong> 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, <strong>Mewbourn</strong> contacted State Farm
- Page 1 and 2: Centennial, Colorado 80112Plaintiff
- Page 3 and 4: Mikel MewbournIATT 0801U1SERVANT,
- Page 5 and 6: 1437 Bannock Street_____________1CO
- Page 7 and 8: 15, 16, 17, 18, 19, 20, 21, 22, 23e
- Page 9 and 10: On September 14, 2007, Mikel Mewbou
- Page 11: On October 7, 2010, Mewbourn gained
- Page 15 and 16: C.R.S.or more of the conspirators;
- Page 17 and 18: CONSPIRACY TO COMMIT THEFT, C.R.S.
- Page 19 and 20: COUNT TWENTY-ONECONSPIRACY TO COMMI
- Page 21 and 22: VIOLATION OF BAIL BOND CONDITIONS,