Mewbourn et al. indictment - Colorado Attorney General

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