B<strong>et</strong>ween and including July 10, 2010 and October 5, 2010, in the State of <strong>Colorado</strong>,over a thing of v<strong>al</strong>ue, namely: United States Currency, of Duram Plumm<strong>et</strong>, with the v<strong>al</strong>ue 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 c<strong>al</strong>iber semiautomatic handgun,<strong>Colorado</strong> 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 <strong>Colorado</strong>, 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 EIGHTB<strong>et</strong>ween and including March 27, 2008 and March 31, 2011, in the State of <strong>Colorado</strong>,obtained or exercised control over the motor vehicle of State Farm Mutu<strong>al</strong> Insurance Company,vehicle for more than twenty-four hours and attempted to <strong>al</strong>ter or disguise or <strong>al</strong>tered or disguisedwithout authorization, or by threat or deception and r<strong>et</strong>ained 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 v<strong>al</strong>ue 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 <strong>al</strong>ter 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.<strong>Colorado</strong>, MIKEL MEWBOURN unlawfully and feloniously attempted to influence D<strong>et</strong>ectiveconsidered or performed by the public servant or the agency or body of which the public servantB<strong>et</strong>ween 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 <strong>al</strong>l other counts in this <strong>indictment</strong> 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 individu<strong>al</strong> parts for profit. Smith was awarelate June or early July, 2010. In addition, <strong>Mewbourn</strong> gave Mr. Plummer other Ferrari parts,In June, 2010, <strong>Mewbourn</strong> used an eBay account under the name “wsmithracing” toIn November, 2009, Mewboum recruited W<strong>al</strong>ter Smith to help disassemble the FerrariIran, <strong>Mewbourn</strong> reported that his car was taken without his knowledge or permission whilePolice investigation led by D<strong>et</strong>ective Binh Tran. Through the course of that investigation,car was <strong>al</strong>leged by <strong>Mewbourn</strong> to have been stolen. Through his sever<strong>al</strong> statements to D<strong>et</strong>ectiveHyatt Hotel in South Denver with Michaela Taylor. <strong>Mewbourn</strong>’s report resulted in a DenverD<strong>et</strong>ective Tran spoke with Mewboum by telephone and person<strong>al</strong>ly, visited the scene of thereported crime, and interviewed sever<strong>al</strong> parties who were working at the Hyatt Hotel when theparked and secured at the Hyatt Hotel. He further reported that he had person<strong>al</strong>ly parked thefrom the same v<strong>al</strong><strong>et</strong> 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 r<strong>et</strong>ained 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 v<strong>al</strong><strong>et</strong> working at the hotel. He stated that he r<strong>et</strong>rieved a key<strong>Mewbourn</strong> later reported that he believed the key that he was given by the v<strong>al</strong><strong>et</strong> was not the keyevidence by D<strong>et</strong>ective Tran. D<strong>et</strong>ective Tran reviewed surveillance tape from the Hyatt from thenight of the incident with Mewboum. The video showed a silver Ferrari that matched thedescription of <strong>Mewbourn</strong>’s car leaving the area on the evening of the reported theft while<strong>Mewbourn</strong> was still dining at the hotel restaurant. D<strong>et</strong>ective Iran was never able to recover thevehicle and it has remained listed as a stolen vehicle in the police database.<strong>Mewbourn</strong>’s Ferrari 550 Maranello was insured by State Farm. Som<strong>et</strong>ime after<strong>Mewbourn</strong> 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 initi<strong>al</strong> report to police. Mewboumbecame the title holder to the Ferrari after paying Mewboum’s insurance claim as the result ofthat <strong>Mewbourn</strong> had claimed that the Ferrari had been stolen and accepted insurance proceeds forOver the course of a week, Smith and <strong>Mewbourn</strong> cut the Ferrari into sm<strong>al</strong>ler pieces.the loss. <strong>Mewbourn</strong> 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 s<strong>al</strong>e. As the result of the advertisement, Duram Plummer ofother parts and <strong>Mewbourn</strong> person<strong>al</strong>ly 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 <strong>Mewbourn</strong> and paid him $2,800 on July 10, 2010 using<strong>Mewbourn</strong>’s Payp<strong>al</strong> 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 <strong>Mewbourn</strong> reve<strong>al</strong>ed an engineThe facts supporting counts TWO through EIGHT are as follows:
- Page 1 and 2: Centennial, Colorado 80112Plaintiff
- Page 3 and 4: Mikel MewbournIATT 0801U1SERVANT,
- Page 5 and 6: 1437 Bannock Street_____________1CO
- Page 7: 15, 16, 17, 18, 19, 20, 21, 22, 23e
- Page 11 and 12: On October 7, 2010, Mewbourn gained
- Page 13 and 14: May 25, 2009. Mewbourn stated, thro
- 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,