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DISTRICT COURT, CITY AND COUNTY OFDENVER, COLORADO1437 Bannock StreetDenver, CO 80202THE PEOPLE OF THE STATE OF COLORADO,v.OMAR GUERRA-NERI AKA JIMMYAKA“CHIMY”OSCAR LOMELI-LOPEZ AKA DANIELJOSE HERIBERTO MARTINEZ-LOPEZ AKA EDDIEURIEL LOMBARDI CALDINO AKA “ALONZO”HUGO MARTINEZ-PASILLAS AKA HUGOJUAN MARTINEZ-RODRIGUEZ AKA “PAISA”JEANETTE GUERRAAUDREY TORREZDANIEL GONZALEZDELFINA CHAVEZTONY LOPEZ-LOPEZ AKA “MORRO”JULIO CESAR JIMENEZ-HDAZ AKA “JULIO”JUAN MANUEL CARBAJAL AKA “WILLO”ROSALIO IBARRA SANCHEZ AKA “CAJEME”NANCY COSSDEBORA COSTINTEENA PADILLAKAAYLA BASWELLTIMOTHY MASCARENAS AKA “SPANKY”MONICA GUARDADOTINA BOGUHNOMAR AMEZQUITA-RAMIREZ AKA “GILANTRA”WENDY HENRYDEIRDRE TRIMBLEJENNIFER BRECKEMARIE MONTOYADefendants.JOHN W. SUTHERS, Attorney GeneralJOHN G. LEE, Assistant Attorney General1525 Sherman Street, 7 th FloorDenver, CO 80203303-866-XXXXRegistration Number: 29980t COURT USE ONLY tCase No.: 07CR10000Ctrm: 6COLORADO STATE GRAND JURY INDICTMENT

The EnterpriseThe enterprise alleged in this count was a group of individuals, associated in fact,although not a legal entity. The enterprise included, but was not limited to, thefollowing: Omar Guerra-Neri AKA Jimmy AKA “Chimmy”, Oscar Lomeli-LopezAKA Daniel , Jose Heriberto Martinez-Lopez AKA Eddie , Uriel Lombardi CaldinoAKA “Alonzo”, Hugo Martinez-Pasillas, Jeanette Guerra, Juan Martinez-RodriguezAKA “Paisa”, Valentin Martinez-Rodriguez, Audrey Torrez, Daniel Gonzalez,Delfina Chavez, Tony Lopez-Lopez AKA “Morro”, Julio Cesar Jimenez-Hdaz,Nancy Coss, Teena Padilla, Kaayla Baswell, and Omar Amezquita-Ramirez AKA“Gilantra”, and other persons known or unknown to the Grand Jury. The individualsassociated with the enterprise were involved in the selling of cocaine and herointhroughout the Denver metropolitain area. Individuals associated with the enterprisewould obtain large quantities of illegal narcotics, such as heroin and cocaine, and thendistribute those illegal narcotics to customers. The customers of the enterpriseconsisted of users and other drug dealers who would purchase larger quantities andthen distribute those to drug users. The enterprise had phone numbers that customerswould call to arrange for the delivery of illegal narcotics. Once they called thetelephone number, a dispatcher associated with the enterprise would typically set upa meeting location, and give the customer an estimated time. The dispatcher wouldthen typically call a drug courier and tell him when and where he was supposed tomeet the customer. On occasion, in the event of a large purchase, the dispatcherhimself would make the delivery. The drug couriers were provided with cars that hadsecret compartments to hide the illegal narcotics. The drug courier would then arriveand complete the transaction with the customer. Further, conversations betweenmembers of the enterprise and drug users were disguised by the use of code andvague terminology to frustrate law enforcement efforts.Pattern of Racketeering ActivityFor purposes of this count, the defendants engaged in acts related to the conduct ofthe enterprise, including:Distribution of a Controlled Substance – Schedule IDistribution of a Controlled Substance – Schedule IIConspiracy to Distribute a Controlled Substance-Schedule IConspiracy to Distribute a Controlled Substance – Schedule IIPossession with the Intent to Distribute a Controlled Substance – Schedule IPossession with the Intent to Distribute a Controlled Substance – Schedule IIUnlawful Use of a Telecommunications FacilityCriminal Impersonationincluding any lesser included offenses of these counts.3

Racketeering ActivityThe acts of racketeering activity that the above named persons committed,attempted to commit, conspired to commit, or solicited, coerced, or intimidated anotherperson to commit, consist of the following:PREDICATE ACT ONE(Distribution of a Controlled Substance - Schedule I)On or about May 19, 2007, in the County of Adams, State of Colorado OscarLomeli Lopez AKA Daniel unlawfully, feloniously, and knowingly sold ordistributed heroin, a schedule I controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)PREDICATE ACT TWO(Distribution of a Controlled Substance - Schedule II)On or about May 19, 2007, in the County of Adams, State of Colorado OscarLomeli Lopez AKA Daniel unlawfully, feloniously, and knowingly sold ordistributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)PREDICATE ACT THREE(Unlawful Use of a Communication Facility)On or about May 19, 2007, in the District Of Colorado, Oscar Lomeli Lopez AKADaniel did knowingly or intentionally use a communications facility, namely, atelephone, to facilitate the commission of a felony, namely, distribution of acontrolled substance and possession with the intent to distribute a controlledsubstance in violation of 21 U.S.C. § 841, such use of a commmunications facilitybeing unlawful, and in violation of 21 U.S.C. § 843The offenses alleged in Predicate Acts One, Two, and Three were committed in thefollowing manner:On May 19, 2007 Deirdre Trimble called Oscar Lomeli Lopez AKA Daniel andordered “2 black and a white.” A meeting was arranged at a gas station at I-25 and58 th avenue. Oscar Lomeli Lopez AKA Daniel dispatched a drug courier bytelephone and told him to go to that location. A drug courier was observed arriving ina tan colored Neon car and completing the drug transaction with Deirdre Trimble.Ms. Trimble’s car was later stopped by Officer Minisini of the the Aurora PoliceDepartment. Two (2) “balloons” or containers of heroin, weighing more than onegram and a “balloon” of cocaine weighing more than one gram were recovered duringa search of the car.4

PREDICATE ACT EIGHT(Conspiracy to Possess a Controlled Substance–Schedule II More than One Gram)On or about June 9, 2007, in the County of Denver, State of Colorado OscarLomeli Lopez, Delfina Chavez, Audrey Torrez and Daniel Gonzalez unlawfully,feloniously, and knowingly conspired with each other and a person or persons to theGrand Jury unknown, to possess more than one gram of 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. (F4)PREDICATE ACT NINE(Unlawful Use of a Communication Facility)On or about June 9, 2007, in the District Of Colorado, Oscar Lomeli Lopez AKADaniel , Delfina Chavez, Audrey Torrez, and Daniel Gonzalez did knowingly orintentionally use a communications facility, namely, a telephone, to facilitate thecommission of a felony, namely, distribution of a controlled substance and possessionwith the intent to distribute a controlled substance in violation of 21 U.S.C. § 841,such use of a commmunications facility being unlawful, and in violation of 21 U.S.C.§ 843The offenses alleged in Predicate Acts Seven through Nine were committed in thefollowing manner:On June 9, 2007 Audrey Torrez and Delfina Chavez talked on the telephone aboutpooling their money and purchasing an ounce of cocaine and then spiltting it betweenthem. Delfina Chavez also called Daniel Gonzalez on the telephone and asked him ifhe would be interested in joining them in buying an ounce of cocaine. DanielGonzalez agreed to participate in the purchase. Delfina Chavez then called OscarLomeli Lopez AKA Daniel on the telephone and asked him if he can sell her an ounceof cocaine. The two then arranged a meeting at Daniel Gonzalez’s house, in Denver,Colorado. Delfina Chavez was seen arriving at the meeting place and completing thetransaction with an unidentified drug courier in a tan in color Neon car.PREDICATE ACT TEN(Distribution of a Controlled Substance - Schedule II)On or about June 13, 2007, in the County of Jefferson, State of Colorado OscarLomeli Lopez AKA Daniel unlawfully, feloniously, and knowingly sold ordistributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)6

PREDICATE ACT ELEVEN(Conspiracy to Possess a Controlled Substance–Schedule II More than One Gram)On or about June 13, 2007, in the County of Denver, State of Colorado OscarLomeli Lopez AKA Daniel and Nancy Coss unlawfully, feloniously, and knowinglyconspired with each other and a person or persons to the Grand Jury unknown, topossess more than one gram of a material, compound, mixture, or preparation thatcontained cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F4)PREDICATE ACT TWELVE(Unlawful Use of a Communication Facility)On or about June 13, 2007, in the District Of Colorado, Oscar Lomeli Lopez AKADaniel and Nancy Coss did knowingly or intentionally use a communications facility,namely, a telephone, to facilitate the commission of a felony, namely, distribution of acontrolled substance and possession with the intent to distribute a controlledsubstance in violation of 21 U.S.C. § 841, such use of a commmunications facilitybeing unlawful, and in violation of 21 U.S.C. § 843PREDICATE ACT THIRTEEN(Unlawful Use of a Communication Facility)On or about June 15, 2007, in the District Of Colorado, Oscar Lomeli LopezAKADaniel and Nancy Coss 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, such use of a commmunicationsfacility being unlawful, and in violation of 21 U.S.C. § 843The offenses alleged in Predicate Acts Ten through Thirteen were committed in thefollowing manner:On June 13, 2007 Nancy Coss placed a phone call to Oscar Lomeli Lopez AKADaniel. In that phone call she asked him to send a drug courier to her home to sell hercocaine. An unidentified drug courier was observed arriving at her home in a WhiteAltima, a car associated with this criminal enterprise. The drug courier went into herhome, then returned to the car a short while later. Soon after the delivery, officersexecuted a search warrant on Ms. Coss’ home. The search revealed more than agram of cocaine, which Ms. Coss admitted belonged to her. On June 15, 2007 Ms.Coss called Daniel and informed him of the search of her home and told him that thepolice had discovered his phone number and he should change it. She also toldDaniel what vehicles the police officers had been driving, and that he should notaccept calls from her phone or come to her house.7

PREDICATE ACT FOURTEEN(Distribution of a Controlled Substance - Schedule II)On or about June 29, 2007, in the County of Denver, State of Colorado OscarLomeli Lopez AKA Daniel unlawfully, feloniously, and knowingly sold ordistributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)PREDICATE ACT FIFTEEN(Possession with Intent to Distribute a Controlled Substance – Schedule II)On or about June 29, 2007, in the County of Denver, State of Colorado DelfinaChavez and Audrey Torrez unlawfully, feloniously, and knowingly possessed withintent to distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.PREDICATE ACT SIXTEEN(Conspiracy to Distribute a Controlled Substance – Schedule II)On or about June 29, 2007, in the County of Denver, State of Colorado OscarLomeli Lopez AKA Daniel , Delfina Chavez, Audrey Torrez and Daniel Gonzalezunlawfully, feloniously, and knowingly conspired with each other and a person orpersons to the Grand Jury unknown, to distribute cocaine, a schedule II controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.PREDICATE ACT SEVENTEEN(Unlawful Use of a Communication Facility)On or about June 29, 2007, in the District Of Colorado, Oscar Lomeli Lopez AKADaniel , Delfina Chavez, Audrey Torrez, and Daniel Gonzalez did knowingly orintentionally use a communications facility, namely, a telephone, to facilitate thecommission of a felony, namely, distribution of a controlled substance and possessionwith the intent to distribute a controlled substance in violation of 21 U.S.C. § 841,such use of a commmunications facility being unlawful, and in violation of 21 U.S.C.§ 843The offenses alleged in Predicate Acts Fourteen through Seventeen werecommitted in the following manner:8

On June 29, 2007 Audrey Torrez and Delfina Chavez spoke on the telephone anddiscussed purchasing an ounce of cocaine together and splitting it. During thesetelephone conversations, Audrey Torrez mentioned that she had customers who werewaiting on the delivery of this cocaine, and that these customers were starting to askwhen Delfina Chavez was going to pick up the drugs. Delfina Chavez also had atelephone conversation with Daniel Gonzalez about whether he would like to join inthe purchase of an ounce of cocaine, and he did indicate interest and agreed to splitthe cocaine. Delfina Chavez called Oscar Lomeli Lopez AKA Daniel on the phoneand set up a place to meet to deliver the cocaine. Ultimately, Delfina Chavez andAudrey Torrez ended up meeting an umidentified drug courier, sent by Oscar LomeliLopez, in front of Audrey Torrez’s house which is in Denver, Colorado. Policeofficers subsequently executed a search warrant on Audrey Torrez’s home at 3811Franklin Street in Denver, Colorado. During the search they found Ms. Torrez inpossession of several balloons of cocaine, several items of paraphernalia, and “cut”which is often mixed with cocaine by a seller in order to increase the weight of thedrugs they are selling. Delfina Chavez then placed a phone call to Oscar Lomeli-Lopez and warned him of the search warrant and that the police had seen the car hisdrug courier was driving.PREDICATE ACT EIGHTEEN(Distribution of a Controlled Substance - Schedule I)On or about July 9, 2007, in the County of Denver, State of Colorado Oscar LomeliLopez AKA Daniel unlawfully, feloniously, and knowingly sold or distributedheroin, a schedule I controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)PREDICATE ACT NINETEEN(Unlawful Use of a Communication Facility)On or about July 9, 2007, in the District Of Colorado, Oscar Lomeli Lopez AKADaniel 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, such use of a commmunicationsfacility being unlawful, and in violation of 21 U.S.C. § 843The offenses alleged in Predicate Acts Eighteen and Nineteen were committed in thefollowing manner:On July 9, 2007 a confidential informant for the West Metro Drug Task Forceplaced a call to Oscar Lomeli-Lopez in order to purchase heroin. They arranged ameeting at 24 th and Irving in Denver, Colorado. Police officers observed anunidentified drug courier arrive in a tan in color Neon to deliver the drugs. Policelater conacted the confidential informant and she was in possession of four (4)balloons of heroin.9

PREDICATE ACT TWENTY(Distribution of a Controlled Substance - Schedule I)On or about July 11, 2007, in the County of Denver, State of Colorado OscarLomeli Lopez AKA Daniel unlawfully, feloniously, and knowingly sold ordistributed heroin, a schedule I controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)PREDICATE ACT TWENTY-ONE(Unlawful Use of a Communication Facility)On or about July 11, 2007, in the District Of Colorado Oscar Lomeli Lopez didknowingly or intentionally use a communications facility, namely, a telephone, tofacilitate the commission of a felony, namely, distribution of a controlled substance inviolation of 21 U.S.C. § 841, such use of a commmunications facility being unlawful,and in violation of 21 U.S.C. § 843The offenses alleged in Predicate Acts Twenty and Twenty-One were committedin the following manner:On July 11, 2007, a confidential informant for the West Metro Drug Task Forcepaged Oscar Lomeli-Lopez and arranged a meeting at Center and Pecos in Denver,Colorado. The purpose of the meeting was to purchase heroin. Oscar Lomeli Lopezsent a drug courier to that location. The unidentified drug courier arrived and sold theconfidential informant six (6) balloons of heroin for $100.PREDICATE ACT TWENTY-TWO(Distribution of a Controlled Substance - Schedule I)On or about July 14, 2007, in the County of Denver, State of Colorado OscarLomeli Lopez AKA Daniel unlawfully, feloniously, and knowingly sold ordistributed heroin, a schedule I controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)PREDICATE ACT TWENTY-THREE(Unlawful Use of a Communication Facility)On or about July 14, 2007, in the District Of Colorado Oscar Lomeli Lopez didknowingly or intentionally use a communications facility, namely, a telephone, tofacilitate the commission of a felony, namely, distribution of a controlled substance inviolation of 21 U.S.C. § 841, such use of a commmunications facility being unlawful,and in violation of 21 U.S.C. § 843The offenses alleged in Predicate Acts Twenty-Two and Twenty-Three werecommitted in the following manner:On July 14, 2007 a confidential informant for the West Metro Drug Task Forcepaged Oscar Lomeli Lopez to arrange for the purchase of heroin. He returned the calland told the confidential informant to meet at approximatley 4 th and Stuart, which isin Denver, Colorado. The confidential informant went to that location and purchasedsix balloons of heroin for $100 from an unidentified drug courier.10

PREDICATE ACT TWENTY-FOUR(Distribution of a Controlled Substance - Schedule I)On or about July 15, 2007, in the County of Denver, State of Colorado UrielLombardi Caldino AKA Alonzo and Tony Lopez-Lopez AKA “Morro” unlawfully,feloniously, and knowingly sold or distributed heroin, a schedule I controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)PREDICATE ACT TWENTY-FIVE(Unlawful Use of a Communication Facility)On or about July 15, 2007, in the District Of Colorado Uriel Lombardi CaldinoAKA Alonzo 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, such use of a commmunicationsfacility being unlawful, and in violation of 21 U.S.C. § 843The offenses alleged in Predicate Acts Twenty-Four and Twenty-Five werecommitted in the following manner:On July 15, 2007 a confidential informant working for the West Metro Drug TaskForce placed a telephone call to the number associated with this criminal enterprise.Uriel Lombardi Caldino AKA Alonzo answered the phone. He told the confidentialinformant to go to 4 th and Zenobia in Denver, Colorado in order to purchase thedrugs. At the meeting location, a White Nissan Altima arrived, driven by TonyLopez-Lopez AKA “Morro.” The confidential informant and an undercover officerpurchased six balloons of heroin for $100. The drugs were sold by the courier“Morro.”PREDICATE ACT TWENTY –SIX(Distribution of a Controlled Substance - Schedule I)On or about July 16, 2007, in the County of Adams, State of Colorado UrielLombardi Caldino AKA Alonzo and Tony Lopez-Lopez AKA “Morro” unlawfully,feloniously, and knowingly sold or distributed heroin, a schedule I controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)PREDICATE ACT TWENTY-SEVEN(Unlawful Use of a Communication Facility)On or about July 16, 2007, in the District Of Colorado Uriel Lombardi CaldinoAKA Alonzo and Tony Lopez-Lopez AKA “Morro” 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,such use of a commmunications facility being unlawful, and in violation of 21 U.S.C.§ 843The offenses alleged in Predicate Acts Twenty-Six and Twenty-Seven werecommitted in the following manner:11

On July 16, 2007, Detective Jay Lopez, working in undercover, placed a telephonecall which was answered by Uriel Lombardi Caldino AKA Alonzo. In that phonecall, the two arrange for a meeting at the Burger King on I-25 and 58 th avenue whichis in Adams County. A few minutes later, Tony Lopez-Lopez AKA “Morro” arrivedin the White Altima. Detective Lopez got in the car and exchanged $100 for six (6)balloons of heroin. “Morro” spit out five of the balloons, and then pulled one from ahidden compartment in the glove box of the car.PREDICATE ACT TWENTY-EIGHT(Distribution of a Controlled Substance - Schedule I)On or about July 18, 2007, in the County of Denver, State of Colorado UrielLombardi Caldino AKA Alonzo and Tony Lopez-Lopez AKA “Morro” unlawfully,feloniously, and knowingly sold or distributed heroin, a schedule I controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)PREDICATE ACT TWENTY-NINE(Unlawful Use of a Communication Facility)On or about July 18, 2007, in the District Of Colorado Uriel Lombardi CaldinoAKA Alonzo and Tony Lopez-Lopez AKA “Morro” 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,such use of a commmunications facility being unlawful, and in violation of 21 U.S.C.§ 843The offenses alleged in Predicate Acts Twenty-Eight and Twenty-Nine werecommitted in the following manner:On July 18, 2007 Detective Jay Lopez, acting in an undercover capacity, placed acall to Uriel Lombardi Caldino AKA Alonzo. In that call, Alonzo directed DetectiveLopez to 4 th and Zenobia in Denver, Colorado. Detective Lopez went to that location,and was met by “Morro” in the White Altima. “Morro” had been dispatched to thatlocation by Alonzo using a telephone. Detective Lopez was able to purchase nine (9)balloons of heroin for $150.PREDICATE ACT THIRTY(Distribution of a Controlled Substance - Schedule I)On or about July 29, 2007, in the County of Denver, State of Colorado UrielLombardi Caldino AKA Alonzo and Tony Lopez-Lopez AKA “Morro” unlawfully,feloniously, and knowingly sold or distributed heroin, a schedule I controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)The offenses alleged in Predicate Act Thirty were committed in the followingmanner:12

On July 29, 2007 Detective Jay Lopez, acting in an undercover capacity, placed aphone call that was answered by Uriel Lombardi Caldino AKA Alonzo. The twoarranged a meeting at 4 th and Zenobia in Denver, Colorado. A short while later, TonyLopez-Lopez AKA “Morro” arrived in a white Nissan Altima. Detective Lopez thengot in the car and purchased six (6) balloons of heroin for $100.PREDICATE ACT THIRTY-ONE(Distribution of a Controlled Substance - Schedule I)On or about August 14, 2007, in the County of Adams, State of Colorado JoseHeriberto Martinez Lopez AKA Eddie and Tony Lopez-Lopez AKA “Morro”unlawfully, feloniously, and knowingly sold or distributed heroin, a schedule Icontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)PREDICATE ACT THIRTY-TWO(Distribution of a Controlled Substance - Schedule II)On or about August 14, 2007, in the County of Adams, State of Colorado JoseHeriberto Martinez Lopez AKA Eddie and Tony Lopez-Lopez AKA “Morro”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. (F3)PREDICATE ACT THIRTY –THREE(Unlawful Use of a Communication Facility)On or about August 14, 2007, in the District Of Colorado Jose Heriberto MartinezLopez AKA Eddie and Tony Lopez-Lopez AKA “Morro” 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, such use of a commmunications facility being unlawful, and inviolation of 21 U.S.C. § 843The offenses alleged in Predicate Acts Thirty-One through Thirty-Three werecommitted in the following manner:On August 14, 2007, Detective Jay Lopez, acting in an undercover capacity, placeda telephone call that was answered by Jose Heriberto Martinez Lopez AKA Eddie.Eddie directed him to 58 th and Washington which is in Adams County, Colorado.Eddie then contacted Tony Lopez-Lopez AKA “Morro” via cellular telephone anddispatched him to the same location. Eddie and “Morro” had a discussion on thephone about how many balloons of drugs “Morro” still had left to sell. “Morro”arrived at the pre-arranged location in the white Nissan Altima. Detective Lopez wasable to purchase three (3) balloons of heroin for $50 and six (6) balloons of cocainefor $100.13

PREDICATE ACT THIRTY-FOUR(Distribution of a Controlled Substance - Schedule I)On or between July 12 and July 13, 2007, in the County of Adams, State ofColorado Omar Guerra Neri AKA Jimmy AKA “Chimmy”, Jeannette Guerra, OmarAmezquita-Ramirez AKA “Gilantra”, Teena Padilla, and Kaayla Baswell unlawfully,feloniously, and knowingly possessed with intent to sell or distribute heroin, aschedule I controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),C.R.S.PREDICATE ACT THIRTY-FIVE(Conspiracy to Distribute a Controlled Substance – Schedule I)On or between July 11, 2007 and July 13, 2007 in the County of Jefferson, State ofColorado Omar Guerra Neri AKA Jimmy AKA “Chimmy”, Jeannette Guerra, OmarAmezquita-Ramirez AKA “Gilantra”, Teena Padilla, and Kaayla Baswell unlawfully,feloniously, and knowingly conspired with each other and a person or persons to theGrand Jury unknown, to distribute heroin, a schedule I controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.PREDICATE ACT THIRTY-SIX(Unlawful Use of a Communication Facility)On or about July 12, 2007 in the District Of Colorado Omar Guerra Neri AKAJimmy AKA “Chimmy” and Jeannette Guerra did knowingly or intentionally use acommunications facility, namely, a telephone, to facilitate the commission of afelony, namely, distribution of a controlled substance in violation of 21 U.S.C. § 841,such use of a commmunications facility being unlawful, and in violation of 21 U.S.C.§ 843PREDICATE ACT THIRTY-SEVEN(Unlawful Use of a Communication Facility)On or about July 12, 2007 in the District Of Colorado Omar Guerra Neri AKAJimmy AKA “Chimmy” and Jeannette Guerra did knowingly or intentionally use acommunications facility, namely, a telephone, to facilitate the commission of afelony, namely, distribution of a controlled substance in violation of 21 U.S.C. § 841,such use of a commmunications facility being unlawful, and in violation of 21 U.S.C.§ 843PREDICATE ACT THIRTY-EIGHT(Unlawful Use of a Communication Facility)On or about July 12, 2007 in the District Of Colorado Omar Guerra Neri AKAJimmy AKA “Chimmy” and Omar Amezquita-Ramirez AKA “Gilantra” didknowingly or intentionally use a communications facility, namely, a telephone, tofacilitate the commission of a felony, namely, distribution of a controlled substance inviolation of 21 U.S.C. § 841, such use of a commmunications facility being unlawful,and in violation of 21 U.S.C. § 84314

PREDICATE ACT THIRTY-NINE(Unlawful Use of a Communication Facility)On or about July 13, 2007 in the District Of Colorado Omar Guerra Neri AKAJimmy AKA “Chimmy” and Jeannette Guerra did knowingly or intentionally use acommunications facility, namely, a telephone, to facilitate the commission of afelony, namely, distribution of a controlled substance in violation of 21 U.S.C. § 841,such use of a commmunications facility being unlawful, and in violation of 21 U.S.C.§ 843PREDICATE ACT FORTY(Unlawful Use of a Communication Facility)On or about July 13, 2007 in the District Of Colorado Teena Padilla and JeannetteGuerra 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, such use of a commmunicationsfacility being unlawful, and in violation of 21 U.S.C. § 843The offenses alleged in Predicate Acts Thirty-Four through Forty were committedin the following manner:On or about July 12, 2007, Omar Guerra Neri offered to pay Teena Padilla andKaayla Baswell to transport heroin from Colorado to Minnesota. The two womencontacted Omar Guerra Neri through Jeanette Guerra. Omar Guerra Neri and JeanetteGuerra had a conversation on the phone where Jeanette Guerra told him that TeenaPadilla needed more money to make the trip. Teena Padilla rented a Ford Expeditionto transport the heroin to the State of Minnesota, and was worried about the increasedcosts. Omar Guerra Neri also had a telephone conversation with Gilantra, who isbased in Minnesota. Jimmy advised Omar Amezquita-Ramirez AKA “Gilantra” thatTeena Padilla was coming with the drugs, and the two discussed how to handle thearrival of the drugs and payment for the drugs. The heroin was being delivered toGilantra so that he could distribute it in Minnesota.On July 13, 2007 Teena Padilla began the trip and was accompanied by herdaughter Kaayla Baswell. On July 13, 2007 Tenna Padilla was contacted by Trooperswith the Nebraska State Patrol. Teena Padilla called Jeanette Guerra and told her shehas been stopped by police. One of the troopers noticed that Kaayla Baswell waswearing Timberland brand boots. They checked the heel of the boot and discoveredone and a half pounds of heroin in the soles of the boots. Kaayla Baswell admittedshe was being paid $1500 to transport the drugs. Jeanette Guerra then had telephoneconversations with Omar Guerra Neri AKA Jimmy about the progress of the trafficstop and subsequent arrest of Kaayla Baswell.15

PREDICATE ACT FORTY-ONE(Unlawful Use of a Communication Facility)On or about July 13, 2007 in the District Of Colorado Omar Guerra Neri AKAJimmy AKA “Chimmy” and Jeannette Guerra did knowingly or intentionally use acommunications facility, namely, a telephone, to facilitate the commission of afelony, namely, distribution of a controlled substance in violation of 21 U.S.C. § 841,such use of a commmunications facility being unlawful, and in violation of 21 U.S.C.§ 843PREDICATE ACT FORTY-TWO(Conspiracy to Distribute a Controlled Substance – Schedule II)On or about July 13, 2007, in the County of Jefferson, State of Colorado OmarGuerra Neri AKA Jimmy AKA “Chimmy” and Jeanette Guerra unlawfully,feloniously, and knowingly conspired with each other and a person or persons to theGrand Jury unknown, to distribute heroin, a schedule I controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.The offenses alleged in Predicate Acts Forty-One and Forty-Two were committedin the following manner:On July 13, 2007 Omar Guerra Neri AKA Jimmy AKA “Chimmy” and JeanetteGuerra had a conversation on the telephone where Jimmy directed Jeanette Guerra tolook into replacing a pager used by the criminal enterprise. The pager had beenpreviously lost when it was seized by police during the arrest of Oscar Lomeli-Lopez.The pager was the primary means used by customers of the criminal enterprise tocontact someone to order illegal narcotics. Jeanette Guerra told him that she wouldlook into itPREDICATE ACT FORTY-THREE(Distribution of a Controlled Substance - Schedule I)On or about July 20, 2007, in the County of Denver, State of Colorado UrielLombardi Caldino AKA “Alonzo” and Tony Lopez-Lopez AKA “Morro” unlawfully,feloniously, and knowingly sold or distributed heroin, a schedule I controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)PREDICATE ACT FORTY-FOUR(Unlawful Use of a Communication Facility)On or about July 20, 2007 in the District Of Colorado Uriel Lombardi Caldino AKA“Alonzo” and Tony Lopez-Lopez AKA “Morro” did knowingly or intentionally use acommunications facility, namely, a telephone, to facilitate the commission of afelony, namely, distribution of a controlled substance in violation of 21 U.S.C. § 841,such use of a commmunications facility being unlawful, and in violation of 21 U.S.C.§ 843The offenses alleged in Predicate Acts Forty-Three and Forty-Four were committedin the following manner:16

On July 20, 2007 a confidential informant working for the West Metro Drug TaskForce called Alonzo on the telephone. The confidential informant arranged a meetingto purchase illegal narcotics. Immediately after that phone call, Alonzo contactedTony Lopez-Lopez AKA “Morro” using the telephone and told him to meet theconfidential informant at 4 th and Zenobia in Denver Colorado. Officers observed“Morro” arrive in a white Nissan Altima. The confidential informant got into his carand exchanged $50 for three balloons of what would later be confirmed to be heroin.PREDICATE ACT FORTY-FIVE(Distribution of a Controlled Substance - Schedule I)On or about July 22, 2007, in the County of Denver, State of Colorado UrielLombardi Caldino AKA “Alonzo” and Tony Lopez-Lopez AKA “Morro” unlawfully,feloniously, and knowingly sold or distributed heroin, a schedule I controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)PREDICATE ACT FORTY-SIX(Unlawful Use of a Communication Facility)On or about July 22, 2007 in the District Of Colorado Uriel Lombardi Caldino AKA“Alonzo” and Tony Lopez-Lopez AKA “Morro” did knowingly or intentionally use acommunications facility, namely, a telephone, to facilitate the commission of afelony, namely, distribution of a controlled substance in violation of 21 U.S.C. § 841,such use of a commmunications facility being unlawful, and in violation of 21 U.S.C.§ 843The offenses alleged in Predicate Acts Forty-Five and Forty-Six were committed inthe following manner:On July 22, 2007 a confidential informant working on behalf of the West MetroDrug Task Force placed a telephone call to Uriel Lombardi Caldino AKA Alonzo.The two arranged for a meeting at 4 th and Zenobia in Denver, Colorado where theconfidential informant could purchase illegal controlled substances. Shortly after thatphone call, Alonzo made a phone call to Tony Lopez-Lopez aka “Morro” anddispatched him to that location. After resolving some car troubles, “Morro” arrivedat the scene and sold the confidential informant three balloons of heroin for $50.PREDICATE ACT FORTY-SEVEN(Distribution of a Controlled Substance - Schedule I)On or about July 23, 2007, in the County of Adams, State of Colorado UrielLombardi Caldino AKA “Alonzo” and Tony Lopez-Lopez AKA “Morro” unlawfully,feloniously, and knowingly sold or distributed heroin, a schedule I controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)The offense alleged in Predicate Act Forty Seven was committed in the followingmanner:17

On July 23, 2007 Deborah Costin placed a phone call to Uriel Lombardi CaldinoAKA “Alonzo.” Ms. Costin told him that she wanted to meet at the Burger King at I-25 and 58 th avenue in Adams County Colorado. A short time later Tony Lopez-LopezAKA “Morro”, a drug courier, arrived and they completed the drug transaction. Ms.Costin was stopped a short time later and three (3) balloons of heroin were found.The gross weight of the three balloons was less than a gram.PREDICATE ACT FORTY-EIGHT(Unlawful Use of a Communication Facility)On or about August 5, 2007 in the District Of Colorado Uriel Lombardi CaldinoAKA “Alonzo” and Juan Martinez-Rodriguez AKA “Paisa” did knowingly orintentionally use a communications facility, namely, a telephone, to facilitate thecommission of a felony, namely, distribution of a controlled substance and possessionof a controlled cubstance with the intent to distribute in violation of 21 U.S.C. § 841,such use of a commmunications facility being unlawful, and in violation of 21 U.S.C.§ 843PREDICATE ACT FORTY-NINE(Distribution of a Controlled Substance - Schedule II)On or about August 6, 2007, in the County of Adams, State of Colorado JuanMartinez-Rodriguez AKA “Paisa” unlawfully, feloniously, and knowingly sold ordistributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)PREDICATE ACT FIFTY(Possession with Intent to Distribute a Controlled Substance – Schedule II)On or about August 6, 2007, in the County of Adams, State of Colorado UrielLombardi Caldino AKA “Alonzo” unlawfully, feloniously, and knowingly possessedwith intent to distribute cocaine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.PREDICATE ACT FIFTY-ONE(Unlawful Use of a Communication Facility)On or about August 6, 2007 in the District Of Colorado Uriel Caldina AKA“Alonzo” and Juan Martinez-Rodriguez AKA “Paisa” did knowingly or intentionallyuse a communications facility, namely, a telephone, to facilitate the commission of afelony, namely, distribution of a controlled substance and possession of a controlledsubstance with the intent to distribute in violation of 21 U.S.C. § 841, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843The offenses alleged in Predicate Acts Forty-Eight through Fifty-One werecommitted in the following manner:18

On August 5, 2007 Alonzo and Paisa had a telephone conversation where Alonzotold Paisa that he needed a favor and could only purchase a half a kilogram ofcocaine. Paisa agreed to sell him that quantity and the two planned on meeting thenext day. On August 6, 2007 the two spoke again on the telephone and arranged tomeet at Alonzo’s stash house to do the transaction. Paisa was observed leaving hishouse and arriving at Alonzo’s stash house at 600 Erie St, Adams County, Colorado.Alonzo arrived a short while later and both were seen going into the house, as theyhad previously discussed. Paisa was then observed leaving a short while later.PREDICATE ACT FIFTY-TWO(Unlawful Use of a Communication Facility)On or about August 26, 2007 in the District Of Colorado Juan Martinez-RodriguezAKA “Paisa” did knowingly or intentionally use a communications facility, namely, atelephone, to facilitate the commission of a felony, namely, distribution of acontrolled substance and possession of a controlled substance with the intent todistribute in violation of 21 U.S.C. § 841, such use of a commmunications facilitybeing unlawful, and in violation of 21 U.S.C. § 843PREDICATE ACT FIFTY-THREE(Unlawful Use of a Communication Facility)On or about August 27, 2007 in the District Of Colorado and Juan Martinez-Rodriguez AKA “Paisa” did knowingly or intentionally use a communicationsfacility, namely, a telephone, to facilitate the commission of a felony, namely,distribution of a controlled substance and possession of a controlled substance withthe intent to distribute in violation of 21 U.S.C. § 841, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843PREDICATE ACT FIFTY-FOUR(Distribution of a Controlled Substance - Schedule II)On or about August 29, 2007, in the County of Pueblo, State of Colorado JuanMartinez-Rodriguez AKA “Paisa” unlawfully, feloniously, and knowingly distributedcocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)PREDICATE ACT FIFTY-FIVE(Conspiracy to Distribute a Controlled Substance – Schedule II)On or between August 26, 2007 and August 29, 2007 in the State of Colorado JuanMartinez-Rodruguez AKA “Paisa” unlawfully, feloniously, and knowingly conspiredwith Valentin Martinez-Rodriguez and a person or persons to the Grand Juryunknown, to distribute cocaine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.The offenses alleged in predicate acts Fifty-Two through Fifty-Five werecommitted in the following manner:19

On August 26, 2007 and August 27, 2007 Valentin Martinez-Rodriuguez and JuanMartinez-Rodriguez AKA “Paisa” had several telephone conversations aboutValentin modifying a car so as to store several kilograms of cocaine that were to betransported to the Denver area. They also discussed Valentin’s progress in modifyingthe car, what quantity of drugs he was bringing up, and when he was going to leave.Further, they discussed bringing two (2) kilograms of cocaine for Omar Guerra-NeriAKA Jimmy. On August 29, 2007 Valentin Martinez-Rodriguez was stopped by theColorado State patrol for a traffic violation. After a search, officers found 5kilograms of cocaine hidden in the wheel wells of the car.PREDICATE ACT FIFTY-SIX(Unlawful Use of a Communication Facility)On or about September 4, 2007 in the District of Colorado Hugo Martinez-Pasillasdid knowingly or intentionally use a communications facility, namely, a telephone, tofacilitate the commission of a felony, namely, distribution of a controlled substanceand possession of a controlled substance with the intent to distribute in violation of 21U.S.C. § 841, such use of a commmunications facility being unlawful, and inviolation of 21 U.S.C. § 843PREDICATE ACT FIFTY-SEVEN(Unlawful Use of a Communication Facility)On or about September 4, 2007 in the District of Colorado Hugo Martinez Pasillasand Jose Heriberto Martinez-Lopez AKA Eddie did knowingly or intentionally use acommunications facility, namely, a telephone, to facilitate the commission of afelony, namely, distribution of a controlled substance and possesion of a controlledsubstance with the intent to distribute in violation of 21 U.S.C. § 841, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843PREDICATE ACT FIFTY-EIGHT(Possession with Intent to Distribute a Controlled Substance – Schedule II)On or about September 4, 2007, in the County of Adams, State of Colorado HugoMartinez Pasillas, Omar Guerra-Neri AKA Jimmy AKA “Chimmy”, and JoseHeriberto Martinez-Lopez AKA Eddie unlawfully, feloniously, and knowinglypossessed with intent to distribute cocaine, a schedule II controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.PREDICATE ACT FIFTY-NINE(Conspiracy to Distribute a Controlled Substance – Schedule II)On or between September 4, 2007 and September 5, 2007, in the Counties ofAdams and Denver, State of Colorado Hugo Martinez-Pasillas, Omar Guerra-NeriAKA Jimmy, and Jose Heriberto Martinez-Lopez AKA Eddie unlawfully,feloniously, and knowingly conspired with each other, Alonzo Martinez-Rodriguezand a person or persons to the Grand Jury unknown, to distribute cocaine, a scheduleII controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.20

PREDICATE ACT SIXTY(Unlawful Use of a Communication Facility)On or about September 4, 2007 in the District of Colorado Jose Heriberto Martinez-Lopez AKA Eddie and Omar Guerra-Neri AKA Jimmy did knowingly orintentionally use a communications facility, namely, a telephone, to facilitate thecommission of a felony, namely, distribution of a controlled substance and possesionof a controlled substance with the intent to distribute in violation of 21 U.S.C. § 841,such use of a commmunications facility being unlawful, and in violation of 21 U.S.C.§ 843PREDICATE ACT SIXTY-ONE(Unlawful Use of a Communication Facility)On or about September 5, 2007 in the District of Colorado Hugo Martinez Pasillasand Omar Guerra-Neri AKA Jimmy did knowingly or intentionally use acommunications facility, namely, a telephone, to facilitate the commission of afelony, namely, distribution of a controlled substance and possesion of a controlledsubstance with the intent to distribute in violation of 21 U.S.C. § 841, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. § 843The offenses alleged in Predicate Acts Fifty-Six through Sixty-One were committedin the following manner:On September 4, 2007 Hugo Martinez-Pasillas had a telephone conversation withAlonzo Martinez Rodriguez. The purpose of the phone call was to set up a meetingso that Hugo could purchase a large quantity of cocaine to be sold to customers of thecriminal enterprise. The two eventually traveled to 600 Erie Street in Adams County,Colorado. That location was being used by Hugo and others as a stash house forkeeping drugs that were to be sold. During the meeting, Hugo had a telephoneconversation with Jose Heriberto Martinez-Lopez AKA Eddie where Hugo told himthat Alonzo Martinez-Rodriguez wanted to weigh out the cocaine, which promptedEddie to go to the stash house. During the transaction, Eddie called Omar Guerra-Neri AKA Jimmy and gave him updates on the progress of the deal, which includedweighing of the drugs. Conversations the next day indicated that it was more than akilogram of cocaine. The day after the deal, Jimmy and Eddie had a telephone callwhere Jimmy directed Eddie to go and pay Alonzo Martinez-Rodriguez. Eddie wasobserved meeting with Alonzo Martinez-Rodriguez in Denver, Colorado.PREDICATE ACT SIXTY-TWO(Distribution of a Controlled Substance - Schedule I)On or about October 16, 2007, in the County of Denver, State of Colorado JoseHeriberto Martinez-Lopez AKA Eddie and Tony Lopez-Lopez aka “Morro”unlawfully, feloniously, and knowingly sold or distributed heroin, a schedule Icontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)21

PREDICATE ACT SIXTY-THREE(Unlawful Use of a Communication Facility)On or about October 16, 2007, in the District of Colorado, Jose Heriberto Martinez-Lopez AKA Eddie and Tony Lopez-Lopez did knowingly or intentionally use acommunications facility, namely, a telephone, to facilitate the commission of afelony, namely, distribution of a controlled substance in violation of 21 U.S.C. § 841,such use of a commmunications facility being unlawful, and in violation of 21 U.S.C.§ 843The offenses alleged in Predicate Acts Sixty-Two and Sixty-Three were committedin the following manner:On October 16, 2007 a telephone call between Jose Heriberto Martinez-LopezAKA Eddie and Tony Lopez-Lopez AKA “Morro” was intercepted. In the phonecall Eddie directed Morro to make a delivery to “Spanky,.” A short while later,officers observed “Morro” arrive in a white Nissan Altima and sell heroin to“Spanky” who is also known as Timothy Mascarenas.PREDICATE ACT SIXTY-FOUR(Distribution of a Controlled Substance - Schedule I)On or about October 23, 2007, in the County of Denver, State of Colorado JoseHeriberto Martinez-Lopez AKA Eddie and Julio Cesar Jimenez-Hdaz unlawfully,feloniously, and knowingly sold or distributed heroin, a schedule I controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)PREDICATE ACT SIXTY-FIVE(Unlawful Use of a Communication Facility)On or about October 23, 2007, in the District of Colorado, Jose Heriberto Martinez-Lopez AKA Eddie and Julio Cesar Jimenez-Hdaz did knowingly or intentionally usea 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,such use of a commmunications facility being unlawful, and in violation of 21 U.S.C.§ 843PREDICATE ACT SIXTY-SIX(Possession with Intent to Distribute a Controlled Substance – Schedule I)On or about October 23, 2007, in the County of Denver, State of Colorado JulioCesar Jimenez-Hdaz unlawfully, feloniously, and knowingly possessed with intent todistribute heroin, a schedule I controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.22

PREDICATE ACT SIXTY-SEVEN(Possession with Intent to Distribute a Controlled Substance – Schedule II)On or about October 23, 2007, in the County of Denver, State of Colorado JulioCesar Jimenez-Hdaz unlawfully, feloniously, and knowingly possessed with intent todistribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.PREDICATE ACT SIXTY-EIGHT(Unlawful Use of a Communication Facility)On or between October 23, 2007 and October 24, 2007, in the District of Colorado,Jose Heriberto Martinez-Lopez AKA Eddie and Omar Guerra-Neri AKA JimmyAKA “Chimmy” 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, such use of a commmunicationsfacility being unlawful, and in violation of 21 U.S.C. § 843The offenses alleged in Predicate Acts Sixty-Four through Sixty-Eight werecommitted in the following manner:On October 23, 2007 Wendy Henry called Jose Heriberto Martinez-Lopez AKAEddie to order drugs. Jose Jeriberto Martinez Lopez AKA “Eddie” called Julio CesarJimenez-Hdaz and directed him to deliver drugs to Wendy Henry. A short time laterJulio was observed arriving at Wendy Henry’s home at 5022 West 8 th avenue inDenver, Colorado. Eddie and Julio had further discussions over the telephone onceJulio was inside the residence about how much he was supposed to give Wendy andhow much she was supposed to pay for it. Julio was then observed leaving theresidence. Julio was stopped by officers with the Lakewood Police Department ashort time later. His car was searched and approximatley four and a half (4.5) ouncesof cocaine and two (2) ounces of heroin were found secreted throughout the car.Also, approximatley $4725 in cash, as well as “pay-owe” sheets, and other indicatorsof distribution were found in the car. After Julio was arrested, Eddie had severaltelephone conversations with Omar Guerra-Neri AKA Jimmy about replacing the carand replacing Julio as a runner for the criminal enterprise.PREDICATE ACT SIXTY-NINE(Distribution of a Controlled Substance - Schedule I)On or about October 12, 2007, in the County of Adams, State of Colorado JoseHeriberto Martinez-Lopez AKA Eddie and Tony Lopez-Lopez aka “Morro”unlawfully, feloniously, and knowingly sold or distributed heroin, a schedule Icontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)23

PREDICATE ACT SEVENTY(Unlawful Use of a Communication Facility)On or about October 12, 2007, in the District Of Colorado, Jose Heriberto Martinez-Lopez AKA Eddie and Tony Lopez-Lopez did knowingly or intentionally use acommunications facility, namely, a telephone, to facilitate the commission of afelony, namely, distribution of a controlled substance in violation of 21 U.S.C. § 841,such use of a commmunications facility being unlawful, and in violation of 21 U.S.C.§ 843The offenses alleged in Predicate Acts Sixty-Nine and Seventy were committed inthe following manner:On October 12, 2007 Jose Heriberto Martinez-Lopez AKA Eddie used a telephoneto dispatch Tony Lopez-Lopez AKA “Morro” to I-25 and 58 th Avenue to sell drugs toTina Boguhn. Officers observed “Morro” arrive at that location which is in AdamsCounty Colorado. Tina Boguhn has been known to purchase heroin from thisorganization in the past. When Morro arrived in the white Nissan Altima, Ms.Boguhn got into his vehicle for a short period of time, then exited his vehicle.PREDICATE ACT SEVENTY-ONE(Distribution of a Controlled Substance - Schedule I)On or about November 2, 2007 in the County of Denver, State of Colorado JoseHeriberto Martinez-Lopez AKA Eddie and Tony Lopez-Lopez aka “Morro”unlawfully, feloniously, and knowingly sold or distributed heroin, a schedule Icontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)PREDICATE ACT SEVENTY-TWO(Unlawful Use of a Communication Facility)On or about November 2, 2007, in the District Of Colorado, Jose HeribertoMartinez-Lopez AKA Eddie and Tony Lopez-Lopez aka “Morro” 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, such use of a commmunications facility being unlawful, and inviolation of 21 U.S.C. § 843The offenses alleged in Predicate Acts Seventy-One and Seventy-Two werecommitted in the following manner:On November 2, 2007 Jose Heriberto Martinez-Lopez AKA Eddie used atelephone to dispatch Tony Lopez-Lopez AKA “Morro” to 4165 W. Nevada Place inDenver, Colorado. This is the residence of Timothy Mascarenas AKA “Spanky.”Officers observed Morro arrive a short time later and sell heroin to TimothyMascarencas. A search warrant was executed on the residence a short while later.The search turned up both heroin and cocaine, and less than a gram of each.24

PREDICATE ACT SEVENTY-THREE(Criminal Impersonation)On or about July 11, 2007, Jeanette Guerra unlawfully, feloniously, and knowinglyassumed a false or fictitious identity or capacity, namely: Omar Guerra-Neri AKAJimmy AKA “Chimmy”, and in such identity or capacity did an act with intent tounlawfully gain a benefit for himself or another or to injure or defraud another; inviolation of section 18-5-113(1)(e), C.R.S. (F6)The offense alleged in Predicate Act Seventy-Three was committed in the followingmanner:On July 3, 2007 Omar Guerra-Neri AKA Jimmy was issued a summons by theDenver Police to appear in court for a traffic citation. When contacted, he gave thefalse name of Omar Guerra-Neri. On July 11, 2007, he contacted Jeanette Guerra andasked her to contact the Denver court and reschedule his court appearance so that hecould go earlier. During the conversation, she asked him what name he had used.Jeanette Guerra then contacted the court because Jimmy did appear early for histraffic citation.PREDICATE ACT SEVENTY-FOUR(Cultivation of Marihuana)On or about November 7, 2007, in the County of Denver, State of Colorado, JoseHeriberto Martinez Lopez AKA Eddie and Hugo Martinez Pasillas unlawfully,feloniously, and knowingly cultivated, grew, produced, processed, or manufacturedmarihuana or marihuana concentrate, or allowed marihuana or marihuana concentrateto be cultivated, grown, produced, processed, or manufactured on land owned,occupied, or controlled by the defendant; in violation of section 18-18-406(8)(a),C.R.S.(F4)PREDICATE ACT SEVENTY-FIVE(Possession with Intent to Distribute a Controlled Substance – Schedule II)On or about November 7, 2007, in the County of Denver, State of Colorado JoseHeriberto Martinez Lopez AKA Eddie and Hugo Martinez Pasillas unlawfully,feloniously, and knowingly possessed with intent to distribute cocaine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.(F3)The offenses alleged in Predicate Acts Seventy-Four and Seventy-Five werecommitted in the following manner:On November 7, 2007 officers executed a search warrant at 4943 Jasper Court,Denver, Colorado. Prior surveillance indicated both Jose Heriberto Martinez-LopezAKA Eddie and Hugo Martinez-Pasillas were living there. Officers foundapproximatley fifteen (15) grams of cocaine, several marihuana plants growing in thehouse, $38,787 in cash, 3 handguns, and several ledgers including records of thebusiness conducted by several drug couriers.25

PREDICATE ACT SEVENTY-SIX(Possession with Intent to Distribute a Controlled Substance – Schedule I)On or about November 7, 2007, in the County of Arapahoe, State of ColoradoTony Lopez-Lopez AKA “Morro” unlawfully, feloniously, and knowingly possessedwith intent to distribute heroin, a schedule I controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.PREDICATE ACT SEVENTY-SEVEN(Possession with Intent to Distribute a Controlled Substance – Schedule II)On or about November 7, 2007, in the County of Arapahoe, State of ColoradoTony Lopez-Lopez AKA “Morro” unlawfully, feloniously, and knowingly possessedwith intent to distribute cocaine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.The offenses alleged in Predicate Acts Seventy-Six and Seventy-Seven werecommitted in the following manner:On November 7, 2007 police officers executed a search warrant on 14806 E. 2 ndAve. Building G-107 Aurora, Arapahoe County, Colorado. This location wasbelieved to be a stash house for this criminal enterprise. When officers entered theresidence they found Tony Lopez-Lopez AKA “Morro” was staying at this apartment.There was 1, 343 grams of heroin, and 851.7 grams of cocaine. Some of the drugswere separated into smaller quantities and were packaged for sale to customers inballoons.PREDICATE ACT SEVENTY-EIGHT(Possession with Intent to Distribute a Controlled Substance – Schedule II)On or about November 14, 2007, in the County of Denver, State of Colorado JuanManuel Carbajal AKA “Willo” unlawfully, feloniously, and knowingly possessedwith intent to distribute cocaine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.PREDICATE ACT SEVENTY-NINE(Possession with Intent to Distribute a Controlled Substance – Schedule I)On or about November 14, 2007, in the County of Denver, State of Colorado JuanManuel Carbajal AKA “Willo” unlawfully, feloniously, and knowingly possessedwith intent to distribute heroin, a schedule I controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.The offenses alleged in Predicate Acts Seventy-Eight and Seventy-Nine werecommitted in the following manner:On November 14, 2007 Juan Manuel Carbajal AKA “Willo” was contacted byDetectives with the West Metro Drug Task Force at 575 S. Federal Blvd Denver,Colorado. The car he was driving was searched, and officers found 12.15 grams ofcocaine and 6.85 grams of heroin. All of the illegal narcotics were secreted in the carand were packaged in balloons.26

PREDICATE ACT EIGHTY(Possession with Intent to Distribute a Controlled Substance – Schedule II)On or about November 14, 2007, in the County of Denver, State of ColoradoRosalio Ibarra Sanchez AKA “Cajeme” unlawfully, feloniously, and knowinglypossessed with intent to distribute cocaine, a schedule II controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.PREDICATE ACT EIGHTY-ONE(Possession with Intent to Distribute a Controlled Substance – Schedule I)On or about November 14, 2007, in the County of Denver, State of ColoradoRosalio Ibarra Sanchez AKA “Cajeme” unlawfully, feloniously, and knowinglypossessed with intent to distribute heroin, a schedule I controlled substance; inviolation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.The offenses alleged in Predicate Acts Eighty and Eighty-One were committed inthe following manner:On November 14, 2007 Rosalio Ibarra Sanchez AKA “Cajeme” was contacted byDetectives from the West Metro Drug Task Force at 3740 Birch Street Denver,Colorado. A search of his car revealed 9 grams of cocaine and approximatley 5grams of heroin. All of the illegal narcotics found were secreted in the car and werepackaged in balloons.PREDICATE ACT EIGHTY-TWO(Possession with Intent to Distribute a Controlled Substance – Schedule I)On or about November 14, 2007, in the County of Denver, State of ColoradoRosalio Ibarra Sanchez AKA “Cajeme” and Juan Manuel Carbajal AKA “Willo” andunlawfully, feloniously, and knowingly possessed with intent to distribute heroin, aschedule I controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),C.R.S.PREDICATE ACT EIGHTY-THREE(Possession with Intent to Distribute a Controlled Substance – Schedule II)On or about November 14, 2007, in the County of Denver, State of ColoradoRosalio Ibarra Sanchez AKA “Cajeme” and Juan Manuel Carbajal AKA “Willo”unlawfully, feloniously, and knowingly possessed with intent to distribute cocaine, 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-Two and Eighty-Three werecommitted in the following manner:On November 14, 2007 police executed a search warrant at 5537 Zion CourtDenver, Colorado. This was the residence of Juan Manuel Carbajal AKA “Willo”and Rosalio Ibarra Sanchez AKA “Cajeme”. Inside the residence, police foundapproximatley 35 grams of cocaine and 6 grams of heroin.27

COUNT THREE81021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE I,C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about May 19, 2007, in the County of Adams, State of Colorado OscarLomeli Lopez AKA Daniel unlawfully, feloniously, and knowingly sold ordistributed heroin, a schedule I controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)COUNT FOUR82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULEII, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about May 19, 2007, in the County of Adams, State of Colorado OscarLomeli Lopez AKA Daniel unlawfully, feloniously, and knowingly sold ordistributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)COUNT FIVE81012 POSSESSION OF A CONTROLLED SUBSTANCE - SCHEDULE I -MORE THAN 1 GRAM, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about May 19, 2007, in the County of Adams, State of Colorado DeirdreTrimble unlawfully, feloniously, and knowingly possessed more than one gram of amaterial, compound, mixture, or preparation that contained heroin, a schedule Icontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.COUNT SIX82012 POSSESSION OF A CONTROLLED SUBSTANCE - SCHEDULE II -MORE THAN 1 GRAM, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F4)On or about May 19, 2007, in the County of Adams, State of Colorado, DeirdreTrimble unlawfully, feloniously, and knowingly possessed more than one gram of amaterial, compound, mixture, or preparation that contained cocaine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.The offenses alleged in Counts Three through Six were committed in the mannerdescribed in Predicate Acts One, Two and ThreeCOUNT SEVEN82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULEII, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about May 31, 2007, in the County of Jefferson, State of Colorado OscarLomeli Lopez AKA Daniel unlawfully, feloniously, and knowingly sold ordistributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)28

COUNT EIGHT82052 CONSPIRACY TO POSSESS A CONTROLLED SUBSTANCE -SCHEDULE II - MORE THAN ONE GRAM, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F4On or about May 31, 2007, in the County of Jefferson, State of Colorado OscarLomeli Lopez AKA Daniel and Nancy Coss unlawfully, feloniously, and knowinglyconspired with each other and a person or persons to the Grand Jury unknown, topossess more than one gram of a material, compound, mixture, or preparation thatcontained cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F4)COUNT NINE82012 POSSESSION OF A CONTROLLED SUBSTANCE - SCHEDULE II -MORE THAN 1 GRAM, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F4)On or about May 19, 2007, in the County of Jefferson, State of Colorado, NancyCoss unlawfully, feloniously, and knowingly possessed more than one gram of amaterial, compound, mixture, or preparation that contained cocaine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.The offenses alleged in Counts Seven through Nine were committed in the mannerdescribed for Predicate Acts Four through Six.COUNT TEN82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULEII, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about June 9, 2007, in the County of Denver, State of Colorado OscarLomeli Lopez AKA Daniel , Delfina Chavez, and Audrey Torrez 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. (F3)COUNT ELEVEN82052 CONSPIRACY TO POSSESS A CONTROLLED SUBSTANCE -SCHEDULE II - MORE THAN ONE GRAM, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F4)On or about June 9, 2007, in the County of Denver, State of Colorado OscarLomeli Lopez AKA Daniel , Delfina Chavez, Audrey Torrez and Daniel Gonzalezunlawfully, feloniously, and knowingly conspired with each other and a person orpersons to the Grand Jury unknown, to possess more than one gram of 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. (F4)29

COUNT TWELVE82041 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLEDSUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about June 9, 2007, in the County of Denver, State of Colorado DelfinaChavez, Audrey Torrez and Daniel Gonzalez unlawfully, feloniously, and knowinglypossessed with intent 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 offenses alleged in Counts Ten, Eleven, and Twelve were committed in themanner described in Predicate Acts Seven through Nine.COUNT THIRTEEN82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULEII, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about June 13, 2007, in the County of Jefferson, State of Colorado OscarLomeli Lopez AKA Daniel unlawfully, feloniously, and knowingly sold ordistributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)COUNT FOURTEEN82052 CONSPIRACY TO POSSESS A CONTROLLED SUBSTANCE -SCHEDULE II - MORE THAN ONE GRAM, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F4)On or about June 13, 2007, in the County of Denver, State of Colorado OscarLomeli Lopez AKA Daniel and Nancy Coss unlawfully, feloniously, and knowinglyconspired with each other and a person or persons to the Grand Jury unknown, topossess more than one gram of a material, compound, mixture, or preparation thatcontained cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F4)The offenses alleged in Counts Thirteen and Fourteen were committed in themanner described in Predicate Acts Ten through Thirteen.30

COUNT FIFTEEN82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULEII, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about June 29, 2007, in the County of Denver, State of Colorado OscarLomeli Lopez AKA Daniel unlawfully, feloniously, and knowingly sold ordistributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)COUNT SIXTEEN82041 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLEDSUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about June 29, 2007, in the County of Denver, State of Colorado DelfinaChavez and Audrey Torrez unlawfully, feloniously, and knowingly possessed withintent to distribute cocaine, a schedule II controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A), C.R.S.COUNT SEVENTEEN82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE -SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about June 29, 2007, in the County of Denver, State of Colorado OscarLomeli Lopez AKA Daniel , Delfina Chavez, Audrey Torrez and Daniel Gonzalezunlawfully, feloniously, and knowingly conspired with each other and a person orpersons to the Grand Jury unknown, to distribute 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 Fifteen, Sixteen, and Seventeen were committed inthe manner described in Predicate Acts Fourteen through SeventeenCOUNT EIGHTEEN82011 POSSESSION OF A CONTROLLED SUBSTANCE - SCHEDULE II -1 GRAM OR LESS, C.R.S. 18-18-405(1),(2.3)(a)(I) (F6)On or about June 28, 2007 in the County of Denver, State of Colorado, MonicaGuardado unlawfully, feloniously, and knowingly possessed one gram or less of amaterial, compound, mixture, or preparation that contained cocaine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2.3)(a)(I), C.R.S.The offense alleged in Count Eighteen was committed in the following manner:On June 28, 2007, police officers executed a search warrant on Monica Guardado’sresidence at 373 S. Quitman, County of Denver, State of Colorado. During the searchthey found .11 grams of cocaine hidden in Ms. Guardado’s closet. She admitted thatshe moved the drugs to that location.31

COUNT NINETEEN82012 POSSESSION OF A CONTROLLED SUBSTANCE - SCHEDULE II -MORE THAN 1 GRAM, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F4)On June 29, 2007 in the County of Denver, State of Colorado, Jennifer Breckeunlawfully, feloniously, and knowingly possessed more than one gram of 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 Nineteen was committed in the following manner:On June 29, 2007 police officers observed Jenifer Brecke completing a drugtransaction with Audrey Torrez outside of her residence at 3811 Franklin, County ofDenver, State of Colorado. Police stopped Ms. Brecke almost immediately and foundher in possession of 2.73 grams of cocaine.COUNT TWENTY82011 POSSESSION OF A CONTROLLED SUBSTANCE - SCHEDULE II -1 GRAM OR LESS, C.R.S. 18-18-405(1),(2.3)(a)(I) (F6)On or about June 29, 2007 in the County of Denver, State of Colorado, DanielGonzalez and Marie Montoya unlawfully, feloniously, and knowingly possessed onegram or less of a material, compound, mixture, or preparation that containedRoxicodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2.3)(a)(I), C.R.S.COUNT TWENTY-ONE82011 POSSESSION OF A CONTROLLED SUBSTANCE - SCHEDULE II -1 GRAM OR LESS, C.R.S. 18-18-405(1),(2.3)(a)(I) (F6)On or about June 29, 2007 in the County of Denver, State of Colorado, DanielGonzalez and Marie Montoya unlawfully, feloniously, and knowingly possessed onegram or less of a material, compound, mixture, or preparation that containedhydrocodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2.3)(a)(I), C.R.S.COUNT TWENTY-TWO82011 POSSESSION OF A CONTROLLED SUBSTANCE - SCHEDULE II -1 GRAM OR LESS, C.R.S. 18-18-405(1),(2.3)(a)(I) (F6)On or about June 29, 2007 in the County of Denver, State of Colorado, DanielGonzalez and Marie Montoya unlawfully, feloniously, and knowingly possessed onegram or less of a material, compound, mixture, or preparation that containedoxycodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2.3)(a)(I), C.R.S.The offenses alleged in Counts Twenty through Twenty-Two were committed inthe following manner:32

On June 29, 2007 police officers executed a search warrant on the residence ofDaniel Gonzalez located at 3334 West Ohio Avenue, Denver, Colorado. Once insidethe residence officers located several pills, not in prescription bottles but in a jewlerybox, in the bedroom shared by Daniel Gonzalez and Marie Montoya. Those pillswere determined to be Roxicodone, Vicodin which is hydrocodone, and Percocetwhich is oxycodone, all Schedule II Controlled Substances.COUNT TWENTY-THREE81021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE I,C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about July 9, 2007, in the County of Denver, State of Colorado Oscar LomeliLopez AKA Daniel unlawfully, feloniously, and knowingly sold or distributedheroin, a schedule I controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)The offense alleged in County Twenty-Three was committed in the mannerdescribed in Predicate Acts Eighteen and NineteenCOUNT TWENTY-FOUR81021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE I,C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about July 11, 2007, in the County of Denver, State of Colorado OscarLomeli Lopez AKA Daniel unlawfully, feloniously, and knowingly sold ordistributed heroin, a schedule I controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)The offense alleged in County Twenty-Four was committed in the manner describedin Predicate Acts Twenty and Twenty-OneCOUNT TWENTY-FIVE81021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE I,C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about July 14, 2007, in the County of Denver, State of Colorado OscarLomeli Lopez AKA Daniel unlawfully, feloniously, and knowingly sold ordistributed heroin, a schedule I controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)The offense alleged in Count Twenty-Five was committed in the manner describedin Predicate Acts Twenty-Two and Twenty-Three33

COUNT TWENTY-SIX81021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE I,C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about July 15, 2007, in the County of Denver, State of Colorado UrielLombardi Caldino AKA Alonzo and Tony Lopez-Lopez AKA “Morro” unlawfully,feloniously, and knowingly sold or distributed heroin, a schedule I controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)The offense alleged in Count Twenty-Six was committed in the manner describedin Predicate Acts Twenty-Four and Twenty-FiveCOUNT TWENTY-SEVEN81021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE I,C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about July 16, 2007, in the County of Adams, State of Colorado UrielLombardi Caldino AKA Alonzo and Tony Lopez-Lopez AKA “Morro” unlawfully,feloniously, and knowingly sold or distributed heroin, a schedule I controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)The offense alleged in Count Twenty-Seven was committed in the manner describedin Predicate Acts Twenty-Six and Twenty-SevenCOUNT TWENTY-EIGHT81021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE I,C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about July 18, 2007, in the County of Denver, State of Colorado UrielLombardi Caldino AKA Alonzo and Tony Lopez-Lopez AKA “Morro” unlawfully,feloniously, and knowingly sold or distributed heroin, a schedule I controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)The offense alleged in Count Twenty-Eight was committed in the mannerdescribed in Predicate Acts Twenty-Eight and Twenty-NineCOUNT TWENTY-NINE81021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE I,C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about July 29, 2007, in the County of Denver, State of Colorado UrielLombardi Caldino AKA Alonzo and Tony Lopez-Lopez AKA “Morro” unlawfully,feloniously, and knowingly sold or distributed heroin, a schedule I controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)The offense alleged in Count Twenty-Nine was committed in the manner describedin Predicate Act Thirty34

COUNT THIRTY81021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE I,C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about August 14, 2007, in the County of Adams, State of Colorado JoseHeriberto Martinez Lopez AKA Eddie and Tony Lopez-Lopez AKA “Morro”unlawfully, feloniously, and knowingly sold or distributed heroin, a schedule Icontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)COUNT THIRTY-ONE82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULEII, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about August 14, 2007, in the County of Adams, State of Colorado JoseHeriberto Martinez Lopez AKA Eddie and Tony Lopez-Lopez AKA “Morro”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. (F3)The offenses alleged in Counts Thirty and Thirty-One were committed in the mannerdescribed in Predicate Acts Thirty-One through Thirty-ThreeCOUNT THIRTY-TWO81043 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLEDSUBSTANCE - SCHEDULE I - 450 TO 1000 GRAMS, C.R.S. 18-18-405(1),(2)(a)(I)(A),(3)(a)(II) (F3)On or between July 12 and July 13, 2007, in the County of Adams, State of OmarGuerra Neri AKA Jimmy AKA “Chimmy”, Jeannette Guerra, Omar Amezquita-Ramirez AKA “Gilantra”, Teena Padilla, and Kaayla Baswell unlawfully,feloniously, and knowingly possessed with intent to sell or distribute heroin, aschedule I controlled substance.Further, the amount was or had been represented to be at least four hundred-fiftygrams or one pound but less than one thousand grams of a material, compound,mixture, or preparation that contained the controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S.COUNT THIRTY-THREE81055 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE -SCHEDULE I - 450 TO 1000 GRAMS, C.R.S. 18-18-405(1),(2)(a)(I)(A),(3)(a)(II) (F3)On or between July 12 and July 13, 2007, in the County of Jefferson, State ofColorado Omar Guerra Neri AKA Jimmy AKA “Chimmy”, Jeannette Guerra, OmarAmezquita-Ramirez AKA “Gilantra”, Teena Padilla, and Kaayla Baswell unlawfully,feloniously, and knowingly conspired with each other and a person or persons to theGrand Jury unknown, to sell or distribute heroin, a schedule I controlled substance.35

Further, the amount was or had been represented to be at least four hundred-fiftygrams or one pound but less than one thousand grams of a material, compound,mixture, or preparation that contained the controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S.The offenses alleged in Counts Thirty-Two and Thirty-Three were committed in themanner described in Predicate Acts Thirty-Four through Forty.COUNT THIRTY-FOUR81021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE I,C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about July 20, 2007, in the County of Denver, State of Colorado UrielLombardi Caldino AKA “Alonzo” and Tony Lopez-Lopez AKA “Morro” unlawfully,feloniously, and knowingly sold or distributed heroin, a schedule I controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)The offense alleged in Count Thirty-Four was committed in the manner described inPredicate Acts Forty-Three and Forty-FourCOUNT THIRTY-FIVE81021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE I,C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about July 22, 2007, in the County of Denver, State of Colorado UrielLombardi Caldino AKA “Alonzo” and Tony Lopez-Lopez AKA “Morro” unlawfully,feloniously, and knowingly sold or distributed heroin, a schedule I controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)The offense alleged in Count Thirty-Five was committed in the manner described inPredicate Acts Forty-Five and Forty-Six.COUNT THIRTY-SIX81021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE I,C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about July 23, 2007, in the County of Adams, State of Colorado UrielLombardi Caldino AKA “Alonzo” and Tony Lopez-Lopez AKA “Morro” unlawfully,feloniously, and knowingly sold or distributed heroin, a schedule I controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)36

COUNT THIRTY-SEVEN81011 POSSESSION OF A CONTROLLED SUBSTANCE - SCHEDULE I - 1GRAM OR LESS, C.R.S. 18-18-405(1),(2.3)(a)(I) (F6)On or about July 23, 2007, in the County of Adams, State of Colorado DeborahCostin unlawfully, feloniously, and knowingly possessed one gram or less of amaterial, compound, mixture, or preparation that contained heroin, a schedule Icontrolled substance; in violation of section 18-18-405(1),(2.3)(a)(I), C.R.S.The offenses alleged in Counts Thirty-Six and Thirty-Seven were committed in themanner described in Predicate Act Forty-Seven.COUNT THIRTY-EIGHT82043 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLEDSUBSTANCE - SCHEDULE II - 450 TO 1000 GRAMS, C.R.S. 18-18-405(1),(2)(a)(I)(A),(3)(a)(II) (F3)On or about August 6, 2007, in the County of Adams, State of Colorado UrielLombardi Caldino unlawfully, feloniously, and knowingly possessed with intent tosell or distribute cocaine, a schedule II controlled substance.Further, the amount was or had been represented to be at least four hundred-fiftygrams or one pound but less than one thousand grams of a material, compound,mixture, or preparation that contained the controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S.The offense alleged in Count Thirty-Eight was committed in the manner describedin Predicate Acts Forty-Eight through Fifty-One.COUNT THIRTY-NINE82044 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLEDSUBSTANCE - SCHEDULE II - 1000 GRAMS OR MORE, C.R.S. 18-18-405(1),(2)(a)(I)(A),(3)(a)(III) (F3)On or about September 4, 2007, in the County of Adams, State of Colorado HugoMartinez Pasillas, Omar Guerra-Neri AKA Jimmy AKA “Chimmy”, and JoseHeriberto Martinez-Lopez AKA Eddie unlawfully, feloniously, and knowinglypossessed with intent to sell or distribute cocaine, a schedule II controlled substance.Further, the amount was or had been represented to be at least one thousand gramsor one kilogram of a material, compound, mixture, or preparation that contained thecontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(III),C.R.S.37

COUNT FORTY82056 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE -SCHEDULE II - 1000 GRAMS OR MORE, C.R.S. 18-18-405(1),(2)(a)(I)(A),(3)(a)(III) (F3)On or between September 4, 2007 and September 5, 2007, in the Counties ofAdams and Denver, State of Colorado Hugo Martinez-Pasillas, Omar Guerra-NeriAKA Jimmy AKA “Chimmy”, and Jose Heriberto Martinez-Lopez AKA Eddieunlawfully, feloniously, and knowingly conspired with Alonzo Martinez-Rodriguezand a person or persons to the Grand Jury unknown, to sell or distribute cocaine, aschedule II controlled substance.Further, the amount was or had been represented to be at least one thousand grams orone kilogram of a material, compound, mixture, or preparation that contained thecontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(III),C.R.S.The offenses alleged in Counts Thirty-Nine and Forty were committed in themanner described in Predicate Acts Fifty-Six through Sixty-One.COUNT FORTY-ONE81021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE I,C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about October 16, 2007, in the County of Denver, State of Colorado JoseHeriberto Martinez-Lopez AKA Eddie and Tony Lopez-Lopez aka “Morro”unlawfully, feloniously, and knowingly sold or distributed heroin, a schedule Icontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)COUNT FORTY-TWO81011 POSSESSION OF A CONTROLLED SUBSTANCE - SCHEDULE I - 1GRAM OR LESS, C.R.S. 18-18-405(1),(2.3)(a)(I) (F6)On or about October 16, 2007, in the County of Denver, State of Colorado, TimothyMascarenas AKA “Spanky” unlawfully, feloniously, and knowingly possessed onegram or less of a material, compound, mixture, or preparation that contained heroin, aschedule I controlled substance; in violation of section 18-18-405(1),(2.3)(a)(I),C.R.S.The offenses alleged in Counts Forty-One and Forty-Two were committed in themanner described in Predicate Acts Sixty-Two and Sixty-Three38

COUNT FORTY-THREE81021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE I,C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about October 23, 2007, in the County of Denver, State of Colorado JoseHeriberto Martinez-Lopez AKA Eddie and Julio Cesar Jimenez-Hdaz unlawfully,feloniously, and knowingly sold or distributed heroin, a schedule I controlledsubstance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)COUNT FORTY-FOUR81042 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLEDSUBSTANCE - SCHEDULE I - 25 TO 450 GRAMS, C.R.S. 18-18-405(1),(2)(a)(I)(A),(3)(a)(I) (F3)On or about October 23, 2007, in the County of Denver, State of Colorado JulioCesar Jimenez-Hdaz unlawfully, feloniously, and knowingly possessed with intent tosell or distribute heroin, a schedule I controlled substance.Further, the amount was or had been represented to be at least twenty-five grams orone ounce but less than four hundred-fifty grams of a material, compound, mixture, orpreparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.COUNT FORTY-FIVE82042 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLEDSUBSTANCE - SCHEDULE II - 25 TO 450 GRAMS, C.R.S. 18-18-405(1),(2)(a)(I)(A),(3)(a)(I) (F3)On or about October 23, 2007, in the County of Denver, State of Colorado JulioCesar Jimenez-Hdaz unlawfully, feloniously, and knowingly possessed with intent tosell or distribute cocaine, a schedule II controlled substance.Further, the amount was or had been represented to be at least twenty-five grams orone ounce but less than four hundred-fifty grams of a material, compound, mixture, orpreparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.The offenses alleged in Counts Forty-Three, Forty-Four and Forty-Five werecommitted in the manner described in Predicate Acts Sixty-Four through Sixty-Eight39

COUNT FORTY-SIX81021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE I,C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about October 12, 2007, in the County of Adams, State of Colorado JoseHeriberto Martinez-Lopez AKA Eddie and Tony Lopez-Lopez aka “Morro”unlawfully, feloniously, and knowingly sold or distributed heroin, a schedule Icontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)COUNT FORTY-SEVEN81011 POSSESSION OF A CONTROLLED SUBSTANCE - SCHEDULE I - 1GRAM OR LESS, C.R.S. 18-18-405(1),(2.3)(a)(I) (F6)On or about October 12, 2007, in the County of Adams, State of Colorado, TinaBoguhn unlawfully, feloniously, and knowingly possessed one gram or less of amaterial, compound, mixture, or preparation that contained heroin, a schedule Icontrolled substance; in violation of section 18-18-405(1),(2.3)(a)(I), C.R.S.The offenses alleged in Counts Forty-Six and Forty-Seven were committed in themanner described in Predicate Acts Sixty-Nine and SeventyCOUNT FORTY-EIGHT81021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE I,C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about November 2, 2007 in the County of Denver, State of Colorado JoseHeriberto Martinez-Lopez AKA Eddie and Tony Lopez-Lopez aka “Morro”unlawfully, feloniously, and knowingly sold or distributed heroin, a schedule Icontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. (F3)COUNT FORTY-NINE81011 POSSESSION OF A CONTROLLED SUBSTANCE - SCHEDULE I - 1GRAM OR LESS, C.R.S. 18-18-405(1),(2.3)(a)(I) (F6)On or about November 2, 2007 in the County of Denver, State of Colorado, TimothyMascarenas unlawfully, feloniously, and knowingly possessed one gram or less of amaterial, compound, mixture, or preparation that contained heroin, a schedule Icontrolled substance; in violation of section 18-18-405(1),(2.3)(a)(I), C.R.S.COUNT FIFTY82011 POSSESSION OF A CONTROLLED SUBSTANCE - SCHEDULE II -1 GRAM OR LESS, C.R.S. 18-18-405(1),(2.3)(a)(I) (F6)On or about November 2, 2007 in the County of Denver, State of Colorado,Timothy Mascarenas unlawfully, feloniously, and knowingly possessed one gram orless of a material, compound, mixture, or preparation that contained cocaine, aschedule II controlled substance; in violation of section 18-18-405(1),(2.3)(a)(I),C.R.S.40

The offenses alleged in Counts Forty-Eight, Forty-Nine, and Fifty were committedin the manner described in Predicate Acts Seventy-One and Seventy-Two.COUNT FIFTY-ONE1011A CRIMINAL IMPERSONATION - GAIN A BENEFIT, C.R.S. 18-5-113(1)(e) (F6)On or about July 11, 2007, Jeanette Guerra unlawfully, feloniously, and knowinglyassumed a false or fictitious identity or capacity, namely: Omar Guerra-Neri, and insuch identity or capacity did an act with intent to unlawfully gain a benefit for himselfor another or to injure or defraud another; in violation of section 18-5-113(1)(e),C.R.S. (F6)The offense alleged in Count Fifty-One was committed in the manner described inPredicate Act Seventy-ThreeCOUNT FIFTY-TWO3441A CULTIVATION OF MARIHUANA, C.R.S. 18-18-406(8)(a)(I) (F4)On or about November 7, 2007, in the County of Denver, State of Colorado, JoseHeriberto Martinez Lopez AKA “Eddie” and Hugo Martinez Pasillas unlawfully,feloniously, and knowingly cultivated, grew, produced, processed, or manufacturedmarihuana or marihuana concentrate, or allowed marihuana or marihuana concentrateto be cultivated, grown, produced, processed, or manufactured on land owned,occupied, or controlled by the defendant; in violation of section 18-18-406(8)(a),C.R.S.COUNT FIFTY-THREE82041 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLEDSUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about November 7, 2007, in the County of Denver, State of Colorado JoseHeriberto Martinez Lopez AKA “Eddie” and Hugo Martinez Pasillas unlawfully,feloniously, and knowingly possessed with intent to distribute cocaine, a schedule IIcontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.COUNT FIFTY-FOUR33445 SPECIAL OFFENDER - DEADLY WEAPON, C.R.S. 18-18-407(1)(f)(SE)On or about November 7, 2007, in the County of Denver, State of Colorado, JoseHeriberto Martinez Lopez AKA Eddie and Hugo Martinez Pasillas committed thefelony offense charged in count Fifty-Three and used, displayed, possessed, or hadavailable for use, a deadly weapon, namely: handgun; in violation of section 18-18-407(1)(f), C.R.S.41

COUNT FIFTY-FIVE33445 SPECIAL OFFENDER - DEADLY WEAPON, C.R.S. 18-18-407(1)(f)(SE)On or about November 7, 2007, in the County of Denver, State of Colorado, JoseHeriberto Martinez Lopez AKA Eddie and Hugo Martinez Pasillas committed thefelony offense charged in count Fifty-Three and used, displayed, possessed, or hadavailable for use, a deadly weapon, namely: handgun; in violation of section 18-18-407(1)(f), C.R.S.COUNT FIFTY-SIX33445 SPECIAL OFFENDER - DEADLY WEAPON, C.R.S. 18-18-407(1)(f)(SE)On or about November 7, 2007, in the County of Denver, State of Colorado, JoseHeriberto Martinez Lopez AKA Eddie and Hugo Martinez Pasillas committed thefelony offense charged in count Fifty-Three and used, displayed, possessed, or hadavailable for use, a deadly weapon, namely: handgun; in violation of section 18-18-407(1)(f), C.R.S.The offenses alleged in Counts Fifty-one through fifty-Six were committed in themanner described in Predicate Acts Seventy-Four and Seventy-FiveCOUNT FIFTY-SEVEN81044 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLEDSUBSTANCE - SCHEDULE I - 1000 GRAMS OR MORE, C.R.S. 18-18-405(1),(2)(a)(I)(A),(3)(a)(III) (F3)On or about November 7, 2007, in the County of Arapahoe, State of ColoradoTony Lopez-Lopez AKA “Morro” unlawfully, feloniously, and knowingly possessedwith intent to sell or distribute heroin, a schedule I controlled substance.Further, the amount was or had been represented to be at least one thousand grams orone kilogram of a material, compound, mixture, or preparation that contained thecontrolled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(III),C.R.S.COUNT FIFTY-EIGHT82043 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLEDSUBSTANCE - SCHEDULE II - 450 TO 1000 GRAMS, C.R.S. 18-18-405(1),(2)(a)(I)(A),(3)(a)(II) (F3)On or about November 7, 2007, in the County of Arapahoe, State of ColoradoTony Lopez-Lopez AKA “Morro” unlawfully, feloniously, and knowingly possessedwith intent to sell or distribute cocaine, a schedule II controlled substance.42

Further, the amount was or had been represented to be at least four hundred-fiftygrams or one pound but less than one thousand grams of a material, compound,mixture, or preparation that contained the controlled substance; in violation of section18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S.The offenses alleged in Counts Fifty-Seven and Fifty-Eight were committed in themanner described in Predicate Acts Seventy-Six and Seventy-SevenCOUNT FIFTY-NINE81011 POSSESSION OF A CONTROLLED SUBSTANCE - SCHEDULE I - 1GRAM OR LESS, C.R.S. 18-18-405(1),(2.3)(a)(I) (F6)On or about October 23, 2007, in the County of Denver, State of Colorado, WendyHenry unlawfully, feloniously, and knowingly possessed one gram or less of amaterial, compound, mixture, or preparation that contained heroin, a schedule Icontrolled substance; in violation of section 18-18-405(1),(2.3)(a)(I), C.R.S.The offense alleged in Count Fifty-One was committed in the manner described inPredicate Acts Sixty-Four through Sixty-EightCOUNT SIXTY81041 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLEDSUBSTANCE - SCHEDULE I, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about November 14, 2007, in the County of Denver, State of Colorado JuanManuel Carbajal AKA “Willo” unlawfully, feloniously, and knowingly possessedwith intent to distribute heroin, a schedule I controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.COUNT SIXTY-ONE82041 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLEDSUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about November 14, 2007, in the County of Denver, State of Colorado JuanManuel Carbajal AKA “Willo” unlawfully, feloniously, and knowingly possessedwith intent to distribute heroin, a schedule I controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.The offenses alleged in Counts Sixty and Sixty-One were committed in the mannerdescribed in Predicate Acts Seventy-Eight and Seventy-Nine.43

COUNT SIXTY-TWO81041 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLEDSUBSTANCE - SCHEDULE I, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about November 14, 2007, in the County of Denver, State of Colorado RosalioIbarra Sanchez AKA “Cajeme” unlawfully, feloniously, and knowingly possessedwith intent to distribute heroin, a schedule I controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.COUNT SIXTY-THREE82041 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLEDSUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about November 14, 2007, in the County of Denver, State of Colorado RosalioIbarra Sanchez AKA “Cajeme” unlawfully, feloniously, and knowingly possessedwith intent to distribute cocaine, a schedule II controlled substance; in violation ofsection 18-18-405(1),(2)(a)(I)(A), C.R.S.The offenses alleged in Count Sixty-Two and Sixty-Three were committed in themanner described in Predicate Acts Eighty and Eighty-One.44

COUNT SIXTY-FOUR82042 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLEDSUBSTANCE - SCHEDULE II - 25 TO 450 GRAMS, C.R.S. 18-18-405(1),(2)(a)(I)(A),(3)(a)(I) (F3)On or about November 14, 2007 in the County of Denver, State of Colorado JuanManuel Carbajal AKA “Willo” and Rosalio Ibarra Sanchez AKA “Cajeme”unlawfully, feloniously, and knowingly possessed with intent to sell or distributecocaine, a schedule II controlled substance.Further, the amount was or had been represented to be at least twenty-five grams orone ounce but less than four hundred-fifty grams of a material, compound, mixture, orpreparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.COUNT SIXTY-FIVE81041 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLEDSUBSTANCE - SCHEDULE I, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)On or about November 14, 2007, in the County of Denver, State of ColoradoRosalio Ibarra Sanchez AKA “Cajeme” and Juan Manuel Carbajal AKA “Willo”unlawfully, feloniously, and knowingly possessed with intent to distribute cocaine, aschedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),C.R.S.The offenses alleged in Counts Sixty-Four and Sixty-Five were committed in themanner described in Predicate Acts Eighty-Two and Eighty-Three.COUNT SIXTY-SIX33443 SPECIAL OFFENDER - CONSPIRACY - PATTERN OF SALE, C.R.S.18-18-407(1)(c) (SE)On or between October 1, 2006 and November 16, 2007 Omar Guerra Nericommitted the felony offenses charged in counts Thirty-Two, Thirty-Three, and Fortywhich was, or was in furtherance of, a conspiracy with one or more persons to engagein a pattern of manufacturing, sale, or distributing a controlled substance, and thedefendant did, or agreed that defendant would organize, plan, finance, direct, manage,or supervise part or all of the conspiracy or manufacture, sale, or distributing; inviolation of section 18-18-407(1)(c), C.R.S.45

COUNT SIXTY-SEVEN33443 SPECIAL OFFENDER - CONSPIRACY - PATTERN OF SALE, C.R.S.18-18-407(1)(c) (SE)On or between October 1, 2006 and November 16, 2007 Jose Heriberto MartinezLopez AKA Eddie committed the felony offenses charged in counts Thirty, Thirty-One, Forty-One, Forty-Three, Forty-Six, and Forty-Eight which was, or was infurtherance of, a conspiracy with one or more persons to engage in a pattern ofmanufacturing, sale, or distributing a controlled substance, and the defendant did, oragreed that defendant would organize, plan, finance, direct, manage, or supervise partor all of the conspiracy or manufacture, sale, or distributing; in violation of section18-18-407(1)(c), C.R.S.COUNTY SIXTY-EIGHT33443 SPECIAL OFFENDER - CONSPIRACY - PATTERN OF SALE, C.R.S.18-18-407(1)(c) (SE)On or between October 1, 2006 and November 16, 2007 Oscar Lomeli Lopez AKADaniel committed the felony offenses charged in counts Three, Four, Seven, Ten,Thirteen, Fifteen, Seventeen, Twenty-Three, and Twenty-Five which was, or was infurtherance of, a conspiracy with one or more persons to engage in a pattern ofmanufacturing, sale, or distributing a controlled substance, and the defendant did, oragreed that defendant would organize, plan, finance, direct, manage, or supervise partor all of the conspiracy or manufacture, sale, or distributing; in violation of section18-18-407(1)(c), C.R.S.COUNT SIXTY-NINE33443 SPECIAL OFFENDER - CONSPIRACY - PATTERN OF SALE, C.R.S.18-18-407(1)(c) (SE)On or between October 1, 2006 and November 16, 2007 Uriel Lombardi CaldinoAKA Alonzo committed the felony offenses charged in counts Thirty-Two, Thirty-Three, and Forty which was, or was in furtherance of, a conspiracy with one or morepersons to engage in a pattern of manufacturing, sale, or distributing a controlledsubstance, and the defendant did, or agreed that defendant would organize, plan,finance, direct, manage, or supervise part or all of the conspiracy or manufacture,sale, or distributing; in violation of section 18-18-407(1)(c), C.R.S.46

AS TO COUNT SIXTY-EIGHT:A TRUE BILL_________________________ForepersonAS TO COUNT SIXTY-NINE:A TRUE BILL_________________________ForepersonA NO TRUE BILL____________________________ForepersonA NO TRUE BILL____________________________Foreperson47

I, ____________________________, the Foreperson of the 2007-2008 Colorado StateGrand Jury, do hereby swear and affirm that each and every True Bill returned in thisindictment by the 2007-2008 Colorado State Grand Jury was arrived at after deliberationand with the assent and agreement to the existence of probable cause by at least ninemembers of the Colorado State Grand Jury. The Colorado State Grand Jury furtherauthorizes and instructs the Colorado Attorney General to return this indictment to opencourt with or without the presence of the foreperson.______________________________ForepersonSubscribed to before me in the City and County of Denver, State of Colorado, this_________ day of November 2007.My commission expires:_____________________________________________________Notary PublicJOHN W. SUTHERSAttorney GeneralJOHN G. LEE, 29980Assistant Attorney General IISpecial Prosecutions UnitCriminal Justice Section48

The 2007-2008 Colorado Statewide Grand Jury presents the within Indictment,and the same is hereby ORDERED FILED this ________ day of November 2007.Pursuant to § 13-73-107, C.R.S., the Court designates ________________County, Colorado as the county of venue for the purposes of trial.So ORDERED, this ___ day of November, 2007____________________________District Court Judge49