district court, city and county of denver, colorado - Colorado Attorney ...

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