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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
Page 1: DISTRICT COURT, CITY AND COUNTY OFD
Page 4: Racketeering ActivityThe acts of ra
Page 7 and 8: PREDICATE ACT ELEVEN(Conspiracy to
Page 9 and 10: On June 29, 2007 Audrey Torrez and
Page 11 and 12: PREDICATE ACT TWENTY-FOUR(Distribut
Page 13 and 14: On July 29, 2007 Detective Jay Lope
Page 15 and 16: PREDICATE ACT THIRTY-NINE(Unlawful
Page 17 and 18: On July 20, 2007 a confidential inf
Page 19 and 20: On August 5, 2007 Alonzo and Paisa
Page 21 and 22: PREDICATE ACT SIXTY(Unlawful Use of
Page 23 and 24: PREDICATE ACT SIXTY-SEVEN(Possessio
Page 25 and 26: PREDICATE ACT SEVENTY-THREE(Crimina
Page 27 and 28: PREDICATE ACT EIGHTY(Possession wit
Page 29 and 30: COUNT EIGHT82052 CONSPIRACY TO POSS
Page 31 and 32: COUNT FIFTEEN82021 DISTRIBUTION OF
Page 33 and 34: On June 29, 2007 police officers ex
Page 35 and 36: COUNT THIRTY81021 DISTRIBUTION OF A
Page 37 and 38: COUNT THIRTY-SEVEN81011 POSSESSION
Page 39 and 40: COUNT FORTY-THREE81021 DISTRIBUTION
Page 41 and 42: The offenses alleged in Counts Fort
Page 43: Further, the amount was or had been
Page 47 and 48: AS TO COUNT SIXTY-EIGHT:A TRUE BILL
Page 49: The 2007-2008 Colorado Statewide Gr

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