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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
Page 1: DISTRICT COURT, CITY AND COUNTY OFD
Page 4: Racketeering ActivityThe acts of ra
Page 7: PREDICATE ACT ELEVEN(Conspiracy to
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 and 44: Further, the amount was or had been
Page 45 and 46: COUNT SIXTY-FOUR82042 POSSESSION WI
Page 47 and 48: AS TO COUNT SIXTY-EIGHT:A TRUE BILL
Page 49: The 2007-2008 Colorado Statewide Gr

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