indictment - Colorado Attorney General

COUNT FIVE(Theft – Vectra Bank payments)Between November 1, 2004 and March 30, 2005, but discovered after June 17, 2008,DEREK R. KENT and ADAM KELEPOLO unlawfully, feloniously, and knowinglyobtained investor money, with a value of fifteen thousand dollars or more, withoutauthorization, or by threat or deception, and knowingly used, concealed, or abandoned thething of value in such manner as to permanently deprive Lion Gate Homes, Inc. investors ofits use or benefit, contrary to the form of the statutes in such case made and provided by§ 18-4-401(1)(b)(2)(d) C.R.S. and against the peace and dignity of the People of the State ofColorado. (Class 3 felony).COUNT SIX(Theft – Vectra Bank payments)Between May 3, 2005 and August 15, 2005, but discovered after June 17, 2008,DEREK R. KENT and ADAM KELEPOLO unlawfully, feloniously, and knowinglyobtained investor money, with a value of fifteen thousand dollars or more, withoutauthorization, or by threat or deception, and knowingly used, concealed, or abandoned thething of value in such manner as to permanently deprive Lion Gate Homes, Inc. investors ofits use or benefit, contrary to the form of the statutes in such case made and provided by§ 18-4-401(1)(b)(2)(d) C.R.S. and against the peace and dignity of the People of the State ofColorado. (Class 3 felony).COUNT SEVEN(Theft – Casino transactions)Between August 19, 2005 and January 5, 2006, but discovered after June 17, 2008,ADAM KELEPOLO unlawfully, feloniously, and knowingly obtained investor money, witha value of fifteen thousand dollars or more, without authorization, or by threat or deception,and knowingly used, concealed, or abandoned the thing of value in such manner as topermanently deprive Lion Gate Homes, Inc. investors of its use or benefit, contrary to theform of the statutes in such case made and provided by § 18-4-401(1)(b)(2)(d) C.R.S. andagainst the peace and dignity of the People of the State of Colorado. (Class 3 felony).COUNT EIGHT(Theft – Casino transactions)Between February 10 and July 24, 2006, but discovered after June 17, 2008, ADAMKELEPOLO unlawfully, feloniously, and knowingly obtained investor money, with a valueof fifteen thousand dollars or more, without authorization, or by threat or deception, and

knowingly used, concealed, or abandoned the thing of value in such manner as topermanently deprive Lion Gate Homes, Inc. investors of its use or benefit, contrary to theform of the statutes in such case made and provided by § 18-4-401(1)(b)(2)(d) C.R.S. andagainst the peace and dignity of the People of the State of Colorado. (Class 3 felony).COUNT NINE(Theft – Personal use of funds)Between January 1 and June 30, 2005, but discovered after June 17, 2008, ADAMKELEPOLO unlawfully, feloniously, and knowingly obtained investor money, with a valueof five hundred dollars or more but less than fifteen thousand dollars, without authorization,or by threat or deception, and knowingly used, concealed, or abandoned the thing of value insuch manner as to permanently deprive Lion Gate Homes, Inc. investors of its use or benefit,contrary to the form of the statutes in such case made and provided by § 18-4-401(1)(b)(2)(c)C.R.S. and against the peace and dignity of the People of the State of Colorado. (Class 4felony).COUNT TEN(Theft – Personal use of funds)Between July 1 and December 31, 2005, but discovered after June 17, 2008, ADAMKELEPOLO unlawfully, feloniously, and knowingly obtained investor money, with a valueof five hundred dollars or more but less than fifteen thousand dollars, without authorization,or by threat or deception, and knowingly used, concealed, or abandoned the thing of value insuch manner as to permanently deprive Lion Gate Homes, Inc. investors of its use or benefit,contrary to the form of the statutes in such case made and provided by § 18-4-401(1)(b)(2)(c)C.R.S. and against the peace and dignity of the People of the State of Colorado. (Class 4felony).COUNT ELEVEN(Theft – Personal use of funds)Between January 1 and June 30, 2006, but discovered after June 17, 2008, ADAMKELEPOLO unlawfully, feloniously, and knowingly obtained investor money, with a valueof five hundred dollars or more but less than fifteen thousand dollars, without authorization,or by threat or deception, and knowingly used, concealed, or abandoned the thing of value insuch manner as to permanently deprive Lion Gate Homes, Inc. investors of its use or benefit,contrary to the form of the statutes in such case made and provided by § 18-4-401(1)(b)(2)(c)C.R.S. and against the peace and dignity of the People of the State of Colorado. (Class 4felony).

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JOHN W. SUTHERSATTORNEY GENERALSTATE OF COLORADOJEAN WOODFORD, #24834First Assistant Attorney GeneralCriminal Justice SectionAttorneys for the People*Counsel of RecordThe 2008-2009 Colorado Statewide Grand Jury presents the within Indictment, andthe same is hereby ORDERED FILED this ________ day of ____________________ 2009.Pursuant to § 13-73-107, C.R.S., the Court designates ________________ County,Colorado as the county of venue for the purposes of trial.Dated this ____ of May, 2009______________________________________Larry J. NavesChief Judge, Denver District Court