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

DISTRICT COURT, CITY AND COUNTY OF 

DENVER, COLORADO 

1437 Bannock Street 

Denver, CO 80202 

THE PEOPLE OF THE STATE OF COLORADO, 

v. 

DANIEL GALVAN 

ANTHONY HARVEY 

STUART KNOWLES 

LEOBARDO LOYA 

ABDON LOYA-SANCHEZ 

ALEXANDER ORAM 

FRANCISCO VALENCIA 

JOSEPH VITTUM 

DEREK DURICA 

MATTHEW BEKKERUS 

BRIAN BUTLER 

ANTHONY EMBRY 

CARL HAYES 

ANDRE ISLER 

GERALD LAMASTER 

GARY LIHUDIS 

MICHAEL MCCAIN 

BERNARDINO MENDOZA 

MARIA MORENO 

RONALD MUNGUIA-MARTIN 

JEROME NELSON 

KAMAL PATTERSON 

TONY ROMERO 

QUENTIN WALLACE 

ADRIAN HERNANDEZ 

ALEJANDRO URIBE 

ALAN JOHNSON 

JIMMIE JOE MONTGOMERY 

KENNETH WEST 

HORACIO BUGARIN 

MARK FRALEIGH 

MITCHELL MORRIS 

SHAWN BLEA 

Defendants. COURT USE ONLY 

1

JOHN W. SUTHERS, Attorney General 

ANNEMARIE L. BRAUN* 

Senior Assistant Attorney General 

1525 Sherman Street, 7 th Floor 

Denver, CO 80203 

303-866-5738 

Registration Number: 39877 

*Counsel of Record 

Case No.: 

GJ Case No.: 11CR01 

Ctrm: 209 

COLORADO STATE GRAND JURY SECOND SUPERSEDING INDICTMENT 

Of the 2011-2012 term of the Denver District Court in the year 2011; the 

2011-2012 Colorado State Grand Jurors, chosen, selected and sworn in the name 

and by the authority of the People of the State of Colorado, upon their oaths, present 

the following: 

COUNT ONE: 

37284 

COUNT TWO: 

37284 

COUNT THREE: 

82021 

COCCA – Pattern of Racketeering – 

Participation in an Enterprise, 

§ 18-17-104(3), C.R.S., (F2) 

Daniel Galvan, Anthony Harvey, 

Stuart Knowles, Leobardo Loya, Abdon Loya- 

Sanchez, Alexander Oram, Francisco Valencia, 

Joseph Vittum , Derek Durica, Alan Johnson, 

Jimmie Joe Montgomery, Kenneth West, and 

Horacio Bugarin 

COCCA – Conspiracy, 

§ 18-17-104(4), C.R.S., (F2) 

Daniel Galvan, Anthony Harvey, 

Stuart Knowles, Leobardo Loya, Abdon Loya- 

Sanchez, Alexander Oram, Francisco Valencia, 

Joseph Vittum, Derek Durica, Alan Johnson, 

Jimmie Joe Montgomery, Kenneth West, and 


Distribution of a Schedule II Controlled 

Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 

Francisco Valencia 

2

COUNT FOUR: 

82022 

COUNT FIVE: 

82022 

COUNT SIX: 

82022 

COUNT SEVEN: 

82022 

COUNT EIGHT: 

82022 

COUNT NINE: 

82021 

COUNT TEN: 

82041 


Substance—25 to 450 Grams, § 18-18-405(1), 

(2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) 

Leobardo Loya 



(2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) 

Leobardo Loya 



(2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) 

Leobardo Loya 



(2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) 

Alan Johnson, Alexander Oram 



(2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) 



Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 

Anthony Harvey 

Possession with Intent to Distribute a Schedule 

II Controlled Substance, § 18-18-405(1), 

(2)(a)(I)(A), C.R.S., (F3) 


3

COUNT ELEVEN: 

82053 

COUNT TWELVE: 

82053 

COUNT THIRTEEN: 

82053 

COUNT FOURTEEN: 

82053 

COUNT FIFTEEN: 

82021 

COUNT SIXTEEN: 

82022 

COUNT SEVENTEEN: 

82053 

Conspiracy to Distribute a Schedule II 

Controlled Substance, 

§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Anthony Harvey, Abdon Loya-Sanchez 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Anthony Harvey, Alan Johnson, Alexander Oram 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Anthony Harvey, Alexander Oram 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Anthony Harvey, Stuart Knowles 


Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 




(2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) 

Joseph Vittum 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Daniel Galvan, Francisco Valencia 

4

COUNT EIGHTEEN: 

82053 

COUNT NINETEEN: 

82021 

COUNT TWENTY: 

82041 

COUNT TWENTY-ONE: 

82053 

COUNT TWENTY-TWO: 

82021 

COUNT TWENTY-THREE: 

82041 

COUNT TWENTY-FOUR: 

82021 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Daniel Galvan, Stuart Knowles 


Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 

Daniel Galvan 



(2)(a)(I)(A), C.R.S., (F3) 

Stuart Knowles 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Anthony Harvey, Abdon Loya-Sanchez 


Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 

Abdon Loya-Sanchez 



(2)(a)(I)(A), C.R.S., (F3) 



Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 

Anthony Embry 

5

COUNT TWENTY-FIVE: 

82021 

COUNT TWENTY-SIX: 

82021 

COUNT TWENTY-SEVEN: 

82021 

COUNT TWENTY-EIGHT: 

82021 

COUNT TWENTY-NINE: 

82021 

COUNT THIRTY: 

82041 

COUNT THIRTY-ONE: 


Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 

Quentin Wallace 


Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 

Anthony Embry 


Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 

Andre Isler 


Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 



Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 

Ronald Munguia-Martin 



(2)(a)(I)(A), C.R.S., (F3) 

Gerald Lamaster 

Possession of a Schedule II Controlled 

Substance – More than a Gram, 

§ 18-18-403.5(1),(2)(a)(I), C.R.S. (F6) 

Gerald Lamaster 

6

COUNT THIRTY-TWO: 

82053 

COUNT THIRTY-THREE: 

82053 

COUNT THIRTY-FOUR: 

82053 

COUNT THIRTY-FIVE: 

82053 

COUNT THIRTY-SIX: 

30011 

COUNT THIRTY-SEVEN: 

82053 

COUNT THIRTY-EIGHT 

82021 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Anthony Harvey, Derek Durica 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Anthony Harvey, Carl Hayes 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Anthony Harvey, Kamal Patterson 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 


Possession of a Dangerous Weapon 

§ 18-12-102(3) (F5) 

Jerome Nelson 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 



Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 


7

COUNT THIRTY-NINE: 

COUNT FORTY: 

82053 

COUNT FORTY-ONE: 

82053 

COUNT FORTY-TWO 

82053 

COUNT FORTY-THREE: 

82053 

COUNT FORTY-FOUR: 

82021 

COUNT FORTY-FIVE: 

82041 

Possession of a Schedule II Controlled 

Substance – More than a Gram, 

§ 18-18-403.5(1),(2)(a)(I), C.R.S. (F6) 

Matthew Bekkerus 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Anthony Harvey, Gary Lihudis 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Anthony Harvey, Maria Moreno 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Anthony Harvey, Jerome Nelson 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Anthony Harvey, Quentin Wallace 


Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 




(2)(a)(I)(A), C.R.S., (F3) 


8

COUNT FORTY-SIX: 

82053 

COUNT FORTY-SEVEN: 

82053 

COUNT FORTY-EIGHT: 

82053 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Anthony Harvey, Gary Lihudis 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Anthony Harvey, Michael McCain 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 


COUNT FORTY-NINE: Distribution of Marijuana – Between 5 and 100 

Pounds, 

§ 18-18-406(6)(b)(I),(III)(B), C.R.S., (F4) 

Abdon Loya-Sanchez, Anthony Harvey 

COUNT FIFTY: Possession with Intent to Distribute Marijuana – 

Between 5 and 100 Pounds, 

§ 18-18-406(6)(b)(I),(III)(B), C.R.S., (F4) 

COUNT FIFTY-ONE: 

82042 

COUNT FIFTY-TWO: 

82041 

Brian Butler 


II Controlled Substance—25 to 450 Grams, 

§ 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S., (F3) 

Leobardo Loya 


II Controlled Substance, 

§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Leobardo Loya 

9

COUNT FIFTY-THREE: 

82042 



§ 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S., (F3) 


COUNT FIFTY-FOUR: Possession with Intent to Distribute Marijuana – 

Between 5 and 100 Pounds, 

§ 18-18-406(6)(b)(I),(III)(B), C.R.S., (F4) 

COUNT FIFTY-FIVE: 

82022 

COUNT FIFTY-SIX: 

82043 

COUNT FIFTY-SEVEN: 

33445 

COUNT FIFTY-EIGHT: 

82043 

COUNT FIFTY-NINE: 

33445 




(2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) 

Tony Romero 



§ 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S., (F3) 

Alexander Oram 

Possession of a Deadly Weapon 

(Special Offender) 

§ 18-18-407(1)(f)(I), C.R.S. 

Alexander Oram 



§ 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S., (F3) 




§ 18-18-407(1)(f)(I), C.R.S. 


10

COUNT SIXTY: 

30074 

Possession of a Weapon by a Previous 

Offender, 

§ 18-12-108(1), C.R.S., (F6) 

Bernardino Mendoza 

COUNT SIXTY-ONE: Cultivation of Marijuana, 

§ 18-18-406(7.5)(c), C.R.S., (F4) 

COUNT SIXTY-TWO: 

82021 

COUNT SIXTY-THREE: 

82053 

COUNT SIXTY-FOUR: 

82053 

COUNT SIXTY-FIVE: 

82053 

COUNT SIXTY-SIX: 

82022 

Daniel Galvan 


Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 

Andre Isler, Anthony Embry 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Anthony Harvey, Tony Romero 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Anthony Harvey, Stuart Knowles 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Abdon Loya-Sanchez, Adrian Hernandez 



(2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) 


11

COUNT SIXTY-SEVEN: 

82042 

COUNT SIXTY-EIGHT: 

82053 

COUNT SIXTY-NINE: 

82022 

COUNT SEVENTY: 

82022 

COUNT SEVENTY-ONE: 

82021 

COUNT SEVENTY-TWO: 

82021 

COUNT SEVENTY-THREE: 

82053 



§ 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S., (F3) 

Adrian Hernandez 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Abdon Loya-Sanchez, Alejandro Uribe 



(2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) 

Alan Johnson 



(2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) 

Alan Johnson 


Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 

Alan Johnson 


Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 

Jimmie Joe Montgomery 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Alan Johnson, Kenneth West 

12

COUNT SEVENTY-FOUR: 

82021 

COUNT SEVENTY-FIVE: 

82041 

COUNT SEVENTY-SIX: 

82053 

COUNT SEVENTY-SEVEN: 

82053 

COUNT SEVENTY-EIGHT: 

82053 

COUNT SEVENTY-NINE: 

82053 

COUNT EIGHTY: 

82053 


Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 

Alan Johnson 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Kenneth West 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Alan Johnson, Mark Fraleigh 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Alan Johnson, Mitchell Morris 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Alan Johnson, Horacio Bugarin 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Alan Johnson, Shawn Blea 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Alan Johnson, Anthony Harvey 

13

COUNT EIGHTY-ONE: 

82053 

COUNT EIGHTY-TWO: 

82053 

COUNT EIGHTY-THREE: 

82053 

COUNT EIGHTY-FOUR: 

82053 

COUNT EIGHTY-FIVE: 

82021 

COUNT EIGHTY-SIX: 

82041 

COUNT EIGHTY-SEVEN: 

82053 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Alan Johnson, Jimmie Joe Montgomery 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 




§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 




§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 



Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 




§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Alan Johnson 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 


14

COUNT EIGHTY-EIGHT: 

82021 

COUNT EIGHTY-NINE: 

82041 

COUNT NINETY: 

82053 

COUNT NINETY-ONE: 

82023 

COUNT NINETY-TWO: 

82043 

COUNT NINETY-THREE: 

82042 

COUNT NINETY-FOUR: 

33445 


Substance, 

§ 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) 




§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Alan Johnson 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 



Substance—450 to 1000 Grams, 

§ 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S., (F3) 

Alan Johnson 



§ 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S., (F3) 




§ 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S., (F3) 




§ 18-18-407(1)(f)(I), C.R.S. 


15

COUNT NINETY-FIVE: 

82053 



§ 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) 

Abdon Loya-Sanchez, Alejandro Uribe 

16

COUNT ONE 

VIOLATION OF THE COLORADO ORGANIZED CRIME CONTROL ACT — 

PATTERN OF RACKETEERING—PARTICIPATION IN AN ENTERPRISE, C.R.S. 

18-17-104(3) and 18-17-105 (F2) 

Between the dates of January 1, 2009 and September 29, 2011, in the State of 

Colorado, Daniel Galvan, Anthony Harvey, Stuart Knowles, Leobardo Loya, 

Abdon Loya-Sanchez, Alexander Oram, Francisco Valencia, Joseph Vittum, 

Derek Durica, Alan Johnson, Jimmie Joe Montgomery, Kenneth West, and 

Horacio Bugarin and others both known and unknown, while employed by or 

associated with an enterprise, unlawfully, feloniously, and knowingly conducted or 

participated, directly or indirectly, in the enterprise through a pattern of racketeering 

activity: in violation of sections 18-17-104(3) and 18-17-105, C.R.S. 

COUNT TWO 

VIOLATION OF THE COLORADO ORGANIZED CRIME CONTROL ACT — 

CONSPIRACY/ENDEAVORING, C.R.S. 18-17-104(4) (F2) 

Between the dates of January 1, 2009 and September 29, 2011, in the State of 

Colorado, Daniel Galvan, Anthony Harvey, Stuart Knowles, Leobardo Loya, 

Abdon Loya-Sanchez, Alexander Oram, Francisco Valencia, Joseph Vittum, 

Derek Durica, Alan Johnson, Jimmie Joe Montgomery, Kenneth West, and 

Horacio Bugarin and others both known and unknown, did unlawfully, knowingly, 

and feloniously conspire and endeavor to conduct and participate, directly or 

indirectly, in an enterprise, through a pattern of racketeering activity in violation of 

C.R.S. § 18-17-104(4) and § 18-17-104(3), C.R.S. 

The offenses alleged in Counts One and Two were committed in the following 

manner: 

The Enterprise 

The enterprise alleged in counts one and two was primarily a group of individuals, 

associated in fact, although not a legal entity. The enterprise included, but was not 

limited to, the following associated in fact individuals and/or legal entities: Daniel 

Galvan, Anthony Harvey, Stuart Knowles, Leobardo Loya, Abdon Loya- 

Sanchez, Alexander Oram, Francisco Valencia, Joseph Vittum, Derek Durica, 

Alan Johnson, Jimmie Joe Montgomery, Kenneth West, and Horacio Bugarin 

and others both known and unknown to the Grand Jury. The individuals associated 

with the enterprise had a primary objective and a common purpose to distribute 

large quantities of illegal controlled substances, including cocaine and 

methamphetamine, both Schedule II Controlled Substances, and marijuana, 

throughout the Northern Colorado area to various customers. Both Anthony Harvey 

and Daniel Galvan supplied their respective dealers with these illegal controlled 

17

substances. These dealers included Stuart Knowles, Leobardo Loya, Alexander 

Oram, Francisco Valencia, Joseph Vittum, Derek Durica, and Alan Johnson. Alan 

Johnson, in turn, supplied his runners, Alexander Oram, Kenneth West, and Jimmie 

Joe Montgomery with cocaine and methamphetamine for further distribution. 

Anthony Harvey, Daniel Galvan, and Alan Johnson, together with their respective 

dealers including Stuart Knowles, Leobardo Loya, Alexander Oram, Francisco 

Valencia, Joseph Vittum, Derek Durica, Kenneth West and Jimmie Joe Montgomery 

relied upon and utilized a system of cellular telephones and other 

telecommunications facilities to arrange and execute the distribution of these illegal 

controlled substances throughout Northern Colorado. 

Further, Anthony Harvey, Daniel Galvan, and Alan Johnson used these cellular 

telephones to communicate with their various sources of supply for these illegal 

controlled substances, including Abdon Loya-Sanchez and Horacio Bugarin. 

Because the members of the criminal enterprise used cellular telephones so 

extensively to conduct the business and operations of the enterprise, the members 

often utilized coded terminology when speaking to each other on the telephone in 

order to conceal their criminal activities. 

Pattern of Racketeering Activity 

Daniel Galvan, Anthony Harvey, Stuart Knowles, Leobardo Loya, Abdon Loya- 

Sanchez, Alexander Oram, Francisco Valencia, Joseph Vittum, Derek Durica, 

Alan Johnson, Jimmie Joe Montgomery, Kenneth West, and Horacio Bugarin 

directly and in concert, engaged in, attempted to engage in, conspired to engage in, 

or solicited another to engage in at least two predicate acts, including any lesser 

offenses, related to the conduct of the enterprise, with at least one of which took 

place in the State of Colorado after July 1, 1981 and the last of the acts of 

racketeering activity occurring within ten years after a prior act of racketeering 

activity and include: 

Distribution of a Controlled Substance – Schedule II 

Possession with Intent to Distribute a Controlled Substance – Schedule II 

Conspiracy to Distribute a Controlled Substance – Schedule II 

Unlawful Use of a Telecommunications Facility 

Racketeering Activity 

The acts of racketeering activity that the above named persons committed, 

attempted to commit, conspired to commit, or solicited, coerced, or intimidated 

another person to commit, consist of the following predicate acts, including any 

lesser included offenses: 

18

PREDICATE ACT ONE 

Distribution of a Controlled Substance – Schedule II – 

25 to 450 Grams, (F3) 

On or about July 2, 2009, in the State of Colorado, Daniel Galvan unlawfully, 

feloniously, and knowingly sold or distributed cocaine, a schedule II controlled 

substance. 

Further, the amount was or had been represented to be at least twenty-five grams 

but not more than four hundred-fifty grams or one pound of a material, compound, 

mixture, or preparation that contained the controlled substance; in violation of 

section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. 

The offense alleged in Predicate Act One was committed in the following manner: 

On July 2nd, 2009, a confidential informant working in cooperation with and at the 

direction of law enforcement officers drove to THE SHOP, a business located at 

1925 S. Timberline Road in Fort Collins. Daniel GALVAN and an individual 

identifiable only as “Andy” LNU came out and met the CI in his/her car. While Daniel 

GALVAN was standing there, taking an active role in the deal, Andy LNU handed 

the CI one ounce of cocaine and the CS paid Andy LNU $475.00. 

PREDICATE ACT TWO 


25 to 450 Grams, (F3) 

On or about July 10, 2010, in the State of Colorado, Stuart Knowles unlawfully, 


substance. 





The offense alleged in Predicate Act Two was committed in the following manner: 

On or about July 10, 2010, Stuart Knowles sold a nine-ounce quantity of cocaine to 

a confidential source, who is fully identifiable to Northern Colorado Drug Task Force 

detectives. 

19

PREDICATE ACT THREE 

Distribution of a Controlled Substance – Schedule II, (F3) 

On or about June 24, 2011, in the State of Colorado, Francisco Valencia 

unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II 

controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. 

The offense alleged in Predicate Act Three was committed in the following manner: 

On June 24, 2011, Francisco Valencia sold a quantity of cocaine to Ronald 

Munguia-Martin in the parking lot at 2519 S. Shields St. in Fort Collins. 

PREDICATE ACT FOUR 


25 to 450 Grams, (F3) 

On or about August 10, 2011, in the State of Colorado, Leobardo Loya unlawfully, 


substance. 





PREDICATE ACT FIVE 

Unlawful Use of a Communication Facility 

On or about August 10, 2011, in the State of Colorado, Leobardo Loya did 

knowingly or intentionally use a communications facility, namely, a telephone, to 

facilitate the commission of a felony, namely, distribution of a controlled substance, 

in violation of 21 U.S.C. §§ 841 and 846, such use of a commmunications facility 

being unlawful, and in violation of 21 U.S.C. § 843. 

The offenses alleged in Predicate Acts Four and Five were committed in the 

following manner: 

On August 10, 2011, Leobardo Loya sold a one-ounce quantity of cocaine to a 

confidential informant in the parking lot of the King Soopers parking lot located at 

Willox and College Ave in Fort Collins. Leobardo Loya utilized his cellular telephone 

(970) 412-9227 to arrange and coordinate the delivery of the cocaine. 

20

PREDICATE ACT SIX 


25 to 450 Grams, (F3) 



substance. 





PREDICATE ACT SEVEN 


On or about August 12, 2011, in the State of Colorado, Leobardo Loya, did 





The offenses alleged in Predicate Acts Six and Seven were committed in the 


On August 12, 2011, Leobardo Loya sold a one-ounce quantity of cocaine to a 

confidential informant in the parking lot of Sports Authority parking lot, at 425 S 

College Ave. in Fort Collins. Leobardo Loya utilized his cellular telephone (970) 

213-3222 to arrange and coordinate the delivery of the cocaine. 

PREDICATE ACT EIGHT 


25 to 450 Grams, (F3) 

On or about September 14, 2011, in the State of Colorado, Leobardo Loya 


controlled substance. 





21

PREDICATE ACT NINE 


On or about September 14, 2011, in the State of Colorado, Leobardo Loya, did 





The offenses alleged in Predicate Acts Eight and Nine were committed in the 


On September 14, 2011, Leobardo Loya sold a three-ounce quantity of cocaine to a 

confidential informant in the parking lot of the King Soopers parking lot located at 

Willox and College Ave in Fort Collins. Leobardo Loya utilized his cellular telephone 

(970) 213-3222 to arrange and coordinate the delivery of the cocaine. 

PREDICATE ACT TEN 


25 to 450 Grams, (F3) 

On or about August 4, 2011, in the State of Colorado, Alan Johnson and 

Alexander Oram unlawfully, feloniously, and knowingly sold or distributed cocaine, 

a schedule II controlled substance. 





PREDICATE ACT ELEVEN 



Alexander Oram did knowingly or intentionally use a communications facility, 

namely, a telephone, to facilitate the commission of a felony, namely, distribution of 

a controlled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of a 

commmunications facility being unlawful, and in violation of 21 U.S.C. § 843. 

The offenses alleged in Predicate Acts Ten and Eleven were committed in the 


On August 4, 2011, Alan Johnson directed Alexander Oram to sell a three-ounce 

quantity of cocaine to a confidential informant. Alexander Oram then sold a threeounce 

quantity of cocaine to the confidential informant from his residence at 1025 

22

Cunningham Drive, apartment C-6 in Fort Collins. Alan Johnson utilized his cellular 

telephone 970-308-1614 and Alexander Oram utilized his cellular telephone number 

970-690-9788 to arrange and coordinate this delivery of the cocaine. 

PREDICATE ACT TWELVE 


25 to 450 Grams, (F3) 








PREDICATE ACT THIRTEEN 







The offenses alleged in Predicate Acts Twelve and Thirteen were committed in the 


On or about August 16, 2011, Alan Johnson directed Alexander Oram to sell a fiveounce 

quantity of cocaine to a confidential informant. On that date, Oram, based on 

Alan Johnson’s express direction to Oram, delivered the five-ounce quantity of 

cocaine to the confidential informant from Oram’s residence at 1025 Cunningham 

Drive, apartment C-6 in Fort Collins. Alan Johnson utilized his cellular telephone 

number to arrange and coordinate the delivery of the cocaine with both Alexander 

Oram and the confidential informant. Alexander Oram utilized his cellular telephone 

number 970-690-9788 to arrange and coordinate the delivery of the cocaine. 

PREDICATE ACT FOURTEEN 


On or about August 24, 2011, in the State of Colorado, Anthony Harvey unlawfully, 


substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. 

23

PREDICATE ACT FIFTEEN 

Possession with Intent to Distribute a Controlled Substance, (F3) 


Alexander Oram unlawfully, feloniously, and knowingly possessed with intent to 

distribute a material, compound, mixture, or preparation that contained cocaine, a 

schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A),(3), 

C.R.S. 

PREDICATE ACT SIXTEEN 


On or about August 24, 2011, in the State of Colorado, Anthony Harvey, Alan 

Johnson and Alexander Oram did knowingly or intentionally use a communications 

facility, namely, a telephone, to facilitate the commission of a felony, namely, 

distribution of a controlled substance, in violation of 21 U.S.C. §§ 841 and 846, such 

use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 

§ 843. 

The offenses alleged in Predicate Acts Fourteen through Sixteen were committed in 

the following manner: 

On August 24, 2011, Alan Johnson, Alexander Oram and Anthony Harvey agreed 

that Harvey would distribute a quantity of cocaine to Alan Johnson by delivering the 

cocaine to Johnson’s runner, Alexander Oram, who would pick up the cocaine from 

Harvey at Harvey’s shop. Alexander Oram went to Anthony Harvey’s shop located 

at 200 Commerce Drive Unit #G in Fort Collins, CO. There, Harvey gave Oram a 

quantity of cocaine. Oram took the quantity of cocaine and then purchased a cutting 

agent, in order to process the cocaine for further distribution. Johnson utilized his 

cellular telephone 970-308-1614, Harvey utilized his cellular telephone 970-388- 

2208 and Oram utilized his cellular telephone number 970-690-9788 to arrange and 

coordinate this delivery of the cocaine. 

PREDICATE ACT SEVENTEEN 

Conspiracy to Distribute a Controlled Substance – Schedule II, (F3) 

On or about August 26, 2011, in the State of Colorado, Anthony Harvey and 

Abdon Loya-Sanchez unlawfully, feloniously, and knowingly conspired with each 

other, 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. 

24

PREDICATE ACT EIGHTEEN 



Abdon Loya-Sanchez did knowingly or intentionally use a communications facility, 




The offenses alleged in Predicate Acts Seventeen and Eighteen were committed in 


On August 26, 2011, Anthony Harvey and Abdon Loya-Sanchez agreed that Loya- 

Sanchez would distribute a quantity of cocaine to Harvey in exchange for money. In 

furtherance of this agreement, Harvey then went to meet Loya- Sanchez in the 

parking lot in the 900 block of E. Harmony Road in Fort Collins, CO. There, Harvey 

gave Loya-Sanchez money that comprised proceeds from the sale of cocaine and 

received a quantity of cocaine from Loya-Sanchez. Harvey utilized his cellular 

telephone 970-388-2208 and Loya-Sanchez utilized his cellular telephone number 

307-215-4762 to arrange and coordinate this meeting in reference to the delivery of 

the cocaine. 

PREDICATE ACT NINETEEN 



Johnson and Alexander Oram unlawfully, feloniously, and knowingly conspired 

with each other, 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. 

PREDICATE ACT TWENTY 



Johnson and Alexander Oram did knowingly or intentionally use a communications 




§ 843. 

The offenses alleged in Predicate Acts Nineteen and Twenty were committed in the 


On August 27, 2011, Alan Johnson and Anthony Harvey agreed that Harvey would 

distribute a quantity of cocaine to Alan Johnson and that Johnson would have his 

25

unner, Alexander Oram, pick up the cocaine from Harvey. Alexander Oram and 

Anthony Harvey agreed that Harvey would distribute a quantity of cocaine to Oram 

in exchange for money. In furtherance of this agreement, Oram then went to 

Anthony Harvey’s shop located at 200 Commerce Drive Unit #G in Fort Collins, CO. 

There, Harvey gave Oram a quantity of cocaine. Harvey utilized his cellular 

telephone 970-388-2208 and Oram utilized his cellular telephone number 970-690- 

9788 and 404-908-7309 to arrange and coordinate this delivery of the cocaine. 

PREDICATE ACT TWENTY-ONE 


On or about September 3, 2011, in the State of Colorado, Anthony Harvey and 

Alexander Oram unlawfully, feloniously, and knowingly conspired with each other, 

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. 

PREDICATE ACT TWENTY-TWO 







The offenses alleged in Predicate Acts Twenty-One and Twenty-Two were 

committed in the following manner: 

On September 3, Alexander Oram and Anthony Harvey agreed that Harvey would 

distribute a quantity of cocaine to Oram in exchange for money. In furtherance of 

this agreement, Oram then went to Anthony Harvey’s home located at 2420 

Manchester Drive in Fort Collins, CO. Harvey utilized his cellular telephone 970- 

388-2208 and Oram utilized his cellular telephone number 970-690-9788 to arrange 

and coordinate this conspiracy to distribute cocaine. 

PREDICATE ACT TWENTY-THREE 



Stuart Knowles unlawfully, feloniously, and knowingly conspired with each other, 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. 

26

PREDICATE ACT TWENTY-FOUR 



Stuart Knowles did knowingly or intentionally use a communications facility, 




The offenses alleged in Predicate Acts Twenty-Three and Twenty-Four were 


On September 6, 2011, Anthony Harvey and Stuart Knowles agreed that Harvey 

would distribute a quantity of cocaine to Knowles in exchange for money. In 

furtherance of this agreement, Knowles then went to Anthony Harvey’s home 

located at 2040 Manchester Drive in Fort Collins, CO. Harvey utilized his cellular 

telephone 970-388-2208 and Knowles utilized his cellular telephone number 970- 

481-8858 to arrange and coordinate this conspiracy to distribute cocaine. 

PREDICATE ACT TWENTY-FIVE 


On or about September 8, 2011, in the State of Colorado, Francisco Valencia 



PREDICATE ACT TWENTY-SIX 


25 to 450 Grams, (F3) 

On or about September 8, 2011, in the State of Colorado, Joseph Vittum 







The offenses alleged in Predicate Acts Twenty-Five and Twenty-Six were committed 

in the following manner: 

On September 8, 2011, Francisco Valencia distributed a quantity of cocaine to 

Joseph Vittum at Valencia’s residence located 1007 Whalers Way in Fort Collins. 

From Valencia’s residence, Vittum then traveled to 3657 S. College Ave. in Fort 

27

Collins. There, Vittum distributed a one-ounce quantity of cocaine to a confidential 

informant who was working in cooperation with and at the direction of law enforcement. 

PREDICATE ACT TWENTY-SEVEN 


Between the dates of September 8 through September 13, 2011, in the State of 

Colorado, Daniel Galvan and Francisco Valencia unlawfully, feloniously, and 

knowingly conspired with each other, to sell or distribute cocaine, a schedule II 


PREDICATE ACT TWENTY-EIGHT 


Between the dates of September 8, 2011 through September 13, 2011, in the State 

of Colorado, Daniel Galvan and Francisco Valencia did knowingly or intentionally 

use a communications facility, namely, a telephone, to facilitate the commission of a 

felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 

§§ 841 and 846, such use of a commmunications facility being unlawful, and in 

violation of 21 U.S.C. § 843. 

The offenses alleged in Predicate Acts Twenty-Seven and Twenty-Eight were 


Beginning on September 8, 2011, and continuing through September 13, 2011, 

Daniel Galvan and Francisco Valencia had a series of telephone conversations and 

ultimately agreed that Galvan would distribute a quantity of cocaine to Valencia in 

exchange for money. In furtherance of this agreement, Galvan then traveled to 

Valencia’s residence at 1007 Whaler’s Way in Fort Collins, CO. There, Galvan 

delivered a quantity of cocaine to Valencia. Galvan utilized his cellular telephone 

970-682-8515 and Valencia utilized his cellular telephone number 970-488-9294 to 

arrange and coordinate this delivery of cocaine. 

PREDICATE ACT TWENTY-NINE 


Between the dates of September 19, 2011, through September 20, 2011, in the 

State of Colorado, Daniel Galvan and Stuart Knowles unlawfully, feloniously, and 



28

PREDICATE ACT THIRTY 


On or about September 20, 2011, in the State of Colorado, Daniel Galvan 



PREDICATE ACT THIRTY-ONE 


On or about September 20, 2011, in the State of Colorado, Stuart Knowles 

unlawfully, feloniously, and knowingly possessed with intent to distribute a material, 

compound, mixture, or preparation that contained cocaine, a schedule II controlled 

substance, in violation of section 18-18-405(1),(2)(a)(I)(A),(3), C.R.S. 

PREDICATE ACT THIRTY TWO 


Between the dates of September 19, 2011, through September 20, 2011, in the 

State of Colorado, Daniel Galvan and Stuart Knowles did knowingly or 

intentionally use a communications facility, namely, a telephone, to facilitate the 

commission of a felony, namely, distribution of a controlled substance, in violation of 

21 U.S.C. §§ 841 and 846, such use of a commmunications facility being unlawful, 

and in violation of 21 U.S.C. § 843. 

The offenses alleged in Predicate Acts Twenty-Nine, Thirty, Thirty-One, and Thirty 

Two were committed in the following manner: 

On September 20, 2011, Daniel Galvan and Stuart Knowles agreed that Galvan 

would distribute a quantity of cocaine to Knowles in exchange for money. In 

furtherance of this agreement, Knowles then met Galvan at the 7-11 convenience 

store located at 970 W. Horsetooth in Fort Collins, CO. There, Galvan delivered a 

quantity of cocaine to Knowles. Galvan utilized his cellular telephone 970-682-8515 

and Knowles utilized his cellular telephone number 970-481-8858 to arrange and 

coordinate this delivery of cocaine. 

PREDICATE ACT THIRTY-THREE 






29

PREDICATE ACT THIRTY-FOUR 


On or about September 24, 2011, in the State of Colorado, Abdon Loya-Sanchez 



PREDICATE ACT THIRTY-FIVE 


On or about September 24, 2011, in the State of Colorado, Anthony Harvey 




PREDICATE ACT THIRTY-SIX 



Abdon Loya-Sanchez did knowingly or intentionally use a communications facility, 




The offenses alleged in Predicate Acts Thirty-Three, Thirty-Four, Thirty-Five and 

Thirty-Six were committed in the following manner: 

On September 24, 2011, Abdon Loya-Sanchez and Anthony Harvey agreed that 

Loya-Sanchez would distribute a quantity of cocaine to Harvey in exchange for 

money. In furtherance of this agreement, Loya-Sanchez then met Harvey at 

Harvey’s shop located at 204 Commerce Drive Unit #D and #E in Fort Collins, CO. 

There, Loya-Sanchez delivered a quantity of cocaine to Harvey. Loya-Sanchez 

utilized his cellular telephone 307-215-4672 and Harvey utilized his cellular 

telephone number 970-388-2208 to arrange and coordinate this delivery of cocaine. 

PREDICATE ACT THIRTY-SEVEN 


On or about September 8, 2011, in the State of Colorado, Joseph Vittum did 





30

The offenses alleged in Predicate Acts Thirty-Seven and Thirty- Eight were 


On September 8, 2011, Vittum distributed a one-ounce quantity of cocaine to a 

confidential informant who was working in cooperation with and at the direction of law 

enforcement. Vittum utilized his cellular telephone to arrange and coordinate this 

delivery of cocaine to the confidential informant. 

PREDICATE ACT THIRTY-EIGHT 


On or about August 24, 2011, in the State of Colorado, Anthony Harvey and Derek 

Durica unlawfully, feloniously, and knowingly conspired with each other, 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. 

PREDICATE ACT THIRTY-NINE 



Durica did knowingly or intentionally use a communications facility, namely, a 

telephone, to facilitate the commission of a felony, namely, distribution of a 

controlled substance, in violation of 21 U.S.C. §§ 841 and 846, such use of a 


The offenses alleged in Predicate Acts Thirty-Eight and Thirty-Nine were committed 


On August 24, 2011, Derek Durica and Anthony Harvey agreed that Harvey would 

distribute a quantity of cocaine to Durica in exchange for money. In furtherance of 

this agreement, Durica then went to Anthony Harvey’s shop located at 200 

Commerce Drive Unit #G in Fort Collins, CO. There, Harvey gave Durica a quantity 

of cocaine. Harvey utilized his cellular telephone 970-388-2208 and Durica utilized 

his cellular telephone number 970-217-7744 to arrange and coordinate this delivery 

of the cocaine. 

PREDICATE ACT FORTY 


On or about August 24, 2011, in the State of Colorado, Anthony Harvey and Carl 

Hayes unlawfully, feloniously, and knowingly conspired with each other, to sell or 


405(1),(2)(a)(I)(A), C.R.S. 

31

PREDICATE ACT FORTY-ONE 


On or about August 24, 2011, in the State of Colorado, Anthony Harvey did 





The offenses alleged in Predicate Acts Forty and Forty-One were committed in the 


On August 24, 2011, Carl Hayes and Anthony Harvey agreed that Harvey would 

distribute a quantity of cocaine to Hayes in exchange for money. In furtherance of 

this agreement, Hayes then went to Anthony Harvey’s shop located at 200 

Commerce Drive Unit #G in Fort Collins, CO. There, Harvey gave Hayes a quantity 

of cocaine. Harvey utilized his cellular telephone 970-388-2208 and Hayes utilized 



PREDICATE ACT FORTY-TWO 


On or about August 24, 2011, in the State of Colorado, Anthony Harvey and Kamal 

Patterson unlawfully, feloniously, and knowingly conspired with each other, 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. 

PREDICATE ACT FORTY-THREE 


On or about August 24, 2011, in the State of Colorado, Anthony Harvey did 





The offenses alleged in Predicate Acts Forty-Two and Forty-Three were committed 


On or about August 24, 2011, Kamal Patterson and Anthony Harvey agreed that 

Harvey would distribute a quantity of cocaine to Patterson in exchange for money. 

In furtherance of this agreement, Patterson then went to Anthony Harvey’s shop 

located at 200 Commerce Drive Unit #G in Fort Collins, CO. There, Patterson gave 

Harvey a quantity of US currency so that Harvey could use that money to ultimately 

32

acquire a quantity of cocaine from Harvey’s source of supply. Harvey utilized his 

cellular telephone 970-388-2208 and Patterson utilized his cellular telephone 

number 719-388-6449 to arrange and coordinate this delivery of cash towards the 

purchase of cocaine. 

PREDICATE ACT FORTY-FOUR 





405(1),(2)(a)(I)(A), C.R.S. 

PREDICATE ACT FORTY-FIVE 



Durica did knowingly or intentionally use a communications facility, namely, a 




The offenses alleged in Predicate Acts Forty-Four and Forty-Five were committed in 


On August 26, 2011, Derek Durica and Anthony Harvey agreed that Harvey would 

distribute a quantity of cocaine to Durica in exchange for money. In furtherance of 

this agreement, Durica then went to Anthony Harvey’s shop located at 200 

Commerce Drive Unit #G in Fort Collins, CO. There, Harvey gave Durica a quantity 

of cocaine. Harvey utilized his cellular telephone 970-388-2208 and Durica utilized 



PREDICATE ACT FORTY-SIX 



Derek Durica unlawfully, feloniously, and knowingly conspired with each other, to 


18-18-405(1),(2)(a)(I)(A), C.R.S. 

33

PREDICATE ACT FORTY-SEVEN 



Derek Durica did knowingly or intentionally use a communications facility, namely, a 




The offenses alleged in Predicate Acts Forty-Six and Forty-Seven were committed in 


On September 2, 2011, Derek Durica and Anthony Harvey agreed that Harvey 

would distribute a quantity of cocaine to Durica in exchange for money. In 

furtherance of this agreement, Durica then met Anthony Harvey at a parking lot 200 

Linden Street in Fort Collins, CO. There, Durica gave Harvey a quantity of US 

currency so that Harvey could use that money to ultimately acquire a quantity of 

cocaine from Harvey’s source of supply. Harvey utilized his cellular telephone 970- 

388-2208 and Durica utilized his cellular telephone number 970-217-7744 to arrange 

and coordinate this delivery of cash towards the purchase of cocaine. 

PREDICATE ACT FORTY-EIGHT 





The offense alleged in Predicate Act Forty-Eight was committed in the following 

manner: 

On September 3, 2011, Anthony Harvey delivered a quantity of cocaine to Matthew 

Bekkerus at Anthony Harvey’s residence located at 2040 Manchester in Fort Collins, 

CO. 

PREDICATE ACT FORTY-NINE 



Gary Lihudis unlawfully, feloniously, and knowingly conspired with each other, to 


18-18-405(1),(2)(a)(I)(A), C.R.S. 

34

PREDICATE ACT FIFTY 


On or about September 3, 2011, in the State of Colorado, Anthony Harvey did 





The offenses alleged in Predicate Acts Forty-Nine and Fifty were committed in the 


On September 3, 2011, Gary Lihudis and Anthony Harvey agreed that Harvey would 

distribute a quantity of cocaine to Lihudis in exchange for money. In furtherance of 

this agreement, Lihudis then went to Anthony Harvey’s residence located at 2040 

Manchester in Fort Collins, CO. There, Harvey gave Lihudis a quantity of cocaine. 

Harvey utilized his cellular telephone 970-388-2208 and Lihudis utilized his cellular 

telephone number 970-231-8105 to arrange and coordinate this delivery of the 

cocaine. 

PREDICATE ACT FIFTY-ONE 


Between the dates of September 3, 2011, and September 10, 2011, in the State of 

Colorado, Anthony Harvey and Maria Moreno unlawfully, feloniously, and 



PREDICATE ACT FIFTY-TWO 



Colorado, Anthony Harvey did knowingly or intentionally use a communications 




§ 843. 

The offenses alleged in Predicate Acts Fifty-One and Fifty-Two were committed in 


Beginning on September 3, 2011, Maria Moreno and Anthony Harvey agreed that 

Harvey would distribute a quantity of cocaine to Moreno in exchange for money. In 

furtherance of this agreement, on September 3, 2011, Moreno then went to Anthony 

35

Harvey’s shop located at 200 Commerce Drive, Unit #G in Fort Collins, CO. There, 

Moreno gave Harvey a quantity of US currency so that Harvey could use that money 

to ultimately acquire a quantity of cocaine from Harvey’s source of supply. Harvey 

utilized his cellular telephone 970-388-2208 and Moreno utilized her cellular 

telephone number 970-286-9717 to arrange and coordinate this delivery of the 

cocaine. 

PREDICATE ACT FIFTY-THREE 



Jerome Nelson unlawfully, feloniously, and knowingly conspired with each other, to 


18-18-405(1),(2)(a)(I)(A), C.R.S. 

PREDICATE ACT FIFTY-FOUR 







The offenses alleged in Predicate Acts Fifty-Three and Fifty-Four were committed in 


On September 7, 2011, Jerome Nelson and Anthony Harvey agreed that Harvey 

would distribute a quantity of cocaine to Nelson in exchange for money. In 

furtherance of this agreement, Nelson then went to Anthony Harvey’s shop located 

at 204 Commerce Drive, Unit #D in Fort Collins, CO. There, Nelson received a 

quantity of cocaine that Harvey had designated for Nelson at Harvey’s shop. Harvey 

utilized his cellular telephone 970-388-2208 and Nelson utilized his cellular 

telephone number 970-213-1503 to arrange and coordinate this delivery of cocaine. 

PREDICATE ACT FIFTY-FIVE 



Quentin Wallace unlawfully, feloniously, and knowingly conspired with each other, 


18-18-405(1),(2)(a)(I)(A), C.R.S. 

36

PREDICATE ACT FIFTY-SIX 





PREDICATE ACT FIFTY-SEVEN 







The offenses alleged in Predicate Acts Fifty-Five through Fifty-Seven were 


On September 7, 2011, Anthony Harvey and Quentin Wallace agreed that Harvey 

would distribute a quantity of cocaine to Wallace in exchange for money. In 

furtherance of this agreement, Wallace then met Harvey at his residence, 2040 

Manchester in Fort Collins, CO. There, Harvey delivered a quantity of cocaine to 

Wallace. Harvey utilized his cellular telephone 970-388-2208 and Wallace utilized 


of cocaine. 

PREDICATE ACT FIFTY-EIGHT 





18-18-405(1),(2)(a)(I)(A), C.R.S. 

PREDICATE ACT FIFTY-NINE 







37

The offenses alleged in Predicate Acts Fifty-Eight and Fifty-Nine were committed in 


On September 9, 2011, Gary Lihudis and Anthony Harvey agreed that Harvey would 

distribute a quantity of cocaine to Lihudis in exchange for money. In furtherance of 

this agreement, Lihudis met Harvey at Lihudis’ residence at 7348 S. College Ave. in 

Fort Collins, CO. There, Lihudis gave Harvey a quantity of US currency so that 

Harvey could use that money to ultimately acquire a quantity of cocaine from 

Harvey’s source of supply. Harvey utilized his cellular telephone 970-388-2208 and 

Lihudis utilized his cellular telephone number to arrange and coordinate this delivery 

of cash towards the purchase of cocaine. 

PREDICATE ACT SIXTY 



Michael McCain unlawfully, feloniously, and knowingly conspired with each other, to 


18-18-405(1),(2)(a)(I)(A), C.R.S. 

PREDICATE ACT SIXTY-ONE 







The offenses alleged in Predicate Acts Sixty and Sixty-One were committed in the 


On September 9, 2011, Michael McCain and Anthony Harvey agreed that Harvey 

would distribute a quantity of cocaine to McCain in exchange for money. In 

furtherance of this agreement, McCain met Harvey at the intersection of College 

Ave. and Harmony Road in Fort Collins, CO. There, McCain gave Harvey a quantity 

of US currency so that Harvey could use that money to ultimately acquire a quantity 

of cocaine from Harvey’s source of supply. Harvey utilized his cellular telephone 

970-388-2208 and McCain utilized his cellular telephone number 720- 648- 0628 to 

arrange and coordinate this delivery of cash towards the purchase of cocaine. 

38

PREDICATE ACT SIXTY-TWO 





18-18-405(1),(2)(a)(I)(A), C.R.S. 

PREDICATE ACT SIXTY-THREE 



Derek Durica did knowingly or intentionally use a communications facility, namely, a 




The offenses alleged in Predicate Acts Sixty-Two and Sixty-Three were committed 


On September 14, 2011, Derek Durica and Anthony Harvey agreed that Harvey 

would distribute a quantity of cocaine to Durica in exchange for money. In 

furtherance of this agreement, Durica then went to Anthony Harvey’s shop located at 

204 Commerce Drive Unit #D in Fort Collins, CO. There, Durica gave Harvey a 

quantity of US currency so that Harvey could use that money to ultimately acquire a 

quantity of cocaine from Harvey’s source of supply. Harvey utilized his cellular 

telephone 970-388-2208 and Durica utilized his cellular telephone number 970-217- 

7744 to arrange and coordinate this delivery of cash towards the purchase of 

cocaine. 

PREDICATE ACT SIXTY-FOUR 

Distribution of Marijuana – Between 5 and 100 Pounds, (F4) 


and Anthony Harvey, unlawfully, feloniously, and knowingly sold or distributed, or 

attempted to sell or distribute, marijuana or marijuana concentrate. 

Further, the amount was at least five pounds but not more than one hundred pounds 

of marijuana; in violation of section 18-18-406(6)(b)(I), (III)(B), C.R.S. 

The offense alleged in Predicate Act Sixty-Four was committed in the following 

manner: 

On September 20, 2011, Abdon Loya-Sanchez and Anthony Harvey distributed 

approximately 10 pounds of marijuana, packaged in single-pound increments to 

39

Brian Butler at Harvey’s residence, 2040 Manchester in Fort Collins, CO. Shortly 

thereafter, at Mile Marker 351 on Hwy 287, law enforcement officers recovered 10 

pounds of marijuana from Brian Butler. 

PREDICATE ACT SIXTY-FIVE 

Possession with Intent to Distribute a Controlled Substance – 

25 to 450 Grams, (F3) 




substance. 





The offense charged in Predicate Act Sixty-FIve was committed in the following 

manner: 

On September 30, 2011, law enforcement officers recovered 336.7 grams of 

cocaine from Leobardo Loya’s residence at 2025 N. College Ave., #225, Fort 

Collins, CO. 

PREDICATE ACT SIXTY-SIX 




compound, mixture, or preparation that contained methamphetamine, a schedule II 

controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. 

The offense charged in Predicate Act Sixty-Six was committed in the following 

manner: 

On September 30, 2011, law enforcement officers recovered 14 grams of 

methamphetamine from Leobardo Loya’s residence at 2025 N. College Ave., #225, 

Fort Collins, CO. 

PREDICATE ACT SIXTY-SEVEN 




40


substance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. 

The offense charged in Predicate Act Sixty-Seven was committed in the following 

manner: 

On September 30, 2011, law enforcement officers recovered 10.7 grams of cocaine 

from the residence of Abdon Loya-Sanchez at 3717 S. Taft Hill, #268, Fort Collins, 

CO. 

PREDICATE ACT SIXTY-EIGHT 

Possession with Intent to Distribute Marijuana – 

Between 5 and 100 Pounds, (F4) 

On or about September 30, 2011, in the State of Colorado, Abdon Loya-Sanchez, 

unlawfully, feloniously, and knowingly possessed or attempted to possess, with 

intent to sell or distribute marijuana or marijuana concentrate. 


of marijuana; in violation of section 18-18-406(6)(b)(I), (III)(B), C.R.S. 

The offense charged in Predicate Act Sixty-Eight was committed in the following 

manner: 

On September 30, 2011, law enforcement officers recovered 2536.7 grams 

(approximately 5 pounds) of marijuana from the residence of Abdon Loya-Sanchez 

at 3717 S. Taft Hill, #268, Fort Collins, CO. Law enforcement officers recovered 

3939.6 grams (approximately 8 pounds) of marijuana from the storage facility rented 

by Abdon Loya-Sanchez at 3702 Manhattan, #E-6, Fort Collins, CO. 

PREDICATE ACT SIXTY-NINE 


450 to 1000 Grams, (F3) 

On or about September 30, 2011, in the State of Colorado, Alexander Oram 



substance. 

Further, the amount was or had been represented to be at least four hundred-fifty 

grams but not more than one thousand grams or one kilogram of a material, 

compound, mixture, or preparation that contained the controlled substance; in 

violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S. 

41

The offense charged in Predicate Act Sixty-Nine was committed in the following 

manner: 

On September 30, 2011, law enforcement officers recovered 477.4 grams of 

cocaine from the residence of Alexander Oram at 1025 Cunningham, #C-6, Fort 

Collins, CO. 

PREDICATE ACT SEVENTY 


450 to 1000 Grams, (F3) 




substance. 





The offense charged in Predicate Act Seventy was committed in the following 

manner: 

On September 30, 2011, law enforcement officers recovered 686 grams of cocaine 

from Francisco Valencia’s bedroom in his residence at 1007 Whalers Way, Fort 

Collins, CO. 

42

PREDICATE ACT SEVENTY-ONE 



Tony Romero unlawfully, feloniously, and knowingly conspired with each other, to 


18-18-405(1),(2)(a)(I)(A), C.R.S. 

PREDICATE ACT SEVENTY-TWO 




sell or distribute cocaine and oxycodonoe, both schedule II controlled substances; in 


PREDICATE ACT SEVENTY-THREE 



Stuart Knowles did knowingly or intentionally use a communications facility, 




The offenses charged in Predicate Acts Seventy-One through Seventy-Three were 


On September 24, 2011, Anthony Harvey and Tony Romero agreed that Harvey 

was going to distribute a quantity of cocaine and that Romero would assist Harvey in 

processing the cocaine for distribution. In furtherance of this agreement, Harvey 

directed Romero to purchase a cutting agent for the cocaine, which Romero did and 

brought to Harvey’s shop. 

Also on that date, Anthony Harvey and Stuart Knowles agreed that Harvey would 

distribute quantities of cocaine and oxycodonoe to Knowles in exchange for money. 

In furtherance of this agreement, Knowles went to Harvey’s shop at 204 Commerce 

Drive, Units #D/E, Fort Collins, CO, in order to pick up a quantity of oxycodone from 

Harvey. Harvey utilized his cellular telephone and Knowles utilized his cellular 

telephone to arrange and coordinate this deal. 

43

PREDICATE ACT SEVENTY-FOUR 



and Adrian Hernandez unlawfully, feloniously, and knowingly conspired with each 



PREDICATE ACT SEVENTY-FIVE 


25 to 450 Grams, (F3) 








PREDICATE ACT SEVENTY-SIX 

Possession with Intent to Distribute a Controlled Substance – Schedule II – 

25 to 450 Grams, (F3) 

On or about September 24, 2011, in the State of Colorado, Adrian Hernandez 

unlawfully, feloniously, and knowingly possessed with intent to distribute cocaine, a 

schedule II controlled substance. 





PREDICATE ACT SEVENTY-SEVEN 



did knowingly or intentionally use a communications facility, namely, a telephone, to 




The offenses charged in Predicate Acts Seventy-Four through Seventy-Seven were 


44

On September 24, 2011, Abdon Loya-Sanchez and Adrian Hernandez agreed that 

Loya-Sanchez would deliver a quantity of cocaine to Hernandez in exchange for 

money. In furtherance of this agreement, Hernandez met Loya-Sanchez in a 

parking lot located at Taft Hill Road and Harmony Road, Fort Collins, CO. At that 

location, Loya-Sanchez distributed approximately a one-pound quantity of cocaine to 

Adrian Hernandez. Hernandez accepted the cocaine and then left the area. 

PREDICATE ACT SEVENTY-EIGHT 



and Alejandro Uribe unlawfully, feloniously, and knowingly conspired with each 



PREDICATE ACT SEVENTY-NINE 







The offenses charged in Predicate Acts Seventy-Eight and Seventy-Nine were 


On September 23, 2011, Abdon Loya-Sanchez and Alejandro Uribe agreed that 

Uribe would deliver an amount of money to Loya-Sanchez as payment for a past 

purchase of cocaine and towards a future purchase of cocaine. In furtherance of 

this agreement, Uribe went to Loya-Sanchez’s residence at 3717 Taft Hill, #268, 

Fort Collins, CO. At that location, Uribe delivered a quantity of money as payment 

for past drug transactions. Loya-Sanchez utilized his cellular telephone 307-215- 

4762 to arrange this meeting. 

45

PREDICATE ACT EIGHTY 


25 to 450 Grams, (F3) 

On or about May 3, 2011, in the State of Colorado, Alan Johnson unlawfully, 


substance. 





PREDICATE ACT EIGHTY-ONE 


On or about May 3, 2011, in the State of Colorado, Alan Johnson did knowingly or 

intentionally use a communications facility, namely, a telephone, to facilitate the 




The offenses alleged in Predicate Acts Eighty and Eighty-One were committed in the 


On May 3, 2011, Alan Johnson sold a five-ounce quantity of cocaine to a 

confidential informant in the parking lot of the Albertson’s grocery store at 3657 S. 

Mason in Fort Collins, CO. Alan Johnson utilized his cellular telephone 970-308- 

1614 to arrange and coordinate the delivery of the cocaine. 

PREDICATE ACT EIGHTY-TWO 


25 to 450 Grams, (F3) 

On or about June 17, 2011, in the State of Colorado, Alan Johnson unlawfully, 


substance. 





46

PREDICATE ACT EIGHTY-THREE 


On or about June 17, 2011, in the State of Colorado, Alan Johnson did knowingly 

or intentionally use a communications facility, namely, a telephone, to facilitate the 




The offenses alleged in Predicate Acts Eighty-Two and Eighty-Three were 


On June 17, 2011, Alan Johnson sold a three-ounce quantity of cocaine to a 

confidential informant in the parking lot of American Furniture Warehouse store at 

625 SW Frontage Road in Fort Collins, CO. Alan Johnson utilized his cellular 

telephone 970-308-1614 to arrange and coordinate the delivery of the cocaine. 

PREDICATE ACT EIGHTY-FOUR 


On or about August 3, 2011, in the State of Colorado, Alan Johnson unlawfully, 

feloniously, and knowingly sold or distributed methamphetamine, a schedule II 


PREDICATE ACT EIGHTY-FIVE 


On or about August 3, 2011, in the State of Colorado, Jimmie Joe Montgomery 

unlawfully, feloniously, and knowingly sold or distributed methamphetamine, a 

schedule 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-Four and Eighty-Five were committed 


On August 3, 2011, Alan Johnson delivered a quantity of methamphetamine to 

Jimmie Joe Montgomery at Johnson’s residence on Cleveland Avenue, Loveland, 

CO. Montgomery then took the methamphetamine from Johnson and delivered 4.3 

grams of methamphetamine to Kevin Caldwell in the 1400 block of Remington Street 

in Fort Collins, CO. 

47

PREDICATE ACT EIGHTY-SIX 


Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado, 

Alan Johnson and Kenneth West unlawfully, feloniously, and knowingly conspired 



PREDICATE ACT EIGHTY-SEVEN 



Alan Johnson unlawfully, feloniously, and knowingly sold or distributed cocaine, a 


C.R.S. 

PREDICATE ACT EIGHTY-EIGHT 



Kenneth West unlawfully, feloniously, and knowingly possessed with intent to 


schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), 

C.R.S. 

PREDICATE ACT EIGHTY-NINE 



Alan Johnson and Mark Fraleigh unlawfully, feloniously, and knowingly conspired 



PREDICATE ACT NINETY 



Alan Johnson and Mitchell Morris unlawfully, feloniously, and knowingly conspired 



48

PREDICATE ACT NINETY-ONE 



Alan Johnson and Kenneth West did knowingly or intentionally use a 

communications facility, namely, a telephone, to facilitate the commission of a 

felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 

§§ 841 and 846, such use of a commmunications facility being unlawful, and in 

violation of 21 U.S.C. § 843. 

The offenses alleged in Predicate Acts Eighty-Six through Ninety-One were 


Between the dates of August 8, 2011 and August 12, 2011, Alan Johnson delivered 

a quantity of cocaine to Kenneth West. West and Johnson then agreed that West 

would travel to Montana and distribute a quantity of cocaine to each of Johnson’s 

customers, Mark Fraleigh and Mitchell Morris. In furtherance of this agreement, 

West traveled to Montana and delivered a quantity of cocaine to both Mark Fraleigh 

and Mitchell Morris. Johnson utilized his cellular telephone 970-308-1614 and West 

utilized his cellular telephone 970-301-5777 to arrange and coordinate this delivery 


At approximately the same time, Johnson agreed with Mark Fraleigh that Johnson 

would deliver a quantity of cocaine to Fraleigh. In furtherance of this agreement, 

Johnson gave a quantity of cocaine to Kenneth West who then transported the 

cocaine to Fraleigh in Montana. Fraleigh then coordinated with Johnson through the 

use of cellular telephones to send the proceeds from the sale of cocaine back to 

Johnson. 

Similarly, Johnson agreed with Mitchell Morris that Johnson would deliver a quantity 

of cocaine to Morris. In furtherance of this agreement, Johnson gave a quantity of 

cocaine to Kenneth West who then transported the cocaine to Morris in Montana. 

Morris then coordinated with Johnson through the use of cellular telephones to 

return the proceeds from the sale of the cocaine back to Johnson. 

PREDICATE ACT NINETY-TWO 


On or about August 12, 2011, in the State of Colorado, Alan Johnson and Horacio 

Bugarin unlawfully, feloniously, and knowingly conspired with each other, to sell or 

distribute methamphetamine, a schedule II controlled substance; in violation of 


49

PREDICATE ACT NINETY-THREE 



Bugarin did knowingly or intentionally use a communications facility, namely, a 




The offenses alleged in Predicate Acts Ninety-Two and Ninety-Three were 


On August 12, 2011, Alan Johnson and Horacio Bugarin agreed that Bugarin would 

distribute a quantity of methamphetamine to Johnson in exchange for money. In 

furtherance of this agreement, Bugarin picked up Alan Johnson from his residence 

on Cleveland Street in Loveland, CO. Bugarin then traveled with Johnson to 

Greeley, CO. Johnson utilized his cellular telephone 970-308-1614 and Bugarin 

utilized his cellular telephone to arrange and coordinate this meeting in reference to 

the conspiracy to distribute the methamphetamine. 

PREDICATE ACT NINETY-FOUR 


On or about August 14, 2011, in the State of Colorado, Alan Johnson and Shawn 

Blea unlawfully, feloniously, and knowingly conspired with each other, to sell or 



PREDICATE ACT NINETY-FIVE 


On or about August 14, 2011, in the State of Colorado, Alan Johnson did knowingly 

or intentionally use a communications facility, namely, a telephone, to facilitate the 




The offenses alleged in Predicate Acts Ninety-Four and Ninety-Five were committed 


On August 14, 2011, Alan Johnson and Shawn Blea agreed that Johnson would 

distribute a quantity of methamphetamine to Blea in exchange for money. In 

furtherance of this agreement, Blea went to Johnson’s residence on Cleveland 

Street, Loveland, CO. At that location, Blea received a quantity of 

methamphetamine from Johnson. 

50

PREDICATE ACT NINETY-SIX 


On or about August 15, 2011, in the State of Colorado, Alan Johnson and Anthony 

Harvey unlawfully, feloniously, and knowingly conspired with each other, to sell or 


405(1),(2)(a)(I)(A), C.R.S. 

PREDICATE ACT NINETY-SEVEN 



Harvey did knowingly or intentionally use a communications facility, namely, a 




The offenses alleged in Predicate Acts Ninety-Six and Ninety-Seven were 


On August 15, 2011, Alan Johnson and Anthony Harvey agreed that Johnson would 

pay an amount of US currency to Harvey as payment both for previous deliveries of 

cocaine and also for future delivery of cocaine. In furtherance of this agreement, 

Johnson and Harvey met at 5000 Boardwalk, Fort Collins, CO. At that location, 

Johnson paid Harvey an amount of US currency towards the future purchase of 

cocaine. 

PREDICATE ACT NINETY-EIGHT 


On or about August 16, 2011, in the State of Colorado, Alan Johnson and Jimmie 

Joe Montgomery unlawfully, feloniously, and knowingly conspired with each other, 

to sell or distribute methamphetamine, a schedule II controlled substance; in 


PREDICATE ACT NINETY-NINE 



Joe Montgomery did knowingly or intentionally use a communications facility, 




51

The offenses alleged in Predicate Acts Ninety-Eight and Ninety-Nine were 


On August 16, 2011, Alan Johnson and Jimmie Joe Montgomery agreed that 

Johnson would distribute a quantity of methamphetamine to Montgomery in 

exchange for money. In furtherance of this agreement, Johnson directed 

Montgomery to go to Johnson’s residence on Cleveland Ave, Loveland, CO. 

Montgomery then traveled to Johnson’s residence to pick up the quantity of 

methamphetamine. Johnson utilized his cellular telephone 970-308-1614 and 

Montgomery utilized his cellular telephone 970-400-0105 to arrange and coordinate 

this delivery of the methamphetamine. 

PREDICATE ACT ONE HUNDRED 






PREDICATE ACT ONE HUNDRED-ONE 







The offenses alleged in Predicate Acts One Hundred and One Hundred-One were 


On August 16, 2011, Alan Johnson and Horacio Bugarin agreed that Johnson would 

pay an amount of US currency to Bugarin as payment both for previous deliveries of 

methamphetamine and also for future delivery of methamphetamine. In furtherance 

of this agreement, Johnson and Bugarin met at the gas station at 1 st and Taft, 

Loveland, CO. At that location, Johnson paid Bugarin an amount of US currency 

towards the future purchase of methamphetamine. 

52

PREDICATE ACT ONE HUNDRED-TWO 






PREDICATE ACT ONE HUNDRED-THREE 







The offenses alleged in Predicate Acts One Hundred-Two and One Hundred-Three 

were committed in the following manner: 

On August 21, 2011, Alan Johnson and Horacio Bugarin agreed that Johnson would 

pay an amount of US currency to Bugarin as payment both for previous deliveries of 

methamphetamine and also for future delivery of methamphetamine. In furtherance 

of this agreement, Johnson and Bugarin met at Bugarin’s residence at 139 Juniper 

#B, Loveland, CO. At that location, Johnson paid Bugarin an amount of US 

currency towards the future purchase of methamphetamine. 

PREDICATE ACT ONE HUNDRED-FOUR 






PREDICATE ACT ONE HUNDRED-FIVE 


On or about August 24, 2011, in the State of Colorado, Horacio Bugarin unlawfully, 



53

PREDICATE ACT ONE HUNDRED-SIX 



feloniously, and knowingly possessed with intent to distribute a material, compound, 

mixture, or preparation that contained methamphetamine, a schedule II controlled 


PREDICATE ACT ONE HUNDRED-SEVEN 







The offenses alleged in Predicate Acts One Hundred-Four though One Hundred- 

Seven were committed in the following manner: 

On August 24, 2011, Alan Johnson and Horacio Bugarin agreed that Bugarin would 

deliver a quantity of methamphetamine to Johnson. In furtherance of this 

agreement, Johnson and Bugarin met at Johnson’s residence at Cleveland Ave., 

Loveland, CO. At that location, Bugarin delivered a quantity of methamphetamine to 

Johnson. 

PREDICATE ACT ONE HUNDRED-EIGHT 





405(1),(2)(a)(I)(A), C.R.S. 

PREDICATE ACT ONE HUNDRED-NINE 





54

PREDICATE ACT ONE HUNDRED-TEN 




mixture, or preparation that contained cocaine, a schedule II controlled substance, in 


PREDICATE ACT ONE HUNDRED-ELEVEN 



Harvey did knowingly or intentionally use a communications facility, namely, a 




The offenses alleged in Predicate Acts One Hundred-Eight through One Hundred- 

Eleven were committed in the following manner: 

On August 26, 2011, Alan Johnson and Anthony Harvey agreed that Harvey would 

deliver a quantity of cocaine to Johnson. In furtherance of this agreement, Johnson 

and Harvey met at 5000 Boardwalk, Fort Collins, CO. At that location, Harvey 

delivered a quantity of cocaine to Johnson, who accepted the delivery. 

PREDICATE ACT ONE HUNDRED-TWELVE 


On or about September 19, 2011, in the State of Colorado, Alan Johnson and 

Anthony Harvey unlawfully, feloniously, and knowingly conspired with each other, 


18-18-405(1),(2)(a)(I)(A), C.R.S. 

55

PREDICATE ACT ONE HUNDRED-THIRTEEN 



Alan Johnson did knowingly or intentionally use a communications facility, namely, 

a telephone, to facilitate the commission of a felony, namely, distribution of a 



The offenses alleged in Predicate Acts One Hundred-Twelve and One Hundred- 

Thirteen were committed in the following manner: 

On September 19, 2011, Alan Johnson and Anthony Harvey agreed that Harvey 

would distribute a quantity of cocaine to Alan Johnson and that Johnson would pay 

Harvey. In furtherance of this agreement, they met at the Inca Restaurant, at 2413 

S. College, Fort Collins, CO. Harvey utilized his cellular telephone 970-388-2208 

and Johnson utilized his cellular telephone number 970-308-1614 to arrange and 

coordinate this conspiracy to distribute cocaine. 

PREDICATE ACT ONE HUNDRED-FOURTEEN 

Distribution of a Schedule II Controlled Substance – 

450 to 1000 Grams, (F3) 

On or about September 29, 2011, in the State of Colorado, Alan Johnson 







The offense charged in Predicate Act One Hundred-Fourteen was committed in the 


On September 29, 2011, Alan Johnson delivered approximately 477.4 grams of 

cocaine to Alexander Oram at Oram’s residence on 1025 Cunningham, #C-6, Fort 

Collins, CO. Johnson directed Oram to store the cocaine for future distribution. 

56

PREDICATE ACT ONE HUNDRED-FIFTEEN 


Schedule II – 450 to 1000 Grams, (F3) 

On or about September 30, 2011, in the State of Colorado, Horacio Bugarin 

unlawfully, feloniously, and knowingly possessed with intent to distribute 

methamphetamine, a schedule II controlled substance. 





PREDICATE ACT ONE HUNDRED-SIXTEEN 










The offenses charged in Predicate Acts One Hundred-Fifteen and One Hundred- 

Sixteen were committed in the following manner: 

On September 30, 2011, law enforcement officers recovered 26.6 grams of cocaine 

and 466.25 grams of methamphetamine from Horacio Bugarin’s residence at 

Juniper Place, Loveland, CO. 

PREDICATE ACT ONE HUNDRED SEVENTEEN 






57

PREDICATE ACT ONE HUNDRED EIGHTEEN 







The offenses charged in Predicate Acts One Hundred-Seventeen and One Hundred- 

Eighteen were committed in the following manner: 

On September 13, 2011, Abdon Loya-Sanchez and Alejandro Uribe agreed that 

Loya-Sanchez would deliver approximately two ounces of cocaine to Uribe. In 

furtherance of this agreement, Loya-Sanchez went to Uribe’s residence on W. 

Laurel Street, Fort Collins, CO. At that location, Loya-Sanchez distributed a quantity 

of cocaine to Alejandro Uribe. Loya-Sanchez utilized his cellular telephone 307-215- 

4762 to arrange this meeting. 

58

COUNT THREE 


On or about June 24, 2011, in the State of Colorado, Francisco Valencia 



The offense alleged in Count Three was committed in the manner described in 

Predicate Act Three. 

COUNT FOUR 


25 to 450 Grams, (F3) 



substance. 





The offense alleged in Count Four was committed in the manner described in 

Predicate Acts Four and Five. 

COUNT FIVE 


25 to 450 Grams, (F3) 



substance. 





The offense alleged in Count Five was committed in the manner described in 

Predicate Acts Six and Seven. 

59

COUNT SIX 


25 to 450 Grams, (F3) 








The offense alleged in Count Six was committed in the manner described in 

Predicate Acts Eight and Nine. 

COUNT SEVEN 


25 to 450 Grams, (F3) 








The offense alleged in Count Seven was committed in the manner described in 

Predicate Acts Ten and Eleven. 

COUNT EIGHT 


25 to 450 Grams, (F3) 








60

The offense alleged in Count Eight was committed in the manner described in 

Predicate Acts Twelve and Thirteen. 

COUNT NINE 





COUNT TEN 



Alexander Oram unlawfully, feloniously, and knowingly possessed with intent to 


schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A),(3), 

C.R.S. 

The offenses alleged in Counts Nine and Ten were committed in the manner 

described in Predicate Acts Fourteen through Sixteen. 

COUNT ELEVEN 






The offense alleged in Count Eleven was committed in the manner described in 

Predicate Acts Seventeen and Eighteen. 

COUNT TWELVE 



Johnson and Alexander Oram unlawfully, feloniously, and knowingly conspired 



The offense alleged in Count Twelve was committed in the manner described in 

Predicate Acts Nineteen and Twenty. 

61

COUNT THIRTEEN 



Alexander Oram unlawfully, feloniously, and knowingly conspired with each other, 


18-18-405(1),(2)(a)(I)(A), C.R.S. 

The offense alleged in Count Thirteen was committed in the manner described in 

Predicate Acts Twenty-One and Twenty-Two. 

COUNT FOURTEEN 





18-18-405(1),(2)(a)(I)(A), C.R.S. 

The offense alleged in Count Fourteen was committed in the manner described in 

Predicate Acts Twenty-Three and Twenty-Four. 

COUNT FIFTEEN 





COUNT SIXTEEN 


25 to 450 Grams, (F3) 

On or about September 8, 2011, in the State of Colorado, Joseph Vittum 







The offenses alleged in Counts Fifteen and Sixteen were committed in the manner 

described in Twenty-Five and Twenty-Six. 

62

COUNT SEVENTEEN 



Colorado, Daniel Galvan and Francisco Valencia unlawfully, feloniously, and 



The offense alleged in Count Seventeen was committed in the manner described in 

Predicate Acts Twenty-Seven and Twenty-Eight. 

COUNT EIGHTEEN 



Colorado, Daniel Galvan and Stuart Knowles unlawfully, feloniously, and 



COUNT NINETEEN 


On or about September 20, 2011, in the State of Colorado, Daniel Galvan 



COUNT TWENTY 


On or about September 20, 2011, in the State of Colorado, Stuart Knowles 




The offenses alleged in Counts Eighteen, Nineteen, and Twenty were committed in 

the manner described in Predicate Acts Twenty-Nine, Thirty, Thirty-One, and Thirty 

Two. 

63

COUNT TWENTY-ONE 






COUNT TWENTY-TWO 





COUNT TWENTY-THREE 






The offenses alleged in Counts Twenty-One, Twenty-Two, and Twenty-Three were 

committed in the manner described in Predicate Acts Thirty-Three, Thirty-Four, 

Thirty-Five and Thirty-Six. 

64

COUNT TWENTY-FOUR 


On or about May 12, 2011, in the State of Colorado, Anthony Embry unlawfully, 



The offense alleged in Count Twenty-Four was committed in the following manner: 

On May 12, 2011, Anthony Embry sold 3.6 grams of cocaine to an undercover 

officer at 3035 W. Prospect Road in Fort Collins. 

COUNT TWENTY-FIVE 


On or about May 26, 2011, in the State of Colorado, Quentin Wallace unlawfully, 



COUNT TWENTY-SIX 


On or about May 26, 2011, in the State of Colorado, Anthony Embry unlawfully, 



The offenses alleged in Count Twenty-Five and Twenty-Six were committed in the 


On May 26, 2011, Quentin Wallace delivered a quantity of cocaine to Anthony 

Embry at 3035 W. Prospect Road in Fort Collins. Then, Anthony Embry sold 4.3 

grams of cocaine to an undercover officer. 

COUNT TWENTY-SEVEN 


On or about June 3, 2011, in the State of Colorado, Andre Isler unlawfully, 



65

COUNT TWENTY-EIGHT 


On or about June 3, 2011, in the State of Colorado, Anthony Embry unlawfully, 



The offenses alleged in Counts Twenty-Seven and Twenty-EIght were committed in 


On June 3, 2011, Andre Isler delivered a quantity of cocaine to Anthony Embry at 

1957 Pecan Street, Fort Collins. Then, Anthony Embry sold 7.7 grams of cocaine to 

an undercover officer at 3035 W. Prospect Road in Fort Collins. 

COUNT TWENTY-NINE 


On or about June 24, 2011, in the State of Colorado, Ronald Munguia-Martin 



COUNT THIRTY 


On or about June 24, 2011, in the State of Colorado, Gerald Lamaster unlawfully, 




COUNT THIRTY-ONE 

Possession of a Controlled Substance – Schedule II, (F6) 

On or about June 24, 2011, in the State of Colorado, Gerald Lamaster unlawfully, 

feloniously, and knowingly possessed a material, compound, mixture, or preparation 

that contained oxycodone, a schedule II controlled substance, in violation of section 

18-18-403.5(1),(2)(a)(I), C.R.S. 

The offenses alleged in Counts Twenty-Nine through Thirty-One were committed in 


On June 24, 2011, Ronald Munguia-Martin sold a quantity of cocaine to Gerald 

Lamaster in the parking lot of Safeway at 860 Cleveland Ave. in Loveland. Shortly 

thereafter, law enforcement officers recovered a quarter-ounce of cocaine and 14 

Oxycodone pills from Gerald Lamaster. 

66

COUNT THIRTY-TWO 





405(1),(2)(a)(I)(A), C.R.S. 

The offense alleged in Count Thirty-Two was committed in the manner described in 

Predicate Acts Thirty-Eight and Thirty-Nine. 

COUNT THIRTY-THREE 


On or about August 24, 2011, in the State of Colorado, Anthony Harvey and Carl 

Hayes unlawfully, feloniously, and knowingly conspired with each other, to sell or 


405(1),(2)(a)(I)(A), C.R.S. 

The offense alleged in Count Thirty-Three was committed in the manner described 

in Predicate Acts Forty and Forty-One. 

COUNT THIRTY-FOUR 


On or about August 24, 2011, in the State of Colorado, Anthony Harvey and Kamal 

Patterson unlawfully, feloniously, and knowingly conspired with each other, 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 offense alleged in Count Thirty-Four was committed in the manner described in 

Predicate Acts Forty-Two and Forty-Three. 

COUNT THIRTY-FIVE 





405(1),(2)(a)(I)(A), C.R.S. 

The offense alleged in Count Thirty-Five was committed in the manner described in 

Predicate Acts Forty-Four and Forty-Five. 

67

COUNT THIRTY-SIX 

Possession of a Dangerous Weapon, (F5) 

On or about September 1, 2011, in the State of Colorado, Jerome Nelson 

unlawfully, feloniously, and knowingly possessed a dangerous weapon, namely: a 

Winchester 12-gauge pump short shotgun; in violation of section 18-12-102(3), 

C.R.S. 

The offense alleged in Count Thirty-Six was committed in the following manner: 

On or about September 1, 2011, Jerome Nelson possessed a Winchester short 

shotgun that he ultimately concealed in the frame of a vehicle located at 200 

Commerce Drive, Unit #G, Fort Collins, CO. 

COUNT THIRTY-SEVEN 





18-18-405(1),(2)(a)(I)(A), C.R.S. 

The offense alleged in Count Thirty-Seven was committed in the manner described 

in Predicate Acts Forty-Six and Forty-Seven. 

COUNT THIRTY-EIGHT 





COUNT THIRTY-NINE 

Possession of a Controlled Substance – Schedule II, (F6) 

On or about September 3, 2011, in the State of Colorado, Matthew Bekkerus 

unlawfully, feloniously, and knowingly possessed a material, compound, mixture, or 

preparation that contained cocaine, a schedule II controlled substance, in violation of 

section 18-18-403.5(1),(2)(a)(I), C.R.S. 

The offenses alleged in Counts Thirty-Eight and Thirty-Nine were committed in the 

manner described in Predicate Act Forty-Eight. 

68

COUNT FORTY 





18-18-405(1),(2)(a)(I)(A), C.R.S. 

The offense alleged in Count Forty was committed in the manner described in 

Predicate Acts Forty-Nine and Fifty. 

COUNT FORTY-ONE 



Colorado, Anthony Harvey and Maria Moreno unlawfully, feloniously, and 



The offense alleged in Count Forty-One was committed in the manner described in 

Predicate Acts Fifty-One and Fifty-Two. 

COUNT FORTY-TWO 



Jerome Nelson unlawfully, feloniously, and knowingly conspired with each other, to 


18-18-405(1),(2)(a)(I)(A), C.R.S. 

The offense alleged in Count Forty-Two was committed in the manner described in 

Predicate Acts Fifty-Three and Fifty-Four 

COUNT FORTY-THREE 



Quentin Wallace unlawfully, feloniously, and knowingly conspired with each other, 


18-18-405(1),(2)(a)(I)(A), C.R.S. 

69

COUNT FORTY-FOUR 





COUNT FORTY-FIVE 


On or about September 7, 2011, in the State of Colorado, Quentin Wallace 




The offenses alleged in Counts Forty-Three through Forty-Five were committed in 

the manner described in Predicate Acts Fifty-Five through Fifty-Seven. 

COUNT FORTY-SIX 





18-18-405(1),(2)(a)(I)(A), C.R.S. 

The offense alleged in Count Forty-Six was committed in the manner described in 

Predicate Acts Fifty-Eight and Fifty-Nine. 

COUNT FORTY-SEVEN 



Michael McCain unlawfully, feloniously, and knowingly conspired with each other, to 


18-18-405(1),(2)(a)(I)(A), C.R.S. 

The offense alleged in Count Forty-Seven was committed in the manner described 

in Predicate Acts Sixty and Sixty-One. 

70

COUNT FORTY-EIGHT 





18-18-405(1),(2)(a)(I)(A), C.R.S. 

The offense alleged in Count Forty-Eight was committed in the manner described in 

Predicate Acts Sixty-Two and Sixty-Three. 

COUNT FORTY-NINE 

Distribution of Marijuana – Between 5 and 100 Pounds, (F4) 


and Anthony Harvey, unlawfully, feloniously, and knowingly sold or distributed, or 

attempted to sell or distribute, marijuana or marijuana concentrate. 


of marijuana; in violation of section 18-18-406(6)(b)(I), (III)(B), C.R.S 

COUNT FIFTY 



On or about September 20, 2011, in the State of Colorado, Brian Butler, unlawfully, 

feloniously, and knowingly possessed or attempted to possess, with intent to sell or 

distribute marijuana or marijuana concentrate. 



The offenses alleged in Counts Forty-Nine and Fifty were committed in the manner 

described in Predicate Act Sixty-Four. 

COUNT FIFTY-ONE 


25 to 450 Grams, (F3) 




substance. 

71





COUNT FIFTY-TWO 




compound, mixture, or preparation that contained methamphetamine, 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 Fity-One and Fifty-Two were committed in the 

manner described in Predicate Acts Sixty-Five and Sixty-Six. 

COUNT FIFTY-THREE 






The offense alleged in Count Fifty-Three was committed in the manner described in 

Predicate Act Sixty-Seven. 

COUNT FIFTY-FOUR 



On or about September 30, 2011, in the State of Colorado, Abdon Loya-Sanchez, 

unlawfully, feloniously, and knowingly possessed or attempted to possess, with 

intent to sell or distribute marijuana or marijuana concentrate. 



The offense alleged in Count Fifty-Four was committed in the manner described in 

Predicate Act Sixty-Eight. 

72

COUNT FIFTY-FIVE 


25 to 450 Grams, (F3) 

On or about September 29, 2011, in the State of Colorado, Tony Romero 







The offense alleged in Count Fifty-Five was committed in the following manner: 

On or about September 29, 2011, Tony Romero delivered approximately 477.4 

grams of cocaine to Alexander Oram at Anthony Harvey’s shop located at 204 

Commerce Drive, Unit D/E, Fort Collins, CO. 

COUNT FIFTY-SIX 


450 to 1000 Grams, (F3) 




substance. 





The offense alleged in Count Fifty-Six was committed in the manner described in 

Predicate Act Sixty-Nine. 

COUNT FIFTY-SEVEN 

Special Offender – Deadly Weapon 


committed the felony offense charged in Count Fifty-Six and used, displayed, 

possessed on his person or within his immediate reach, a deadly weapon, namely: a 

Kel-Tec .380 caliber pistol; in violation of section 18-18-407(1)(f)(I), C.R.S. 

The offense charged in Count Fifty-Seven was committed in the following manner: 

73

On September 30, 2011, law enforcement officers recovered a Kel-Tec .380 caliber 

pistol within close proximity of 477.4 grams of cocaine from the residence of 

Alexander Oram at 1025 Cunningham, #C-6, Fort Collins, CO. 

COUNT FIFTY-EIGHT 


450 to 1000 Grams, (F3) 




substance. 





The offense alleged in Count Fifty-Eight was committed in the manner described in 

Predicate Act Seventy. 

COUNT FIFTY-NINE 



committed the felony offense charged in Count Fifty-Eight and used, displayed, 

possessed on his person or within his immediate reach, a deadly weapon, namely: a 

.40 caliber pistol; in violation of section 18-18-407(1)(f)(I), C.R.S. 

The offense charged in Count Fifty-Nine was committed in the following manner: 

On September 30, 2011, law enforcement officers recovered a .40 caliber pistol from 

Francisco Valencia’s bedroom in his residence at 1007 Whalers Way, Fort Collins, 

CO, within close proximity of 686 grams of cocaine that Valencia possessed in order 

to distribute to his customers. 

74

COUNT SIXTY 

Possession of a Weapon by a Previous Offender (F6) 

On or about September 30, 2011, in the State of Colorado, Bernardino Mendoza 

unlawfully, feloniously, and knowingly possessed, used, or carried upon [his] person 

a firearm or other weapon, namely: Tech 9 handgun, and Bernardino Mendoza was 

previously convicted of a felony, namely: First Degree Criminal Trespass, on July 

15, 2008; in violation of section 18-12-108(1), C.R.S. 

The offense alleged in Count Sixty was committed in the following manner: 

On September 30, 2011, law enforcement officers recovered a Tech 9 handgun from 

Bernardino Mendoza’s bedroom in his residence at 1007 Whalers Way, Fort Collins, 

CO. Mendoza was previously convicted of a felony, namely: First Degree Criminal 

Trespass, on July 15, 2008, in Larimer County Case No. 08 CR 867. 

COUNT SIXTY-ONE 

Cultivation of Marijuana, (F4) 

On or about September 30, 2011, in the State of Colorado, Daniel Galvan, 

unlawfully, knowingly, and feloniously cultivated, grew, produced, processed, or 

manufactured marijuana or marijuana concentrate, or allowed marijuana or 

marijuana concentrate to be cultivated, grown, produced, processed, or 

manufactured on land owned, occupied, or controlled by the defendant; in violation 

of section 18-18-406(7.5)(c), C.R.S. 

The offense alleged in Count Sixty-One was committed in the following manner: 

On September 30, 2011, law enforcement officers located a marijuana grow 

consisting of 58 plants in the residence of Daniel Galvan at 2430 Leghorn, Fort 

Collins, CO. 

COUNT SIXTY-TWO 


On or about June 23, 2011, in the State of Colorado, Andre Isler and Anthony 

Embry unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule 

II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. 

The offense alleged in Count Sixty-Two was committed in the following manner: 

On June 23, 2011, Andre Isler delivered a quantity of cocaine to Anthony who then 

sold 7.6 grams of cocaine to an undercover officer at 3035 W. Prospect Road in Fort 

Collins. 

75

COUNT SIXTY-THREE 



Tony Romero unlawfully, feloniously, and knowingly conspired with each other, to 


18-18-405(1),(2)(a)(I)(A), C.R.S. 

COUNT SIXTY-FOUR 




sell or distribute cocaine and oxycodone, both schedule II controlled substances; in 


The offenses charged in Counts Sixty-Three and Sixty-Four were committed in the 

manner described in Predicate Acts Seventy-One through Seventy-Three. 

COUNT SIXTY-FIVE 



and Adrian Hernandez unlawfully, feloniously, and knowingly conspired with each 



COUNT SIXTY-SIX 


25 to 450 Grams, (F3) 








76

COUNT SIXTY-SEVEN 

Possession with Intent to Distribute a Controlled Substance – Schedule II – 

25 to 450 Grams, (F3) 

On or about September 24, 2011, in the State of Colorado, Adrian Hernandez 







The offenses charged in Counts Sixty-Five through Sixty-Seven were committed in 

the manner described in Predicate Acts Seventy-Four through Seventy-Seven. 

COUNT SIXTY-EIGHT 






The offense charged in Count Sixty-Eight was committed in the manner described in 

Predicate Acts Seventy-Eight and Seventy-Nine. 

COUNT SIXTY-NINE 


25 to 450 Grams, (F3) 

On or about May 3, 2011, in the State of Colorado, Alan Johnson unlawfully, 


substance. 





The offense alleged in Count Sixty-Nine was committed in the manner described in 

Predicate Acts Eighty and Eighty-One. 

77

COUNT SEVENTY 


25 to 450 Grams, (F3) 

On or about June 17, 2011, in the State of Colorado, Alan Johnson unlawfully, 


substance. 





The offense alleged in Count Seventy was committed in the manner described in 

Predicate Acts Eighty-Two and Eighty-Three. 

COUNT SEVENTY-ONE 





COUNT SEVENTY-TWO 


On or about August 3, 2011, in the State of Colorado, Jimmie Joe Montgomery 

unlawfully, feloniously, and knowingly sold or distributed methamphetamine, a 


C.R.S. 

The offenses alleged in Counts Seventy-One and Seventy-Two were committed in 

the manner described in Predicate Acts Eighty-Four and Eighty-Five. 

COUNT SEVENTY-THREE 



Alan Johnson and Kenneth West unlawfully, feloniously, and knowingly conspired 



78

COUNT SEVENTY-FOUR 



Alan Johnson unlawfully, feloniously, and knowingly sold or distributed cocaine, a 


C.R.S. 

COUNT SEVENTY-FIVE 



Kenneth West unlawfully, feloniously, and knowingly possessed with intent to 


schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), 

C.R.S. 

COUNT SEVENTY-SIX 



Alan Johnson and Mark Fraleigh unlawfully, feloniously, and knowingly conspired 



COUNT SEVENTY-SEVEN 



Alan Johnson and Mitchell Morris unlawfully, feloniously, and knowingly conspired 



The offenses alleged in Counts Seventy-Three through Seventy-Seven were 

committed in the manner described in Predicate Acts Eighty-Six through Ninety- 

One. 

79

COUNT SEVENTY-EIGHT 






The offense alleged in Count Seventy-Eight was committed in the manner described 

in Predicate Acts Ninety-Two and Ninety-Three. 

COUNT SEVENTY-NINE 


On or about August 14, 2011, in the State of Colorado, Alan Johnson and Shawn 

Blea unlawfully, feloniously, and knowingly conspired with each other, to sell or 



The offense alleged in Count Seventy-Nine was committed in the manner described 

in Predicate Acts Ninety-Four and Ninety-Five. 

COUNT EIGHTY 





405(1),(2)(a)(I)(A), C.R.S. 

The offense alleged in Count Eighty was committed in the manner described in 

Predicate Acts Ninety-Six and Ninety-Seven. 

COUNT EIGHTY-ONE 



Joe Montgomery unlawfully, feloniously, and knowingly conspired with each other, 

to sell or distribute methamphetamine, a schedule II controlled substance; in 


The offense alleged Count Eighty-One was committed in the manner described in 

Predicate Acts Ninety-Eight and Ninety-Nine. 

80

COUNT EIGHTY-TWO 






The offense alleged in County Eighty-Two was committed in the manner described 

in Predicate Acts One Hundred and One Hundred-One. 

COUNT EIGHTY-THREE 






The offense alleged in Count Eighty-Three was committed in the manner described 

in Predicate Acts One Hundred-Two and One Hundred-Three. 

COUNT EIGHTY-FOUR 






COUNT EIGHTY-FIVE 


On or about August 24, 2011, in the State of Colorado, Horacio Bugarin unlawfully, 



81

COUNT EIGHTY-SIX 




mixture, or preparation that contained methamphetamine, a schedule II controlled 


The offenses alleged in Counts Eighty-Four through Eighty-Six were committed in 

the manner described in Predicate Acts One Hundred-Four though One Hundred- 

Seven. 

COUNT EIGHTY-SEVEN 





405(1),(2)(a)(I)(A), C.R.S. 

COUNT EIGHTY-EIGHT 





COUNT EIGHTY-NINE 






The offenses alleged in Counts Eighty-Seven through Eighty-Nine were committed 

in the manner described in Predicate Acts One Hundred-Eight through One 

Hundred-Eleven. 

82

COUNT NINETY 


On or about September 19, 2011, in the State of Colorado, Alan Johnson and 

Anthony Harvey unlawfully, feloniously, and knowingly conspired with each other, 


18-18-405(1),(2)(a)(I)(A), C.R.S. 

The offense alleged in Count Ninety was committed in the manner described in 

Predicate Acts One Hundred-Twelve and One Hundred-Thirteen. 

COUNT NINETY-ONE 

Distribution of a Schedule II Controlled Substance – 

450 to 1000 Grams, (F3) 

On or about September 29, 2011, in the State of Colorado, Alan Johnson 







The offense charged in Count Ninety-One was committed in the manner described 

in Predicate Act One Hundred-Fourteen. 

COUNT NINETY-TWO 




unlawfully, feloniously, and knowingly possessed with intent to distribute 

methamphetamine, a schedule II controlled substance. 





83

COUNT NINETY-THREE 










The offenses charged in Counts Ninety-Two and Ninety-Three was committed in the 

manner described in Predicate Acts One Hundred-Fifteen and One Hundred- 

Sixteen. 

COUNT NINETY-FOUR 



committed the felony offenses charged in Counts Thirty and Thirty-One and used, 

displayed, possessed on his person or within his immediate reach, a deadly 

weapon, namely: a Glock 27 .40 caliber pistol; in violation of section 18-18- 

407(1)(f)(I), C.R.S. 

The offense charged in Count Ninety-Four was committed in the following manner: 

On September 30, 2011, law enforcement officers recovered a .40 caliber pistol in 

close proximity to a large quantity of methamphetamine and cocaine from Horacio 

Bugarin’s residence at Juniper Place, Loveland, CO. 

COUNT NINETY-FIVE 






The offense charged in Count Ninety-Five was committed in the manner described 

in Predicate Acts One Hundred-Seventeen and One Hundred-Eighteen. 

84

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

You also want an ePaper? Increase the reach of your titles

Delete template?

Save as template?