Dark Angel Indictment 2

Case 1:12-cr-00242-WJM Document 1 Filed 05/23/12 USDC Colorado Page 1 of 15
IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Criminal Action No. 12-cr-00242 WJM
UNITED STATES OF AMERICA, Plaintiff, v. 1. 2. 3. REYNA MENDOZA-HARO, a/k/a Reyna Mendoza, Reyna, Reyna Gonzalez, Amanda Gonzalez, ARNALDO ALVAREZ-GONZALEZ, a/k/a Indio, Monra, JAIME MORENO-LOPEZ, a/k/a El Guapo, Jaime Lopez, Jaime Moreno, Adrian Lopez-Villeda, Alberto Torres-Trejo RICKY HENRY CISNEROS, a/k/a Ricky Cisneros, IVAN GOMEZ-AVILA, a/k/a Ivan Avila, Ivan Flores, Jose Gomez, SHANA LOUISE CLAYBOURN, a/k/a Melissa Renee Rodriguez, Becky Smith, Shana Claybourn, Tiffany Claybourn, Shana Contreras, Shana Louise Contreras-Pineda, CRIS ANTHONY SANDOVAL, a/k/a Cris Sandoval, Christopher Sandoval, TODD JOSEPH TRUJILLO, a/k/a Todd Trujillo, Tracy Petterson, Todd Jose Trujillo, KENNIE RAY SNYDER, a/k/a Kennie Snyder, CHRISTINA ROSE MALMGREN, a/k/a Christina Malmgren, and DESIREE ROSE CEBALLES, a/k/a Desiree Rosa Allen, Desiree Rose Lucy, Desiree Ceballes, Desiree Rose Martinez, Defendants.
4. 5. 6.
7. 8. 9. 10. 11.
______________________________________________________________________________ INDICTMENT 21 U.S.C. 846 21 U.S.C. 841(a)(1), 841(b)(1)(A)(viii), 841(b)(1)(B)(viii), and 841(b)(1)(C) 21 U.S.C. 843(b) 18 U.S.C. 2 ______________________________________________________________________________ THE GRAND JURY CHARGES: COUNT ONE From on or about October 21, 2010, through on or about May 23, 2012, both dates being approximate and inclusive, within the State and District of Colorado and elsewhere, the defendants; REYNA MENDOZA-HARO, ARNALDO ALVAREZ-GONZALEZ, JAIME MORENO-LOPEZ, RICKY HENRY CISNEROS, IVAN GOMEZ-AVILA, SHANA LOUISE CLAYBOURN, CRIS ANTHONY SANDOVAL, TODD JOSEPH TRUJILLO, KENNIE RAY SNYDER, CHRISTINA ROSE MALMGREN, DESIREE ROSE CEBALLES, did knowingly and intentionally conspire with each other and with others known and unknown to the Grand Jury, to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. All in violation of Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii). 2
COUNT TWO On or about January 23, 2011, within the State and District of Colorado, the defendant, REYNA MENDOZA-HARO did knowingly and intentionally distribute and possess with the intent to distribute 5 grams or more of actual of methamphetamine, a Schedule II controlled substance, and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 21, United States Code, Sections 841(a)(1), and 841(b)(1)(B)(viii) and Title 18, United States Code, Section 2. COUNT THREE On or about July 8, 2011, within the State and District of Colorado, the defendant, KENNIE RAY SNYDER did knowingly and intentionally distribute and possess with the intent to distribute 5 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 21, United States Code, Sections 841(a)(1), and 841(b)(1)(C) and Title 18, United States Code, Section 2.
COUNT FOUR On or about July 14, 2011, within the State and District of Colorado, the defendants, IVAN GOMEZ-AVILA and SHANA LOUISE CLAYBOURN, did knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A)(viii) and Title 18, United States Code, Section 2. COUNT FIVE On or about August 3, 2011, within the State and District of Colorado, the defendant, TODD JOSEPH TRUJILLO did knowingly and intentionally distribute and possess with the intent to distribute 5 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. All in violation of Title 21, United States Code, Sections 841(a)(1), and 841(b)(1)(C) and Title 18, United States Code, Section 2.
COUNT SIX On or about May 19, 2012, within the State and District of Colorado, the defendant, REYNA MENDOZA-HARO did knowingly and intentionally distribute and possess with the intent to distribute 5 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 50 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. All in violation of Title 21, United States Code, Sections 841(a)(1), and 841(b)(1)(B)(viii). COUNT SEVEN On or about July 5, 2011, within the State and District of Colorado, the defendant, JAIME MORENO-LOPEZ, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this Indictment. All in violation of Title 21, United States Code, Section 843(b).
COUNT EIGHT On or about July 5, 2011, within the State and District of Colorado, the defendant, CHRISTINA ROSE MALMGREN, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this Indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT NINE On or about July 8, 2011, within the State and District of Colorado, the defendant, KENNIE RAY SNYDER, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this Indictment. All in violation of Title 21, United States Code, Section 843(b).
COUNT TEN On or about July 10, 2011, within the State and District of Colorado, the defendant, SHANA LOUISE CLAYBOURN, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this Indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT ELEVEN On or about July 12, 2011, within the State and District of Colorado, the defendant, SHANA LOUISE CLAYBOURN, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this Indictment. All in violation of Title 21, United States Code, Section 843(b).
COUNT TWELVE On or about July 12, 2011, within the State and District of Colorado, the defendant, REYNA MENDOZA-HARO, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this Indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT THIRTEEN On or about July 13, 2011, within the State and District of Colorado, the defendant, CRIS ANTHONY SANDOVAL, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this Indictment. All in violation of Title 21, United States Code, Section 843(b).
COUNT FOURTEEN On or about July 16, 2011, within the State and District of Colorado, the defendant, REYNA MENDOZA-HARO, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this Indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT FIFTEEN On or about July 17, 2011, within the State and District of Colorado, the defendant, CRIS ANTHONY SANDOVAL, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this Indictment. All in violation of Title 21, United States Code, Section 843(b).
COUNT SIXTEEN On or about July 22, 2011, within the State and District of Colorado, the defendant, JAIME MORENO-LOPEZ, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this Indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT SEVENTEEN On or about July 24, 2011, within the State and District of Colorado, the defendant, REYNA MENDOZA-HARO and ARNALDO ALVAREZ-GONZALEZ, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this Indictment. All in violation of Title 21, United States Code, Section 843(b).
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COUNT EIGHTEEN On or about July 25, 2011, within the State and District of Colorado, the defendant, CHRISTINA ROSE MALMGREN, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this Indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT NINETEEN On or about July 27, 2011, within the State and District of Colorado, the defendant, TODD JOSEPH TRUJILLO, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this Indictment. All in violation of Title 21, United States Code, Section 843(b).
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COUNT TWENTY On or about July 28, 2011, within the State and District of Colorado, the defendants, REYNA MENDOZA-HARO and DESIREE ROSE CEBALLES, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this Indictment. All in violation of Title 21, United States Code, Section 843(b). COUNT TWENTY-ONE On or about July 28, 2011, within the State and District of Colorado, the defendants, REYNA MENDOZA-HARO and ARNALDO ALVAREZ-GONZALEZ, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable
amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this Indictment. All in violation of Title 21, United States Code, Section 843(b).
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COUNT TWENTY-TWO On or about August 5, 2011, within the State and District of Colorado, the defendants, REYNA MENDOZA-HARO and DESIREE ROSE CEBALLES, did knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of the offense of conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this Indictment. All in violation of Title 21, United States Code, Section 843(b). FORFEITURE ALLEGATION The allegations contained in Counts One through Twenty-two of this Indictment are hereby re-alleged and incorporated by reference for the purpose of alleging forfeiture pursuant to the provisions of 21 U.S.C. 853. Upon conviction of the violations alleged in Counts One through Twenty-two of this Indictment involving violations of 21 U.S.C. 846, 841(a)(1), 841(b)(1)(A)(ii)(II), and 841(b)(1)(B)(ii)(II), 21 U.S.C. 843(b), the defendants; REYNA MENDOZA-HARO, ARNALDO ALVAREZ-GONZALEZ, JAIME MORENO-LOPEZ, RICKY HENRY CISNEROS, IVAN GOMEZ-AVILA, SHANA LOUISE CLAYBOURN, CRIS ANTHONY SANDOVAL, TODD JOSEPH TRUJILLO, KENNIE RAY SNYDER, CHRISTINA ROSE MALMGREN, and DESIREE ROSE CEBALLES, shall forfeit to the United States, pursuant to Title 21, United States Code, Section 853 any and all of the defendants right, title and interest in all property constituting and derived from any proceeds obtained directly and indirectly as a 13
result of such offense, and in all property used, or intended to be used, in any manner or part, to commit, or to facilitate the commission of such offense, including, but not limited to a money judgment in the amount of proceeds obtained by the conspiracy and by the defendants. If any of the property as a result of any act or omission of the defendants: a) b) c) d) e) cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with, a third party; has been placed beyond the jurisdiction of the Court; has been substantially diminished in value; or has been commingled with other property which cannot be subdivided without difficulty;
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to seek forfeiture of any other property of said defendants up to the value of the forfeitable property.
A TRUE BILL:
Ink signature on file in the Clerks Office__ FOREPERSON
APPROVED: JOHN F. WALSH United States Attorney
BY:
__s/ Zachary Phillips____________ ZACHARY PHILLIPS Assistant United States Attorney U.S. Attorneys Office 1225 17th Street, Suite 700 Denver, CO. 80202 Telephone (303) 454-0118 Fax (303) 454-0401 Zachary.phillips@usdoj.gov Attorney for Government 14
BY:
Kasandra R. Carleton KASANDRA R. CARLETON Assistant U.S. Attorney U.S. Attorneys Office 1225 17th St., Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0100 Fax: (303) 454-0401 e-mail: Kasandra.Carleton@usdoj.gov Attorney for the Government
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Case 1:12-cr-00242-WJM Document 1-1 Filed 05/23/12 USDC Colorado Page 1 of 3
DEFENDANT 1:
REYNA MENDOZA-HARO, a/k/a Reyna Mendoza Reyna Reyna Gonzalez Amanda Gonzalez 1980 or 1981 Corcoran, CA YES T NO
YOB: ADDRESS:
COMPLAINT FILED?
IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. COUNT TWO: Title 21, United States Code, Sections 841(a)(1), and 841(b)(1)(B)(viii), and Title 18, United States Code, Section 2 - knowingly and intentionally distribute and possess with the intent to distribute 5 grams or more of methamphetamine (actual), a Schedule II controlled substance, and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. COUNT SIX: Title 21, United States Code, Sections 841(a)(1), and 841(b)(1)(B)(viii) - knowingly and intentionally distribute and possess with the intent to distribute 5 grams or more of methamphetamine (actual), a Schedule II controlled substance, and 50 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. COUNTS TWELVE, FOURTEEN, SEVENTEEN, TWENTY, TWENTYONE, and TWENTY-TWO: Title 21, United States Code, Section 843(b) knowingly and intentionally use a communication facility, the telephone, in committing and in causing and facilitating the commission of a felony drug offense. LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO YES T NO
PENALTY:
COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. COUNT TWO and SIX: NLT 5 years, NMT 40 years imprisonment, $5 million fine, or both; NLT 4 years supervised release, $100 Special Assessment Fee COUNTS TWELVE, FOURTEEN, SEVENTEEN, TWENTY, TWENTYONE, and TWENTY-TWO: NMT 4 years imprisonment, $250,000.00 fine, or both; NMT 1 year supervised release; and a $100 Special Assessment Fee (per count).
AGENT:
TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys 5 days or more
AUTHORIZED BY:
ESTIMATED TIME OF TRIAL:
THE GOVERNMENT will seek detention in this case The statutory presumption of detention is applicable to this defendant. OCDETF CASE: T Yes No
DEFENDANT 2:
ARNALDO ALVAREZ-GONZALEZ, a/k/a Indio Monra 1978
YOB: ADDRESS:
COMPLAINT FILED?
YES
NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. COUNTS SEVENTEEN and TWENTY-ONE: Title 21, United States Code, Section 843(b) - knowingly and intentionally use a communication facility, the telephone, in committing and in causing and facilitating the commission of a felony drug offense. LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. COUNTS SEVENTEEN and TWENTY-ONE: NMT 4 years imprisonment, $250,000.00 fine, or both; NMT 1 year supervised release; and a $100 Special Assessment Fee (per count). AGENT: TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys YES T NO
AUTHORIZED BY:
5 days or more
DEFENDANT 3:
JAIME MORENO-LOPEZ, a/k/a El Guapo Jaime Lopez Jaime Moreno Adrian Lopez-Villeda Alberto Torres-Trejo 1981 or 1980
YOB: ADDRESS:
COMPLAINT FILED?
YES
NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance COUNTS SEVEN and SIXTEEN: Title 21, United States Code, Section 843(b) - knowingly and intentionally use a communication facility, the telephone, in committing and in causing and facilitating the commission of a felony drug offense. LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. COUNTS SEVEN and SIXTEEN: NMT 4 years imprisonment, $250,000.00 fine, or both; NMT 1 year supervised release; and a $100 Special Assessment Fee (per count). YES T NO
AGENT:
TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys 5 days or more
AUTHORIZED BY:
DEFENDANT 4:
RICKY HENRY CISNEROS, a/k/a Ricky Cisneros 1974 Denver, Colorado YES T NO
YOB: ADDRESS:
COMPLAINT FILED?
IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. YES T NO
LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys 5 days or more
AGENT:
AUTHORIZED BY:
DEFENDANT 5:
IVAN GOMEZ-AVILA, a/k/a Ivan Avila Ivan Flores Jose Gomez 1981 or 1980 Denver, Colorado YES T NO
YOB: ADDRESS:
COMPLAINT FILED?
IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance COUNT FOUR: Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A)(viii) and Title 18, United States Code, Section 2 - knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. COUNT FOUR: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee AGENT: TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys YES T NO
AUTHORIZED BY:
5 days or more
DEFENDANT 7:
CRIS ANTHONY SANDOVAL, a/k/a "Cris Sandoval" "Christopher Sandoval" 1959
YOB: ADDRESS:
COMPLAINT FILED?
YES
NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. COUNTS THIRTEEN and FIFTEEN: Title 21, United States Code, Section 843(b) - knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of a felony drug offense. LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. COUNTS THIRTEEN and FIFTEEN: NMT 4 years imprisonment, $250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00 Special Assessment Fee (per count) AGENT: TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys YES T NO
AUTHORIZED BY:
5 days or more
DEFENDANT 8:
TODD JOSEPH TRUJILLO, a/k/a "Todd Trujillo" "Tracy Petterson" "Todd Jose Trujillo" 1967 Westminster, Colorado YES T NO
YOB: ADDRESS:
COMPLAINT FILED?
IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. COUNT FIVE: Title 21, United States Code, Sections 841(a)(1), and 841(b)(1)(C) and Title 18, United States Code, Section 2 - knowingly and intentionally distribute and possess with the intent to distribute 5 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. COUNT NINETEEN: Title 21, United States Code, Section 843(b) knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of a felony drug offense. LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. YES T NO
COUNT FIVE: NMT 20 years imprisonment, $1 million fine, or both; NLT 3 years supervised release, $100 Special Assessment Fee COUNT NINETEEN: NMT 4 years imprisonment, $250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00 Special Assessment Fee. AGENT: TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys 5 days or more
AUTHORIZED BY:
DEFENDANT 9:
KENNIE RAY SNYDER, a/k/a "Kennie Snyder" 1966 Lakewood, Colorado YES T NO
YOB: ADDRESS:
COMPLAINT FILED?
IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. COUNT THREE: Title 21, United States Code, Sections 841(a)(1), and 841(b)(1)(C) and Title 18, United States Code, Section 2 - knowingly and intentionally distribute and possess with the intent to distribute 5 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance, and did knowingly and intentionally aid, abet, counsel, command, induce or procure the same. COUNT NINE: Title 21, United States Code, Section 843(b) knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of a felony drug offense. LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. COUNT THREE: NMT 20 years imprisonment, $1 million fine, or both; NLT 3 years supervised release, $100 Special Assessment Fee. COUNT NINE: NMT 4 years imprisonment, $250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00 Special Assessment Fee. TFO Leonard A. Huskey YES T NO
AGENT:
Drug Enforcement Administration AUTHORIZED BY: Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys 5 days or more
DEFENDANT 10:
CHRISTINA ROSE MALMGREN, a/k/a "Christina Malmgren" 1987
YOB: ADDRESS:
COMPLAINT FILED?
YES
NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. COUNTS EIGHT and EIGHTEEN: Title 21, United States Code, Section 843(b) - knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of a felony drug offense. LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. COUNTS EIGHT and EIGHTEEN: NMT 4 years imprisonment, $250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00 Special Assessment Fee (per count) AGENT: TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys YES T NO
AUTHORIZED BY:
5 days or more
DEFENDANT 11:
DESIREE ROSE CEBALLES, a/k/a Desiree Rosa Allen Desiree Rose Lucy Desiree Ceballes Desiree Rose Martinez 1985
YOB: ADDRESS:
COMPLAINT FILED?
YES
NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER: IF NO, PROCEED TO OFFENSE SECTION HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? IF NO, A NEW WARRANT IS REQUIRED OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and 841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance containing a detectable amount of methamphetamine, a Schedule II controlled substance. COUNTS TWENTY and TWENTY-TWO: Title 21, United States Code, Section 843(b) - knowingly and intentionally use a communication facility, the telephone, in committing and in facilitating the commission of a felony drug offense. LOCATION OF OFFENSE (COUNTY/STATE): Denver County, Denver, CO PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both; NLT 5 years supervised release, $100 Special Assessment Fee. COUNTS TWENTY and TWENTY-TWO: NMT 4 years imprisonment, $250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00 Special Assessment Fee (per count). AGENT: TFO Leonard A. Huskey Drug Enforcement Administration Zachary H. Phillips Kasandra R. Carleton Assistant U.S. Attorneys 5 days or more YES T NO
AUTHORIZED BY:

Dark Angel Indictment 2

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Ink signature on file in the Clerks Office__ FOREPERSON

APPROVED: JOHN F. WALSH United States Attorney

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ESTIMATED TIME OF TRIAL:

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ARNALDO ALVAREZ-GONZALEZ, a/k/a Indio Monra 1978

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ESTIMATED TIME OF TRIAL:

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ESTIMATED TIME OF TRIAL:

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ESTIMATED TIME OF TRIAL:

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ESTIMATED TIME OF TRIAL:

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CRIS ANTHONY SANDOVAL, a/k/a "Cris Sandoval" "Christopher Sandoval" 1959

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ESTIMATED TIME OF TRIAL:

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ESTIMATED TIME OF TRIAL:

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ESTIMATED TIME OF TRIAL:

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CHRISTINA ROSE MALMGREN, a/k/a "Christina Malmgren" 1987

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ESTIMATED TIME OF TRIAL:

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ESTIMATED TIME OF TRIAL:

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