DISTRICT COURT, CITY AND COUNTY OF DENVER, COLORADO 1437 Bannock Street Denver, CO 80202 THE PEOPLE OF THE

STATE OF COLORADO, v. Robin Steinke, Jeffrey Clawson, Celeste Deherrera, Leticia Deherrera, Christopher Peterson, aka Christopher Petersen Christopher Gemeinhardt, Shawna Lawley, Joel Barr, Jacqueline Geist, Andrew Guerrero, Lisa Teitelbaum, Rhonda Scott, Sadie Grubbs, Daniel Burke, and Laurie Ann Larrew Defendants. JOHN W. SUTHERS, Attorney General ROBERT S. SHAPIRO, First Assistant Attorney General 1525 Sherman Street, 7th Floor Denver, CO 80203 303-866-5450 Registration Number: 26869

COURT USE ONLY

Case No.: GJ Case No.: 12CR0001 Ctrm: 209

COLORADO STATE GRAND JURY INDICTMENT Of the 2012-2013 term of the Denver District Court in the year 2013; the 2012-2013 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 VIOLATION OF THE COLORADO ORGANIZED CRIME CONTROL ACT PATTERN OF RACKETEERING - PARTICIPATION IN AN ENTERPRISE, C.R.S. 18-17-104(3) (F2) 37284 Jeffrey Clawson, Robin Steinke, Celeste Dehererra, Leticia Deherrera, Christopher Gemeinhardt, Shawna Lawley, Joel Barr, Jacqueline Geist and Andrew Guerrero COUNT TWO VIOLATION OF THE COLORADO ORGANIZED CRIME CONTROL ACT- CONSPIRACY, C.R.S. 18-17-104(4) (F2) 37285 Jeffrey Clawson, Robin Steinke, Celeste Dehererra, Leticia Deherrera, Christopher Peterson (aka Christopher Petersen), Christopher Gemeinhardt, Shawna Lawley, Joel Barr, Jacqueline Geist and Andrew Guerrero COUNT THREE DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18 405(1),(2)(a)(I)(A) (F3) 82021 Jeffrery Clawson COUNT FOUR CONTROLLED SUBSTANCE - FALSE APPLICATION OR REPORT, C.R.S. 18-18414(1)(r) (F4) 3345B Jeffrery Clawson COUNT FIVE MANUFACTURING OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 1818-405(1),(2)(a)(I)(A) (F3) 82021 Jeffrey Clawson

COUNT SIX DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18405(1),(2)(a)(I)(A) (F3) 82021 Jeffrey Clawson COUNT SEVEN CONTROLLED SUBSTANCE - FALSE APPLICATION OR REPORT, C.R.S. 18-18-414(1)(r) (F4) 3345B Jeffrey Clawson COUNT EIGHT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 1818-415(1)(a) (F6) 3541J Christopher Peterson COUNT NINE CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6) 3541JA Christopher Peterson and Shawna Lawley COUNT TEN DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18405(1),(2)(a)(I)(A) (F3) 82021 Jeffrey Clawson COUNT ELEVEN CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3) 82053 Jeffrey Clawson, Robin Steinke, Leticia DeHerrera, Celeste DeHerrera, Jacqueline Geist and Andrew Guerrero

COUNT TWELVE DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18405(1),(2)(a)(I)(A) (F3) 82021 Jeffrey Clawson COUNT THIRTEEN CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3) 82053 Jeffrey Clawson, Robin Steinke, Shawna Lawley and Jacqueline Geist COUNT FOURTEEN CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3) 82053 Jeffrey Clawson, Robin Steinke, Joel Barr and Jacqueline Geist COUNT FIFTEEN CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3) 82053 Jeffrey Clawson, Robin Steinke, Joel Barr and Shawna Lawley COUNT SIXTEEN POSSESSION OF FORGED INSTRUMENT, C.R.S. 18-5-105 (F6) Shawna Lawley COUNT SEVENTEEN CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3) 82053 Robin Steinke 10040

COUNT EIGHTEEN DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18405(1),(2)(a)(I)(A) (F3) 82021 Jeffrey Clawson COUNT NINETEEN CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3) 82053 Jeffrey Clawson, Robin Steinke and Joel Barr COUNT TWENTY DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18405(1),(2)(a)(I)(A) (F3) 82021 Robin Steinke COUNT TWENTY-ONE CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3) 82053 Jeffrey Clawson and Robin Steinke COUNT TWENTY-TWO POSSESSION OF FORGED INSTRUMENT, C.R.S. 18-5-105 (F6) Robin Steinke and Celeste Deherrera COUNT TWENTY-THREE OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 1818-415(1)(a) (F6) 3541J Jacqueline Geist and Andrew Guerrero 10040

COUNT TWENTY-FOUR CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3) 82053 Jacqueline Geist and Andrew Guerrero COUNT TWENTY-FIVE POSSESSION OF FORGED INSTRUMENT, C.R.S. 18-5-105 (F6) Jacqueline Geist and Andrew Guerrero COUNT TWENTY-SIX CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6) 3541JA Robin Steinke COUNT TWENTY-SEVEN CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6) 3541JA Robin Steinke COUNT TWENTY-EIGHT CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3) 82053 Robin Steinke, Leticia Deherrera, Christopher Gemeinhardt, Daniel Burke and/or Sadie Grubbs COUNT TWENTY-NINE CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6) 3541JA Robin Steinke, Leticia Deherrra and Christopher Gemeinhardt 10040

COUNT THIRTY CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3) 82053 Robin Steinke and Rhonda Scott COUNT THIRTY-ONE CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6) 3541JA Robin Steinke COUNT THIRTY-TWO CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3) 82053 Robin Steinke and Christopher Gemeinhardt COUNT THIRTY-THREE POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3) 82041 Robin Steinke and Christopher Gemeinhardt COUNT THIRTY-FOUR POSSESSION OF METHAMPHETAMINE-LESS THAN 2 GRAMS, C.R.S. 18-18403.5(1),(2), (b)(I) (F6) 8201B Robin Steinke and Christopher Gemeinhardt COUNT THIRTY-FIVE CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6) 3541JA Robin Steinke and Christopher Gemeinhardt

COUNT THIRTY-SIX POSSESSION OF FORGED INSTRUMENT, C.R.S. 18-5-105 (F6) Robin Steinke and Christopher Gemeinhardt COUNT THIRTY-SEVEN CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3) 82053 Robin Steinke, Jeffrey Clawson and Celeste Deherrera COUNT THIRTY-EIGHT POSSESSION OF A CONTROLLED SUBSTANCE-SCHEDULE II - 4 GRAMS OR LESS, C.R.S 18-18-403.5(1), (2)(a)(I) (F6) 82019 Lisa Teitelbaum COUNT THIRTY-NINE OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 1818-415(1)(a) (F6) 3541J Lisa Teitelbaum COUNT FORTY CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3) 82053 Robin Steinke and Laurie Ann Larrew COUNT FORTY-ONE CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6) 3541JA Robin Steinke and Laurie Ann Larrew 10040

COUNT FORTY-TWO POSSESSION OF FORGED INSTRUMENT, C.R.S. 18-5-105 (F6) 10040 Robin Steinke and Laurie Ann Larrew COUNT FORTY-THREE POSSESSION OF METHAMPHETAMINE-LESS THAN 2 GRAMS, C.R.S. 18-18403.5(1),(2), (b)(I) (F6) 8201B Robin Steinke

COUNT ONE 37284 VIOLATION OF THE COLORADO ORGANIZED CRIME CONTROL ACT PATTERN OF RACKETEERING - PARTICIPATION IN AN ENTERPRISE, C.R.S. 18-17-104(3) (F2) On and between April 1, 2010 and January 10, 2013 in the State of Colorado, Jeffrey Clawson, Robin Steinke, Celeste Dehererra, Leticia Deherrera, Christopher Gemeinhardt, Shawna Lawley, Joel Barr, Jacqueline Geist and/or Andrew Guerrero 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 37285 VIOLATION OF THE COLORADO ORGANIZED CRIME CONTROL ACT- CONSPIRACY, C.R.S. 18-17-104(4) (F2) On and between April 1, 2010 and January 10, 2013 in the State of Colorado, Jeffrey Clawson, Robin Steinke, Celeste Dehererra, Leticia Deherrera, Christopher Peterson (aka Christopher Petersen), Christopher Gemeinhardt, Shawna Lawley, Joel Barr, Jacqueline Geist and/or Andrew Guerrero did unlawfully, knowingly, and feloniously conspire and/or endeavor to conduct and participate, directly or indirectly, in an enterprise, through a pattern of racketeering activity in violation of C.R.S. 18-17104(4) and 18-17-104(3), C.R.S. The offenses alleged in Counts One and Two were committed in the following manner:

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The Enterprise

The enterprise alleged in these two counts was primarily, albeit not exclusively, a group of individuals who were associated in fact, although not operating as a legal entity. The enterprise included, but was not limited to, the following individuals and/or legal entities: Jeffrey Clawson, Robin Steinke, Celeste Deherrera, Leticia Deherrera, Christopher Peterson (aka Christopher Petersen), Shawna Lawley, Jacqueline Geist, Andrew Guerrero, Christopher Gemeinhardt, Lisa Teitelbaum, Rhonda Scott, Sadie Grubbs, Daniel Burke, Joel Barr, Lori Ann Larrew, Platte Valley Family Pharmacy, Inc. and other persons or entities known or unknown to the Grand Jury. The individuals comprising the enterprise had a primary objective and a common purpose which centered around using an orchestrated scheme to fraudulenlty acquire, divert and/or distribute large quantities of Oxycodone, a Schedule II Controlled Substance, in and around the metropolitan Denver, Colorado area as well as in other states such as Oklahoma. Oxycodone is a potent prescription medication that is classified as an opiod. In recent years the unmonitored abuse of and reliance on Oxycodone and other opiods have contributed to a proliferation of fraudulent schemes being employed by individuals and groups to obtain and divert this addictive controlled substance. According to data released by the Centers for Disease Control and Prevention during 2008 overdoses from prescription pain medications were contributing factors in the deaths of 14,800 citizens nationwide, more than from cocaine and heroin combined. According to 2010 data from the Colorado Department of Public Health and Environments Health Statistics Section deaths in Colorado that were associated with the abuse of opiods rose from 180 in 2000 to 392 in 2009. The 392 opiod related deaths in 2009 constituted the bulk of the states 445 total prescription drug related deaths. The 445 people who died in Colorado from prescription drug abuse in 2009 was more than twice (158) the number than those who died from drunk-driving related crashes in this state according to statistics from the National HighwayTraffic Safety Adminstration. Finally, according to 2010 data from the Denver Office of Drug Strategy, the State of Colorados Prescription Drug Monitoring Program (PDMP) reports that Oxycodone prescriptions for Denver residents rose 41.7% from 2007 to 2010. The ongoing leadership structure of this particular enterprise centered on Robin Steinke who coordinated and orchestrated a scheme that relied on a group of indivdiuals who possessed a similar purpose of making a financial profit from the illicit acquisition and distribution of Oxycodone. Robin Steinke directed her associates to obtain Oxycodone via various techniques so that this controlled substance could subsequently be distributed to people who were willing to pay approximately 50 cents per milligram or about $15.00 for one 30 mg dosage unit.

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Ms. Steinkes scheme later evolved to include using and paying a pharmacist named Jeffrey Clawson, who while acting as the owner and operator of the Platte Valley Family Pharmacy, Inc. in Brighton, CO, jointly collaborated with Robin Steinke and her network of patients to divert large quantities of Oxycodone though various forms of fraud and deceit with the purpose of subsequently selling and distributing to others via the illicit black market. During part of the alleged time period that the Enterprise was operating Jeffrey Clawson and Platte Valley Pharmacy also had an ongoing contractual arrangement with the McKesson Corporation, a DEA registered national distributor which has a presence in Aurora, CO, through its regional distribution center. The arrangement between Platte Valley Pharmacy and McKesson allowed McKesson to serve as the regulated supplier of many of Platte Valley Pharmacys controlled substances, including Oxycodone. A key issue during this time period was that McKesson, like all other DEA registered suppliers, had an obligation under the federal Controlled Substances Act, to report to DEA suspicious sales or orders of controlled substances. The Grand Jury learned of evidence demonstrating that Clawsons Platte Valley Pharmacy engaged in the regular purchase of Oxycodone from McKesson that was either unusually large, unusually frequent, and/or which substantially deviated from the normal pattern typically observed for comparable pharmacies in the area in and around Brighton. Colorado. From 2008-2011 the percentage increase for Oxycodone 30 mg orders supplied by McKesson to Platte Valley Pharmacy was approximately 1,469%. Further evidence was presented that the DEA did not receive any reports from McKesson regarding Platte Valley Pharmacys purchases of Oxycodone that were arguably suspicious in terms of quantities and frequency. Upon Jeffrey Clawson voluntarily surrendering the pharmacys DEA registration and subsequently selling Platte Valley Pharmacy in mid-2012 the Steinke-led enterprise started to rely more on alternative sources of supply to continue obtaining Oxycodone for subsequent redistribution and financial gain.

Pattern of Racketeering Activity Jeffrey Clawson, Robin Steinke, Celeste Deherrera, Leticia Deherrera, Christopher Peterson (aka Christopher Petersen), Christopher Gemeinhardt, Shawna Lawley, Joel Barr, Jacqueline Geist and Andrew Guerrero 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 include:

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Distribution of a Controlled Substance Schedule II, 18-18-405, C.R.S.; Conspiracy to Distribute a Controlled Substance Schedule II, 18-18-405, C.R.S.; Possession with Intent to Distribute a Controlled Substance Schedule II, 18-18- 405, C.R.S.; Obtaining a Controlled Substance by Fraud or Deceit, 18-18-415, C.R.S.; Criminal Attempt to Commit Obtaining a Controlled Substance by Fraud or Deceit, 18-18-415, 18-2-101, C.R.S.; Controlled Substance-False Application or Report, 18-18-414(1)(r), C.R.S.; Posssesion of a Forged Instrument, 18-5-105, C.R.S.; Obtain Controlled Substance by Fraud, 63 O.S. 2-407; and Unlawful Possession of Controlled Drug with Intent to Distribute, 63 O.S. 2-401(B)(2)

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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:

PREDICATE ACT ONE (Obtain Controlled Substance By Fraud) On or about March 28, 2012, in Carter County, State of Oklahoma, Robin Steinke and Leticia Deherrera, by obtaining Oxycodone, a controlled substance of Schedule II under the Uniform Controlled Dangerous Substances Act of Oklahoma, from CVS Pharmacy, and attempting to obtain Oxycodone, a controlled substance of Schedule II under the Uniform Controlled Dangerous Substances Act of Oklahoma, from Reed Family Pharmacy by means of presenting a prescription that was forged with the name of Robyn Myles, knowing that these prescriptions were false, contrary to the form of the statute, 63 O.S. 2-407, in such cases made and provided, and against the peace and dignity of the State of Oklahoma. PREDICATE ACT TWO (Unlawful Possession of Controlled Drug with Intent to Distribute) On or about March 28, 2012, in Carter County, State of Oklahoma, Robin Steinke and Leticia Deherrera, by possessing Oxycodone, as classified as Schedule II in the Uniform Controlled Dangerous Substances Act of Oklahoma, located at 814 W. Broadway, City of Ardmore, Carter County, Oklahoma, with the intent to distribute the same, contrary to the form of the statute, 63 O.S. 2-401(B)(2), in such cases made and provided, and against the peace and dignity of the State of Oklahoma.

Pursuant to C.R.S. 18-17-103(5)(b), Racketeering Activity means and also includes any violation of the enumerated Colorado statutues at issue or any criminal act committed in any jurisidiction of the United States which, if committed in the State of Colorado, would be a crime pursuant to an enumerated Colorado statute. In this matter, in addition to specific violations of enumerated Colorado statutes, Predicate Acts One and Two are criminal acts which occurred in the State of Oklahoma. If these offenses had occurred in the State of Colorado, Predicate Acts One and Two would be also crimes under an enumerated Colorado statute for charging purposes under the Colorado Organized Crime Control Act. Furthermore, Predicate Acts One and Two are both related to the ongoing behavior of this Enterprise during the charged time period.

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Furthermore, all of the listed narratives below which contain and summarize the essential facts for a specific Predicate Act or set of Predicate Acts are incorporated within and support each other.

The essential facts supporting the offenses alleged in Predicate Acts One and Two are the following: On March 28, 2012, police in Ardmore, Oklahoma were dispatched to the Reed Family Pharmacy regarding an allegation that a fraudulent prescription had been brought by a customer seeking to have fill it. The prescription that was presented to the pharmacy was done so by a male using a Colorado ID card with a photo of a woman and containing the name Robyn Myles. The hard copy prescription sought to have 280 dosage units of Oxycodone filled. Oxycodone is a Scheduled II Controlled Substance. An employee of Reed Family Pharmacy began to take some steps in attempt to confirm the validity of the prescription. These steps included making a phone call to the number of the doctors office that was listed on the prescription. The prescribing doctor was supposedly Peter Kaye. The employee then called that number that purportedly belonged to Dr. Kaye and talked to a person. However, after the employee received some inconsistent information from the person who she was talking to the employee found a valid number for Dr. Kaye and learned that Dr. Kaye had not written this prescription. The pharmacist, Paul Reed, further learned that some of Dr. Kayes prescription pads had previously been stolen. Later that day the male suspect called and inquired about the status of the prescription. While law enforcement was at the pharmacy a Michael Bruzda came inside and was contacted by law enforcement. Upon contact Mr. Bruzda was in possession of a Colorado drivers license with the name of Robin Myles. Law enforcement then made contact with two women seated in the vehicle bearing Colorado plates. The two women were Robin Steinke and Leticia Deherrera and each were making furtive gestures with their hands while inside the vehicle, including Ms. Steinke attempting to hide a bottle of pills and her trying to reach under the front passenger seat where she was seated. After Ms. Steinke was asked by law enforcement to exit the vehicle numerous pills poured out onto the passenger seat along with a container containing various pills located on the floor between that seat and the door. Additionally, two glass vials with suspected methamphetamine were located. Law enforcement then searched the vehicle and observed suspected marijuana, various pills, glass pipes with residue, two digital scales, and numerous small empty zip lock bags in the passenger compartment. Law enforcement also observed two lap-top computers, a copier/scanner/printer, a laminator and a paper cutter. Later on a weapon along with three more Colorado drivers licenses with Robin Steinkes picture but containing other peoples names were located in the vehicle.

Robin Steinke agreed to speak with officers from the Ardmore, OK police department and stated that Deherrera, Brudza and herself did get a fraudulent prescription filled at the

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CVS Pharmacy in Ardmore, OK for Oxycodone and attempted to fill others at two different pharmacies before going to the Reed Pharmacy. Steinke further stated that she had acquired blank prescriptions from different doctors in Colorado and she was able to have Brudza use a photo shop computer program to create and print fraudulent prescriptions. This included changing the doctors phone numbers so that when a pharmacy called the printed number the call would be routed to a cell phone belonging to Steinke, Brudza or Deherrera. Additionally, Steinke possessed a list of doctors and DEA numbers for these doctors. Finally, Steinke admitted that both she and Brudza had created fraudulent prescriptions and drivers licenses with her photo on them. Michael Brudza stated that the three of them drove from Colorado to Kansas where they got two prescriptions filled in Kansas before they headed to Oklahoma in an attempt to fill more prescriptions. Brudza stated that they were able to successfully fill a prescription at the CVS Pharmacy in Ardmore, OK right before they went back to the Reed Family Pharmacy. He also stated that the three of them also made fake IDs. Leticia Deherrera stated that she was the one who went into the CVS Pharmacy in Ardmore, OK to pick up and actually paid for the filled prescription of Oxycodone.

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PREDICATE ACT THREE (Teitelbaum and McCartyTransactions) 82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about April 27, 2010 to May 1, 2012, in the State of Colorado, Jeffrey Clawson, unlawfully, feloniously, and knowingly sold or distributed Oxycodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

PREDICATE ACT FOUR (Teitelbaum Transactions) 3345B CONTROLLED SUBSTANCE - FALSE APPLICATION OR REPORT, C.R.S. 18-18-414(1)(r) (F4)

On or about April 27, 2010 to October 1, 2011, in the State of Colorado, Jeffrey Clawson, unlawfully, feloniously, and knowingly furnished false or fraudulent material information in, or omitted any material information from, any application, report, other document or record required to be kept or filed pursuant to Colorado law; in violation of section 18-18-414(1)(r), C.R.S.

The essential facts supporting the offenses alleged in Predicate Acts Three and Four are the following: Between April 27, 2010 and October 1, 2011 then Brighton, CO based pharmacist Jeffrey Clawson knowingly sold or distributed various quantities of Oxycodone, a Schedule II Controlled Substance to Lisa Teitelbaum either without a valid prescription or which was done in a manner known as an early fill. On approximately ten (10) occasions during this time period Jeffrey Clawson represented to the State of Colorados Prescription Drug Monitoring Program (PDMP) that he had dispensed Oxycodone to Lisa Teitelbaum pursuant to orders authorized by Dr. Douglas Hammond. In particular, regarding alleged fills on April 27, 2010, April 28, 2010, April 29, 2010, April 30, 2010, May 3, 2010, May 6, 2010, May 7, 2010, and May 10, 2010 Clawson informed the PDMP via his reporting or record keeping obligations that he had filled 60 dosage units (pills) of Oxycodone 80 mg for Teitelbaum on each occasion. On October 1, 2011, Clawson also reported to the PDMP that he had filled 165 dosage units of Oxycodone 30 mg for Ms. Teitelbaum. Ms. Teitelbaum had been an ongoing patient of Dr. Douglas Hammond and his pain management practice. Dr. Hammond was later contacted by law enforcement and he informed them that after he had compared his patient charts to the data that Clawson

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reported to the PDMP he was able to confirm that these supposed prescriptions, as reported by Clawson, on behalf of Teitelbaum were not authentic. Ms. Teitelbaum was also contacted by law enforcement and informed them that she was a user of Oxycodone and that she had received her medication from Clawsons Platte Valley Pharmacy because Clawsons prices were so much lower than other pharmacies and because Clawson was willing to early fill her Oxycodone prescriptions. An early fill is when a pharmacist, without any legal or medical authorization, provides a patient with medication, including a controlled substance, before the prescription authorizes such a dispensing by a pharmacist. Ms. Teitelbaum informed law enforcement that she herself did not forge any Hammond prescriptions because of Clawsons willingness to distribute by early filling. Another witness, Trevor McCarty, provided the Grand Jury with information about Clawsons distribution activities that was similar in nature to Teitelbaum and thus supports the transactions cited above. McCarty testified that he also had an unusual pharmacist/patient relationship with Clawson which included Clawson not only agreeing to early fill oxycodone but also giving McCarty extra Oxycodone without a prescription and sometimes for free. McCarty stated that Clawson had provided Oxycodone to him without a prescription on many occasions, including during the time period alleged in Predicate Act Three. McCarty also stated that he had met Lisa Teitelbaum and Chris Petersen through Dr. Hammonds office and heard them say that Clawson did in fact provide them with Oxycodone through early fills. On May 18, 2012 Jeffrey Clawson agreed to speak with law enforcement about various transactions occuring at his Platte Valley Pharmacy. This contact occurred after two Confidential Informamts, known as CI # 1065 and #1069, had agreed to work with the South Metro Drug Task Force to build a narcotics trafficking case against Robin Steinke, Jeffrey Clawson and other people associated with them. A summary of Clawsons statement will be addressed later after the following foundational facts have been discussed. The key relevant facts leading up to the May 18, 2012 statement by Clawson included CI #1069 informing law enforcement that a person known as Robin Steinke, who lived at 3250 S. Bryant St in Sheridan, CO, was a main source of supply for illicit Oxycodone sales. On May 11, 2012 CI #1069, under the supervision of law enforcement, conducted a controlled purchase of 10 dosage units of presumptive Oxycodone from Robin Steinke after CI # 1069 had contacted Steinkes partner Celeste Deherrera at the S. Bryant St. residence. It should be noted that Celeste Deherrera is the mother of Leticia Deherrera who was with Steinke in Ardmore, Oklahoma in March 2012 when she was contacted regarding the behavior alleged in Predicate Acts One and Two. Following this May 11, 2012 controlled purchase the South Metro Drug Task Force (SMDTF) began collaborating with the Drug Enforcement Administration (DEA) of the United States Justice Department which was conducting a related investigation. The next phase of this joint investigation evolved by relying on and verifying the information of CI # 1065 who informed law enforcement that Steinke had a pharmacist

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named Jeffrey Clawson on her payroll who allowed any type of prescription to be passed at his Platte Valley Pharmacy in Brighton. It was learned that Steinke had supposedly assisted Clawson to pay off a gambling debt. CI #1065 also stated that Steinke: Has a group of individuals who often run fraudulent prescriptions for her and she pays for Drs visits and for prescriptions for Oxycodone so that the acquired drugs can be sold to other people; Manufactures fraudulent prescriptions and fake IDs that are used at pharmacies; and Communicates with Clawson to set up dates and times for people to go to his pharmacy and pass fraudulent scripts through him.

On May 18, 2012 CI #1065, under the supervision of the SMDTF, conducted a controlled purchase of Oxycodone from Jeffrey Clawson at Platte Valley Pharmacy via a partial early fill of 75 dosage units that had been coordinated by Robin Steinke. On this day Steinke gave CI # 1065 $300.00 to buy the pills, but Clawson did not charge on this occasion after he gave the CI the Oxycodone. CI #1065 later gave Steinke the pills who who had returned to the parking lot at the Platte Valley Hospital where the pharmacy was located. CI #1065 met with Steinke that day in an Isuzu Rodeo that was being monitored by law enforcement. After the transaction had been completed Steinke was contacted by law enforcement while she was with Christopher Peterson and Lisa Teitelbaum. Steinke agreed to speak and stated the following: That she had met Clawson approximately three (3) years prior so that she could purchase Oxycodone and Opana (Oxymorphone) from him She started seeing Dr. Hammond and received prescriptions for pills that she got filled by Clawson In addtion to legitimate scripts from Hammond she also forged others that she took to Clawson who would fill them for her Clawson would often give her pills without a prescription until she could get another prescription that Clawson would fill after subtracting the amount of the early fill She would call Clawson to ensure that he was there to fill the script She paid Clawson $1000.00 per week in order for her to pass prescriptions at his pharmacy

Clawsons statement from May 18, 2012 included information that he did know Steinke but that he had only met her in September to October 2011 when she came into his pharmacy as a patient wishing to fill prescriptions for controlled substances. Clawson then stated that from that time he started filling prescriptions for Steinke and people under Steinkes direction. Clawson was asked by law enforcement why he agreed to do these transactions. His reply to this question was that he was not forceful enough to say to say no to these people. Clawson admitted a few times that he did knowingly fill

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fraudulent prescriptions, but only did so after he was threatened by Steinke that she would call the DEA if he refused to continue filling the prescriptions Clawson added that the people would always pay with cash. Clawson said that he made $50.00 above cost per fraudulent transaction and that he did 2-3 fraudulent prescriptions per week and about 100 total fraudulent prescriptions. Clawson also acknowledged that the controlled substances that he provided were going to drug abusers and street sales.

PREDICATE ACT FIVE (Compunding Transactions) 82021 MANUFACTURING OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about October 17, 2010 to May 7, 2012, in the State of Colorado, Jeffrey Clawson, unlawfully, feloniously, and knowingly manufactured Oxycodone and/or Oxycodone dosage units, a schedule II controlled substance; in violation of section 1818-405(1),(2)(a)(I)(A), C.R.S. The essential facts supporting the offense alleged in Predicate Act Five are the following: Jeffrey Clawson reported to the PDMP that during the dates alleged in Predicate Act Five that he dispensed thousands of Oxycodone 80 mg dosage units for either Lorenzo Hernandez and/or Lusina Hernandez upon orders from a Dr. Martin McDermott of Fort Lupton, CO. Law enforcements review of various acquired records actually showed evidence that Clawson filled many of these prescriptions after he had manufactured the 80 mg Oxycodone dosage units through a process known as compounding. Compounding is a closely regulated process under C.R.S. 12-22-121 which states that a pharmacist can only manufacture a commercially available drug like Oxycodone if the compounded drug is significantly different from the commercially available drug or use of compounded drug is in the best medical interest of the patient, based on a practitioners drug order. An example of a practitioner ordering a drug like Oxycodone to be compounded would occur if a dye contained in a commercially available drug causes an allergic reaction for a patient, thus making the compounding necessary. In these incidences Dr. McDermott informed law enforcement that he did write prescriptions for Lorenzo and Lusina Hernandez to have Oxycodone 80 mg filled. However, Dr. McDermott stated that he did not request nor authorize the compounding of Oxycodone 80 mg dosage units for these patients. In fact Dr. McDermott further stated that he did not know that Oxycodone 80 mg could be compounded and had no recollection of ever being contacted by a pharmacy to have Oxycodone 80 mg compounded.

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PREDICATE ACT SIX (Peterson Transactions) 82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about April 1, 2011 to July 29, 2011, in the State of Colorado, Jeffrey Clawson, unlawfully, feloniously, and knowingly sold or distributed Oxycodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT SEVEN (Peterson Transactions) 3345B CONTROLLED SUBSTANCE - FALSE APPLICATION OR REPORT, C.R.S. 18-18-414(1)(r) (F4)

On or about April 1, 2011 to July 29, 2011, in the State of Colorado, Jeffrey Clawson, unlawfully, feloniously, and knowingly furnished false or fraudulent material information in, or omitted any material information from, any application, report, other document or record required to be kept or filed pursuant to Colorado law; in violation of section 1818-414(1)(r), C.R.S. PREDICATE ACT EIGHT 3541J OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a) (F6)

On or about April 1, 2011 to July 29, 2011, in the State of Colorado, Christopher Peterson, unlawfully, feloniously, and knowingly obtained or procured the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of section 18-18-415(1)(a), C.R.S.

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PREDICATE ACT NINE 3541JA CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6)

On or about May 24, 2012, in the State of Colorado, by engaging in conduct constituting a substantial step toward the commission of obtaining a controlled substance by fraud or deceit, Christopher Peterson and/or Shawna Lawley, unlawfully, feloniously, and knowingly attempted to obtain or procure the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of sections 18-18415(1)(a), 18-2-101, C.R.S.

The essential facts supporting the offenses alleged in Predicate Acts Six through Nine are the following: In the Summer of 2011 witness Trevor McCarty stated that after establishing a friendship with Jeffrey Clawson, which included Clawson agreeing to early fill his Oxycodone prescriptions, giving McCarty free Oxycodone and/or distributing unprescribed Oxycodone to him, McCarty met Christopher Peterson (aka Peterson) and Lisa Teitelbaum at Dr. Douglas Hammonds office. McCarty related that during the summer of 2011 he had been given a ride by Petersen and Teitelbaum to Clawsons Platte Valley Pharmacy so that he could fill his Oxycodone prescription. During this contact McCarty stated that all three of them discussed how Clawson was willing to give all of them early fills of Oxycodone. As the law enforcement investigation progressed, a comparison of records from both Platte Valley Pharmacy and Dr. Hammonds office showed at least five (5) occasions during the dates alleged in the above Predicate Acts when Jeffrey Clawson knowingly distributed Oxycodone to Christopher Petersen without a valid prescription. The first questionable incident occurred on April 1, 2011 with the distribution of 360 dosage units of Oxycodone 30 mg to Peterson according to PDMP records which were created from data that was submitted by Clawson. The second incident with the same amount of 360 dosage units of Oxycodone 30 mg occurred only 12 days later on April 12, 2011. The third transaction with the same amount of 360 dosage units of Oxycodone 30 mg occurred 14 days later on April 26, 2011. The fourth and fifth transactions of 360 dosage units of Oxycodone 30 mg occurred on July 15, 2011 and July 29, 2011. Clawson also reported these fills to the State of Colorados PDMP. Dr. Hammond confirmed that he did not write the prescriptions for the above referenced fraudulent transactions. On May 24-25, 2012, only six days after Clawsons Platte Valley Pharmacy was no longer able to dispense controlled substances, officers from the Littleton Police Department were dispatched to the Rite Aid Pharmacy located in Littleton, CO on the report of an in progress prescription fraud. Officers made contact with Christopher

22

Peterson (aka Petersen) who was trying to have a paper prescription filled for a controlled substance that was supposedly ordered by a physician working out of Gastroenterology of the Rockies. Law enforcement contacted that medical practice which verified that they no longer use prescription pads after they had some pads stolen a few months earlier. Peterson agreed to talk to law enforcement and stated that a friend named Shawna Lawley, a person who knew his girlfriend/wife, Lisa Teitelbaum, gave him the prescription after Lawley filled it out for 180 dosage units of Oxycodone 30 mg and signed it as if she was the physician. Lawley drove with Peterson in his Isuzu Rodeo and gave him $200.00 along with the fake prescription. Shawna Lawley, who will be discussed in greater detail later in this Indictment, was independently interviewed by law enforcement on April 3, 2012 when she admitted being involved in the Robin Steinke led poly-drug trafficking organization that distributed 1000-2000 Oxycodone tablets per day. Lawley stated that 20-30 indivduals may have been involved in the scheme. Lawley talked in this interview about obtaining prescriptions from doctors and also using forgeries to obtain the Oxycodone with the majority of the drugs going to Steinke for distribution. Lawley talked about Steinke selling the collected pills for 50 cents per milligram and that Steinke had Clawson on her payroll. Lawley acknowledged that while working for Steinke she had passed forged prescriptions seeking Oxycodone after falsely representing that they had been authorized by Gastroenterology of the Rockies. Lawley confirmed that this specifically occurred at Clawsons pharmacy twice on January 18, 2012. Based on the Grand Jurys reliance on Ms. Lawleys April 2012 statement it is a reasonable inference that the attempted fraud by Peterson on May 24, 2012 also involved Lawley acting as either as a principal or as a complicitor. PREDICATE ACT TEN (Tsamasfyros Transactions) 82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about September 6, 2011 to February 2, 2012, in the State of Colorado, Jeffrey Clawson, unlawfully, feloniously, and knowingly sold or distributed Oxycodone and/or Oxymorphone, both schedule II controlled substances; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S.

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PREDICATE ACT ELEVEN (Tsamasfyros Transactions) 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about September 6, 2011 to February 2, 2012, in the State of Colorado, Jeffrey Clawson, Robin Steinke, Leticia DeHerrera, Celeste DeHerrera, Jacqueline Geist and Andrew Guerrero unlawfully, feloniously, and knowingly conspired with each other and/or a person or persons to the Grand Jury unknown, to sell or distribute Oxycodone and/or Oxymorphone, schedule II controlled substances; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

The essential facts supporting the offenses alleged in Predicate Acts Ten and Eleven are the following: During the dates alleged in the above Predicate Acts Jeffrey Clawson collaborated with Robin Steinke and some of her associates to have approximately thirty (30) fraudulent prescriptions for controlled substances filled which all falsely represented that Dr. Constantine Tsamasfyros had ordered these prescriptions. On May 16, 2012 law enforcement officials met with Dr. Tsamasfyros at his Denver office and he was asked to compare PDMP records that were created from data inputed by Clawson and Platte Valley Pharmacy versus Dr. Tsamasfyros own records. Dr. Tsamasfyros confirmed that all but one of the entries contained in the PDMP were fraudulent and not the result of any prescription that he had written because the alleged patients had not seen by him or his practice. The only listed patient who had been seen by Dr. Tsamasfyros was Robin Steinke for one visit that occurred on or about December 20, 2011. During this one visit Steinke was prescribed 120 units of Oxycodone 15mg with no refills. Dr. Tsamasfyros also stated that Celeste Deherrera was listed in his system but had not been seen by his office. Of the apparent fraudulent transactions where Clawson and Platte Valley Pharmacy filled for Oxycodone or Opana (Oxymorphone) the following were shown to be false by Dr. Tsamasfyros and occurred as follows:
Date Contolled Substance Quantity Alleged Patient

9/6/2011 9/7/2011 9/29/2011 12/8/2011 12/9/2011 12/13/2011 12/14/2011 12/14/2011 12/15/2011 12/15/2011 12/15/2011

Oxycodone 30mg Oxycodone 30mg Oxycodone 30mg Oxycodone 30mg Oxycodone 30mg Oxycodone 30mg Opana 20mg Oxycodone 30mg Opana 30 mg Oxycodone 30 mg Opana 30 mg

700 850 750 380 320 280 30 340 30 380 30

Pumphrey Tasker Tasker CI CI L. Deherrera C. Deherrera C. Deherrera Roby Roby Roby

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12/20/2011 12/20/2011 12/20/2011 12/20/2011 12/20/2011 12/24/2011 12/24/2011 12/24/2011 12/27/2011 12/27/2011 12/27/2011 12/27/2011 12/30/2011 12/30/2011 12/31/2011 2/2/2012 2/2/2012 2/2/2012 2/2/2012

Opana 40 mg Oxycodone 15 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 15 mg Oxycodone 30 mg Oxycodone 30 mg Opana 40 mg Oxycodone 15 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 15 mg Oxycodone 30 mg Oxycodone 30 mg Opana 40 mg Oxycodone 15 mg Oxycodone 30 mg Oxycodone 30 mg

30 190 360 380 380 190 300 380 30 60 320 380 170 340 380 30 190 340 380

Chambers Roelofs Chambers Roelofs Roelofs Mazzei Max Deherrera Mazzei M. Deherrera Roby Roby M. Deherrera Landers Landers Steinke Keneson Hudnall Keneson Hudnall

A review of the fraudulent filled prescriptions shows that some of the alleged names used were real names or identities of Steinke and/or her known associates (C. Deherrera, L. Deherrera, and the two confidential informants) as well as assumed names that have been linked to other Steinke associates such as Giuseppe Mazzei possibly being used by Andrew Guerrero and/or Jacqueline Geist.

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PREDICATE ACT TWELVE (Gastroenterolgy Prescriptions) 82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about January 18, 2012 to January 31, 2012, in the State of Colorado, Jeffrey Clawson, unlawfully, feloniously, and knowingly sold or distributed Oxycodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT THIRTEEN (Gastroenterolgy Prescriptions) 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about January 18, 2012 to January 31, 2012 in the State of Colorado, Jeffrey Clawson, Robin Steinke, Shawna Lawley and/or Jacqueline Geist, unlawfully, feloniously, and knowingly conspired with each other and/or one or more persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT FOURTEEN (Gastroenterolgy Prescriptions) 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about February 1, 2012 to February 29, 2012 in the State of Colorado, Robin Steinke, Joel Barr and/or Jaqcqueline Geist unlawfully, feloniously, and knowingly conspired with each other and/or one or more persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT FIFTEEN (Gastroenterolgy Prescriptions) 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about March 1, 2012 to March 31, 2012 in the State of Colorado, Robin Steinke. Joel Barr and/or Shawna Lawley, unlawfully, feloniously, and knowingly conspired with each other and/or one or more persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S.

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PREDICATE ACT SIXTEEN 10040 POSSESSION OF FORGED INSTRUMENT, C.R.S. 18-5-105 (F6)

On or about March 26-27, 2012, in the State of Colorado, Shawna Lawley, unlawfully and feloniously possessed one or more forged instruments, namely: completed and blank precriptions, insurance documents, drivers licenses/permits, and/or service animal documents, with knowledge that the documents were forged and with intent to use the instruments to defraud; in violation of section 18-5-105, C.R.S. PREDICATE ACT SEVENTEEN (Gastroenterolgy Prescriptions) 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about April 1, 2012 to April 30, 2012 in the State of Colorado, Robin Steinke, unlawfully, feloniously, and knowingly conspired with one or more persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT EIGHTEEN (Gastroenterolgy Prescriptions) 82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about May 1, 2012 to May 31, 2012, in the State of Colorado, Jeffrey Clawson, unlawfully, feloniously, and knowingly sold or distributed Oxycodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT NINETEEN (Gastroenterolgy Prescriptions) 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about May 1, 2012 to May 31, 2012 in the State of Colorado, Jeffrey Clawson, Robin Steinke and/or Joel Barr unlawfully, feloniously, and knowingly conspired with each other and/or one or more persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S.

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The essential facts supporting the offenses alleged in Predicate Acts Twelve through Nineteen are the following: During the time period alleged in the Predicate Acts above the Robin Steinke led drug trafficking organization, along with Jeffrey Clawson acting as Steinkes retained pharmacist, significantly relied on the fraudulent use of unauthorized prescriptions, including the use of stolen prescription pads, that were appeared to be written by representatives of Gastroenterology of the Rockies. All of the following fraudulent prescriptions were not authorized by any physician at Gastroenterology of the Rockies. The specific transactions that are in bold were filled by Jeffrey Clawson and Platte Valley Pharmacy:

Date

Controlled Substance

Quantity

Alledged Patient

1/18/2012 1/18/2012 1/18/2012 1/18/2012 1/22/2012 1/28/2012 1/28/2012 1/28/2012 1/30/2012 1/30/2012 1/30/2012 1/31/2012 1/31/2012 1/31/2012 1/31/2012 2/2/2012 2/7/2012 2/8/2012 2/10/2012 2/10/2012 2/13/2012 2/13/2012 2/14/2012 2/14/2012 2/15/2012 2/15/2012 3/10/2012 3/16/2012 3/25/2012 3/28/2012

Oxycodone 15 mg Oxycodone 30 mg Oxycodone 15 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 15 mg Oxycodone 30 mg Oxycodone 15 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 15 mg Oxycodone 30 mg Oxycodone 15 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 15 mg Oxycodone 30 mg Oxycodone 15 mg Oxycodone 30 mg Oxycodone 15 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 15 mg Oxycodone 30 mg

150 300 160 320 180 180 160 320 140 240 320 150 300 120 240 300 180 112 140 280 140 280 140 280 280 180 280 112 84 90

Roby Roby Lawley Lawley Leticia Deherrera Belardinelli Landers Landers Belardinelli Leticia Deherrera Harris Walker Walker Geist Geist Roby Steinke Barr Flores Flores Geist Geist Mazzei Mazzei DeHerrera Pineda DeHerrera Barr Steinke Batikha

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4/5/2012 4/13/2012 4/18/2012 4/26/2012 4/26/2012 4/30/2012 5/1/2012 5/1/2012 5/10/2012 5/10/2012

Oxycodone 30 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 15 mg Oxycodone 30 mg Oxycodone 30 mg Oxycodone 30 mg

90 112 120 120 120 180 200 240 240 112

Steinke Smerdel Whiteman Fyke Schadegg Landers Schadles Schadles Flores Barr

A review of the fraudulent filled prescriptions shows that some of the alleged names used were real names or identities of Steinke and/or her known associates including Leticia Deherrera, Jacqueline Geist, Shawna Lawley, and Lawleys boyfriend Joel Barr. Additionally other assumed names that have been linked to Steinke and other Steinke associates were used such as Flores and Belardinelli. Also the name Giuseppe Mazzei had been linked to Andrew Guerrero and/or Jacqueline Geist along with the name of Tamer Batikha being used by Joel Barr, as recently as November 19, 2012 in Greenwood Village when he was with Shawna Lawley. On March 26, 2012 Shawna Lawley was contacted by officers from the Greenwood Village Police Department while driving a truck. During the contact evidence developed justifying the officers to search this truck. The search led to the observation and seizure of various documents and receipts, a prescription bottle for Oxycodone 30 mg for a Heather Steinke and Oxycodone pills. Additionally Ms. Lawley agreed to speak with law enforcement with her stating the following: Many of the documents, such as temporary drivers licenses and insurance cards/policies, were forged and had been made by her boyfriend Joel Barr for the Robin Steinke-led organization. Forged prescription blanks from Gastroenterology of the Rockies included ones for Lawley, Barr, Steinke and Batikha (Barrs alias). Lawley talked about Barr introducing her to Steinke and that big money could be made from selling pain pills. Sometimes members of the group would steal prescription blanks from a doctors office. Lawley explained that the group also used and sold heroin, methamphetamine, and other substances. As the investigation continued on March 2627, 2012 law enforcement went to Lawleys motel room and after receiving consent from Lawley, law enforcement observed forgery equipment, more fraudulent prescriptions from Gastroenterology of the Rockies, and unknown pills. A safe was also searched pursuant to a Search Warrant.

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PREDICATE ACT TWENTY (Controlled Purchase CI #1069) 82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about May 11, 2012, in the State of Colorado, Robin Steinke, unlawfully, feloniously, and knowingly sold or distributed Oxycodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT TWENTY-ONE (Controlled Purchase CI # 1065) 82053 CONSPIRACY TO TO DISTRIBUTE A CONTROLLED SUBSTANCESCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about May 18, 2012 in the State of Colorado, Robin Steinke and/or Jeffrey Clawson unlawfully, feloniously, and knowingly conspired with each other and/or one or more persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18 405(1),(2)(a)(I)(A), C.R.S PREDICATE ACT TWENTY-TWO 10040 POSSESSION OF FORGED INSTRUMENT, C.R.S. 18-5-105 (F6)

On or about May 18, 2012, in the State of Colorado, Robin Steinke and/or Celeste Deherrera, unlawfully and feloniously possessed one or more forged instruments, namely: completed and blank prescriptions, with knowledge that the documents were forged and with intent to use the instruments to defraud; in violation of section 18-5-105, C.R.S. The essential facts supporting the offenses alleged in Predicate Acts Twenty through Twenty-One are the following: The factual summary cited above in support of Predicate Three and Four provides the essential facts for Predicate Acts Twenty and Twenty-One and are incorporated herein. The essential facts for Predicate Act Twenty-Two are as follows: On May 18, 2012 law enforcement officers executed a Search Warrant at the home shared by Robin Steinke and Celeste Deherrera. During this search a variety of relevant items, including numerous documents were observed and seized. The

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documents included the blank and completed prescriptions for controlled substances that listed various peoples names that had been used in a fraudulent manner on other occasions.

PREDICATE ACT TWENTY-THREE 35411 OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a) (F6)

On or about June 14, 2012 through June 26, 2012 in the State of Colorado, Jacqueline Geist and/or Andrew Guerrero, unlawfully, feloniously, and knowingly obtained or procured the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of section 18-18-415(1)(a), C.R.S. PREDICATE ACT TWENTY-FOUR 82053 CONSPIRACY TO TO DISTRIBUTE A CONTROLLED SUBSTANCESCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about June 14, 2012 through July 22, 2012, in the State of Colorado, Jacqueline Geist and/or Andrew Guerrero unlawfully, feloniously, and knowingly conspired with each other and/or one or more persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18 405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT TWENTY-FIVE 10040 POSSESSION OF FORGED INSTRUMENT, C.R.S. 18-5-105 (F6)

On or about July 22, 2012, in the State of Colorado, Jacqueline Geist and/or Andrew Guerrero, unlawfully and feloniously possessed one or more forged instruments, namely: completed and blank precriptions, with knowledge that the documents were forged and with intent to use the instruments to defraud; in violation of section 18-5-105, C.R.S. The essential facts supporting the offenses alleged in Predicate Acts Twenty-Three through Twenty-Five are the following: On July 22, 2012 at 2:41 am a Thornton PD officer contacted a vehicle being driven by Jacqueline Geist with a passenger named Andrew Guerrero also in the vehicle. During this contact evidence developed justifying a search of the vehicle. Relevant items that were observed included an Apple laptop computer, a color printer, one 30 mg Oxycodone tablet, items consistent with drug use, and various documents. Later as part of an ongoing investigation a review of the seized documentation from July 22, 2012

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showed that various alleged prescriptions for Oxycodone that were supposedly written by Dr. Daniel Drennan of Comprehensive Pain Specialists had been in the possession of Geist and Guerrero. An additonal 13 prescriptions for Oxycodone that were supposedly written by the same doctor for a patient named Giuseppe Mazzei. were observed. It appeared to law enforcement that all 13 prescriptions were very similar, if not identical in terms of content and appearance. Law enforcement also located a letter in the seized documents that had been addressed to Ms. Geist and was written by Dr. Drennan on July 13, 2012. This letter served as notice to Ms. Geist that Dr. Drennan had dismissed her from his practice based on his awareness that she had been filling opiod medications that were supposedly authorized by another physician. As the investigation progressed it was determined that on June 14, 2012 Ms. Geist submitted a forged prescription, dated June 3, 2012, seeking 240 units of Oxycodone 30 mg to Todds Harvard Park Pharmacy in Denver. This forged script was filled. The supposed prescribing medical doctor was Peter Kaye of Gastrenterology of the Rockies. Law enforcement has since further verified with that practice that this prescription was fraudulent. On June 15, 2012 Ms. Geist again submitted a prescription, dated June 13, 2012, seeking 240 units of Oxycodone 30 mg that had supposedly been written by Dr. Daniel Drennan. This prescription, that was later determined to be fraudulent after verification by Dr. Drennans practice, was filled at the Safeway in Idaho Springs. On June 20, 2012, Andrew Guerrero submitted a prescription , dated June 20, 2012, seeking 240 units of Oxycodone 30 mg that had supposedly been written by Dr. Daniel Drennan. This prescription, that was later determined to be fraudulent after verifying with Dr. Drennans practice, was filled at a Walgreens in Broomfield. On June 26, 2012, Jacqueline Geist submitted a prescription , dated June 13, 2012, seeking 240 units of Oxycodone 30 mg that had supposedly been written by Dr. Daniel Drennan. This prescription, that was later determined to be fraudulent after verifying with Dr. Drennans practice, was filled at the King Soopers in Bergen Park, CO. PREDICATE ACT TWENTY-SIX 3541JA CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6)

On or about July 4, 2012 through September 17, 2012, in the State of Colorado, by engaging in conduct constituting a substantial step toward the commission of obtaining a controlled substance by fraud or deceit, Robin Steinke, unlawfully, feloniously, and knowingly attempted to obtain or procure the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of sections 18-18415(1)(a), 18-2-101, C.R.S.

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PREDICATE ACT TWENTY-SEVEN 3541JA CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6)

On or about October 4, 2012 through October 13, 2012, in the State of Colorado, by engaging in conduct constituting a substantial step toward the commission of obtaining a controlled substance by fraud or deceit, Robin Steinke, unlawfully, feloniously, and knowingly attempted to obtain or procure the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of sections 18-18415(1)(a), 18-2-101, C.R.S. The essential facts supporting the offenses alleged in Predicate Acts Twenty-Six and Twenty-Seven are the following: On or about June 6, 2012 Robin Steinke became a patient of Denver Pain Management (DPM) claiming that she was suffering from pain. On June 27, 2012 a physician at DPM wrote one prescription for Steinke to fill 240 dosage units of Oxycodone 30 mg. On August 8, 2012 DPM provided law enforcement with information that Ms. Steinke passed that prescription not once, but on at least three separate occasions and all at different pharmacies. These dates were July 4, 2012 at a Walgreens in Denver, on July 7, 2012 at a Rite Aid in Littleton and on July 9, 2012 at Todds Harvard Park Pharmacy in Denver. With DPM initially being unaware of Steinkes actions DPM wrote Steinke another prescription on August 1, 2012 for 240 dosage units of Oxycodone 30 mg. On August 7, 2012 DPM received a phone call from a Safeway pharmacy in Englewood alerting DPM that Steinke was attempting to pass the most recent prescription after it had already been filled by two other pharmacies a few days earlier. The first incident was at a King Soopers in Englewood on August 1, 2012 and later at the same Rite Aid on August 2, 2012. Regarding the August 7, 2012 incident the Safeway employee told law enforcement that when Steinke was told that the prescription needed to be checked Steinke fled the store. On October 13, 2012 Sheridan Police officers were dispatched to a Target store in that city regarding an attempted prescription fraud. When law enforcement arrived the woman who was attempting to pass the prescription seeking Oxycodone 30 mg had left the store. The name that was used by the customer was Erica Meyer, with a DOB of 4/25/1966 and who was described to be a 40 year old white woman who looked like a man. Robin Steinkes DOB is 4/25/1967. Another fraudulent prescription from a few days earlier was shown to law enforcement by employees of the Target store that represented that a person claiming to be Audry Scott, with a DOB of 7/7/1987 and living

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at 3250 S. Bryant Street in Englewood had a script for 240 units of Oxycodone 30 mg. The address on S. Byrant St. is actually Steinkes house that she shares with Celeste Deherrerra. This prescription was supposedly authorized by a doctor at DPM on October 4, 2012. Target employees then located a report and a picture from a Lakewood Target from September 7, 2012 showing the suspect in that stores fraud was driving a Nissan SUV with a license plate that was registered to Robin Steinke. The picture of the suspect from the Lakewood fraud looked similar to the person who committed the October 13, 2012 Sheridan fraud. A photo array with Robin Steinke located in position # 5 was created and shown to the Sheridan Target pharmacist who interacted with the suspect from October 13, 2012. Without any hesitation this pharmacist positively identified Robin Steinke as the person who attempted to pass the fraudulent prescription on October 13, 2012. PREDICATE ACT TWENTY-EIGHT 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about November 12-14, 2012 in the State of Colorado, Robin Steinke, Leticia Deherrera, and Christopher Gemeinhardt unlawfully, feloniously, and knowingly conspired each other and/or Daniel Burke, Sadie Grubbs and/or a person or persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT TWENTY-NINE 3541JA CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6)

On or about November 12-14, 2012, in the State of Colorado, by engaging in conduct constituting a substantial step toward the commission of obtaining a controlled substance by fraud or deceit, Robin Steinke, Leticia DeHerrera and Christopher Gemeinhardt, unlawfully, feloniously, and knowingly attempted to obtain or procure the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of sections 18-18-415(1)(a), 18-2-101, C.R.S.

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PREDICATE ACT THIRTY 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about November 19, 2012 in the State of Colorado, Robin Steinke, unlawfully, feloniously, and knowingly conspired with Rhonda Scott and/or a person or persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT THIRTY-ONE 3541JA CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6)

On or about November 19, 2012, in the State of Colorado, by engaging in conduct constituting a substantial step toward the commission of obtaining a controlled substance by fraud or deceit, Robin Steinke, unlawfully, feloniously, and knowingly attempted to obtain or procure the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of sections 18-18-415(1)(a), 18-2-101, C.R.S. PREDICATE ACT THIRTY-TWO 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about November 21, 2012 in the State of Colorado, Robin Steinke and Christopher Gemeinhardt, unlawfully,feloniously, and knowingly conspired with each other and/or a person or persons to the Grand Jury unknown, to sell or distribute Oxycodone, a Schedule II Controlled Substance; in violation of section 18-18 405(1),(2)(a)(I)(A), C.R.S.

PREDICATE ACT THIRTY-THREE 82041 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about November 21, 2012 in the State of Colorado, Robin Steinke and Christopher Gemeinhardt, unlawfully, feloniously, and knowingly possessed with intent to sell or distribute Oxycodone, a Schedule II Controlled Substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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PREDICATE ACT THIRTY-FOUR 8201B POSSESSION OF METHAMPHETAMINE-LESS THAN 2 GRAMS, C.R.S. 18-18-403.5(1),(2), (b)(I) (F6)

On or about November 21, 2012 in the State of Colorado, Robin Steinke and Christopher Gemeinhardt, unlawfully, feloniously, and knowingly possessed more than two grams of a material, compound, mixture, preparation that contained Methamphetamine, a controlled substance, in violation of section 18-18-403.5(1),(2), (b)(I), C.R.S. PREDICATE ACT THIRTY-FIVE 3541JA CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6)

On or about November 21, 2012, in the State of Colorado, by engaging in conduct constituting a substantial step toward the commission of obtaining a controlled substance by fraud or deceit, Robin Steinke and/or Christopher Gemeinhardt, unlawfully, feloniously, and knowingly attempted to obtain or procure the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of sections 18-18-415(1)(a), 18-2-101, C.R.S. PREDICATE ACT THIRTY-SIX 10040 POSSESSION OF FORGED INSTRUMENT, C.R.S. 18-5-105 (F6)

On or about November 21, 2012, in the State of Colorado, Robin Steinke and/or Christopher Gemeinhardt, unlawfully and feloniously possessed one or more forged instruments, namely: completed and blank precriptions, fraudulent identifications, with knowledge that the documents were forged and with intent to use the instruments to defraud; in violation of section 18-5-105, C.R.S.

The essential facts supporting the offenses alleged in Predicate Acts Twenty-Eight through Thirty-Six are the following: On November 14, 2012 officers from the Parker Police Department were dispatched to the Crown Point Pharmacy regarding a suspected prescription fraud occurring. Upon arrival officers learned that a Sadie Grubbs had passed an apparently fraudulent prescription seeking 180 dosage units of Oxycodone 30 mg and her boyfriend, Daniel Burke was now waiting for the prescription to be filled. The pharmacy learned that the prescription was a forgery because the supposed phone number for the ordering physician

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was disconnected and because that same pharmacy had just filled a questionable Oxycodone prescription for Daniel Burke just two days earlier on November 12, 2012. When the pharmacy started to compare the Grubbs prescription to the Burke prescription various consistent problems were observed and later confirmed to false, such as the listed doctor on both prescriptions having not worked at the listed practice for a period of time. During this initial period of the investigation and also on November 12, 2012 the same pharmacy noted that another suspected fraudulent prescription seeking 240 dosage units of Oxycodone 30 mg had been passed by Leticia Deherrera. The pharmacy then learned that this script was a forgery. Law enforcement then had an opportunity to talk with Daniel Burke and learned that Burke owed $1000.00 to a female known to him as BB or Robin and that he could reduce his debt to her if he would pick up Oxycodone. Burke stated that the debt to BB or Robin occurred after he had bought Oxycodone from her. Burke acknowledged that he knew the prescriptions were fraudulent and that he brought his girlfriend, Sadie Grubbs into this scheme. Burke said that BB told him that she would cut down his debt to $300.00 if he retrieved the Oxycodone on top of him being allowed to buy some from her. Burke said that BB wrote prescriptions for both Sadie and him. When Burke filled the pills on November 12, 2012 he gave the pills to BB. Burke also stated that BB/Robins daughter Leticia was also coming to this pharmacy that day to get more Oxycodone. Leticia Deherrera eventually came back and was contacted by Parker police. Ms. Deherrera admitted passing fake prescriptions to make some extra money. Finally, another person named Christopher Gemeinhardt also tried to pass a fraudulent prescription at this same pharmacy on November 14, 2012 for Oxycodone and Oxymorphone. Gemeinhardt acknowledged that the various scripts in his possession were forgeries. On November 19, 2012 Denver PD officers were notified by officials affiliated with Todds Harvard Pharmacy that a woman was trying to pass a forged prescription. The woman who was next observed running from the police was identified as Rhonda Scott after she was contacted with Robin Steinke. Steinke told these Denver officers that she was with Scott after Scott stated that she needed to pick up some medicine for Scotts boyfriend. Steinke futher stated that she had no idea why Scott was running. The fraudulent prescription at issue was for 240 dosage units of Oxycodone 30 mg. On November 21, 2012 Denver PD officers responded to a Rite Aid pharmacy regarding a prescription fraud that was in progress involving a male later identified as Christopher Gemeinhardt seated in a silver Nissan Pathfinder and Robin Steinke seated in the passenger seat. Officers observed less than 2 g of suspected methamphetamine being possessed by Gemeinhardt, with Steinke also possessing suspected methamphetamine, as well as a suspected meth pipe and 80 pills that were presumptively positive as being Oxycodone. Steinkes Nissan contained fraudulent prescription documents, notes with pharmacy and doctors names, fake identifications, an iPad with a key board, cell phones (one with a scanner app operating) and an HP printer.

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PREDICATE ACT THIRTY-SEVEN (C. DeHerrera Alteration of Hammond Prescription) 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about April 22, 2011 in the State of Colorado, Robin Steinke, Jeffrey Clawson, and/or Celeste Dehererra unlawfully,feloniously, and knowingly conspired with each other and/or a person or persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S. The essential facts supporting the offense alleged in Predicate Act Thirty-Seven are the following: Records obtained by the DEA reflected that on April 22, 2011 Jeffrey Clawson and Platte Valley Pharmacy filled a prescription for 640 dosage units of Oxycodone 30 mg for the benefit of Celeste Deherrera. The listed ordering physician was Dr. Douglas Hammond who has subsequently confirmed for law enforcement that his prescription only authorized 40 dosage units of Oxycodone 30 mg to be filled, not 640. Thus, based on the totality of the evidence of the entire scheme the alteration of an arguably more reasonable amount like 40 dosage units of Oxycodone 30 mg to a much more suspicious amount of 640 dosage units provides a strong indication that a portion of 640 dosage units were destined for further distribution via street sales by Ms. Steinke and Ms. Deherrera after receiving the assistance of Mr. Clawson and his willingness to fill this fraudulent prescription. PREDICATE ACT THIRTY-EIGHT 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about December 27, 2012 in the State of Colorado, Robin Steinke, unlawfully, feloniously, and knowingly conspired with Laurie Anne Larrew and/or a person or persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S.

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PREDICATE ACT THIRTY-NINE 3541JA CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6)

On or about December 27, 2012, in the State of Colorado, by engaging in conduct constituting a substantial step toward the commission of obtaining a controlled substance by fraud or deceit, Robin Steinke, unlawfully, feloniously, and knowingly attempted to obtain or procure the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of sections 18-18-415(1)(a), 18-2-101, C.R.S.

PREDICATE ACT FORTY 10040 POSSESSION OF FORGED INSTRUMENT, C.R.S. 18-5-105 (F6)

On or about December 27, 2012, in the State of Colorado, Robin Steinke, unlawfully and feloniously possessed one or more forged instruments, namely: completed and blank precriptions as well as fraudulent identifications, with knowledge that the documents were forged and with intent to use the instruments to defraud; in violation of section 185-105, C.R.S.

PREDICATE ACT FORTY-ONE 8201B POSSESSION OF METHAMPHETAMINE-LESS THAN 2 GRAMS, C.R.S. 18-18-403.5(1),(2), (b)(I) (F6)

On or about December 27, 2012 in the State of Colorado, Robin Steinke unlawfully, feloniously, and knowingly possessed more than two grams of a material, compound, mixture, preparation that contained Methamphetamine, a controlled substance, in violation of section 18-18-403.5(1),(2), (b)(I), C.R.S. The essential facts supporting the offenses alleged in Predicate Act Thirty-Eight through Forty-One are the following: On December 27, 2012, officers from the Broomfield Police Department were dispatched to a pharmacy at a Safeway in that jurisdiction on the report of a prescription fraud that was occuring. Pharmacy staffers reported that the two female suspects had just left in a Ford Mustang after one of them had tried to have a prescription filled for 180 dosage units of Oxycodone 30 mg using a suspicious Colorado ID and prescription

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naming a Crystal Larri. The IDs photo looked more like the other woman who was present but who was not presenting the prescription. The suspected prescribing doctors office was called and confirmed the prescription was fraudulent because Crystal Larri was never a patient and the purported signature of the prescribing doctor was not authentic. When the pharmacy staff tried to stall the two women the one who was not at the counter (described as a white female, with very short hair, who was slightly overweight and appearing like a male) communicated to the other that they needed to leave. When the Mustang was contacted by law enforcement later that day Robin Steinke was in the drivers seat with a Laurie Ann Larrew in the passenger seat. The Mustang was a rental that had been rented in the name of Celeste Deherrera and was one month overdue. An initial inventory search and a subsequent search pursuant to a search warrant of this car located 1.93 grams of presumptively positive methamphetamine on the drivers side floor board, dozens of fraudulent prescription forms (some completed and some blank) listing various doctors from throughout the metro Denver area, dozens of unused small sealable baggies that are consistent with narcotics distribution, notes summarizing pharmacy names, doctors, DEA numbers, and dozens of credit cards and IDs with the majority of these credit cards naming Steinke. Officers also located several ID cards, and a passport with other peoples names in Steinkes pocket.

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COUNT THREE (Teitelbaum and McCartyTransactions) 82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about April 27, 2010 to May 1, 2012, in the State of Colorado, Jeffrey Clawson, unlawfully, feloniously, and knowingly sold or distributed Oxycodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT FOUR (Teitelbaum Transactions) 3345B CONTROLLED SUBSTANCE - FALSE APPLICATION OR REPORT, C.R.S. 18-18-414(1)(r) (F4)

On or about April 27, 2010 to October1, 2011, in the State of Colorado, Jeffrey Clawson, unlawfully, feloniously, and knowingly furnished false or fraudulent material information in, or omitted any material information from, any application, report, other document or record required to be kept or filed under article 18, C.R.S. or under part 3 of article 22 of title 12, C.R.S.; in violation of section 18-18-414(1)(r), C.R.S. The essential facts for Counts Three and Four were previously summarized above as the essential facts for Predicate Acts Three and Four that were in support of Counts One and Two and are incorporated herein. COUNT FIVE (Compunding Transactions) 82021 MANUFACTURING OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about October 17, 2010 to May 7, 2012, in the State of Colorado, Jeffrey Clawson, unlawfully, feloniously, and knowingly manufactured Oxycodone and/or Oxycodone dosage units, a schedule II controlled substance; in violation of section 1818-405(1),(2)(a)(I)(A), C.R.S. The essential facts for Count Five were previously summarized above as the essential facts for Predicate Act Five that was in support of Counts One and Two and are incorporated herein.

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COUNT SIX (Peterson Transactions) 82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about April 1, 2011 to July 29, 2011, in the State of Colorado, Jeffrey Clawson, unlawfully, feloniously, and knowingly sold or distributed Oxycodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT SEVEN (Peterson Transactions) 3345B CONTROLLED SUBSTANCE - FALSE APPLICATION OR REPORT, C.R.S. 18-18-414(1)(r) (F4)

On or about April 1, 2011 to July 29, 2011, in the State of Colorado, Jeffrey Clawson, unlawfully, feloniously, and knowingly furnished false or fraudulent material information in, or omitted any material information from, any application, report, other document or record required to be kept or filed under article 18, C.R.S. or under part 3 of article 22 of title 12, C.R.S.; in violation of section 18-18-414(1)(r), C.R.S. COUNT EIGHT 3541J OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a) (F6)

On or about April 1, 2011 to July 29, 2011, in the State of Colorado, Christopher Peterson, unlawfully, feloniously, and knowingly obtained or procured the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of section 18-18-415(1)(a), C.R.S.

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COUNT NINE 3541JA CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6)

On or about May 24, 2012, in the State of Colorado, by engaging in conduct constituting a substantial step toward the commission of obtaining a controlled substance by fraud or deceit, Christopher Peterson and Shawna Lawley, unlawfully, feloniously, and knowingly attempted to obtain or procure the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of sections 18-18415(1)(a), 18-2-101, C.R.S. The essential facts for Counts Six through Nine were previously summarized above as the essential facts for Predicate Acts Six through Nine that were in support of Counts One and Two and are incorporated herein. COUNT TEN (Tsamasfyros Transactions) 82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about September 6, 2011 to February 2, 2012, in the State of Colorado, Jeffrey Clawson, unlawfully, feloniously, and knowingly sold or distributed Oxycodone and/or Oxymorphone, both schedule II controlled substances; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S. COUNT ELEVEN (Tsamasfyros Transactions) 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about September 6, 2011 to February 2, 2012, in the State of Colorado, Jeffrey Clawson, Robin Steinke, Leticia DeHerrera, Celeste DeHerrera, Jacqueline Geist and Andrew Guerrero unlawfully, feloniously, and knowingly conspired with each other and/or a person or persons to the Grand Jury unknown, to sell or distribute Oxycodone and/or Oxymorphone, schedule II controlled substances; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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The essential facts for Counts Ten and Eleven were previously summarized above as the essential facts for Predicate Acts Ten and Eleven that were in support of Counts One and Two and are incorporated herein. COUNT TWELVE (Gastroenterolgy Prescriptions) 82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about January 18, 2012 to January 31, 2012, in the State of Colorado, Jeffrey Clawson, unlawfully, feloniously, and knowingly sold or distributed Oxycodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT THIRTEEN (Gastroenterolgy Prescriptions) 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about January 18, 2012 to January 31, 2012 in the State of Colorado, Jeffrey Clawson, Robin Steinke, Shawna Lawley and/or Jacqueline Geist, unlawfully, feloniously, and knowingly conspired with each other and/or one or more persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT FOURTEEN (Gastroenterolgy Prescriptions) 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about February 1, 2012 to February 29, 2012 in the State of Colorado, Robin Steinke, Joel Barr and/or Jaqcqueline Geist unlawfully, feloniously, and knowingly conspired with each other and/or one or more persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S.

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COUNT FIFTEEN (Gastroenterolgy Prescriptions) 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about March 1, 2012 to March 31, 2012 in the State of Colorado, Robin Steinke. Joel Barr and/or Shawna Lawley, unlawfully, feloniously, and knowingly conspired with each other and/or one or more persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S. COUNT SIXTEEN 10040 POSSESSION OF FORGED INSTRUMENT, C.R.S. 18-5-105 (F6)

On or about March 26-27, 2012, in the State of Colorado, Shawna Lawley, unlawfully and feloniously possessed one or more forged instruments, namely: completed and blank precriptions, insurance documents, drivers licenses/permits, and/or service animal documents, with knowledge that the documents were forged and with intent to use the instruments to defraud; in violation of section 18-5-105, C.R.S. COUNT SEVENTEEN (Gastroenterolgy Prescriptions) 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about April 1, 2012 to April 30, 2012 in the State of Colorado, Robin Steinke, unlawfully, feloniously, and knowingly conspired with one or more persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT EIGHTEEN (Gastroenterolgy Prescriptions) 82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about May 1, 2012 to May 31, 2012, in the State of Colorado, Jeffrey Clawson, unlawfully, feloniously, and knowingly sold or distributed Oxycodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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COUNT NINETEEN (Gastroenterolgy Prescriptions) 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about May 1, 2012 to May 31, 2012 in the State of Colorado, Jeffrey Clawson, Robin Steinke and/or Joel Barr unlawfully, feloniously, and knowingly conspired with each other and/or one or more persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S. The essential facts for Counts Twelve through Nineteen were previously summarized above as the essential facts for Predicate Acts Twelve through Nineteen that were in support of Counts One and Two and are incorporated herein. COUNT TWENTY (Controlled Purchase CI #1069) 82021 DISTRIBUTION OF A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about May 11, 2012, in the State of Colorado, Robin Steinke, unlawfully, feloniously, and knowingly sold or distributed Oxycodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT TWENTY-ONE (Controlled Purchase CI # 1065) 82053 CONSPIRACY TO TO DISTRIBUTE A CONTROLLED SUBSTANCESCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about May 18, 2012 in the State of Colorado, Robin Steinke and/or Jeffrey Clawson unlawfully, feloniously, and knowingly conspired with each other and/or one or more persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18 405(1),(2)(a)(I)(A), C.R.S

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COUNT TWENTY-TWO 10040 POSSESSION OF FORGED INSTRUMENT, C.R.S. 18-5-105 (F6)

On or about May 18, 2012, in the State of Colorado, Robin Steinke and/or Celeste Deherrera, unlawfully and feloniously possessed one or more forged instruments, namely: completed and blank precriptions, with knowledge that the documents were forged and with intent to use the instruments to defraud; in violation of section 18-5-105, C.R.S. The essential facts for Counts Twenty through Twenty-Two were previously summarized above as the essential facts for Predicate Acts Twenty through Twenty-Two that were in support of Counts One and Two and are incorporated herein. COUNT TWENTY-THREE 35411 OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a) (F6)

On or about June 14-26, 2012 in the State of Colorado, Jacqueline Geist and/or Andrew Guerrero, unlawfully, feloniously, and knowingly obtained or procured the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of section 18-18-415(1)(a), C.R.S. COUNT TWENTY-FOUR 82053 CONSPIRACY TO TO DISTRIBUTE A CONTROLLED SUBSTANCESCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about June 14, 2012 through July 22, 2012, in the State of Colorado, Jacqueline Geist and/or Andrew Guerrero unlawfully, feloniously, and knowingly conspired with each other and/or one or more persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18 405(1),(2)(a)(I)(A), C.R.S. COUNT TWENTY-FIVE 10040 POSSESSION OF FORGED INSTRUMENT, C.R.S. 18-5-105 (F6)

On or about July 22, 2012, in the State of Colorado, Jacqueline Geist and/or Andrew Guerrero, unlawfully and feloniously possessed one or more forged instruments, namely: completed and blank prescriptions, with knowledge that the documents were forged and with intent to use the instruments to defraud; in violation of section 18-5-105, C.R.S.

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The essential facts for Counts Twenty-Three through Twenty-Five were previously summarized above as the essential facts for Predicate Acts Twenty-Three through Twenty-Five that were in support of Counts One and Two and are incorporated herein. COUNT TWENTY-SIX 3541JA CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6)

On or about July 4, 2012 through September 17, 2012, in the State of Colorado, by engaging in conduct constituting a substantial step toward the commission of obtaining a controlled substance by fraud or deceit, Robin Steinke, unlawfully, feloniously, and knowingly attempted to obtain or procure the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of sections 18-18415(1)(a), 18-2-101, C.R.S. COUNT TWENTY-SEVEN 3541JA CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6)

On or about October 4-13, 2012, in the State of Colorado, by engaging in conduct constituting a substantial step toward the commission of obtaining a controlled substance by fraud or deceit, Robin Steinke, unlawfully, feloniously, and knowingly attempted to obtain or procure the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of sections 18-18-415(1)(a), 18-2-101, C.R.S. The essential facts for Counts Twenty-Six and Twenty-Seven were previously summarized above as the essential facts for Predicate Acts Twenty-Six and TwentySeven that were in support of Counts One and Two and are incorporated herein.

COUNT TWENTY-EIGHT 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about November 12-14, 2012 in the State of Colorado, Robin Steinke, Leticia Deherrera, Christopher Gemeinhardt, Daniel Burke and/or Sadie Grubbs unlawfully, feloniously, and knowingly conspired each other and/ and/or a person or persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S.

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COUNT TWENTY-NINE 3541JA CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6)

On or about November 12-14, 2012, in the State of Colorado, by engaging in conduct constituting a substantial step toward the commission of obtaining a controlled substance by fraud or deceit, Robin Steinke, Leticia DeHerrera, and/or Christopher Gemeinhardt, unlawfully, feloniously, and knowingly attempted to obtain or procure the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of sections 18-18-415(1)(a), 18-2-101, C.R.S. COUNT THIRTY 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about November 19, 2012 in the State of Colorado, Robin Steinke and Rhonda Scott, unlawfully, feloniously, and knowingly conspired with each other and/or a person Or persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S.

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COUNT THIRTY-ONE 3541JA CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6)

On or about November 19, 2012, in the State of Colorado, by engaging in conduct constituting a substantial step toward the commission of obtaining a controlled substance by fraud or deceit, Robin Steinke, unlawfully, feloniously, and knowingly attempted to obtain or procure the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of sections 18-18-415(1)(a), 18-2-101, C.R.S.

COUNT THIRTY-TWO 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about November 21, 2012 in the State of Colorado, Robin Steinke and Christopher Gemeinhardt, unlawfully,feloniously, and knowingly conspired with each other and/or a person or persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18 405(1),(2)(a)(I)(A), C.R.S. COUNT THIRTY-THREE 82041 POSSESSION WITH INTENT TO DISTRIBUTE A CONTROLLED SUBSTANCE - SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about November 21, 2012 in the State of Colorado, Robin Steinke and Christopher Gemeinhardt, unlawfully, feloniously, and knowingly possessed with intent to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT THIRTY-FOUR 8201B POSSESSION OF METHAMPHETAMINE-LESS THAN 2 GRAMS, C.R.S. 18-18-403.5(1),(2), (b)(I) (F6)

On or about November 21, 2012 in the State of Colorado, Robin Steinke and Christopher Gemeinhardt, unlawfully, feloniously, and knowingly possessed more than two grams of a material, compound, mixture, preparation that contained Methamphetamine, a controlled substance, in violation of section 18-18-403.5(1),(2), (b)(I), C.R.S.

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COUNT THIRTY-FIVE 3541JA CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6)

On or about November 21, 2012, in the State of Colorado, by engaging in conduct constituting a substantial step toward the commission of obtaining a controlled substance by fraud or deceit, Robin Steinke and/or Christopher Gemeinhardt, unlawfully, feloniously, and knowingly attempted to obtain or procure the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of sections 18-18-415(1)(a), 18-2-101, C.R.S. COUNT THIRTY-SIX 10040 POSSESSION OF FORGED INSTRUMENT, C.R.S. 18-5-105 (F6)

On or about November 21, 2012, in the State of Colorado, Robin Steinke and/or Christopher Gemeinhardt, unlawfully and feloniously possessed one or more forged instruments, namely: completed and blank precriptions, fraudulent identifications, with knowledge that the documents were forged and with intent to use the instruments to defraud; in violation of section 18-5-105, C.R.S. The essential facts for Counts Twenty-Eight through Thirty-Six were previously summarized above as the essential facts for Predicate Acts Twenty-Eight and Thirty-Six that were in support of Counts One and Two and are incorporated herein. COUNT THIRTY-SEVEN (C. DeHerrera Alteration of a Hammond Prescription) 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about April 22, 2011 in the State of Colorado, Robin Steinke, Jeffrey Clawson, and/or Celeste Dehererra unlawfully,feloniously, and knowingly conspired with each other and/or a person or persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S. The essential facts for Count Thirty-Seven were previously summarized above as the essential facts for Predicate Act Thirty-Seven that were in support of Counts One and Two and are incorporated herein.

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COUNT THIRTY-EIGHT 82019 POSSESSION OF A CONTROLLED SUBSTANCE-SCHEDULE II4 GRAMS OR LESS, C.R.S 18-18-403.5(1), (2)(a)(I) (F6)

On or about May 18, 2012, in the State of Colorado, Lisa Teitelbaum, unlawfully, feloniously and knowingly possessed four grams or less of 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. COUNT THIRTY-NINE 35411 OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a) (F6)

On or about April 27, 2010 thorugh October 1, 2011, in the State of Colorado, Lisa Teitelbaum, unlawfully, feloniously, and knowingly obtained or procured the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of section 18-18-415(1)(a), C.R.S.

The essential facts for Counts Thirty-Eight and Thirty-Nine occurred as follows and also includes the facts previously summarized above in support of Predicate Acts Three and Four for Counts One and Two and are incorporated herein: On May 18, 2012 law enforcement officers from the North Metro Drug Task Force assisted the DEA and the South Metro Drug Task Force with a controlled purchase at the Platte Valley Pharmacy in Brighton. During this operation Lisa Teitelbaum was contacted with Christopher Peterson and Robin Steinke when it was discovered that Ms. Teitelbaum possessed four Oxycodone pills that day. COUNT FORTY 82053 CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE SCHEDULE II, C.R.S. 18-18-405(1),(2)(a)(I)(A) (F3)

On or about December 27, 2012 in the State of Colorado, Robin Steinke and Laurie Anne Larrew unlawfully, feloniously, and knowingly conspired with each and/or a person or persons to the Grand Jury unknown, to sell or distribute Oxycodone, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S.

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COUNT FORTY-ONE 3541JA CRIMINAL ATTEMPT TO COMMIT OBTAINING A CONTROLLED SUBSTANCE BY FRAUD OR DECEIT, C.R.S. 18-18-415(1)(a); 18-2-101 (F6)

On or about December 27, 2012, in the State of Colorado, by engaging in conduct constituting a substantial step toward the commission of obtaining a controlled substance by fraud or deceit, Robin Steinke and Laurie Ann Larrew, unlawfully, feloniously, and knowingly attempted to obtain or procure the administration of Oxycodone, a controlled substance, by fraud, deceit, misrepresentation, or subterfuge, the forgery or alteration of an order, and/or the concealment of a material fact in violation of sections 18-18415(1)(a), 18-2-101, C.R.S.

COUNT FORTY-TWO 10040 POSSESSION OF FORGED INSTRUMENT, C.R.S. 18-5-105 (F6)

On or about December 27, 2012, in the State of Colorado, Robin Steinke and Laurie Ann Larrew, unlawfully and feloniously possessed one or more forged instruments, namely: completed and blank precriptions as well as fraudulent identifications, with knowledge that the documents were forged and with intent to use the instruments to defraud; in violation of section 18-5-105, C.R.S.

COUNT FORTY-THREE 8201B POSSESSION OF METHAMPHETAMINE-LESS THAN 2 GRAMS, C.R.S. 18-18-403.5(1),(2), (b)(I) (F6)

On or about December 27, 2012 in the State of Colorado, Robin Steinke unlawfully, feloniously, and knowingly possessed more than two grams of a material, compound, mixture, preparation that contained Methamphetamine, a controlled substance, in violation of section 18-18-403.5(1),(2), (b)(I), C.R.S. The essential facts supporting the offenses alleged in Counts Forty through Forty-Three were previously summarized in support of Predicate Acts Thirty-Eight through Forty-One above that were in support of Counts One and Two and are incorporated herein.

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Subscribed to before me in the City and County of Denver, State of Colorado, this _________ day of January, 2013. ______________________________ Notary Public My commission expires:_______________________

JOHN W. SUTHERS Attorney General

ROBERT SHAPIRO, 26869 First Assistant Attorney General Special Prosecutions Unit Criminal Justice Section

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The 2012-2013 Colorado Statewide Grand Jury presents the Indictment contained within and the same is hereby ORDERED FILED this ________ day of January, 2013. Pursuant to 13-73-107, C.R.S., the Court designates ________________ County, Colorado as the county of venue for the purposes of trial.

Warrants are Issued for: Robin Steinke with a bond set at $ _____________________ Jeffrey Clawson with a bond set at $ _____________________ Celeste Deherrera with a bond set at $ _____________________ Leticia Deherrera with a bond set at $ _____________________ Shawna Lawley with a bond set at $ _____________________ Christopher Peterson with a bond set at $ _____________________ Joel Barr with a bond set at $ _____________________ Jacqueline Geist with a bond set at $ _____________________ Andrew Guerrero with a bond set at $ _____________________ Christopher Gemeinhardt with a bond set at $ _____________________ Lisa Teitelbaum with a bond set at $ ______________________ Sadie Grubbs with a bond set at $ ________________________ Daniel Burke with a bond set at $ ________________________ Laurie Ann Larrew with a bond set at $ ____________________

____________________________ District Court Judge, Second Judicial District

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I, ____________________________, the Foreperson of the 2012-2013 Colorado State Grand Jury, do hereby swear and affirm that each and every True Bill returned in this indictment by the 2012-2013 Colorado State Grand Jury was arrived at after deliberation and with the assent and agreement to the existence of probable cause by at least nine members of the Colorado State Grand Jury. The Colorado State Grand Jury further authorizes and instructs the Colorado Attorney General to return this indictment to open court with or without the presence of the foreperson. ______________________________ Foreperson

AS TO COUNT ONE: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT TWO: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT THREE: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT FOUR: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

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AS TO COUNT FIVE: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT SIX: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT SEVEN: A TRUE BILL _________________________

A NO TRUE BILL ____________________________

AS TO COUNT EIGHT: A TRUE BILL _________________________ Foreperson AS TO COUNT NINE: A TRUE BILL _________________________ Foreperson AS TO COUNT TEN: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

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AS TO COUNT ELEVEN: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT TWELVE: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT THIRTEEN: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT FOURTEEN: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT FIFTEEN: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT SIXTEEN: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

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AS TO COUNT SEVENTEEN: A TRUE BILL _________________________ Foreperson AS TO COUNT EIGHTEEN: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT NINETEEN: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT TWENTY: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT TWENTY-ONE: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT TWENTY-TWO: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT TWENTY-THREE: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

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AS TO COUNT TWENTY-FOUR: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT TWENTY-FIVE: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT TWENTY-SIX: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT TWENTY-SEVEN: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT TWENTY-EIGHT: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT TWENTY-NINE: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

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AS TO COUNT THIRTY: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT THIRTY-ONE: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT THIRTY-TWO: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT THIRTY-THREE: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT THIRTY-FOUR: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT THIRTY-FIVE: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

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AS TO COUNT THIRTY-SIX: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT THIRTY-SEVEN: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT THIRTY-EIGHT: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT THIRTY-NINE: A TRUE BILL _________________________ Foreperson AS TO COUNT FORTY: A TRUE BILL _________________________ Foreperson AS TO COUNT FORTY-ONE: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

AS TO COUNT FORTY-TWO: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

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AS TO COUNT FORTY-THREE: A TRUE BILL _________________________ Foreperson

A NO TRUE BILL ____________________________ Foreperson

Subscribed to before me in the City and County of Denver, State of Colorado, this _________ day of January, 2013. ______________________________ Notary Public My commission expires:_______________________

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