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

STATE OF COLORADO, v. DANIEL GALVAN ANTHONY HARVEY STUART KNOWLES LEOBARDO LOYA ABDON LOYA-SANCHEZ ALEXANDER ORAM FRANCISCO VALENCIA JOSEPH VITTUM DEREK DURICA MATTHEW BEKKERUS BRIAN BUTLER ANTHONY EMBRY CARL HAYES ANDRE ISLER GERALD LAMASTER GARY LIHUDIS MICHAEL MCCAIN BERNARDINO MENDOZA MARIA MORENO RONALD MUNGUIA-MARTIN JEROME NELSON KAMAL PATTERSON TONY ROMERO QUENTIN WALLACE ADRIAN HERNANDEZ ALEJANDRO URIBE ALAN JOHNSON JIMMIE JOE MONTGOMERY KENNETH WEST HORACIO BUGARIN MARK FRALEIGH MITCHELL MORRIS SHAWN BLEA Defendants.

COURT USE ONLY

JOHN W. SUTHERS, Attorney General ANNEMARIE L. BRAUN* Senior Assistant Attorney General 1525 Sherman Street, 7th Floor Denver, CO 80203 303-866-5738 Registration Number: 39877 *Counsel of Record

Case No.: GJ Case No.: 11CR01 Ctrm: 209

COLORADO STATE GRAND JURY SECOND SUPERSEDING INDICTMENT Of the 2011-2012 term of the Denver District Court in the year 2011; the 2011-2012 Colorado State Grand Jurors, chosen, selected and sworn in the name and by the authority of the People of the State of Colorado, upon their oaths, present the following: COUNT ONE: 37284 COCCA Pattern of Racketeering Participation in an Enterprise, 18-17-104(3), C.R.S., (F2) Daniel Galvan, Anthony Harvey, Stuart Knowles, Leobardo Loya, Abdon LoyaSanchez, Alexander Oram, Francisco Valencia, Joseph Vittum , Derek Durica, Alan Johnson, Jimmie Joe Montgomery, Kenneth West, and Horacio Bugarin COUNT TWO: 37284 COCCA Conspiracy, 18-17-104(4), C.R.S., (F2) Daniel Galvan, Anthony Harvey, Stuart Knowles, Leobardo Loya, Abdon LoyaSanchez, Alexander Oram, Francisco Valencia, Joseph Vittum, Derek Durica, Alan Johnson, Jimmie Joe Montgomery, Kenneth West, and Horacio Bugarin COUNT THREE: 82021 Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Francisco Valencia

COUNT FOUR: 82022

Distribution of a Schedule II Controlled Substance25 to 450 Grams, 18-18-405(1), (2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) Leobardo Loya

COUNT FIVE: 82022

Distribution of a Schedule II Controlled Substance25 to 450 Grams, 18-18-405(1), (2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) Leobardo Loya

COUNT SIX: 82022

Distribution of a Schedule II Controlled Substance25 to 450 Grams, 18-18-405(1), (2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) Leobardo Loya

COUNT SEVEN: 82022

Distribution of a Schedule II Controlled Substance25 to 450 Grams, 18-18-405(1), (2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) Alan Johnson, Alexander Oram

COUNT EIGHT: 82022

Distribution of a Schedule II Controlled Substance25 to 450 Grams, 18-18-405(1), (2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) Alan Johnson, Alexander Oram

COUNT NINE: 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Anthony Harvey

COUNT TEN: 82041

Possession with Intent to Distribute a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Alan Johnson, Alexander Oram

COUNT ELEVEN: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Abdon Loya-Sanchez

COUNT TWELVE: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Alan Johnson, Alexander Oram

COUNT THIRTEEN: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Alexander Oram

COUNT FOURTEEN: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Stuart Knowles

COUNT FIFTEEN: 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Francisco Valencia

COUNT SIXTEEN: 82022

Distribution of a Schedule II Controlled Substance25 to 450 Grams, 18-18-405(1), (2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) Joseph Vittum

COUNT SEVENTEEN: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Daniel Galvan, Francisco Valencia

COUNT EIGHTEEN: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Daniel Galvan, Stuart Knowles

COUNT NINETEEN: 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Daniel Galvan

COUNT TWENTY: 82041

Possession with Intent to Distribute a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Stuart Knowles

COUNT TWENTY-ONE: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Abdon Loya-Sanchez

COUNT TWENTY-TWO: 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Abdon Loya-Sanchez

COUNT TWENTY-THREE: 82041

Possession with Intent to Distribute a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Anthony Harvey

COUNT TWENTY-FOUR: 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Anthony Embry

COUNT TWENTY-FIVE: 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Quentin Wallace

COUNT TWENTY-SIX: 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Anthony Embry

COUNT TWENTY-SEVEN: 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Andre Isler

COUNT TWENTY-EIGHT: 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Quentin Wallace

COUNT TWENTY-NINE: 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Ronald Munguia-Martin

COUNT THIRTY: 82041

Possession with Intent to Distribute a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Gerald Lamaster

COUNT THIRTY-ONE:

Possession of a Schedule II Controlled Substance More than a Gram, 18-18-403.5(1),(2)(a)(I), C.R.S. (F6) Gerald Lamaster

COUNT THIRTY-TWO: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Derek Durica

COUNT THIRTY-THREE: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Carl Hayes

COUNT THIRTY-FOUR: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Kamal Patterson

COUNT THIRTY-FIVE: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Derek Durica

COUNT THIRTY-SIX: 30011

Possession of a Dangerous Weapon 18-12-102(3) (F5) Jerome Nelson

COUNT THIRTY-SEVEN: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Derek Durica

COUNT THIRTY-EIGHT 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Anthony Harvey

COUNT THIRTY-NINE:

Possession of a Schedule II Controlled Substance More than a Gram, 18-18-403.5(1),(2)(a)(I), C.R.S. (F6) Matthew Bekkerus

COUNT FORTY: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Gary Lihudis

COUNT FORTY-ONE: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Maria Moreno

COUNT FORTY-TWO 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Jerome Nelson

COUNT FORTY-THREE: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Quentin Wallace

COUNT FORTY-FOUR: 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Anthony Harvey

COUNT FORTY-FIVE: 82041

Possession with Intent to Distribute a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Quentin Wallace

COUNT FORTY-SIX: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Gary Lihudis

COUNT FORTY-SEVEN: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Michael McCain

COUNT FORTY-EIGHT: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Derek Durica

COUNT FORTY-NINE:

Distribution of Marijuana Between 5 and 100 Pounds, 18-18-406(6)(b)(I),(III)(B), C.R.S., (F4) Abdon Loya-Sanchez, Anthony Harvey

COUNT FIFTY:

Possession with Intent to Distribute Marijuana Between 5 and 100 Pounds, 18-18-406(6)(b)(I),(III)(B), C.R.S., (F4) Brian Butler

COUNT FIFTY-ONE: 82042

Possession with Intent to Distribute a Schedule II Controlled Substance25 to 450 Grams, 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S., (F3) Leobardo Loya

COUNT FIFTY-TWO: 82041

Possession with Intent to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Leobardo Loya

COUNT FIFTY-THREE: 82042

Possession with Intent to Distribute a Schedule II Controlled Substance25 to 450 Grams, 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S., (F3) Abdon Loya-Sanchez

COUNT FIFTY-FOUR:

Possession with Intent to Distribute Marijuana Between 5 and 100 Pounds, 18-18-406(6)(b)(I),(III)(B), C.R.S., (F4) Abdon Loya-Sanchez

COUNT FIFTY-FIVE: 82022

Distribution of a Schedule II Controlled Substance25 to 450 Grams, 18-18-405(1), (2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) Tony Romero

COUNT FIFTY-SIX: 82043

Possession with Intent to Distribute a Schedule II Controlled Substance450 to 1000 Grams, 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S., (F3) Alexander Oram

COUNT FIFTY-SEVEN: 33445

Possession of a Deadly Weapon (Special Offender) 18-18-407(1)(f)(I), C.R.S. Alexander Oram

COUNT FIFTY-EIGHT: 82043

Possession with Intent to Distribute a Schedule II Controlled Substance450 to 1000 Grams, 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S., (F3) Francisco Valencia

COUNT FIFTY-NINE: 33445

Possession of a Deadly Weapon (Special Offender) 18-18-407(1)(f)(I), C.R.S. Francisco Valencia

10

COUNT SIXTY: 30074

Possession of a Weapon by a Previous Offender, 18-12-108(1), C.R.S., (F6) Bernardino Mendoza

COUNT SIXTY-ONE:

Cultivation of Marijuana, 18-18-406(7.5)(c), C.R.S., (F4) Daniel Galvan

COUNT SIXTY-TWO: 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Andre Isler, Anthony Embry

COUNT SIXTY-THREE: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Tony Romero

COUNT SIXTY-FOUR: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Anthony Harvey, Stuart Knowles

COUNT SIXTY-FIVE: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Abdon Loya-Sanchez, Adrian Hernandez

COUNT SIXTY-SIX: 82022

Distribution of a Schedule II Controlled Substance25 to 450 Grams, 18-18-405(1), (2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) Abdon Loya-Sanchez

11

COUNT SIXTY-SEVEN: 82042

Possession with Intent to Distribute a Schedule II Controlled Substance25 to 450 Grams, 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S., (F3) Adrian Hernandez

COUNT SIXTY-EIGHT: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Abdon Loya-Sanchez, Alejandro Uribe

COUNT SIXTY-NINE: 82022

Distribution of a Schedule II Controlled Substance25 to 450 Grams, 18-18-405(1), (2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) Alan Johnson

COUNT SEVENTY: 82022

Distribution of a Schedule II Controlled Substance25 to 450 Grams, 18-18-405(1), (2)(a)(I)(A), (3)(a)(I), C.R.S., (F3) Alan Johnson

COUNT SEVENTY-ONE: 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Alan Johnson

COUNT SEVENTY-TWO: 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Jimmie Joe Montgomery

COUNT SEVENTY-THREE: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Alan Johnson, Kenneth West

12

COUNT SEVENTY-FOUR: 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Alan Johnson

COUNT SEVENTY-FIVE: 82041

Possession with Intent to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Kenneth West

COUNT SEVENTY-SIX: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Alan Johnson, Mark Fraleigh

COUNT SEVENTY-SEVEN: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Alan Johnson, Mitchell Morris

COUNT SEVENTY-EIGHT: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Alan Johnson, Horacio Bugarin

COUNT SEVENTY-NINE: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Alan Johnson, Shawn Blea

COUNT EIGHTY: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Alan Johnson, Anthony Harvey

13

COUNT EIGHTY-ONE: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Alan Johnson, Jimmie Joe Montgomery

COUNT EIGHTY-TWO: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Alan Johnson, Horacio Bugarin

COUNT EIGHTY-THREE: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Alan Johnson, Horacio Bugarin

COUNT EIGHTY-FOUR: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Alan Johnson, Horacio Bugarin

COUNT EIGHTY-FIVE: 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Horacio Bugarin

COUNT EIGHTY-SIX: 82041

Possession with Intent to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Alan Johnson

COUNT EIGHTY-SEVEN: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Alan Johnson, Anthony Harvey

14

COUNT EIGHTY-EIGHT: 82021

Distribution of a Schedule II Controlled Substance, 18-18-405(1), (2)(a)(I)(A), C.R.S., (F3) Anthony Harvey

COUNT EIGHTY-NINE: 82041

Possession with Intent to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Alan Johnson

COUNT NINETY: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Alan Johnson, Anthony Harvey

COUNT NINETY-ONE: 82023

Distribution of a Schedule II Controlled Substance450 to 1000 Grams, 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S., (F3) Alan Johnson

COUNT NINETY-TWO: 82043

Possession with Intent to Distribute a Schedule II Controlled Substance450 to 1000 Grams, 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S., (F3) Horacio Bugarin

COUNT NINETY-THREE: 82042

Possession with Intent to Distribute a Schedule II Controlled Substance25 to 450 Grams, 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S., (F3) Horacio Bugarin

COUNT NINETY-FOUR: 33445

Possession of a Deadly Weapon (Special Offender) 18-18-407(1)(f)(I), C.R.S. Horacio Bugarin

15

COUNT NINETY-FIVE: 82053

Conspiracy to Distribute a Schedule II Controlled Substance, 18-18-405(1),(2)(a)(I)(A), C.R.S., (F3) Abdon Loya-Sanchez, Alejandro Uribe

16

COUNT ONE VIOLATION OF THE COLORADO ORGANIZED CRIME CONTROL ACT PATTERN OF RACKETEERINGPARTICIPATION IN AN ENTERPRISE, C.R.S. 18-17-104(3) and 18-17-105 (F2) Between the dates of January 1, 2009 and September 29, 2011, in the State of Colorado, Daniel Galvan, Anthony Harvey, Stuart Knowles, Leobardo Loya, Abdon Loya-Sanchez, Alexander Oram, Francisco Valencia, Joseph Vittum, Derek Durica, Alan Johnson, Jimmie Joe Montgomery, Kenneth West, and Horacio Bugarin and others both known and unknown, while employed by or associated with an enterprise, unlawfully, feloniously, and knowingly conducted or participated, directly or indirectly, in the enterprise through a pattern of racketeering activity: in violation of sections 18-17-104(3) and 18-17-105, C.R.S. COUNT TWO VIOLATION OF THE COLORADO ORGANIZED CRIME CONTROL ACT CONSPIRACY/ENDEAVORING, C.R.S. 18-17-104(4) (F2) Between the dates of January 1, 2009 and September 29, 2011, in the State of Colorado, Daniel Galvan, Anthony Harvey, Stuart Knowles, Leobardo Loya, Abdon Loya-Sanchez, Alexander Oram, Francisco Valencia, Joseph Vittum, Derek Durica, Alan Johnson, Jimmie Joe Montgomery, Kenneth West, and Horacio Bugarin and others both known and unknown, did unlawfully, knowingly, and feloniously conspire and endeavor to conduct and participate, directly or indirectly, in an enterprise, through a pattern of racketeering activity in violation of C.R.S. 18-17-104(4) and 18-17-104(3), C.R.S. The offenses alleged in Counts One and Two were committed in the following manner: The Enterprise The enterprise alleged in counts one and two was primarily a group of individuals, associated in fact, although not a legal entity. The enterprise included, but was not limited to, the following associated in fact individuals and/or legal entities: Daniel Galvan, Anthony Harvey, Stuart Knowles, Leobardo Loya, Abdon LoyaSanchez, Alexander Oram, Francisco Valencia, Joseph Vittum, Derek Durica, Alan Johnson, Jimmie Joe Montgomery, Kenneth West, and Horacio Bugarin and others both known and unknown to the Grand Jury. The individuals associated with the enterprise had a primary objective and a common purpose to distribute large quantities of illegal controlled substances, including cocaine and methamphetamine, both Schedule II Controlled Substances, and marijuana, throughout the Northern Colorado area to various customers. Both Anthony Harvey and Daniel Galvan supplied their respective dealers with these illegal controlled 17

substances. These dealers included Stuart Knowles, Leobardo Loya, Alexander Oram, Francisco Valencia, Joseph Vittum, Derek Durica, and Alan Johnson. Alan Johnson, in turn, supplied his runners, Alexander Oram, Kenneth West, and Jimmie Joe Montgomery with cocaine and methamphetamine for further distribution. Anthony Harvey, Daniel Galvan, and Alan Johnson, together with their respective dealers including Stuart Knowles, Leobardo Loya, Alexander Oram, Francisco Valencia, Joseph Vittum, Derek Durica, Kenneth West and Jimmie Joe Montgomery relied upon and utilized a system of cellular telephones and other telecommunications facilities to arrange and execute the distribution of these illegal controlled substances throughout Northern Colorado. Further, Anthony Harvey, Daniel Galvan, and Alan Johnson used these cellular telephones to communicate with their various sources of supply for these illegal controlled substances, including Abdon Loya-Sanchez and Horacio Bugarin. Because the members of the criminal enterprise used cellular telephones so extensively to conduct the business and operations of the enterprise, the members often utilized coded terminology when speaking to each other on the telephone in order to conceal their criminal activities. Pattern of Racketeering Activity Daniel Galvan, Anthony Harvey, Stuart Knowles, Leobardo Loya, Abdon LoyaSanchez, Alexander Oram, Francisco Valencia, Joseph Vittum, Derek Durica, Alan Johnson, Jimmie Joe Montgomery, Kenneth West, and Horacio Bugarin directly and in concert, engaged in, attempted to engage in, conspired to engage in, or solicited another to engage in at least two predicate acts, including any lesser offenses, related to the conduct of the enterprise, with at least one of which took place in the State of Colorado after July 1, 1981 and the last of the acts of racketeering activity occurring within ten years after a prior act of racketeering activity and include: Distribution of a Controlled Substance Schedule II Possession with Intent to Distribute a Controlled Substance Schedule II Conspiracy to Distribute a Controlled Substance Schedule II Unlawful Use of a Telecommunications Facility

Racketeering Activity The acts of racketeering activity that the above named persons committed, attempted to commit, conspired to commit, or solicited, coerced, or intimidated another person to commit, consist of the following predicate acts, including any lesser included offenses: 18

PREDICATE ACT ONE Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about July 2, 2009, in the State of Colorado, Daniel Galvan unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. The offense alleged in Predicate Act One was committed in the following manner: On July 2nd, 2009, a confidential informant working in cooperation with and at the direction of law enforcement officers drove to THE SHOP, a business located at 1925 S. Timberline Road in Fort Collins. Daniel GALVAN and an individual identifiable only as Andy LNU came out and met the CI in his/her car. While Daniel GALVAN was standing there, taking an active role in the deal, Andy LNU handed the CI one ounce of cocaine and the CS paid Andy LNU $475.00. PREDICATE ACT TWO Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about July 10, 2010, in the State of Colorado, Stuart Knowles unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.

The offense alleged in Predicate Act Two was committed in the following manner: On or about July 10, 2010, Stuart Knowles sold a nine-ounce quantity of cocaine to a confidential source, who is fully identifiable to Northern Colorado Drug Task Force detectives.

19

PREDICATE ACT THREE Distribution of a Controlled Substance Schedule II, (F3) On or about June 24, 2011, in the State of Colorado, Francisco Valencia unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Predicate Act Three was committed in the following manner: On June 24, 2011, Francisco Valencia sold a quantity of cocaine to Ronald Munguia-Martin in the parking lot at 2519 S. Shields St. in Fort Collins. PREDICATE ACT FOUR Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about August 10, 2011, in the State of Colorado, Leobardo Loya unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. PREDICATE ACT FIVE Unlawful Use of a Communication Facility On or about August 10, 2011, in the State of Colorado, Leobardo Loya did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Four and Five were committed in the following manner: On August 10, 2011, Leobardo Loya sold a one-ounce quantity of cocaine to a confidential informant in the parking lot of the King Soopers parking lot located at Willox and College Ave in Fort Collins. Leobardo Loya utilized his cellular telephone (970) 412-9227 to arrange and coordinate the delivery of the cocaine.

20

PREDICATE ACT SIX Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about August 12, 2011, in the State of Colorado, Leobardo Loya unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. PREDICATE ACT SEVEN Unlawful Use of a Communication Facility On or about August 12, 2011, in the State of Colorado, Leobardo Loya, did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Six and Seven were committed in the following manner: On August 12, 2011, Leobardo Loya sold a one-ounce quantity of cocaine to a confidential informant in the parking lot of Sports Authority parking lot, at 425 S College Ave. in Fort Collins. Leobardo Loya utilized his cellular telephone (970) 213-3222 to arrange and coordinate the delivery of the cocaine. PREDICATE ACT EIGHT Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about September 14, 2011, in the State of Colorado, Leobardo Loya unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.

21

PREDICATE ACT NINE Unlawful Use of a Communication Facility On or about September 14, 2011, in the State of Colorado, Leobardo Loya, did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Eight and Nine were committed in the following manner: On September 14, 2011, Leobardo Loya sold a three-ounce quantity of cocaine to a confidential informant in the parking lot of the King Soopers parking lot located at Willox and College Ave in Fort Collins. Leobardo Loya utilized his cellular telephone (970) 213-3222 to arrange and coordinate the delivery of the cocaine. PREDICATE ACT TEN Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about August 4, 2011, in the State of Colorado, Alan Johnson and Alexander Oram unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. PREDICATE ACT ELEVEN Unlawful Use of a Communication Facility On or about August 4, 2011, in the State of Colorado, Alan Johnson and Alexander Oram did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Ten and Eleven were committed in the following manner: On August 4, 2011, Alan Johnson directed Alexander Oram to sell a three-ounce quantity of cocaine to a confidential informant. Alexander Oram then sold a threeounce quantity of cocaine to the confidential informant from his residence at 1025 22

Cunningham Drive, apartment C-6 in Fort Collins. Alan Johnson utilized his cellular telephone 970-308-1614 and Alexander Oram utilized his cellular telephone number 970-690-9788 to arrange and coordinate this delivery of the cocaine. PREDICATE ACT TWELVE Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about August 16, 2011, in the State of Colorado, Alan Johnson and Alexander Oram unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. PREDICATE ACT THIRTEEN Unlawful Use of a Communication Facility On or about August 16, 2011, in the State of Colorado, Alan Johnson and Alexander Oram did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Twelve and Thirteen were committed in the following manner: On or about August 16, 2011, Alan Johnson directed Alexander Oram to sell a fiveounce quantity of cocaine to a confidential informant. On that date, Oram, based on Alan Johnsons express direction to Oram, delivered the five-ounce quantity of cocaine to the confidential informant from Orams residence at 1025 Cunningham Drive, apartment C-6 in Fort Collins. Alan Johnson utilized his cellular telephone number to arrange and coordinate the delivery of the cocaine with both Alexander Oram and the confidential informant. Alexander Oram utilized his cellular telephone number 970-690-9788 to arrange and coordinate the delivery of the cocaine. PREDICATE ACT FOURTEEN Distribution of a Controlled Substance Schedule II, (F3) On or about August 24, 2011, in the State of Colorado, Anthony Harvey unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. 23

PREDICATE ACT FIFTEEN Possession with Intent to Distribute a Controlled Substance, (F3) On or about August 24, 2011, in the State of Colorado, Alan Johnson and Alexander Oram unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A),(3), C.R.S. PREDICATE ACT SIXTEEN Unlawful Use of a Communication Facility On or about August 24, 2011, in the State of Colorado, Anthony Harvey, Alan Johnson and Alexander Oram did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Fourteen through Sixteen were committed in the following manner: On August 24, 2011, Alan Johnson, Alexander Oram and Anthony Harvey agreed that Harvey would distribute a quantity of cocaine to Alan Johnson by delivering the cocaine to Johnsons runner, Alexander Oram, who would pick up the cocaine from Harvey at Harveys shop. Alexander Oram went to Anthony Harveys shop located at 200 Commerce Drive Unit #G in Fort Collins, CO. There, Harvey gave Oram a quantity of cocaine. Oram took the quantity of cocaine and then purchased a cutting agent, in order to process the cocaine for further distribution. Johnson utilized his cellular telephone 970-308-1614, Harvey utilized his cellular telephone 970-3882208 and Oram utilized his cellular telephone number 970-690-9788 to arrange and coordinate this delivery of the cocaine. PREDICATE ACT SEVENTEEN Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 26, 2011, in the State of Colorado, Anthony Harvey and Abdon Loya-Sanchez unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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PREDICATE ACT EIGHTEEN Unlawful Use of a Communication Facility On or about August 26, 2011, in the State of Colorado, Anthony Harvey and Abdon Loya-Sanchez did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Seventeen and Eighteen were committed in the following manner: On August 26, 2011, Anthony Harvey and Abdon Loya-Sanchez agreed that LoyaSanchez would distribute a quantity of cocaine to Harvey in exchange for money. In furtherance of this agreement, Harvey then went to meet Loya- Sanchez in the parking lot in the 900 block of E. Harmony Road in Fort Collins, CO. There, Harvey gave Loya-Sanchez money that comprised proceeds from the sale of cocaine and received a quantity of cocaine from Loya-Sanchez. Harvey utilized his cellular telephone 970-388-2208 and Loya-Sanchez utilized his cellular telephone number 307-215-4762 to arrange and coordinate this meeting in reference to the delivery of the cocaine. PREDICATE ACT NINETEEN Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 27, 2011, in the State of Colorado, Anthony Harvey, Alan Johnson and Alexander Oram unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT TWENTY Unlawful Use of a Communication Facility On or about August 27, 2011, in the State of Colorado, Anthony Harvey, Alan Johnson and Alexander Oram did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Nineteen and Twenty were committed in the following manner: On August 27, 2011, Alan Johnson and Anthony Harvey agreed that Harvey would distribute a quantity of cocaine to Alan Johnson and that Johnson would have his 25

runner, Alexander Oram, pick up the cocaine from Harvey. Alexander Oram and Anthony Harvey agreed that Harvey would distribute a quantity of cocaine to Oram in exchange for money. In furtherance of this agreement, Oram then went to Anthony Harveys shop located at 200 Commerce Drive Unit #G in Fort Collins, CO. There, Harvey gave Oram a quantity of cocaine. Harvey utilized his cellular telephone 970-388-2208 and Oram utilized his cellular telephone number 970-6909788 and 404-908-7309 to arrange and coordinate this delivery of the cocaine. PREDICATE ACT TWENTY-ONE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 3, 2011, in the State of Colorado, Anthony Harvey and Alexander Oram unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT TWENTY-TWO Unlawful Use of a Communication Facility On or about September 3, 2011, in the State of Colorado, Anthony Harvey and Alexander Oram did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Twenty-One and Twenty-Two were committed in the following manner: On September 3, Alexander Oram and Anthony Harvey agreed that Harvey would distribute a quantity of cocaine to Oram in exchange for money. In furtherance of this agreement, Oram then went to Anthony Harveys home located at 2420 Manchester Drive in Fort Collins, CO. Harvey utilized his cellular telephone 970388-2208 and Oram utilized his cellular telephone number 970-690-9788 to arrange and coordinate this conspiracy to distribute cocaine. PREDICATE ACT TWENTY-THREE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 6, 2011, in the State of Colorado, Anthony Harvey and Stuart Knowles unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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PREDICATE ACT TWENTY-FOUR Unlawful Use of a Communication Facility On or about September 6, 2011, in the State of Colorado, Anthony Harvey and Stuart Knowles did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Twenty-Three and Twenty-Four were committed in the following manner: On September 6, 2011, Anthony Harvey and Stuart Knowles agreed that Harvey would distribute a quantity of cocaine to Knowles in exchange for money. In furtherance of this agreement, Knowles then went to Anthony Harveys home located at 2040 Manchester Drive in Fort Collins, CO. Harvey utilized his cellular telephone 970-388-2208 and Knowles utilized his cellular telephone number 970481-8858 to arrange and coordinate this conspiracy to distribute cocaine. PREDICATE ACT TWENTY-FIVE Distribution of a Controlled Substance Schedule II, (F3) On or about September 8, 2011, in the State of Colorado, Francisco Valencia unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT TWENTY-SIX Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about September 8, 2011, in the State of Colorado, Joseph Vittum unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. The offenses alleged in Predicate Acts Twenty-Five and Twenty-Six were committed in the following manner: On September 8, 2011, Francisco Valencia distributed a quantity of cocaine to Joseph Vittum at Valencias residence located 1007 Whalers Way in Fort Collins. From Valencias residence, Vittum then traveled to 3657 S. College Ave. in Fort 27

Collins. There, Vittum distributed a one-ounce quantity of cocaine to a confidential informant who was working in cooperation with and at the direction of law enforcement.

PREDICATE ACT TWENTY-SEVEN Conspiracy to Distribute a Controlled Substance Schedule II, (F3) Between the dates of September 8 through September 13, 2011, in the State of Colorado, Daniel Galvan and Francisco Valencia unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT TWENTY-EIGHT Unlawful Use of a Communication Facility Between the dates of September 8, 2011 through September 13, 2011, in the State of Colorado, Daniel Galvan and Francisco Valencia did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Twenty-Seven and Twenty-Eight were committed in the following manner: Beginning on September 8, 2011, and continuing through September 13, 2011, Daniel Galvan and Francisco Valencia had a series of telephone conversations and ultimately agreed that Galvan would distribute a quantity of cocaine to Valencia in exchange for money. In furtherance of this agreement, Galvan then traveled to Valencias residence at 1007 Whalers Way in Fort Collins, CO. There, Galvan delivered a quantity of cocaine to Valencia. Galvan utilized his cellular telephone 970-682-8515 and Valencia utilized his cellular telephone number 970-488-9294 to arrange and coordinate this delivery of cocaine. PREDICATE ACT TWENTY-NINE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) Between the dates of September 19, 2011, through September 20, 2011, in the State of Colorado, Daniel Galvan and Stuart Knowles unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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PREDICATE ACT THIRTY Distribution of a Controlled Substance Schedule II, (F3) On or about September 20, 2011, in the State of Colorado, Daniel Galvan unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT THIRTY-ONE Possession with Intent to Distribute a Controlled Substance, (F3) On or about September 20, 2011, in the State of Colorado, Stuart Knowles unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A),(3), C.R.S. PREDICATE ACT THIRTY TWO Unlawful Use of a Communication Facility Between the dates of September 19, 2011, through September 20, 2011, in the State of Colorado, Daniel Galvan and Stuart Knowles did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Twenty-Nine, Thirty, Thirty-One, and Thirty Two were committed in the following manner: On September 20, 2011, Daniel Galvan and Stuart Knowles agreed that Galvan would distribute a quantity of cocaine to Knowles in exchange for money. In furtherance of this agreement, Knowles then met Galvan at the 7-11 convenience store located at 970 W. Horsetooth in Fort Collins, CO. There, Galvan delivered a quantity of cocaine to Knowles. Galvan utilized his cellular telephone 970-682-8515 and Knowles utilized his cellular telephone number 970-481-8858 to arrange and coordinate this delivery of cocaine. PREDICATE ACT THIRTY-THREE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 24, 2011, in the State of Colorado, Anthony Harvey and Abdon Loya-Sanchez unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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PREDICATE ACT THIRTY-FOUR Distribution of a Controlled Substance Schedule II, (F3) On or about September 24, 2011, in the State of Colorado, Abdon Loya-Sanchez unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

PREDICATE ACT THIRTY-FIVE Possession with Intent to Distribute a Controlled Substance, (F3) On or about September 24, 2011, in the State of Colorado, Anthony Harvey unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A),(3), C.R.S. PREDICATE ACT THIRTY-SIX Unlawful Use of a Communication Facility On or about September 24, 2011, in the State of Colorado, Anthony Harvey and Abdon Loya-Sanchez did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Thirty-Three, Thirty-Four, Thirty-Five and Thirty-Six were committed in the following manner: On September 24, 2011, Abdon Loya-Sanchez and Anthony Harvey agreed that Loya-Sanchez would distribute a quantity of cocaine to Harvey in exchange for money. In furtherance of this agreement, Loya-Sanchez then met Harvey at Harveys shop located at 204 Commerce Drive Unit #D and #E in Fort Collins, CO. There, Loya-Sanchez delivered a quantity of cocaine to Harvey. Loya-Sanchez utilized his cellular telephone 307-215-4672 and Harvey utilized his cellular telephone number 970-388-2208 to arrange and coordinate this delivery of cocaine. PREDICATE ACT THIRTY-SEVEN Unlawful Use of a Communication Facility On or about September 8, 2011, in the State of Colorado, Joseph Vittum did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. 30

The offenses alleged in Predicate Acts Thirty-Seven and Thirty- Eight were committed in the following manner: On September 8, 2011, Vittum distributed a one-ounce quantity of cocaine to a confidential informant who was working in cooperation with and at the direction of law enforcement. Vittum utilized his cellular telephone to arrange and coordinate this delivery of cocaine to the confidential informant. PREDICATE ACT THIRTY-EIGHT Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 24, 2011, in the State of Colorado, Anthony Harvey and Derek Durica unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT THIRTY-NINE Unlawful Use of a Communication Facility On or about August 24, 2011, in the State of Colorado, Anthony Harvey and Derek Durica did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Thirty-Eight and Thirty-Nine were committed in the following manner: On August 24, 2011, Derek Durica and Anthony Harvey agreed that Harvey would distribute a quantity of cocaine to Durica in exchange for money. In furtherance of this agreement, Durica then went to Anthony Harveys shop located at 200 Commerce Drive Unit #G in Fort Collins, CO. There, Harvey gave Durica a quantity of cocaine. Harvey utilized his cellular telephone 970-388-2208 and Durica utilized his cellular telephone number 970-217-7744 to arrange and coordinate this delivery of the cocaine. PREDICATE ACT FORTY Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 24, 2011, in the State of Colorado, Anthony Harvey and Carl Hayes unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, 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 FORTY-ONE Unlawful Use of a Communication Facility On or about August 24, 2011, in the State of Colorado, Anthony Harvey did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Forty and Forty-One were committed in the following manner: On August 24, 2011, Carl Hayes and Anthony Harvey agreed that Harvey would distribute a quantity of cocaine to Hayes in exchange for money. In furtherance of this agreement, Hayes then went to Anthony Harveys shop located at 200 Commerce Drive Unit #G in Fort Collins, CO. There, Harvey gave Hayes a quantity of cocaine. Harvey utilized his cellular telephone 970-388-2208 and Hayes utilized his cellular telephone number 832-279-7728 to arrange and coordinate this delivery of the cocaine. PREDICATE ACT FORTY-TWO Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 24, 2011, in the State of Colorado, Anthony Harvey and Kamal Patterson unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 1818-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT FORTY-THREE Unlawful Use of a Communication Facility On or about August 24, 2011, in the State of Colorado, Anthony Harvey did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Forty-Two and Forty-Three were committed in the following manner: On or about August 24, 2011, Kamal Patterson and Anthony Harvey agreed that Harvey would distribute a quantity of cocaine to Patterson in exchange for money. In furtherance of this agreement, Patterson then went to Anthony Harveys shop located at 200 Commerce Drive Unit #G in Fort Collins, CO. There, Patterson gave Harvey a quantity of US currency so that Harvey could use that money to ultimately 32

acquire a quantity of cocaine from Harveys source of supply. Harvey utilized his cellular telephone 970-388-2208 and Patterson utilized his cellular telephone number 719-388-6449 to arrange and coordinate this delivery of cash towards the purchase of cocaine. PREDICATE ACT FORTY-FOUR Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 26, 2011, in the State of Colorado, Anthony Harvey and Derek Durica unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT FORTY-FIVE Unlawful Use of a Communication Facility On or about August 26, 2011, in the State of Colorado, Anthony Harvey and Derek Durica did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Forty-Four and Forty-Five were committed in the following manner: On August 26, 2011, Derek Durica and Anthony Harvey agreed that Harvey would distribute a quantity of cocaine to Durica in exchange for money. In furtherance of this agreement, Durica then went to Anthony Harveys shop located at 200 Commerce Drive Unit #G in Fort Collins, CO. There, Harvey gave Durica a quantity of cocaine. Harvey utilized his cellular telephone 970-388-2208 and Durica utilized his cellular telephone number 970-217-7744 to arrange and coordinate this delivery of the cocaine. PREDICATE ACT FORTY-SIX Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 2, 2011, in the State of Colorado, Anthony Harvey and Derek Durica unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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PREDICATE ACT FORTY-SEVEN Unlawful Use of a Communication Facility On or about September 2, 2011, in the State of Colorado, Anthony Harvey and Derek Durica did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Forty-Six and Forty-Seven were committed in the following manner: On September 2, 2011, Derek Durica and Anthony Harvey agreed that Harvey would distribute a quantity of cocaine to Durica in exchange for money. In furtherance of this agreement, Durica then met Anthony Harvey at a parking lot 200 Linden Street in Fort Collins, CO. There, Durica gave Harvey a quantity of US currency so that Harvey could use that money to ultimately acquire a quantity of cocaine from Harveys source of supply. Harvey utilized his cellular telephone 970388-2208 and Durica utilized his cellular telephone number 970-217-7744 to arrange and coordinate this delivery of cash towards the purchase of cocaine. PREDICATE ACT FORTY-EIGHT Distribution of a Controlled Substance Schedule II, (F3) On or about September 3, 2011, in the State of Colorado, Anthony Harvey unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Predicate Act Forty-Eight was committed in the following manner: On September 3, 2011, Anthony Harvey delivered a quantity of cocaine to Matthew Bekkerus at Anthony Harveys residence located at 2040 Manchester in Fort Collins, CO. PREDICATE ACT FORTY-NINE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 3, 2011, in the State of Colorado, Anthony Harvey and Gary Lihudis unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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PREDICATE ACT FIFTY Unlawful Use of a Communication Facility On or about September 3, 2011, in the State of Colorado, Anthony Harvey did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843.

The offenses alleged in Predicate Acts Forty-Nine and Fifty were committed in the following manner: On September 3, 2011, Gary Lihudis and Anthony Harvey agreed that Harvey would distribute a quantity of cocaine to Lihudis in exchange for money. In furtherance of this agreement, Lihudis then went to Anthony Harveys residence located at 2040 Manchester in Fort Collins, CO. There, Harvey gave Lihudis a quantity of cocaine. Harvey utilized his cellular telephone 970-388-2208 and Lihudis utilized his cellular telephone number 970-231-8105 to arrange and coordinate this delivery of the cocaine. PREDICATE ACT FIFTY-ONE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) Between the dates of September 3, 2011, and September 10, 2011, in the State of Colorado, Anthony Harvey and Maria Moreno unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT FIFTY-TWO Unlawful Use of a Communication Facility Between the dates of September 3, 2011, and September 10, 2011, in the State of Colorado, Anthony Harvey did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Fifty-One and Fifty-Two were committed in the following manner: Beginning on September 3, 2011, Maria Moreno and Anthony Harvey agreed that Harvey would distribute a quantity of cocaine to Moreno in exchange for money. In furtherance of this agreement, on September 3, 2011, Moreno then went to Anthony 35

Harveys shop located at 200 Commerce Drive, Unit #G in Fort Collins, CO. There, Moreno gave Harvey a quantity of US currency so that Harvey could use that money to ultimately acquire a quantity of cocaine from Harveys source of supply. Harvey utilized his cellular telephone 970-388-2208 and Moreno utilized her cellular telephone number 970-286-9717 to arrange and coordinate this delivery of the cocaine. PREDICATE ACT FIFTY-THREE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 7, 2011, in the State of Colorado, Anthony Harvey and Jerome Nelson unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT FIFTY-FOUR Unlawful Use of a Communication Facility On or about September 7, 2011, in the State of Colorado, Anthony Harvey did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Fifty-Three and Fifty-Four were committed in the following manner: On September 7, 2011, Jerome Nelson and Anthony Harvey agreed that Harvey would distribute a quantity of cocaine to Nelson in exchange for money. In furtherance of this agreement, Nelson then went to Anthony Harveys shop located at 204 Commerce Drive, Unit #D in Fort Collins, CO. There, Nelson received a quantity of cocaine that Harvey had designated for Nelson at Harveys shop. Harvey utilized his cellular telephone 970-388-2208 and Nelson utilized his cellular telephone number 970-213-1503 to arrange and coordinate this delivery of cocaine. PREDICATE ACT FIFTY-FIVE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 7, 2011, in the State of Colorado, Anthony Harvey and Quentin Wallace unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

36

PREDICATE ACT FIFTY-SIX Distribution of a Controlled Substance Schedule II, (F3) On or about September 7, 2011, in the State of Colorado, Anthony Harvey unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

PREDICATE ACT FIFTY-SEVEN Unlawful Use of a Communication Facility On or about September 7, 2011, in the State of Colorado, Anthony Harvey did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Fifty-Five through Fifty-Seven were committed in the following manner: On September 7, 2011, Anthony Harvey and Quentin Wallace agreed that Harvey would distribute a quantity of cocaine to Wallace in exchange for money. In furtherance of this agreement, Wallace then met Harvey at his residence, 2040 Manchester in Fort Collins, CO. There, Harvey delivered a quantity of cocaine to Wallace. Harvey utilized his cellular telephone 970-388-2208 and Wallace utilized his cellular telephone number 970-599-8451 to arrange and coordinate this delivery of cocaine. PREDICATE ACT FIFTY-EIGHT Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 9, 2011, in the State of Colorado, Anthony Harvey and Gary Lihudis unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT FIFTY-NINE Unlawful Use of a Communication Facility On or about September 9, 2011, in the State of Colorado, Anthony Harvey did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. 37

The offenses alleged in Predicate Acts Fifty-Eight and Fifty-Nine were committed in the following manner: On September 9, 2011, Gary Lihudis and Anthony Harvey agreed that Harvey would distribute a quantity of cocaine to Lihudis in exchange for money. In furtherance of this agreement, Lihudis met Harvey at Lihudis residence at 7348 S. College Ave. in Fort Collins, CO. There, Lihudis gave Harvey a quantity of US currency so that Harvey could use that money to ultimately acquire a quantity of cocaine from Harveys source of supply. Harvey utilized his cellular telephone 970-388-2208 and Lihudis utilized his cellular telephone number to arrange and coordinate this delivery of cash towards the purchase of cocaine. PREDICATE ACT SIXTY Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 9, 2011, in the State of Colorado, Anthony Harvey and Michael McCain unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT SIXTY-ONE Unlawful Use of a Communication Facility On or about September 9, 2011, in the State of Colorado, Anthony Harvey did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Sixty and Sixty-One were committed in the following manner: On September 9, 2011, Michael McCain and Anthony Harvey agreed that Harvey would distribute a quantity of cocaine to McCain in exchange for money. In furtherance of this agreement, McCain met Harvey at the intersection of College Ave. and Harmony Road in Fort Collins, CO. There, McCain gave Harvey a quantity of US currency so that Harvey could use that money to ultimately acquire a quantity of cocaine from Harveys source of supply. Harvey utilized his cellular telephone 970-388-2208 and McCain utilized his cellular telephone number 720- 648- 0628 to arrange and coordinate this delivery of cash towards the purchase of cocaine.

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PREDICATE ACT SIXTY-TWO Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 14, 2011, in the State of Colorado, Anthony Harvey and Derek Durica unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT SIXTY-THREE Unlawful Use of a Communication Facility On or about September 14, 2011, in the State of Colorado, Anthony Harvey and Derek Durica did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Sixty-Two and Sixty-Three were committed in the following manner: On September 14, 2011, Derek Durica and Anthony Harvey agreed that Harvey would distribute a quantity of cocaine to Durica in exchange for money. In furtherance of this agreement, Durica then went to Anthony Harveys shop located at 204 Commerce Drive Unit #D in Fort Collins, CO. There, Durica gave Harvey a quantity of US currency so that Harvey could use that money to ultimately acquire a quantity of cocaine from Harveys source of supply. Harvey utilized his cellular telephone 970-388-2208 and Durica utilized his cellular telephone number 970-2177744 to arrange and coordinate this delivery of cash towards the purchase of cocaine. PREDICATE ACT SIXTY-FOUR Distribution of Marijuana Between 5 and 100 Pounds, (F4) On or about September 20, 2011, in the State of Colorado, Abdon Loya-Sanchez and Anthony Harvey, unlawfully, feloniously, and knowingly sold or distributed, or attempted to sell or distribute, marijuana or marijuana concentrate. Further, the amount was at least five pounds but not more than one hundred pounds of marijuana; in violation of section 18-18-406(6)(b)(I), (III)(B), C.R.S. The offense alleged in Predicate Act Sixty-Four was committed in the following manner: On September 20, 2011, Abdon Loya-Sanchez and Anthony Harvey distributed approximately 10 pounds of marijuana, packaged in single-pound increments to 39

Brian Butler at Harveys residence, 2040 Manchester in Fort Collins, CO. Shortly thereafter, at Mile Marker 351 on Hwy 287, law enforcement officers recovered 10 pounds of marijuana from Brian Butler. PREDICATE ACT SIXTY-FIVE Possession with Intent to Distribute a Controlled Substance 25 to 450 Grams, (F3) On or about September 30, 2011, in the State of Colorado, Leobardo Loya unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. The offense charged in Predicate Act Sixty-FIve was committed in the following manner: On September 30, 2011, law enforcement officers recovered 336.7 grams of cocaine from Leobardo Loyas residence at 2025 N. College Ave., #225, Fort Collins, CO. PREDICATE ACT SIXTY-SIX Possession with Intent to Distribute a Controlled Substance, (F3) On or about September 30, 2011, in the State of Colorado, Leobardo Loya unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained methamphetamine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense charged in Predicate Act Sixty-Six was committed in the following manner: On September 30, 2011, law enforcement officers recovered 14 grams of methamphetamine from Leobardo Loyas residence at 2025 N. College Ave., #225, Fort Collins, CO. PREDICATE ACT SIXTY-SEVEN Possession with Intent to Distribute a Controlled Substance, (F3) On or about September 30, 2011, in the State of Colorado, Abdon Loya-Sanchez unlawfully, feloniously, and knowingly possessed with intent to distribute a material, 40

compound, mixture, or preparation that contained cocaine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense charged in Predicate Act Sixty-Seven was committed in the following manner: On September 30, 2011, law enforcement officers recovered 10.7 grams of cocaine from the residence of Abdon Loya-Sanchez at 3717 S. Taft Hill, #268, Fort Collins, CO. PREDICATE ACT SIXTY-EIGHT Possession with Intent to Distribute Marijuana Between 5 and 100 Pounds, (F4) On or about September 30, 2011, in the State of Colorado, Abdon Loya-Sanchez, unlawfully, feloniously, and knowingly possessed or attempted to possess, with intent to sell or distribute marijuana or marijuana concentrate. Further, the amount was at least five pounds but not more than one hundred pounds of marijuana; in violation of section 18-18-406(6)(b)(I), (III)(B), C.R.S. The offense charged in Predicate Act Sixty-Eight was committed in the following manner: On September 30, 2011, law enforcement officers recovered 2536.7 grams (approximately 5 pounds) of marijuana from the residence of Abdon Loya-Sanchez at 3717 S. Taft Hill, #268, Fort Collins, CO. Law enforcement officers recovered 3939.6 grams (approximately 8 pounds) of marijuana from the storage facility rented by Abdon Loya-Sanchez at 3702 Manhattan, #E-6, Fort Collins, CO. PREDICATE ACT SIXTY-NINE Possession with Intent to Distribute a Controlled Substance 450 to 1000 Grams, (F3) On or about September 30, 2011, in the State of Colorado, Alexander Oram unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least four hundred-fifty grams but not more than one thousand grams or one kilogram of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S.

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The offense charged in Predicate Act Sixty-Nine was committed in the following manner: On September 30, 2011, law enforcement officers recovered 477.4 grams of cocaine from the residence of Alexander Oram at 1025 Cunningham, #C-6, Fort Collins, CO. PREDICATE ACT SEVENTY Possession with Intent to Distribute a Controlled Substance 450 to 1000 Grams, (F3) On or about September 30, 2011, in the State of Colorado, Francisco Valencia unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least four hundred-fifty grams but not more than one thousand grams or one kilogram of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S. The offense charged in Predicate Act Seventy was committed in the following manner: On September 30, 2011, law enforcement officers recovered 686 grams of cocaine from Francisco Valencias bedroom in his residence at 1007 Whalers Way, Fort Collins, CO.

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PREDICATE ACT SEVENTY-ONE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 24, 2011, in the State of Colorado, Anthony Harvey and Tony Romero unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT SEVENTY-TWO Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 24, 2011, in the State of Colorado, Anthony Harvey and Stuart Knowles unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine and oxycodonoe, both schedule II controlled substances; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT SEVENTY-THREE Unlawful Use of a Communication Facility On or about September 24, 2011, in the State of Colorado, Anthony Harvey and Stuart Knowles did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses charged in Predicate Acts Seventy-One through Seventy-Three were committed in the following manner: On September 24, 2011, Anthony Harvey and Tony Romero agreed that Harvey was going to distribute a quantity of cocaine and that Romero would assist Harvey in processing the cocaine for distribution. In furtherance of this agreement, Harvey directed Romero to purchase a cutting agent for the cocaine, which Romero did and brought to Harveys shop. Also on that date, Anthony Harvey and Stuart Knowles agreed that Harvey would distribute quantities of cocaine and oxycodonoe to Knowles in exchange for money. In furtherance of this agreement, Knowles went to Harveys shop at 204 Commerce Drive, Units #D/E, Fort Collins, CO, in order to pick up a quantity of oxycodone from Harvey. Harvey utilized his cellular telephone and Knowles utilized his cellular telephone to arrange and coordinate this deal.

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PREDICATE ACT SEVENTY-FOUR Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 24, 2011, in the State of Colorado, Abdon Loya-Sanchez and Adrian Hernandez unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT SEVENTY-FIVE Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about September 24, 2011, in the State of Colorado, Abdon Loya-Sanchez unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. PREDICATE ACT SEVENTY-SIX Possession with Intent to Distribute a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about September 24, 2011, in the State of Colorado, Adrian Hernandez unlawfully, feloniously, and knowingly possessed with intent to distribute cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. PREDICATE ACT SEVENTY-SEVEN Unlawful Use of a Communication Facility On or about September 24, 2011, in the State of Colorado, Abdon Loya-Sanchez did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses charged in Predicate Acts Seventy-Four through Seventy-Seven were committed in the following manner: 44

On September 24, 2011, Abdon Loya-Sanchez and Adrian Hernandez agreed that Loya-Sanchez would deliver a quantity of cocaine to Hernandez in exchange for money. In furtherance of this agreement, Hernandez met Loya-Sanchez in a parking lot located at Taft Hill Road and Harmony Road, Fort Collins, CO. At that location, Loya-Sanchez distributed approximately a one-pound quantity of cocaine to Adrian Hernandez. Hernandez accepted the cocaine and then left the area. PREDICATE ACT SEVENTY-EIGHT Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 23, 2011, in the State of Colorado, Abdon Loya-Sanchez and Alejandro Uribe unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT SEVENTY-NINE Unlawful Use of a Communication Facility On or about September 23, 2011, in the State of Colorado, Abdon Loya-Sanchez did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses charged in Predicate Acts Seventy-Eight and Seventy-Nine were committed in the following manner: On September 23, 2011, Abdon Loya-Sanchez and Alejandro Uribe agreed that Uribe would deliver an amount of money to Loya-Sanchez as payment for a past purchase of cocaine and towards a future purchase of cocaine. In furtherance of this agreement, Uribe went to Loya-Sanchezs residence at 3717 Taft Hill, #268, Fort Collins, CO. At that location, Uribe delivered a quantity of money as payment for past drug transactions. Loya-Sanchez utilized his cellular telephone 307-2154762 to arrange this meeting.

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PREDICATE ACT EIGHTY Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about May 3, 2011, in the State of Colorado, Alan Johnson unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. PREDICATE ACT EIGHTY-ONE Unlawful Use of a Communication Facility On or about May 3, 2011, in the State of Colorado, Alan Johnson did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Eighty and Eighty-One were committed in the following manner: On May 3, 2011, Alan Johnson sold a five-ounce quantity of cocaine to a confidential informant in the parking lot of the Albertsons grocery store at 3657 S. Mason in Fort Collins, CO. Alan Johnson utilized his cellular telephone 970-3081614 to arrange and coordinate the delivery of the cocaine. PREDICATE ACT EIGHTY-TWO Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about June 17, 2011, in the State of Colorado, Alan Johnson unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.

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PREDICATE ACT EIGHTY-THREE Unlawful Use of a Communication Facility On or about June 17, 2011, in the State of Colorado, Alan Johnson did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Eighty-Two and Eighty-Three were committed in the following manner: On June 17, 2011, Alan Johnson sold a three-ounce quantity of cocaine to a confidential informant in the parking lot of American Furniture Warehouse store at 625 SW Frontage Road in Fort Collins, CO. Alan Johnson utilized his cellular telephone 970-308-1614 to arrange and coordinate the delivery of the cocaine. PREDICATE ACT EIGHTY-FOUR Distribution of a Controlled Substance Schedule II, (F3) On or about August 3, 2011, in the State of Colorado, Alan Johnson unlawfully, feloniously, and knowingly sold or distributed methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT EIGHTY-FIVE Distribution of a Controlled Substance Schedule II, (F3) On or about August 3, 2011, in the State of Colorado, Jimmie Joe Montgomery unlawfully, feloniously, and knowingly sold or distributed methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offenses alleged in Predicate Acts Eighty-Four and Eighty-Five were committed in the following manner: On August 3, 2011, Alan Johnson delivered a quantity of methamphetamine to Jimmie Joe Montgomery at Johnsons residence on Cleveland Avenue, Loveland, CO. Montgomery then took the methamphetamine from Johnson and delivered 4.3 grams of methamphetamine to Kevin Caldwell in the 1400 block of Remington Street in Fort Collins, CO.

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PREDICATE ACT EIGHTY-SIX Conspiracy to Distribute a Controlled Substance Schedule II, (F3) Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado, Alan Johnson and Kenneth West unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT EIGHTY-SEVEN Distribution of a Controlled Substance Schedule II, (F3) Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado, Alan Johnson unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT EIGHTY-EIGHT Possession with Intent to Distribute a Controlled Substance, (F3) Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado, Kenneth West unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT EIGHTY-NINE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado, Alan Johnson and Mark Fraleigh unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT NINETY Conspiracy to Distribute a Controlled Substance Schedule II, (F3) Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado, Alan Johnson and Mitchell Morris unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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PREDICATE ACT NINETY-ONE Unlawful Use of a Communication Facility Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado, Alan Johnson and Kenneth West did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Eighty-Six through Ninety-One were committed in the following manner: Between the dates of August 8, 2011 and August 12, 2011, Alan Johnson delivered a quantity of cocaine to Kenneth West. West and Johnson then agreed that West would travel to Montana and distribute a quantity of cocaine to each of Johnsons customers, Mark Fraleigh and Mitchell Morris. In furtherance of this agreement, West traveled to Montana and delivered a quantity of cocaine to both Mark Fraleigh and Mitchell Morris. Johnson utilized his cellular telephone 970-308-1614 and West utilized his cellular telephone 970-301-5777 to arrange and coordinate this delivery of the cocaine. At approximately the same time, Johnson agreed with Mark Fraleigh that Johnson would deliver a quantity of cocaine to Fraleigh. In furtherance of this agreement, Johnson gave a quantity of cocaine to Kenneth West who then transported the cocaine to Fraleigh in Montana. Fraleigh then coordinated with Johnson through the use of cellular telephones to send the proceeds from the sale of cocaine back to Johnson. Similarly, Johnson agreed with Mitchell Morris that Johnson would deliver a quantity of cocaine to Morris. In furtherance of this agreement, Johnson gave a quantity of cocaine to Kenneth West who then transported the cocaine to Morris in Montana. Morris then coordinated with Johnson through the use of cellular telephones to return the proceeds from the sale of the cocaine back to Johnson. PREDICATE ACT NINETY-TWO Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 12, 2011, in the State of Colorado, Alan Johnson and Horacio Bugarin unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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PREDICATE ACT NINETY-THREE Unlawful Use of a Communication Facility On or about August 12, 2011, in the State of Colorado, Alan Johnson and Horacio Bugarin did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Ninety-Two and Ninety-Three were committed in the following manner: On August 12, 2011, Alan Johnson and Horacio Bugarin agreed that Bugarin would distribute a quantity of methamphetamine to Johnson in exchange for money. In furtherance of this agreement, Bugarin picked up Alan Johnson from his residence on Cleveland Street in Loveland, CO. Bugarin then traveled with Johnson to Greeley, CO. Johnson utilized his cellular telephone 970-308-1614 and Bugarin utilized his cellular telephone to arrange and coordinate this meeting in reference to the conspiracy to distribute the methamphetamine. PREDICATE ACT NINETY-FOUR Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 14, 2011, in the State of Colorado, Alan Johnson and Shawn Blea unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT NINETY-FIVE Unlawful Use of a Communication Facility On or about August 14, 2011, in the State of Colorado, Alan Johnson did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Ninety-Four and Ninety-Five were committed in the following manner: On August 14, 2011, Alan Johnson and Shawn Blea agreed that Johnson would distribute a quantity of methamphetamine to Blea in exchange for money. In furtherance of this agreement, Blea went to Johnsons residence on Cleveland Street, Loveland, CO. At that location, Blea received a quantity of methamphetamine from Johnson. 50

PREDICATE ACT NINETY-SIX Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 15, 2011, in the State of Colorado, Alan Johnson and Anthony Harvey unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT NINETY-SEVEN Unlawful Use of a Communication Facility On or about August 15, 2011, in the State of Colorado, Alan Johnson and Anthony Harvey did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts Ninety-Six and Ninety-Seven were committed in the following manner: On August 15, 2011, Alan Johnson and Anthony Harvey agreed that Johnson would pay an amount of US currency to Harvey as payment both for previous deliveries of cocaine and also for future delivery of cocaine. In furtherance of this agreement, Johnson and Harvey met at 5000 Boardwalk, Fort Collins, CO. At that location, Johnson paid Harvey an amount of US currency towards the future purchase of cocaine. PREDICATE ACT NINETY-EIGHT Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 16, 2011, in the State of Colorado, Alan Johnson and Jimmie Joe Montgomery unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT NINETY-NINE Unlawful Use of a Communication Facility On or about August 16, 2011, in the State of Colorado, Alan Johnson and Jimmie Joe Montgomery did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843.

51

The offenses alleged in Predicate Acts Ninety-Eight and Ninety-Nine were committed in the following manner: On August 16, 2011, Alan Johnson and Jimmie Joe Montgomery agreed that Johnson would distribute a quantity of methamphetamine to Montgomery in exchange for money. In furtherance of this agreement, Johnson directed Montgomery to go to Johnsons residence on Cleveland Ave, Loveland, CO. Montgomery then traveled to Johnsons residence to pick up the quantity of methamphetamine. Johnson utilized his cellular telephone 970-308-1614 and Montgomery utilized his cellular telephone 970-400-0105 to arrange and coordinate this delivery of the methamphetamine. PREDICATE ACT ONE HUNDRED Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 16, 2011, in the State of Colorado, Alan Johnson and Horacio Bugarin unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT ONE HUNDRED-ONE Unlawful Use of a Communication Facility On or about August 16, 2011, in the State of Colorado, Alan Johnson and Horacio Bugarin did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts One Hundred and One Hundred-One were committed in the following manner: On August 16, 2011, Alan Johnson and Horacio Bugarin agreed that Johnson would pay an amount of US currency to Bugarin as payment both for previous deliveries of methamphetamine and also for future delivery of methamphetamine. In furtherance of this agreement, Johnson and Bugarin met at the gas station at 1st and Taft, Loveland, CO. At that location, Johnson paid Bugarin an amount of US currency towards the future purchase of methamphetamine.

52

PREDICATE ACT ONE HUNDRED-TWO Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 21, 2011, in the State of Colorado, Alan Johnson and Horacio Bugarin unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT ONE HUNDRED-THREE Unlawful Use of a Communication Facility On or about August 21, 2011, in the State of Colorado, Alan Johnson and Horacio Bugarin did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts One Hundred-Two and One Hundred-Three were committed in the following manner: On August 21, 2011, Alan Johnson and Horacio Bugarin agreed that Johnson would pay an amount of US currency to Bugarin as payment both for previous deliveries of methamphetamine and also for future delivery of methamphetamine. In furtherance of this agreement, Johnson and Bugarin met at Bugarins residence at 139 Juniper #B, Loveland, CO. At that location, Johnson paid Bugarin an amount of US currency towards the future purchase of methamphetamine. PREDICATE ACT ONE HUNDRED-FOUR Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 24, 2011, in the State of Colorado, Alan Johnson and Horacio Bugarin unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT ONE HUNDRED-FIVE Distribution of a Controlled Substance Schedule II, (F3) On or about August 24, 2011, in the State of Colorado, Horacio Bugarin unlawfully, feloniously, and knowingly sold or distributed methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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PREDICATE ACT ONE HUNDRED-SIX Possession with Intent to Distribute a Controlled Substance, (F3) On or about August 24, 2011, in the State of Colorado, Alan Johnson unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained methamphetamine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT ONE HUNDRED-SEVEN Unlawful Use of a Communication Facility On or about August 24, 2011, in the State of Colorado, Alan Johnson and Horacio Bugarin did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts One Hundred-Four though One HundredSeven were committed in the following manner: On August 24, 2011, Alan Johnson and Horacio Bugarin agreed that Bugarin would deliver a quantity of methamphetamine to Johnson. In furtherance of this agreement, Johnson and Bugarin met at Johnsons residence at Cleveland Ave., Loveland, CO. At that location, Bugarin delivered a quantity of methamphetamine to Johnson. PREDICATE ACT ONE HUNDRED-EIGHT Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 26, 2011, in the State of Colorado, Alan Johnson and Anthony Harvey unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT ONE HUNDRED-NINE Distribution of a Controlled Substance Schedule II, (F3) On or about August 26, 2011, in the State of Colorado, Anthony Harvey unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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PREDICATE ACT ONE HUNDRED-TEN Possession with Intent to Distribute a Controlled Substance, (F3) On or about August 26, 2011, in the State of Colorado, Alan Johnson unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. PREDICATE ACT ONE HUNDRED-ELEVEN Unlawful Use of a Communication Facility On or about August 26, 2011, in the State of Colorado, Alan Johnson and Anthony Harvey did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts One Hundred-Eight through One HundredEleven were committed in the following manner: On August 26, 2011, Alan Johnson and Anthony Harvey agreed that Harvey would deliver a quantity of cocaine to Johnson. In furtherance of this agreement, Johnson and Harvey met at 5000 Boardwalk, Fort Collins, CO. At that location, Harvey delivered a quantity of cocaine to Johnson, who accepted the delivery. PREDICATE ACT ONE HUNDRED-TWELVE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 19, 2011, in the State of Colorado, Alan Johnson and Anthony Harvey unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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PREDICATE ACT ONE HUNDRED-THIRTEEN Unlawful Use of a Communication Facility On or about September 19, 2011, in the State of Colorado, Anthony Harvey and Alan Johnson did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses alleged in Predicate Acts One Hundred-Twelve and One HundredThirteen were committed in the following manner: On September 19, 2011, Alan Johnson and Anthony Harvey agreed that Harvey would distribute a quantity of cocaine to Alan Johnson and that Johnson would pay Harvey. In furtherance of this agreement, they met at the Inca Restaurant, at 2413 S. College, Fort Collins, CO. Harvey utilized his cellular telephone 970-388-2208 and Johnson utilized his cellular telephone number 970-308-1614 to arrange and coordinate this conspiracy to distribute cocaine. PREDICATE ACT ONE HUNDRED-FOURTEEN Distribution of a Schedule II Controlled Substance 450 to 1000 Grams, (F3) On or about September 29, 2011, in the State of Colorado, Alan Johnson unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least four hundred-fifty grams but not more than one thousand grams or one kilogram of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S. The offense charged in Predicate Act One Hundred-Fourteen was committed in the following manner: On September 29, 2011, Alan Johnson delivered approximately 477.4 grams of cocaine to Alexander Oram at Orams residence on 1025 Cunningham, #C-6, Fort Collins, CO. Johnson directed Oram to store the cocaine for future distribution.

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PREDICATE ACT ONE HUNDRED-FIFTEEN Possession with Intent to Distribute a Controlled Substance Schedule II 450 to 1000 Grams, (F3) On or about September 30, 2011, in the State of Colorado, Horacio Bugarin unlawfully, feloniously, and knowingly possessed with intent to distribute methamphetamine, a schedule II controlled substance. Further, the amount was or had been represented to be at least four hundred-fifty grams but not more than one thousand grams or one kilogram of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S. PREDICATE ACT ONE HUNDRED-SIXTEEN Possession with Intent to Distribute a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about September 30, 2011, in the State of Colorado, Horacio Bugarin unlawfully, feloniously, and knowingly possessed with intent to distribute cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. The offenses charged in Predicate Acts One Hundred-Fifteen and One HundredSixteen were committed in the following manner: On September 30, 2011, law enforcement officers recovered 26.6 grams of cocaine and 466.25 grams of methamphetamine from Horacio Bugarins residence at Juniper Place, Loveland, CO. PREDICATE ACT ONE HUNDRED SEVENTEEN Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 13, 2011, in the State of Colorado, Abdon Loya-Sanchez and Alejandro Uribe unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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PREDICATE ACT ONE HUNDRED EIGHTEEN Unlawful Use of a Communication Facility On or about September 13, 2011, in the State of Colorado, Abdon Loya-Sanchez did knowingly or intentionally use a communications facility, namely, a telephone, to facilitate the commission of a felony, namely, distribution of a controlled substance, in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843. The offenses charged in Predicate Acts One Hundred-Seventeen and One HundredEighteen were committed in the following manner: On September 13, 2011, Abdon Loya-Sanchez and Alejandro Uribe agreed that Loya-Sanchez would deliver approximately two ounces of cocaine to Uribe. In furtherance of this agreement, Loya-Sanchez went to Uribes residence on W. Laurel Street, Fort Collins, CO. At that location, Loya-Sanchez distributed a quantity of cocaine to Alejandro Uribe. Loya-Sanchez utilized his cellular telephone 307-2154762 to arrange this meeting.

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COUNT THREE Distribution of a Controlled Substance Schedule II, (F3) On or about June 24, 2011, in the State of Colorado, Francisco Valencia unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Three was committed in the manner described in Predicate Act Three. COUNT FOUR Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about August 10, 2011, in the State of Colorado, Leobardo Loya unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. The offense alleged in Count Four was committed in the manner described in Predicate Acts Four and Five. COUNT FIVE Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about August 12, 2011, in the State of Colorado, Leobardo Loya unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.

The offense alleged in Count Five was committed in the manner described in Predicate Acts Six and Seven.

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COUNT SIX Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about September 14, 2011, in the State of Colorado, Leobardo Loya unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. The offense alleged in Count Six was committed in the manner described in Predicate Acts Eight and Nine. COUNT SEVEN Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about August 4, 2011, in the State of Colorado, Alan Johnson and Alexander Oram unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. The offense alleged in Count Seven was committed in the manner described in Predicate Acts Ten and Eleven. COUNT EIGHT Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about August 16, 2011, in the State of Colorado, Alan Johnson and Alexander Oram unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. 60

The offense alleged in Count Eight was committed in the manner described in Predicate Acts Twelve and Thirteen. COUNT NINE Distribution of a Controlled Substance Schedule II, (F3) On or about August 24, 2011, in the State of Colorado, Anthony Harvey unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT TEN Possession with Intent to Distribute a Controlled Substance, (F3) On or about August 24, 2011, in the State of Colorado, Alan Johnson and Alexander Oram unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A),(3), C.R.S. The offenses alleged in Counts Nine and Ten were committed in the manner described in Predicate Acts Fourteen through Sixteen. COUNT ELEVEN Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 26, 2011, in the State of Colorado, Anthony Harvey and Abdon Loya-Sanchez unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Eleven was committed in the manner described in Predicate Acts Seventeen and Eighteen. COUNT TWELVE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 27, 2011, in the State of Colorado, Anthony Harvey, Alan Johnson and Alexander Oram unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Twelve was committed in the manner described in Predicate Acts Nineteen and Twenty.

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COUNT THIRTEEN Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 3, 2011, in the State of Colorado, Anthony Harvey and Alexander Oram unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Thirteen was committed in the manner described in Predicate Acts Twenty-One and Twenty-Two. COUNT FOURTEEN Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 6, 2011, in the State of Colorado, Anthony Harvey and Stuart Knowles unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Fourteen was committed in the manner described in Predicate Acts Twenty-Three and Twenty-Four. COUNT FIFTEEN Distribution of a Controlled Substance Schedule II, (F3) On or about September 8, 2011, in the State of Colorado, Francisco Valencia unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT SIXTEEN Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about September 8, 2011, in the State of Colorado, Joseph Vittum unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. The offenses alleged in Counts Fifteen and Sixteen were committed in the manner described in Twenty-Five and Twenty-Six. 62

COUNT SEVENTEEN Conspiracy to Distribute a Controlled Substance Schedule II, (F3) Between the dates of September 8 through September 13, 2011, in the State of Colorado, Daniel Galvan and Francisco Valencia unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

The offense alleged in Count Seventeen was committed in the manner described in Predicate Acts Twenty-Seven and Twenty-Eight. COUNT EIGHTEEN Conspiracy to Distribute a Controlled Substance Schedule II, (F3) Between the dates of September 19 through September 20, 2011, in the State of Colorado, Daniel Galvan and Stuart Knowles unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT NINETEEN Distribution of a Controlled Substance Schedule II, (F3) On or about September 20, 2011, in the State of Colorado, Daniel Galvan unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT TWENTY Possession with Intent to Distribute a Controlled Substance, (F3) On or about September 20, 2011, in the State of Colorado, Stuart Knowles unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A),(3), C.R.S. The offenses alleged in Counts Eighteen, Nineteen, and Twenty were committed in the manner described in Predicate Acts Twenty-Nine, Thirty, Thirty-One, and Thirty Two.

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COUNT TWENTY-ONE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 24, 2011, in the State of Colorado, Anthony Harvey and Abdon Loya-Sanchez unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT TWENTY-TWO Distribution of a Controlled Substance Schedule II, (F3) On or about September 24, 2011, in the State of Colorado, Abdon Loya-Sanchez unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT TWENTY-THREE Possession with Intent to Distribute a Controlled Substance, (F3) On or about September 24, 2011, in the State of Colorado, Anthony Harvey unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offenses alleged in Counts Twenty-One, Twenty-Two, and Twenty-Three were committed in the manner described in Predicate Acts Thirty-Three, Thirty-Four, Thirty-Five and Thirty-Six.

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COUNT TWENTY-FOUR Distribution of a Controlled Substance Schedule II, (F3) On or about May 12, 2011, in the State of Colorado, Anthony Embry unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Twenty-Four was committed in the following manner: On May 12, 2011, Anthony Embry sold 3.6 grams of cocaine to an undercover officer at 3035 W. Prospect Road in Fort Collins. COUNT TWENTY-FIVE Distribution of a Controlled Substance Schedule II, (F3) On or about May 26, 2011, in the State of Colorado, Quentin Wallace unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT TWENTY-SIX Distribution of a Controlled Substance Schedule II, (F3) On or about May 26, 2011, in the State of Colorado, Anthony Embry unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offenses alleged in Count Twenty-Five and Twenty-Six were committed in the following manner: On May 26, 2011, Quentin Wallace delivered a quantity of cocaine to Anthony Embry at 3035 W. Prospect Road in Fort Collins. Then, Anthony Embry sold 4.3 grams of cocaine to an undercover officer. COUNT TWENTY-SEVEN Distribution of a Controlled Substance Schedule II, (F3) On or about June 3, 2011, in the State of Colorado, Andre Isler unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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COUNT TWENTY-EIGHT Distribution of a Controlled Substance Schedule II, (F3) On or about June 3, 2011, in the State of Colorado, Anthony Embry unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offenses alleged in Counts Twenty-Seven and Twenty-EIght were committed in the following manner: On June 3, 2011, Andre Isler delivered a quantity of cocaine to Anthony Embry at 1957 Pecan Street, Fort Collins. Then, Anthony Embry sold 7.7 grams of cocaine to an undercover officer at 3035 W. Prospect Road in Fort Collins. COUNT TWENTY-NINE Distribution of a Controlled Substance Schedule II, (F3) On or about June 24, 2011, in the State of Colorado, Ronald Munguia-Martin unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT THIRTY Possession with Intent to Distribute a Controlled Substance, (F3) On or about June 24, 2011, in the State of Colorado, Gerald Lamaster unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT THIRTY-ONE Possession of a Controlled Substance Schedule II, (F6) On or about June 24, 2011, in the State of Colorado, Gerald Lamaster unlawfully, feloniously, and knowingly possessed a material, compound, mixture, or preparation that contained oxycodone, a schedule II controlled substance, in violation of section 18-18-403.5(1),(2)(a)(I), C.R.S. The offenses alleged in Counts Twenty-Nine through Thirty-One were committed in the following manner: On June 24, 2011, Ronald Munguia-Martin sold a quantity of cocaine to Gerald Lamaster in the parking lot of Safeway at 860 Cleveland Ave. in Loveland. Shortly thereafter, law enforcement officers recovered a quarter-ounce of cocaine and 14 Oxycodone pills from Gerald Lamaster. 66

COUNT THIRTY-TWO Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 24, 2011, in the State of Colorado, Anthony Harvey and Derek Durica unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Thirty-Two was committed in the manner described in Predicate Acts Thirty-Eight and Thirty-Nine. COUNT THIRTY-THREE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 24, 2011, in the State of Colorado, Anthony Harvey and Carl Hayes unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Thirty-Three was committed in the manner described in Predicate Acts Forty and Forty-One. COUNT THIRTY-FOUR Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 24, 2011, in the State of Colorado, Anthony Harvey and Kamal Patterson unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 1818-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Thirty-Four was committed in the manner described in Predicate Acts Forty-Two and Forty-Three. COUNT THIRTY-FIVE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 26, 2011, in the State of Colorado, Anthony Harvey and Derek Durica unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Thirty-Five was committed in the manner described in Predicate Acts Forty-Four and Forty-Five.

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COUNT THIRTY-SIX Possession of a Dangerous Weapon, (F5) On or about September 1, 2011, in the State of Colorado, Jerome Nelson unlawfully, feloniously, and knowingly possessed a dangerous weapon, namely: a Winchester 12-gauge pump short shotgun; in violation of section 18-12-102(3), C.R.S. The offense alleged in Count Thirty-Six was committed in the following manner: On or about September 1, 2011, Jerome Nelson possessed a Winchester short shotgun that he ultimately concealed in the frame of a vehicle located at 200 Commerce Drive, Unit #G, Fort Collins, CO. COUNT THIRTY-SEVEN Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 2, 2011, in the State of Colorado, Anthony Harvey and Derek Durica unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Thirty-Seven was committed in the manner described in Predicate Acts Forty-Six and Forty-Seven. COUNT THIRTY-EIGHT Distribution of a Controlled Substance Schedule II, (F3) On or about September 3, 2011, in the State of Colorado, Anthony Harvey unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT THIRTY-NINE Possession of a Controlled Substance Schedule II, (F6) On or about September 3, 2011, in the State of Colorado, Matthew Bekkerus unlawfully, feloniously, and knowingly possessed a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance, in violation of section 18-18-403.5(1),(2)(a)(I), C.R.S. The offenses alleged in Counts Thirty-Eight and Thirty-Nine were committed in the manner described in Predicate Act Forty-Eight.

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COUNT FORTY Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 3, 2011, in the State of Colorado, Anthony Harvey and Gary Lihudis unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Forty was committed in the manner described in Predicate Acts Forty-Nine and Fifty. COUNT FORTY-ONE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) Between the dates of September 3, 2011, and September 10, 2011, in the State of Colorado, Anthony Harvey and Maria Moreno unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Forty-One was committed in the manner described in Predicate Acts Fifty-One and Fifty-Two. COUNT FORTY-TWO Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 7, 2011, in the State of Colorado, Anthony Harvey and Jerome Nelson unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Forty-Two was committed in the manner described in Predicate Acts Fifty-Three and Fifty-Four COUNT FORTY-THREE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 7, 2011, in the State of Colorado, Anthony Harvey and Quentin Wallace unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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COUNT FORTY-FOUR Distribution of a Controlled Substance Schedule II, (F3) On or about September 7, 2011, in the State of Colorado, Anthony Harvey unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT FORTY-FIVE Possession with Intent to Distribute a Controlled Substance, (F3) On or about September 7, 2011, in the State of Colorado, Quentin Wallace unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offenses alleged in Counts Forty-Three through Forty-Five were committed in the manner described in Predicate Acts Fifty-Five through Fifty-Seven. COUNT FORTY-SIX Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 9, 2011, in the State of Colorado, Anthony Harvey and Gary Lihudis unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Forty-Six was committed in the manner described in Predicate Acts Fifty-Eight and Fifty-Nine. COUNT FORTY-SEVEN Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 9, 2011, in the State of Colorado, Anthony Harvey and Michael McCain unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Forty-Seven was committed in the manner described in Predicate Acts Sixty and Sixty-One.

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COUNT FORTY-EIGHT Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 14, 2011, in the State of Colorado, Anthony Harvey and Derek Durica unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Forty-Eight was committed in the manner described in Predicate Acts Sixty-Two and Sixty-Three. COUNT FORTY-NINE Distribution of Marijuana Between 5 and 100 Pounds, (F4) On or about September 20, 2011, in the State of Colorado, Abdon Loya-Sanchez and Anthony Harvey, unlawfully, feloniously, and knowingly sold or distributed, or attempted to sell or distribute, marijuana or marijuana concentrate. Further, the amount was at least five pounds but not more than one hundred pounds of marijuana; in violation of section 18-18-406(6)(b)(I), (III)(B), C.R.S COUNT FIFTY Possession with Intent to Distribute Marijuana Between 5 and 100 Pounds, (F4) On or about September 20, 2011, in the State of Colorado, Brian Butler, unlawfully, feloniously, and knowingly possessed or attempted to possess, with intent to sell or distribute marijuana or marijuana concentrate. Further, the amount was at least five pounds but not more than one hundred pounds of marijuana; in violation of section 18-18-406(6)(b)(I), (III)(B), C.R.S The offenses alleged in Counts Forty-Nine and Fifty were committed in the manner described in Predicate Act Sixty-Four. COUNT FIFTY-ONE Possession with Intent to Distribute a Controlled Substance 25 to 450 Grams, (F3) On or about September 30, 2011, in the State of Colorado, Leobardo Loya unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance.

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Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. COUNT FIFTY-TWO Possession with Intent to Distribute a Controlled Substance, (F3) On or about September 30, 2011, in the State of Colorado, Leobardo Loya unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained methamphetamine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offenses alleged in Counts Fity-One and Fifty-Two were committed in the manner described in Predicate Acts Sixty-Five and Sixty-Six. COUNT FIFTY-THREE Possession with Intent to Distribute a Controlled Substance, (F3) On or about September 30, 2011, in the State of Colorado, Abdon Loya-Sanchez unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Fifty-Three was committed in the manner described in Predicate Act Sixty-Seven. COUNT FIFTY-FOUR Possession with Intent to Distribute Marijuana Between 5 and 100 Pounds, (F4) On or about September 30, 2011, in the State of Colorado, Abdon Loya-Sanchez, unlawfully, feloniously, and knowingly possessed or attempted to possess, with intent to sell or distribute marijuana or marijuana concentrate. Further, the amount was at least five pounds but not more than one hundred pounds of marijuana; in violation of section 18-18-406(6)(b)(I), (III)(B), C.R.S The offense alleged in Count Fifty-Four was committed in the manner described in Predicate Act Sixty-Eight.

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COUNT FIFTY-FIVE Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about September 29, 2011, in the State of Colorado, Tony Romero unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. The offense alleged in Count Fifty-Five was committed in the following manner: On or about September 29, 2011, Tony Romero delivered approximately 477.4 grams of cocaine to Alexander Oram at Anthony Harveys shop located at 204 Commerce Drive, Unit D/E, Fort Collins, CO. COUNT FIFTY-SIX Possession with Intent to Distribute a Controlled Substance 450 to 1000 Grams, (F3) On or about September 30, 2011, in the State of Colorado, Alexander Oram unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least four hundred-fifty grams but not more than one thousand grams or one kilogram of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S. The offense alleged in Count Fifty-Six was committed in the manner described in Predicate Act Sixty-Nine. COUNT FIFTY-SEVEN Special Offender Deadly Weapon On or about September 30, 2011, in the State of Colorado, Alexander Oram committed the felony offense charged in Count Fifty-Six and used, displayed, possessed on his person or within his immediate reach, a deadly weapon, namely: a Kel-Tec .380 caliber pistol; in violation of section 18-18-407(1)(f)(I), C.R.S. The offense charged in Count Fifty-Seven was committed in the following manner: 73

On September 30, 2011, law enforcement officers recovered a Kel-Tec .380 caliber pistol within close proximity of 477.4 grams of cocaine from the residence of Alexander Oram at 1025 Cunningham, #C-6, Fort Collins, CO. COUNT FIFTY-EIGHT Possession with Intent to Distribute a Controlled Substance 450 to 1000 Grams, (F3) On or about September 30, 2011, in the State of Colorado, Francisco Valencia unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least four hundred-fifty grams but not more than one thousand grams or one kilogram of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S. The offense alleged in Count Fifty-Eight was committed in the manner described in Predicate Act Seventy. COUNT FIFTY-NINE Special Offender Deadly Weapon On or about September 30, 2011, in the State of Colorado, Francisco Valencia committed the felony offense charged in Count Fifty-Eight and used, displayed, possessed on his person or within his immediate reach, a deadly weapon, namely: a .40 caliber pistol; in violation of section 18-18-407(1)(f)(I), C.R.S. The offense charged in Count Fifty-Nine was committed in the following manner: On September 30, 2011, law enforcement officers recovered a .40 caliber pistol from Francisco Valencias bedroom in his residence at 1007 Whalers Way, Fort Collins, CO, within close proximity of 686 grams of cocaine that Valencia possessed in order to distribute to his customers.

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COUNT SIXTY Possession of a Weapon by a Previous Offender (F6) On or about September 30, 2011, in the State of Colorado, Bernardino Mendoza unlawfully, feloniously, and knowingly possessed, used, or carried upon [his] person a firearm or other weapon, namely: Tech 9 handgun, and Bernardino Mendoza was previously convicted of a felony, namely: First Degree Criminal Trespass, on July 15, 2008; in violation of section 18-12-108(1), C.R.S. The offense alleged in Count Sixty was committed in the following manner: On September 30, 2011, law enforcement officers recovered a Tech 9 handgun from Bernardino Mendozas bedroom in his residence at 1007 Whalers Way, Fort Collins, CO. Mendoza was previously convicted of a felony, namely: First Degree Criminal Trespass, on July 15, 2008, in Larimer County Case No. 08 CR 867. COUNT SIXTY-ONE Cultivation of Marijuana, (F4) On or about September 30, 2011, in the State of Colorado, Daniel Galvan, unlawfully, knowingly, and feloniously cultivated, grew, produced, processed, or manufactured marijuana or marijuana concentrate, or allowed marijuana or marijuana concentrate to be cultivated, grown, produced, processed, or manufactured on land owned, occupied, or controlled by the defendant; in violation of section 18-18-406(7.5)(c), C.R.S. The offense alleged in Count Sixty-One was committed in the following manner: On September 30, 2011, law enforcement officers located a marijuana grow consisting of 58 plants in the residence of Daniel Galvan at 2430 Leghorn, Fort Collins, CO. COUNT SIXTY-TWO Distribution of a Controlled Substance Schedule II, (F3) On or about June 23, 2011, in the State of Colorado, Andre Isler and Anthony Embry unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Sixty-Two was committed in the following manner: On June 23, 2011, Andre Isler delivered a quantity of cocaine to Anthony who then sold 7.6 grams of cocaine to an undercover officer at 3035 W. Prospect Road in Fort Collins. 75

COUNT SIXTY-THREE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 24, 2011, in the State of Colorado, Anthony Harvey and Tony Romero unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT SIXTY-FOUR Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 24, 2011, in the State of Colorado, Anthony Harvey and Stuart Knowles unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine and oxycodone, both schedule II controlled substances; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offenses charged in Counts Sixty-Three and Sixty-Four were committed in the manner described in Predicate Acts Seventy-One through Seventy-Three. COUNT SIXTY-FIVE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 24, 2011, in the State of Colorado, Abdon Loya-Sanchez and Adrian Hernandez unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT SIXTY-SIX Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about September 24, 2011, in the State of Colorado, Abdon Loya-Sanchez unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S.

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COUNT SIXTY-SEVEN Possession with Intent to Distribute a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about September 24, 2011, in the State of Colorado, Adrian Hernandez unlawfully, feloniously, and knowingly possessed with intent to distribute cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. The offenses charged in Counts Sixty-Five through Sixty-Seven were committed in the manner described in Predicate Acts Seventy-Four through Seventy-Seven. COUNT SIXTY-EIGHT Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 23, 2011, in the State of Colorado, Abdon Loya-Sanchez and Alejandro Uribe unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense charged in Count Sixty-Eight was committed in the manner described in Predicate Acts Seventy-Eight and Seventy-Nine. COUNT SIXTY-NINE Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about May 3, 2011, in the State of Colorado, Alan Johnson unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. The offense alleged in Count Sixty-Nine was committed in the manner described in Predicate Acts Eighty and Eighty-One.

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COUNT SEVENTY Distribution of a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about June 17, 2011, in the State of Colorado, Alan Johnson unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. The offense alleged in Count Seventy was committed in the manner described in Predicate Acts Eighty-Two and Eighty-Three. COUNT SEVENTY-ONE Distribution of a Controlled Substance Schedule II, (F3) On or about August 3, 2011, in the State of Colorado, Alan Johnson unlawfully, feloniously, and knowingly sold or distributed methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT SEVENTY-TWO Distribution of a Controlled Substance Schedule II, (F3) On or about August 3, 2011, in the State of Colorado, Jimmie Joe Montgomery unlawfully, feloniously, and knowingly sold or distributed methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offenses alleged in Counts Seventy-One and Seventy-Two were committed in the manner described in Predicate Acts Eighty-Four and Eighty-Five. COUNT SEVENTY-THREE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado, Alan Johnson and Kenneth West unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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COUNT SEVENTY-FOUR Distribution of a Controlled Substance Schedule II, (F3) Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado, Alan Johnson unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT SEVENTY-FIVE Possession with Intent to Distribute a Controlled Substance, (F3) Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado, Kenneth West unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT SEVENTY-SIX Conspiracy to Distribute a Controlled Substance Schedule II, (F3) Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado, Alan Johnson and Mark Fraleigh unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT SEVENTY-SEVEN Conspiracy to Distribute a Controlled Substance Schedule II, (F3) Between the dates of August 8, 2011 and August 15, 2011, in the State of Colorado, Alan Johnson and Mitchell Morris unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offenses alleged in Counts Seventy-Three through Seventy-Seven were committed in the manner described in Predicate Acts Eighty-Six through NinetyOne.

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COUNT SEVENTY-EIGHT Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 12, 2011, in the State of Colorado, Alan Johnson and Horacio Bugarin unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Seventy-Eight was committed in the manner described in Predicate Acts Ninety-Two and Ninety-Three. COUNT SEVENTY-NINE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 14, 2011, in the State of Colorado, Alan Johnson and Shawn Blea unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Seventy-Nine was committed in the manner described in Predicate Acts Ninety-Four and Ninety-Five. COUNT EIGHTY Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 15, 2011, in the State of Colorado, Alan Johnson and Anthony Harvey unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Eighty was committed in the manner described in Predicate Acts Ninety-Six and Ninety-Seven. COUNT EIGHTY-ONE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 16, 2011, in the State of Colorado, Alan Johnson and Jimmie Joe Montgomery unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged Count Eighty-One was committed in the manner described in Predicate Acts Ninety-Eight and Ninety-Nine.

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COUNT EIGHTY-TWO Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 16, 2011, in the State of Colorado, Alan Johnson and Horacio Bugarin unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in County Eighty-Two was committed in the manner described in Predicate Acts One Hundred and One Hundred-One. COUNT EIGHTY-THREE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 21, 2011, in the State of Colorado, Alan Johnson and Horacio Bugarin unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Eighty-Three was committed in the manner described in Predicate Acts One Hundred-Two and One Hundred-Three. COUNT EIGHTY-FOUR Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 24, 2011, in the State of Colorado, Alan Johnson and Horacio Bugarin unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT EIGHTY-FIVE Distribution of a Controlled Substance Schedule II, (F3) On or about August 24, 2011, in the State of Colorado, Horacio Bugarin unlawfully, feloniously, and knowingly sold or distributed methamphetamine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S.

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COUNT EIGHTY-SIX Possession with Intent to Distribute a Controlled Substance, (F3) On or about August 24, 2011, in the State of Colorado, Alan Johnson unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained methamphetamine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offenses alleged in Counts Eighty-Four through Eighty-Six were committed in the manner described in Predicate Acts One Hundred-Four though One HundredSeven. COUNT EIGHTY-SEVEN Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about August 26, 2011, in the State of Colorado, Alan Johnson and Anthony Harvey unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18405(1),(2)(a)(I)(A), C.R.S. COUNT EIGHTY-EIGHT Distribution of a Controlled Substance Schedule II, (F3) On or about August 26, 2011, in the State of Colorado, Anthony Harvey unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. COUNT EIGHTY-NINE Possession with Intent to Distribute a Controlled Substance, (F3) On or about August 26, 2011, in the State of Colorado, Alan Johnson unlawfully, feloniously, and knowingly possessed with intent to distribute a material, compound, mixture, or preparation that contained cocaine, a schedule II controlled substance, in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offenses alleged in Counts Eighty-Seven through Eighty-Nine were committed in the manner described in Predicate Acts One Hundred-Eight through One Hundred-Eleven.

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COUNT NINETY Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 19, 2011, in the State of Colorado, Alan Johnson and Anthony Harvey unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense alleged in Count Ninety was committed in the manner described in Predicate Acts One Hundred-Twelve and One Hundred-Thirteen. COUNT NINETY-ONE Distribution of a Schedule II Controlled Substance 450 to 1000 Grams, (F3) On or about September 29, 2011, in the State of Colorado, Alan Johnson unlawfully, feloniously, and knowingly sold or distributed cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least four hundred-fifty grams but not more than one thousand grams or one kilogram of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S. The offense charged in Count Ninety-One was committed in the manner described in Predicate Act One Hundred-Fourteen. COUNT NINETY-TWO Possession with Intent to Distribute a Controlled Substance Schedule II 450 to 1000 Grams, (F3) On or about September 30, 2011, in the State of Colorado, Horacio Bugarin unlawfully, feloniously, and knowingly possessed with intent to distribute methamphetamine, a schedule II controlled substance. Further, the amount was or had been represented to be at least four hundred-fifty grams but not more than one thousand grams or one kilogram of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(II), C.R.S.

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COUNT NINETY-THREE Possession with Intent to Distribute a Controlled Substance Schedule II 25 to 450 Grams, (F3) On or about September 30, 2011, in the State of Colorado, Horacio Bugarin unlawfully, feloniously, and knowingly possessed with intent to distribute cocaine, a schedule II controlled substance. Further, the amount was or had been represented to be at least twenty-five grams but not more than four hundred-fifty grams or one pound of a material, compound, mixture, or preparation that contained the controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A),(3)(a)(I), C.R.S. The offenses charged in Counts Ninety-Two and Ninety-Three was committed in the manner described in Predicate Acts One Hundred-Fifteen and One HundredSixteen. COUNT NINETY-FOUR Special Offender Deadly Weapon On or about September 30, 2011, in the State of Colorado, Horacio Bugarin committed the felony offenses charged in Counts Thirty and Thirty-One and used, displayed, possessed on his person or within his immediate reach, a deadly weapon, namely: a Glock 27 .40 caliber pistol; in violation of section 18-18407(1)(f)(I), C.R.S. The offense charged in Count Ninety-Four was committed in the following manner: On September 30, 2011, law enforcement officers recovered a .40 caliber pistol in close proximity to a large quantity of methamphetamine and cocaine from Horacio Bugarins residence at Juniper Place, Loveland, CO. COUNT NINETY-FIVE Conspiracy to Distribute a Controlled Substance Schedule II, (F3) On or about September 13, 2011, in the State of Colorado, Abdon Loya-Sanchez and Alejandro Uribe unlawfully, feloniously, and knowingly conspired with each other, to sell or distribute cocaine, a schedule II controlled substance; in violation of section 18-18-405(1),(2)(a)(I)(A), C.R.S. The offense charged in Count Ninety-Five was committed in the manner described in Predicate Acts One Hundred-Seventeen and One Hundred-Eighteen.

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