hell's lovers indictment 2
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IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLORADO
Criminal Case No.
UNITED STATES OF AMERICA,
Plaintiff,v.
1. GEORGE H. ASKEW,2. ROMELL E. BULLOCK,3. GREGORY A. COLLINS,
4. GEORGE A. GADDY,5. DELBERT J. GARDNER,6. RICHARD W. JOHNSON,7. SHEPS H. KHAMSAHU,8. ERIC LUGO,9. LAWRENCE T. MARTIN,10. JOHNIE A. MYERS,11. DARRELL R. PARKER,12. CALVIN R. RILEY,13. COREY L. RILEY,14. THOMAS A. SCHRAH, JR.,
15. JAMES R. SWITZER, and16. CLIFFORD M. WRIGHT,
Defendants.
______________________________________________________________________________
INDICTMENT
Maintaining Drug-Involved Premises
(21 U.S.C. 856(a)(1) and (2) and (b))
Possession with Intent to Distribute Cocaine
(21 U.S.C. 841(a)(1) and (b)(1)(A),(B), and (C))
Prohibited Person in Possession of Firearm
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(18 U.S.C. 922(g)(1) and 924(a)(2))
Possession of Firearm in Furtherance of Drug Trafficking Felony
(18 U.S.C. 924(c))
Possession with Intent to Distribute Marijuana
(21 U.S.C. 841(a)(1) and (b)(1)(D))
Conspiracy to Distribute Cocaine(21 U.S.C. 846 and 841(a)(1) and (b)(1)(A),(B), and (C))
Conspiracy to Maintain Drug-Involved Premises
(21 U.S.C. 846 and 856(a)(1) and (2) and (b))
Aiding and Abetting
(18 U.S.C. 2)______________________________________________________________________________
The Grand Jury Charges:
COUNT ONEPossession with Intent to Distribute More than 28 Grams of Crack Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(B)
On or about March 17, 2009, within the State and District of Colorado, the defendant,
GEORGE H. ASKEW,
knowingly distributed and possessed with intent to distribute more than 28 grams of a substance and
mixture containing a detectable amount of cocaine base (also known as crack cocaine), a Schedule
II controlled substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(B).
COUNT TWO
Prohibited Person in Possession of Firearm
18 U.S.C. 922(g)(1), 924(a)(2) and 2
On or about March 17, 2009, within the State and District of Colorado, the defendant,
GEORGE H. ASKEW,
knowingly possessed a firearm which had been transported in interstate commerce, having been
convicted previously of a crime punishable by imprisonment for a term exceeding one year.
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All in violation of Title 18, United States Code, Sections 922(g)(1), 924(a)(2) and 2,
Possession of Weapon by Prohibited Person.
COUNT THREEUsing a Residence for the Purpose of Distributing Controlled Substance
21 U.S.C. 856(a)(1) and (2) and (b)
On or about March 17, 2009, within the State and District of Colorado, the defendant,
GEORGE H. ASKEW,
knowingly used a place, to wit: the residence known as 3701 E. 29th Avenue, Denver, Colorado,
for the purpose of distributing quantities of a mixture and substance containing a detectable amount
of cocaine base (also known as crack cocaine), a Schedule II controlled substance.
All in violation of Title 21, United States Code, Section 856(a)(1) and (2) and (b),
Maintaining drug-involved premises.
COUNT FOUR
Possession of Firearm in Furtherance of Drug Trafficking Felony
18 U.S.C. 924(c)
On or about March 17, 2009, within the State and District of Colorado, the defendant,
GEORGE H. ASKEW,
knowingly possessed a firearm in furtherance of a felony drug trafficking crime for which he could
be prosecuted in a court of the United States, to wit: knowingly to use and maintain a drug involved
premises in violation of Title 21 U.S.C. 856 (a)(1) and (2) and (b)(1), and knowingly possessing
with intent to distribute a quantity of a substance and mixture containing a detectable amount of
cocaine base, a Schedule II controlled substance commonly known as crack cocaine, in violation
of Title 21 U.S.C. 841(a)(1) and (b).
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All in violation of Title 18, United States Code, Section 924(c)(1)(A)(I), Possessing a
firearm in furtherance of drug trafficking felony offense.
COUNT FIVEPossession with Intent to Distribute Crack Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)
On or about June 18, 2009, within the State and District of Colorado, the defendant,
DELBERT J. GARDNER,
knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of cocaine base (also known as crack cocaine), a Schedule II controlled
substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
COUNT SIX
Possession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)
On or about March 12, 2010, within the State and District of Colorado, the defendant,
ERIC LUGO,
knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of cocaine, a Schedule II controlled substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
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COUNT SEVEN
Possession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)18 U.S.C. 2
On or about April 14, 2010, within the State and District of Colorado, the defendant,
ERIC LUGO,
knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of cocaine, a Schedule II controlled substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(c) and Title
18, United States Code, Section 2.
COUNT EIGHT
Prohibited Person in Possession of Firearm
18 U.S.C. 922(g)(1), 924(a)(2) and 2
On or about October 30, 2010, within the State and District of Colorado, the defendant,
DARRELL R. PARKER,
knowingly possessed a firearm and ammunition which had been transported in interstate
commerce, having been convicted previously of a crime punishable by imprisonment for a term
exceeding one year.
All in violation of Title 18, United States Code, Sections 922(g)(1), 924(a)(2) and 2,
Possession of Weapon by Prohibited Person.
COUNT NINE
Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)
On or about January 29, 2009, within the State and District of Colorado, the defendant,
CALVIN R. RILEY,
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knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of cocaine, a Schedule II controlled substance and intentionally did aid, abet, and
cause the same.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
COUNT TEN
Prohibited Person in Possession of Firearm
18 U.S.C. 922(g)(1), 924(a)(2) and 2
On or about July 10, 2009, within the State and District of Colorado, the defendant,
CALVIN R. RILEY,
knowingly possessed a firearm and ammunition which had been transported in interstate commerce,
having been convicted previously of a crime punishable by imprisonment for a term exceeding one
year.
All in violation of Title 18, United States Code, Sections 922(g)(1), 924(a)(2) and 2,
Possession of Weapon by Prohibited Person.
COUNT ELEVEN
Maintaining Drug-Involved Premises
21 U.S.C. 856(a)(1) and (2) and (b)
Between on or about April 7, 2010, and on or about July 30, 2011, within the State and
District of Colorado, the defendant,
COREY L. RILEY,
knowingly used a place, to wit: the residence known as 2331 Pontiac Street, Denver, Colorado, for
the purpose of distributing quantities of a substance containing a detectable amount of cocaine, a
Schedule II controlled substance, and marijuana, a Schedule I controlled substance.
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All in violation of Title 21, United States Code, Section 856(a)(1) and (2) and (b),
Maintaining drug-involved premises.
COUNT TWELVEPossession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)
On or about April 7, 2010, within the State and District of Colorado, the defendant,
COREY L. RILEY,
knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of cocaine, a Schedule II controlled substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
COUNT THIRTEEN
Possession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)
On or about May 6, 2010, within the State and District of Colorado, the defendant,
COREY L. RILEY,
knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of cocaine, a Schedule II controlled substance..
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1).
COUNT FOURTEEN
Possession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)
On or about May 26, 2010, within the State and District of Colorado, the defendant,
COREY L. RILEY,
knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
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detectable amount of cocaine, a Schedule II controlled substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
COUNT FIFTEENPossession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)
On or about July 14, 2010, within the State and District of Colorado, the defendant,
COREY L. RILEY,
knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of cocaine, a Schedule II controlled substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
COUNT SIXTEEN
Possession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)
On or about March 31, 2011, within the State and District of Colorado, the defendant,
COREY L. RILEY,
knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of cocaine, a Schedule II controlled substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
COUNT SEVENTEEN
Possession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)
On or about April 8, 2011, within the State and District of Colorado, the defendant,
COREY L. RILEY,
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knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of cocaine, a Schedule II controlled substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
COUNT EIGHTEEN
Possession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)
On or about April 13, 2011, within the State and District of Colorado, the defendant,
COREY L. RILEY,
knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of cocaine, a Schedule II controlled substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
COUNT NINETEEN
Possession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)
On or about May 12, 2011, within the State and District of Colorado, the defendant,
COREY L. RILEY,
knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of cocaine, a Schedule II controlled substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
COUNT TWENTY
Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)
On or about May 20, 2011, within the State and District of Colorado, the defendant,
COREY L. RILEY,
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knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of cocaine, a Schedule II controlled substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
COUNT TWENTY-ONE
Possession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)
On or about June 3, 2011, within the State and District of Colorado, the defendant,
COREY L. RILEY,
knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of cocaine, a Schedule II controlled substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
COUNT TWENTY-TWO
Possession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)18 U.S.C. 2
On or about June 30, 2011, within the State and District of Colorado, the defendant,
COREY L. RILEY,
knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of cocaine, a Schedule II controlled substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(c) and Title
18 Section 2.
COUNT TWENTY-THREE
Possession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)
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On or about July 14, 2011, within the State and District of Colorado, the defendant,
COREY L. RILEY,
knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of cocaine, a Schedule II controlled substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
COUNT TWENTY-FOUR
Possession with Intent to Distribute Marijuana
21 U.S.C. 841(a)(1) and (b)(1)(D)
On or about July 14, 2011, within the State and District of Colorado, the defendant,
COREY L. RILEY,
knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of marijuana, a Schedule I controlled substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(D).
COUNT TWENTY-FIVE
Possessing Firearm in Furtherance of Drug Trafficking Felony Offense18 U.S.C. 924(c)
On or about July 14, 2011, within the State and District of Colorado, the defendant,
COREY L. RILEY,
knowingly possessed a firearm in furtherance of a federal felony drug trafficking crime, to wit:
knowingly to use and maintain a drug involved premises, the residence known as 2331 Pontiac
Street, Denver, Colorado, in violation of Title 21 U.S.C. 856 (a)(1) and (2) and (b)(1).
All in violation of Title 18, United States Code, Section 924(c)(1)(A)(I), Possessing a
firearm in furtherance of drug trafficking felony offense.
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COUNT TWENTY-SIX
Possession with Intent to Distribute More than 500 grams of Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(B)18 U.S.C. 2
On or about June 12, 2007, within the State and District of Colorado, the defendant,
COREY L. RILEY,
knowingly distributed and knowingly possessed with intent to distribute more than 500 grams of
a substance and mixture containing a detectable amount of cocaine, a Schedule II controlled
substance and intentionally did aid and abet the same.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(B) and Title
18, United States Code, Section 2.
COUNT TWENTY-SEVEN
Conspiracy to Distribute more than 5 Kilograms of Cocaine
21 U.S.C. 846 and 841(a)(1) and (b)(1)(A)18 U.S.C. 2
Between on or about January 1, 2005 and on or about June 12, 2007, within the State
and District of Colorado and elsewhere, the defendant,
COREY L. RILEY,
knowingly agreed with Z.A. and other persons to the Grand Jury known and unknown knowingly
to possess with intent to distribute and knowingly to distribute more than five kilograms of a
substance and mixture containing a detectable amount of cocaine, a Schedule II controlled
substance, and intentionally did aid, abet, and cause the same.
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All in violation of Title 21, United States Code, Sections 846 and 841(a)(1) and (b)(1)(A)
and Title 18, United States Code, Section 2, Conspiracy to distribute more than five kilograms of
cocaine.
COUNT TWENTY-EIGHT
Prohibited Person in Possession of Firearm
18 U.S.C. 922(g)(1), 924(a)(2) and 2
On or about February 13, 2009, within the State and District of Colorado, the defendant,
JAMES R. SWITZER,
knowingly possessed a firearm and ammunition which had been transported in interstate commerce,
having been convicted previously of a crime punishable by imprisonment for a term exceeding one
year.
All in violation of Title 18, United States Code, Sections 922(g)(1), 924(a)(2) and 2.
COUNT TWENTY-NINE
Possession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)
On or about January 28, 2010, within the State and District of Colorado, the defendant,
CLIFFORD M. WRIGHT,
knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of cocaine, a Schedule II controlled substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C) .
COUNT THIRTY
Possession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)
On or about February 19, 2010, within the State and District of Colorado, the defendant,
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CLIFFORD M. WRIGHT,
knowingly possessed with intent to distribute a quantity of a substance and mixture containing a
detectable amount of cocaine, a Schedule II controlled substance.
All in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C).
COUNT THIRTY-ONE
Conspiracy to Use and Maintain Drug-Involved Premises
21 U.S.C. 846 and 856(a)(1) and (2) and (b)
Between on or about January 1, 2005, and on or about September 30, 2011, within the State
and District of Colorado, the defendants,
2. ROMELL E. BULLOCK,
3. GREGORY A. COLLINS,
4. GEORGE A. GADDY,
7. SHEPS H. KHAMSAHU,
9. LAWRENCE T. MARTIN,
10. JOHNIE A. MYERS,
12. CALVIN R. RILEY,
13. COREY L. RILEY, and
14. THOMAS A. SCHRAH, JR.,
knowingly agreed with one another and with others, to the Grand Jury known and unknown, to
maintain and to use a place, to wit: premises informally known as the Hells Lovers Motorcycle
Club clubhouse, for the purpose of using and distributing quantities of a substance containing a
detectable amount of cocaine, a Schedule II controlled substance, and quantities of a substance and
mixture containing a detectable amount of marijuana, a Schedule I controlled substance.
All in violation of Title 21, United States Code, Sections 846 and 856(a)(1) and (2) and (b),
and Pinkerton v. United States, 328 U.S. 640 (1946)(Pinkerton liability for the reasonably
foreseeable conduct of co-conspirators), Conspiracy to use and maintain drug-involved premises.
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COUNT THIRTY-TWO
Using and Maintaining Drug-Involved Premises
21 U.S.C. 856(a)(1) and (2) and (b)
Aiding and Abetting
18 U.S.C. 2
Between on or about January 1, 2005, and on or about December 30, 2011, within the State
and District of Colorado, the defendants,
1. GEORGE H. ASKEW,
2. ROMELL E. BULLOCK,
3. GREGORY A. COLLINS,
4. GEORGE A. GADDY,
5. DELBERT J. GARDNER,
6. RICHARD W. JOHNSON,
7. SHEPS H. KHAMSAHU,8. ERIC LUGO,
9. LAWRENCE T. MARTIN,
10. JOHNIE A. MYERS,
11. DARRELL R. PARKER,
12. CALVIN R. RILEY,
13. COREY L. RILEY,
14. THOMAS A. SCHRAH, JR.,
15. JAMES R. SWITZER, and
16. CLIFFORD M. WRIGHT,
knowingly maintained and used a place, to wit: premises informally known as the Hells Lovers
Motorcycle Club clubhouse, for the purpose of using and distributing quantities of a substance and
mixture containing a detectable amount of marijuana, a Schedule I controlled substance, and
quantities of a substance containing a detectable amount of cocaine, a Schedule II controlled
substance, and intentionally aided and abetted another to maintain and use said premises for the
purposes of using and distributing Schedule I and a Schedule II controlled substances.
All in violation of Title 21, United States Code, Section 856(a)(1) and (2) and (b), and
Title 18, United States Code, Section 2, Maintaining drug-involved premises, and aiding and
abetting another to do so.
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FORFEITURE ALLEGATION
18 U.S.C. 3665
1. The allegations contained in Counts One through Thirty-Two of this Indictment are
hereby re-alleged and incorporated by reference for the purpose of alleging forfeiture pursuant to
the provisions of Title 18, United States Code, Section 3665 and Title 28, United States Code,
Section 2461(c).
2. Upon conviction of the violations alleged in Counts One through Thirty-Two of this
Indictment, each such defendant shall forfeit to the United States, pursuant to Title 18, United States
Code, Section 3665 any and all of the defendants right, title and interest in all property constituting
and derived from any proceeds obtained directly and indirectly as a result of such offense, and in
all property used, or intended to be used, in any manner or part, to commit, or to facilitate the
commission of such offense, to wit:
(A) Firearms;
(B) Approximately $16,500.00 in cash;
(C) Currency;
(D) Ammunition.
3. If any of the property described above, as a result of any act or omission of the
defendants:
a) cannot be located upon the exercise of due diligence;
b) has been transferred or sold to, or deposited with, a third
party;
c) has been placed beyond the jurisdiction of the Court;
d) has been substantially diminished in value; or
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e) has been commingled with other property which
cannot be subdivided without difficulty;
it is the intent of the United States, pursuant to Title 28, United States Code, Section 2461(c), to
seek forfeiture of any other property of said defendants up to the value of the forfeitable
property.
A TRUE BILL:
_Ink signature on file in the Clerks Office__GRAND JURY FOREPERSON
JOHN F. WALSHUnited States Attorney
s/ Guy TillBy: GUY TILLAssistant United States AttorneyUnited States Attorneys OfficeDistrict of Colorado
1225 17
th
Street, Suite 700Denver, CO 80202Telephone: (303) 454-0100Fax: (303) 454-0409Guy.Till@usdoj.gov
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DEFENDANT: 1. GEORGE H. ASKEW
YEARS OF BIRTH: 1973, 1975
ADDRESS: Denver, Colorado
COMPLAINT FILED: YES X NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO
OFFENSE:
Count One: Possession with Intent to Distribute More than 28 Grams of Crack Cocaine21 U.S.C. 841(a)(1) and (b)(1)(B)
Count Two: Prohibited Person in Possession of Firearm18 U.S.C. 922(g)(1), 924(a)(2) and 2
Count Three: Using a Residence for the Purpose of Distributing Controlled Substance21 U.S.C. 856(a)(1) and (2) and (b)
Count Four: Possession of Firearm in Furtherance of Drug Trafficking Felony18 U.S.C. 924(c)
Count Thirty-Two: Using and Maintaining Drug-Involved Premises
21 U.S.C. 856(a)(1) and (2) and (b)Aiding and Abetting18 U.S.C. 2
LOCATION OF OFFENSE: Denver County, Colorado(COUNTY/CITY/STATE)
PENALTY:
Count One: Defendant has a prior PCS state felony conviction. NLT 10 years, NMT lifeimprisonment; a fine of NMT $8,000,000.00, or both; NLT 8 years supervised release following
any period of imprisonment; and a $100.00 special assessment.
Count Two: NMT 10 years imprisonment; a fine of NMT $250,000.00, or both; NMT 3 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.
Count Three: NMT 20 years imprisonment; a fine of NMT $500,000.00, or both; NMT 5 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.
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Count Four: NLT 5 years imprisonment; a fine of NMT $250,000.00, or both; and a $100.00special assessment.
Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.
NOTICE OF FORFEITURE
AGENT: Special Agent Jason ColeAlcohol Tobacco and Firearms
AUTHORIZED BY: Guy TillAssistant U.S. Attorney
ESTIMATED TIME OF TRIAL:
five days or less X over five days other
THE GOVERNMENT
X will seek detention in this case will not seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: X Yes No
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DEFENDANT: 2. ROMELL E. BULLOCK
YEAR OF BIRTH: 1975
ADDRESS: Denver, Colorado
COMPLAINT FILED: YES X NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO
OFFENSE:
Count Thirty-One: Conspiracy to Use and Maintain Drug-Involved Premises
21 U.S.C. 846 and 856(a)(1) and (2) and (b)
Count Thirty-Two: Using and Maintaining Drug-Involved Premises21 U.S.C. 856(a)(1) and (2) and (b)Aiding and Abetting18 U.S.C. 2
LOCATION OF OFFENSE: Denver County, Colorado(COUNTY/CITY/STATE)
PENALTY:
Count Thirty-One: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 5years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3years supervised release following any period of imprisonment; and a $100.00 special
assessment.
NOTICE OF FORFEITURE
AGENT: Special Agent Jason ColeAlcohol Tobacco and Firearms
AUTHORIZED BY: Guy TillAssistant U.S. Attorney
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ESTIMATED TIME OF TRIAL:
five days or less X over five days other
THE GOVERNMENT
X will seek detention in this case will not seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: X Yes No
2
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DEFENDANT: 3. GREGORY A. COLLINS
YEAR OF BIRTH: 1954, 1958
ADDRESS: Denver, Colorado
COMPLAINT FILED: YES X NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO
OFFENSE:
Count Thirty-One: Conspiracy to Use and Maintain Drug-Involved Premises
21 U.S.C. 846 and 856(a)(1) and (2) and (b)
Count Thirty-Two: Using and Maintaining Drug-Involved Premises21 U.S.C. 856(a)(1) and (2) and (b)
Aiding and Abetting18 U.S.C. 2
LOCATION OF OFFENSE: Denver County, Colorado
(COUNTY/CITY/STATE)
PENALTY:
Count Thirty-One: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 5years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.
NOTICE OF FORFEITURE
AGENT: Special Agent Jason ColeAlcohol Tobacco and Firearms
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AUTHORIZED BY: Guy TillAssistant U.S. Attorney
ESTIMATED TIME OF TRIAL:
five days or less X over five days other
THE GOVERNMENT
X will seek detention in this case will not seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: X Yes No
2
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DEFENDANT: 4. GEORGE A. GADDY
YEAR OF BIRTH: 1945
ADDRESS: Denver, Colorado
COMPLAINT FILED: YES X NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO
Count Thirty-One: Conspiracy to Use and Maintain Drug-Involved Premises21 U.S.C. 846 and 856(a)(1) and (2) and (b)
Count Thirty-Two: Using and Maintaining Drug-Involved Premises21 U.S.C. 856(a)(1) and (2) and (b)
Aiding and Abetting18 U.S.C. 2
LOCATION OF OFFENSE: Denver County, Colorado(COUNTY/CITY/STATE)
PENALTY:
Count Thirty-One: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 5years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.
NOTICE OF FORFEITURE
AGENT: Special Agent Jason Cole
Alcohol Tobacco and Firearms
AUTHORIZED BY: Guy TillAssistant U.S. Attorney
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ESTIMATED TIME OF TRIAL:
five days or less X over five days other
THE GOVERNMENT
X will seek detention in this case will not seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: X Yes No
2
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DEFENDANT: 5. DELBERT J. GARDNER
YEAR OF BIRTH: 1980
ADDRESS: Denver, Colorado
COMPLAINT FILED: YES X NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO
OFFENSE:
Count Five: Possession with Intent to Distribute Crack Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)
Count Thirty-Two: Using and Maintaining Drug-Involved Premises21 U.S.C. 856(a)(1) and (2) and (b)
Aiding and Abetting18 U.S.C. 2
LOCATION OF OFFENSE: Denver County, Colorado(COUNTY/CITY/STATE)
PENALTY:
Count Five: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.
Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.
NOTICE OF FORFEITURE
AGENT: Special Agent Jason Cole
Alcohol Tobacco and Firearms
AUTHORIZED BY: Guy TillAssistant U.S. Attorney
ESTIMATED TIME OF TRIAL:
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five days or less X over five days other
THE GOVERNMENT
X will seek detention in this case will not seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: X Yes No
2
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DEFENDANT: 6. RICHARD W. JOHNSON
YEAR OF BIRTH: 1955
ADDRESS: Denver, Colorado
COMPLAINT FILED: YES X NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO
OFFENSE:
Count Thirty-Two: Using and Maintaining Drug-Involved Premises
21 U.S.C. 856(a)(1) and (2) and (b)Aiding and Abetting18 U.S.C. 2
LOCATION OF OFFENSE: Denver County, Colorado(COUNTY/CITY/STATE)
PENALTY:
Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3
years supervised release following any period of imprisonment; and a $100.00 specialassessment
NOTICE OF FORFEITURE
AGENT: Special Agent Jason ColeAlcohol Tobacco and Firearms
AUTHORIZED BY: Guy TillAssistant U.S. Attorney
ESTIMATED TIME OF TRIAL:
five days or less X over five days other
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THE GOVERNMENT
X will seek detention in this case will not seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: X Yes No
2
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DEFENDANT: 7. SHEPS H. KHAMSAHU
YEAR OF BIRTH: 1972
ADDRESS: Denver, Colorado
COMPLAINT FILED: YES X NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO
Count Thirty-One: Conspiracy to Use and Maintain Drug-Involved Premises21 U.S.C. 846 and 856(a)(1) and (2) and (b)
Count Thirty-Two: Using and Maintaining Drug-Involved Premises21 U.S.C. 856(a)(1) and (2) and (b)Aiding and Abetting18 U.S.C. 2
LOCATION OF OFFENSE: Denver County, Colorado(COUNTY/CITY/STATE)
PENALTY:
Count Thirty-One: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 5years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.
NOTICE OF FORFEITURE
AGENT: Special Agent Jason ColeAlcohol Tobacco and Firearms
AUTHORIZED BY: Guy TillAssistant U.S. Attorney
ESTIMATED TIME OF TRIAL:
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five days or less X over five days other
THE GOVERNMENT
X will seek detention in this case will not seek detention in this case
The statutory presumption of detention is not applicable to this defendant.
OCDETF CASE: X Yes No
2
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DEFENDANT: 8. ERIC LUGO
YEAR OF BIRTH: 1976
ADDRESS: Denver, Colorado
COMPLAINT FILED: YES X NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO
OFFENSE:
Count Six: Possession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)
Count Seven: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)18 U.S.C. 2
Count Thirty-Two: Using and Maintaining Drug-Involved Premises21 U.S.C. 856(a)(1) and (2) and (b)Aiding and Abetting18 U.S.C. 2
LOCATION OF OFFENSE: Denver County, Colorado(COUNTY/CITY/STATE)
PENALTY:
Count Six: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.
Count Seven: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.
Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.
NOTICE OF FORFEITURE
AGENT: Special Agent Jason Cole
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Alcohol Tobacco and Firearms
AUTHORIZED BY: Guy TillAssistant U.S. Attorney
ESTIMATED TIME OF TRIAL:
five days or less X over five days other
THE GOVERNMENT
X will seek detention in this case will not seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: X Yes No
2
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DEFENDANT: 9. LAWRENCE T. MARTIN
YEAR OF BIRTH: 1958
ADDRESS: Denver, Colorado
COMPLAINT FILED: YES X NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO
Count Thirty-One: Conspiracy to Use and Maintain Drug-Involved Premises21 U.S.C. 846 and 856(a)(1) and (2) and (b)
Count Thirty-Two: Using and Maintaining Drug-Involved Premises21 U.S.C. 856(a)(1) and (2) and (b)Aiding and Abetting18 U.S.C. 2
LOCATION OF OFFENSE: Denver County, Colorado(COUNTY/CITY/STATE)
PENALTY:
Count Thirty-One: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 5years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment
NOTICE OF FORFEITURE
AGENT: Special Agent Jason Cole
Alcohol Tobacco and Firearms
AUTHORIZED BY: Guy TillAssistant U.S. Attorney
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ESTIMATED TIME OF TRIAL:
five days or less X over five days other
THE GOVERNMENT
X will seek detention in this case will not seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: X Yes No
2
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DEFENDANT: 10. JOHNIE A. MYERS
YEAR OF BIRTH: 1954
ADDRESS: Denver, Colorado
COMPLAINT FILED: YES X NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO
Count Thirty-One: Conspiracy to Use and Maintain Drug-Involved Premises21 U.S.C. 846 and 856(a)(1) and (2) and (b)
Count Thirty-Two: Using and Maintaining Drug-Involved Premises21 U.S.C. 856(a)(1) and (2) and (b)Aiding and Abetting18 U.S.C. 2
LOCATION OF OFFENSE: Denver County, Colorado(COUNTY/CITY/STATE)
PENALTY:
Count Thirty-One: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 5years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment
NOTICE OF FORFEITURE
AGENT: Special Agent Jason Cole
Alcohol Tobacco and Firearms
AUTHORIZED BY: Guy TillAssistant U.S. Attorney
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ESTIMATED TIME OF TRIAL:
five days or less X over five days other
THE GOVERNMENT
X will seek detention in this case will not seek detention in this case
The statutory presumption of detention is applicable to this defendant.OCDETF CASE: X Yes No
2
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DEFENDANT: 11. DARRELL R. PARKER
YEAR OF BIRTH: 1947, 1949
ADDRESS: Denver, Colorado
COMPLAINT FILED: YES X NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO
OFFENSE:
Count Eight: Prohibited Person in Possession of Firearm
18 U.S.C. 922(g)(1), 924(a)(2) and 2
Count Thirty-Two: Using and Maintaining Drug-Involved Premises21 U.S.C. 856(a)(1) and (2) and (b)Aiding and Abetting18 U.S.C. 2
LOCATION OF OFFENSE: Denver County, Colorado(COUNTY/CITY/STATE)
PENALTY:
Count Eight: NMT 10 years imprisonment; a fine of NMT $250,000.00, or both; NMT 3 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.
Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.
NOTICE OF FORFEITURE
AGENT: Special Agent Jason ColeAlcohol Tobacco and Firearms
AUTHORIZED BY: Guy Till
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Assistant U.S. Attorney
ESTIMATED TIME OF TRIAL:
five days or less X over five days other
THE GOVERNMENT
X will seek detention in this case will not seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: X Yes No
2
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DEFENDANT: 12. CALVIN R. RILEY
YEAR OF BIRTH: 1961
ADDRESS: Denver, Colorado
COMPLAINT FILED: YES X NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO
OFFENSE:
Count Nine: Possession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)
Count Ten: Prohibited Person in Possession of Firearm18 U.S.C. 922(g)(1), 924(a)(2) and 2
Count Thirty-One: Conspiracy to Use and Maintain Drug-Involved Premises21 U.S.C. 846 and 856(a)(1) and (2) and (b)
Count Thirty-Two: Using and Maintaining Drug-Involved Premises21 U.S.C. 856(a)(1) and (2) and (b)
Aiding and Abetting18 U.S.C. 2
LOCATION OF OFFENSE: Denver County, Colorado(COUNTY/CITY/STATE)
PENALTY:
Count Nine: Defendant has a prior PCS state felony conviction. NMT 30 years imprisonment; afine of NMT $2,000,000.00, or both; NLT 6 years supervised release following any period ofimprisonment; and a $100.00 special assessment.
Count Ten: NMT 10 years imprisonment; a fine of NMT $250,000.00, or both; NMT 3 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.
Count Thirty-One: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 5years supervised release following any period of imprisonment; and a $100.00 specialassessment.
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Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3
years supervised release following any period of imprisonment; and a $100.00 special
assessment.
NOTICE OF FORFEITURE
AGENT: Special Agent Jason ColeAlcohol Tobacco and Firearms
AUTHORIZED BY: Guy TillAssistant U.S. Attorney
ESTIMATED TIME OF TRIAL:
five days or less X over five days other
THE GOVERNMENT
X will seek detention in this case will not seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: X Yes No
2
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DEFENDANT: 13. COREY L. RILEY
YEAR OF BIRTH: 1969
ADDRESS: Denver, Colorado
COMPLAINT FILED: YES X NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO
OFFENSE:
Count Eleven: Maintaining Drug-Involved Premises21 U.S.C. 856(a)(1) and (2) and (b)
Count Twelve: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)
Count Thirteen: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)
Count Fourteen: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)
Count Fifteen: Possession with Intent to Distribute Cocaine
21 U.S.C. 841(a)(1) and (b)(1)(C)
Count Sixteen: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)
Count Seventeen: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)
Count Eighteen: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)
Count Nineteen: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)
Count Twenty: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)
Count Twenty-One: Possession with Intent to Distribute Cocaine
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21 U.S.C. 841(a)(1) and (b)(1)(C)
Count Twenty-Two: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)18 U.S.C. 2
Count Twenty-Three: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)
Count Twenty-Four: Possession with Intent to Distribute Marijuana21 U.S.C. 841(a)(1) and (b)(1)(D)
Count Twenty-Five: Possessing Firearm in Furtherance of Drug Trafficking FelonyOffense18 U.S.C. 924(c)
Count Twenty-Six: Possession with Intent to Distribute More than 500 grams ofCocaine21 U.S.C. 841(a)(1) and (b)(1)(B)18 U.S.C. 2
Count Tenty-Seven: Conspiracy to Distribute more than 5 Kilograms of Cocaine21 U.S.C. 846 and 841(a)(1) and (b)(1)(A)
Count Thirty-One: Conspiracy to Use and Maintain Drug-Involved Premises21 U.S.C. 846 and 856(a)(1) and (2) and (b)
Count Thirty-Two: Using and Maintaining Drug-Involved Premises21 U.S.C. 856(a)(1) and (2) and (b)Aiding and Abetting18 U.S.C. 2
LOCATION OF OFFENSE: Denver County, Colorado(COUNTY/CITY/STATE)
PENALTY:
Count Eleven: NMT 20 years imprisonment; a fine of NMT $500,000.00, or both; NMT 5 yearssupervised release following any period of imprisonment; and a $100.00 special assessment.
Count Twelve: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.
2
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Count Thirteen: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Fourteen: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Fifteen: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Sixteen: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Seventeen: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Eighteen: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Nineteen: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 special
assessment.
Count Twenty: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Twenty-One: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT3 years supervised release following any period of imprisonment; and a $100.00 special
assessment.
Count Twenty-Two: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT
3 years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Twenty-Three: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT3 years supervised release following any period of imprisonment; and a $100.00 specialassessment.
3
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Count Twenty-Four: NMT 5 years imprisonment; a fine of NMT $250,000, or both; NLT 2years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Twenty-Five: NLT 5 years imprisonment, consecutive to any other sentence; a fine ofNMT $250,00.00, or both; NMT 3 years supervised release following any period ofimprisonment; and a $100.00 special assessment.
Count Twenty-Six: NLT 5 years, NMT 40 years imprisonment; a fine of NMT $5,000,000.00,or both; NLT 4 years supervised release following any period of imprisonment; and a $100.00special assessment.
Count Twenty-Seven: NLT 10 years, NMT life imprisonment; a fine of NMT $10,000,000.00,or both; NLT 5 years supervised release following any period of imprisonment; and a $100.00special assessment.
Count Thirty-One: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 5years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.
NOTICE OF FORFEITURE
AGENT: Special Agent Jason ColeAlcohol Tobacco and Firearms
AUTHORIZED BY: Guy TillAssistant U.S. Attorney
ESTIMATED TIME OF TRIAL:
five days or less X over five days other
THE GOVERNMENT
X will seek detention in this case will not seek detention in this case
4
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The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: X Yes No
5
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DEFENDANT: 14. THOMAS A. SCHRAH, JR.
YEAR OF BIRTH: 1948
ADDRESS: Denver, Colorado
COMPLAINT FILED: YES X NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO
Count Thirty-One: Conspiracy to Use and Maintain Drug-Involved Premises21 U.S.C. 846 and 856(a)(1) and (2) and (b)
Count Thirty-Two: Using and Maintaining Drug-Involved Premises21 U.S.C. 856(a)(1) and (2) and (b)Aiding and Abetting18 U.S.C. 2
LOCATION OF OFFENSE: Denver County, Colorado(COUNTY/CITY/STATE)
PENALTY:
Count Thirty-One: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 5years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.
NOTICE OF FORFEITURE
AGENT: Special Agent Jason ColeAlcohol Tobacco and Firearms
AUTHORIZED BY: Guy TillAssistant U.S. Attorney
ESTIMATED TIME OF TRIAL:
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five days or less X over five days other
THE GOVERNMENT
X will seek detention in this case will not seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: X Yes No
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DEFENDANT: 15. JAMES R. SWITZER
YEAR OF BIRTH: 1983
ADDRESS: Denver, Colorado
COMPLAINT FILED: YES X NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO
Count Twenty-Eight: Prohibited Person in Possession of Firearm18 U.S.C. 922(g)(1), 924(a)(2) and 2
Count Thirty-Two: Using and Maintaining Drug-Involved Premises
21 U.S.C. 856(a)(1) and (2) and (b)Aiding and Abetting18 U.S.C. 2
LOCATION OF OFFENSE: Denver County, Colorado(COUNTY/CITY/STATE)
PENALTY:
Count Twenty-Eight: NMT 10 years imprisonment; a fine of NMT $250,000.00, or both; NMT3 years supervised release following any period of imprisonment; and a $100.00 special
assessment.
Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3years supervised release following any period of imprisonment; and a $100.00 specialassessment.
NOTICE OF FORFEITURE
AGENT: Special Agent Jason ColeAlcohol Tobacco and Firearms
AUTHORIZED BY: Guy TillAssistant U.S. Attorney
ESTIMATED TIME OF TRIAL:
five days or less X over five days other
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THE GOVERNMENT
X will seek detention in this case will not seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: X Yes No
2
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DEFENDANT: 16. CLIFFORD M. WRIGHT
YEAR OF BIRTH: 1972
ADDRESS: Denver, Colorado
COMPLAINT FILED: YES X NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES X NO
OFFENSE:
Count Twenty-Nine: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)
Count Thirty: Possession with Intent to Distribute Cocaine21 U.S.C. 841(a)(1) and (b)(1)(C)
Count Thirty-Two: Using and Maintaining Drug-Involved Premises21 U.S.C. 856(a)(1) and (2) and (b)Aiding and Abetting18 U.S.C. 2
LOCATION OF OFFENSE: Denver County, Colorado(COUNTY/CITY/STATE)
PENALTY:
Count Twenty-Nine: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT3 years supervised release following any period of imprisonment; and a $100.00 specialassessment.
Count Thirty: NMT 20 years imprisonment; a fine of NMT $1,000,000.00, or both; NLT 3 years
supervised release following any period of imprisonment; and a $100.00 special assessment.
Count Thirty-Two: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 3
years supervised release following any period of imprisonment; and a $100.00 specialassessment.
NOTICE OF FORFEITURE
AGENT: Special Agent Jason ColeAlcohol Tobacco and Firearms
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AUTHORIZED BY: Guy TillAssistant U.S. Attorney
ESTIMATED TIME OF TRIAL:
five days or less X over five days other
THE GOVERNMENT
X will seek detention in this case will not seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: X Yes No
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