dark angel indictment 2
TRANSCRIPT
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Criminal Action No.
UNITED STATES OF AMERICA,
Plaintiff,
v.
1. REYNA MENDOZA-HARO,a/k/a Reyna Mendoza, Reyna, Reyna Gonzalez, Amanda Gonzalez,
2. ARNALDO ALVAREZ-GONZALEZ,
a/k/a Indio, Monra,3. JAIME MORENO-LOPEZ,
a/k/a El Guapo, Jaime Lopez, Jaime Moreno, Adrian Lopez-Villeda,Alberto Torres-Trejo4. RICKY HENRY CISNEROS,
a/k/a Ricky Cisneros,
5. IVAN GOMEZ-AVILA,
a/k/a Ivan Avila, Ivan Flores, Jose Gomez,6. SHANA LOUISE CLAYBOURN,
a/k/a Melissa Renee Rodriguez, Becky Smith, Shana Claybourn, Tiffany
Claybourn, Shana Contreras, Shana Louise Contreras-Pineda,7. CRIS ANTHONY SANDOVAL,
a/k/a Cris Sandoval, Christopher Sandoval,
8. TODD JOSEPH TRUJILLO,a/k/a Todd Trujillo, Tracy Petterson, Todd Jose Trujillo,
9. KENNIE RAY SNYDER,
a/k/a Kennie Snyder,10. CHRISTINA ROSE MALMGREN,
a/k/a Christina Malmgren, and
11. DESIREE ROSE CEBALLES,
a/k/a Desiree Rosa Allen, Desiree Rose Lucy, Desiree Ceballes, DesireeRose Martinez,
Defendants.
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______________________________________________________________________________
INDICTMENT
21 U.S.C. 846
21 U.S.C. 841(a)(1), 841(b)(1)(A)(viii), 841(b)(1)(B)(viii), and 841(b)(1)(C)
21 U.S.C. 843(b)18 U.S.C. 2
______________________________________________________________________________
THE GRAND JURY CHARGES:
COUNT ONE
From on or about October 21, 2010, through on or about May 23, 2012, both dates being
approximate and inclusive, within the State and District of Colorado and elsewhere, the
defendants;
REYNA MENDOZA-HARO,
ARNALDO ALVAREZ-GONZALEZ,
JAIME MORENO-LOPEZ,RICKY HENRY CISNEROS,
IVAN GOMEZ-AVILA,
SHANA LOUISE CLAYBOURN,CRIS ANTHONY SANDOVAL,
TODD JOSEPH TRUJILLO,
KENNIE RAY SNYDER,CHRISTINA ROSE MALMGREN,
DESIREE ROSE CEBALLES,
did knowingly and intentionally conspire with each other and with others known and unknown to
the Grand Jury, to knowingly and intentionally distribute and possess with the intent to distribute
50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500
grams or more of a mixture or substance containing a detectable amount of methamphetamine, a
Schedule II controlled substance.
All in violation of Title 21, United States Code, Sections 846 and 841(a)(1), and
841(b)(1)(A)(viii).
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COUNT TWO
On or about January 23, 2011, within the State and District of Colorado, the defendant,
REYNA MENDOZA-HARO did knowingly and intentionally distribute and possess with the
intent to distribute 5 grams or more of actual of methamphetamine, a Schedule II controlled
substance, and did knowingly and intentionally aid, abet, counsel, command, induce or procure
the same.
All in violation of Title 21, United States Code, Sections 841(a)(1), and
841(b)(1)(B)(viii) and Title 18, United States Code, Section 2.
COUNT THREE
On or about July 8, 2011, within the State and District of Colorado, the defendant,
KENNIE RAY SNYDER did knowingly and intentionally distribute and possess with the intent
to distribute 5 grams or more of a mixture or substance containing a detectable amount of
methamphetamine, a Schedule II controlled substance, and did knowingly and intentionally aid,
abet, counsel, command, induce or procure the same.
All in violation of Title 21, United States Code, Sections 841(a)(1), and 841(b)(1)(C) and
Title 18, United States Code, Section 2.
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COUNT FOUR
On or about July 14, 2011, within the State and District of Colorado, the defendants,
IVAN GOMEZ-AVILA and SHANA LOUISE CLAYBOURN, did knowingly and intentionally
distribute and possess with the intent to distribute 50 grams or more of methamphetamine
(actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance
containing a detectable amount of methamphetamine, a Schedule II controlled substance, and did
knowingly and intentionally aid, abet, counsel, command, induce or procure the same.
All in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A)(viii)
and Title 18, United States Code, Section 2.
COUNT FIVE
On or about August 3, 2011, within the State and District of Colorado, the defendant,
TODD JOSEPH TRUJILLO did knowingly and intentionally distribute and possess with the
intent to distribute 5 grams or more of a mixture or substance containing a detectable amount of
methamphetamine, a Schedule II controlled substance, and did knowingly and intentionally aid,
abet, counsel, command, induce or procure the same.
All in violation of Title 21, United States Code, Sections 841(a)(1), and 841(b)(1)(C) and
Title 18, United States Code, Section 2.
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COUNT SIX
On or about May 19, 2012, within the State and District of Colorado, the defendant,
REYNA MENDOZA-HARO did knowingly and intentionally distribute and possess with the
intent to distribute 5 grams or more of methamphetamine (actual), a Schedule II controlled
substance, or 50 grams or more of a mixture or substance containing a detectable amount of
methamphetamine, a Schedule II controlled substance.
All in violation of Title 21, United States Code, Sections 841(a)(1), and
841(b)(1)(B)(viii).
COUNT SEVEN
On or about July 5, 2011, within the State and District of Colorado, the defendant,
JAIME MORENO-LOPEZ, did knowingly and intentionally use a communication facility, the
telephone, in committing and in facilitating the commission of the offense of conspiracy to
knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more
of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a
mixture or substance containing a detectable amount of methamphetamine, a Schedule II
controlled substance, as alleged in Count One of this Indictment.
All in violation of Title 21, United States Code, Section 843(b).
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COUNT EIGHT
On or about July 5, 2011, within the State and District of Colorado, the defendant,
CHRISTINA ROSE MALMGREN, did knowingly and intentionally use a communication
facility, the telephone, in committing and in facilitating the commission of the offense of
conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50
grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams
or more of a mixture or substance containing a detectable amount of methamphetamine, a
Schedule II controlled substance, as alleged in Count One of this Indictment.
All in violation of Title 21, United States Code, Section 843(b).
COUNT NINE
On or about July 8, 2011, within the State and District of Colorado, the defendant,
KENNIE RAY SNYDER, did knowingly and intentionally use a communication facility, the
telephone, in committing and in facilitating the commission of the offense of conspiracy to
knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more
of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a
mixture or substance containing a detectable amount of methamphetamine, a Schedule II
controlled substance, as alleged in Count One of this Indictment.
All in violation of Title 21, United States Code, Section 843(b).
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COUNT TEN
On or about July 10, 2011, within the State and District of Colorado, the defendant,
SHANA LOUISE CLAYBOURN, did knowingly and intentionally use a communication
facility, the telephone, in committing and in facilitating the commission of the offense of
conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50
grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams
or more of a mixture or substance containing a detectable amount of methamphetamine, a
Schedule II controlled substance, as alleged in Count One of this Indictment.
All in violation of Title 21, United States Code, Section 843(b).
COUNT ELEVEN
On or about July 12, 2011, within the State and District of Colorado, the defendant,
SHANA LOUISE CLAYBOURN, did knowingly and intentionally use a communication
facility, the telephone, in committing and in facilitating the commission of the offense of
conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50
grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams
or more of a mixture or substance containing a detectable amount of methamphetamine, a
Schedule II controlled substance, as alleged in Count One of this Indictment.
All in violation of Title 21, United States Code, Section 843(b).
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COUNT TWELVE
On or about July 12, 2011, within the State and District of Colorado, the defendant,
REYNA MENDOZA-HARO, did knowingly and intentionally use a communication facility, the
telephone, in committing and in facilitating the commission of the offense of conspiracy to
knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more
of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a
mixture or substance containing a detectable amount of methamphetamine, a Schedule II
controlled substance, as alleged in Count One of this Indictment.
All in violation of Title 21, United States Code, Section 843(b).
COUNT THIRTEEN
On or about July 13, 2011, within the State and District of Colorado, the defendant, CRIS
ANTHONY SANDOVAL, did knowingly and intentionally use a communication facility, the
telephone, in committing and in facilitating the commission of the offense of conspiracy to
knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more
of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a
mixture or substance containing a detectable amount of methamphetamine, a Schedule II
controlled substance, as alleged in Count One of this Indictment.
All in violation of Title 21, United States Code, Section 843(b).
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COUNT FOURTEEN
On or about July 16, 2011, within the State and District of Colorado, the defendant,
REYNA MENDOZA-HARO, did knowingly and intentionally use a communication facility, the
telephone, in committing and in facilitating the commission of the offense of conspiracy to
knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more
of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a
mixture or substance containing a detectable amount of methamphetamine, a Schedule II
controlled substance, as alleged in Count One of this Indictment.
All in violation of Title 21, United States Code, Section 843(b).
COUNT FIFTEEN
On or about July 17, 2011, within the State and District of Colorado, the defendant, CRIS
ANTHONY SANDOVAL, did knowingly and intentionally use a communication facility, the
telephone, in committing and in facilitating the commission of the offense of conspiracy to
knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more
of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a
mixture or substance containing a detectable amount of methamphetamine, a Schedule II
controlled substance, as alleged in Count One of this Indictment.
All in violation of Title 21, United States Code, Section 843(b).
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COUNT SIXTEEN
On or about July 22, 2011, within the State and District of Colorado, the defendant,
JAIME MORENO-LOPEZ, did knowingly and intentionally use a communication facility, the
telephone, in committing and in facilitating the commission of the offense of conspiracy to
knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more
of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a
mixture or substance containing a detectable amount of methamphetamine, a Schedule II
controlled substance, as alleged in Count One of this Indictment.
All in violation of Title 21, United States Code, Section 843(b).
COUNT SEVENTEEN
On or about July 24, 2011, within the State and District of Colorado, the defendant,
REYNA MENDOZA-HARO and ARNALDO ALVAREZ-GONZALEZ, did knowingly and
intentionally use a communication facility, the telephone, in committing and in facilitating the
commission of the offense of conspiracy to knowingly and intentionally distribute and possess
with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II
controlled substance, or 500 grams or more of a mixture or substance containing a detectable
amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this
Indictment.
All in violation of Title 21, United States Code, Section 843(b).
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COUNT EIGHTEEN
On or about July 25, 2011, within the State and District of Colorado, the defendant,
CHRISTINA ROSE MALMGREN, did knowingly and intentionally use a communication
facility, the telephone, in committing and in facilitating the commission of the offense of
conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50
grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams
or more of a mixture or substance containing a detectable amount of methamphetamine, a
Schedule II controlled substance, as alleged in Count One of this Indictment.
All in violation of Title 21, United States Code, Section 843(b).
COUNT NINETEEN
On or about July 27, 2011, within the State and District of Colorado, the defendant,
TODD JOSEPH TRUJILLO, did knowingly and intentionally use a communication facility, the
telephone, in committing and in facilitating the commission of the offense of conspiracy to
knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more
of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a
mixture or substance containing a detectable amount of methamphetamine, a Schedule II
controlled substance, as alleged in Count One of this Indictment.
All in violation of Title 21, United States Code, Section 843(b).
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COUNT TWENTY
On or about July 28, 2011, within the State and District of Colorado, the defendants,
REYNA MENDOZA-HARO and DESIREE ROSE CEBALLES, did knowingly and
intentionally use a communication facility, the telephone, in committing and in facilitating the
commission of the offense of conspiracy to knowingly and intentionally distribute and possess
with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II
controlled substance, or 500 grams or more of a mixture or substance containing a detectable
amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this
Indictment.
All in violation of Title 21, United States Code, Section 843(b).
COUNT TWENTY-ONE
On or about July 28, 2011, within the State and District of Colorado, the defendants,
REYNA MENDOZA-HARO and ARNALDO ALVAREZ-GONZALEZ, did knowingly and
intentionally use a communication facility, the telephone, in committing and in facilitating the
commission of the offense of conspiracy to knowingly and intentionally distribute and possess
with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II
controlled substance, or 500 grams or more of a mixture or substance containing a detectable
amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this
Indictment.
All in violation of Title 21, United States Code, Section 843(b).
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COUNT TWENTY-TWO
On or about August 5, 2011, within the State and District of Colorado, the defendants,
REYNA MENDOZA-HARO and DESIREE ROSE CEBALLES, did knowingly and
intentionally use a communication facility, the telephone, in committing and in facilitating the
commission of the offense of conspiracy to knowingly and intentionally distribute and possess
with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II
controlled substance, or 500 grams or more of a mixture or substance containing a detectable
amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this
Indictment.
All in violation of Title 21, United States Code, Section 843(b).
FORFEITURE ALLEGATION
The allegations contained in Counts One through Twenty-two of this Indictment are
hereby re-alleged and incorporated by reference for the purpose of alleging forfeiture pursuant to
the provisions of 21 U.S.C. 853.
Upon conviction of the violations alleged in Counts One through Twenty-two of this
Indictment involving violations of 21 U.S.C. 846, 841(a)(1), 841(b)(1)(A)(ii)(II), and
841(b)(1)(B)(ii)(II), 21 U.S.C. 843(b), the defendants; REYNA MENDOZA-HARO,
ARNALDO ALVAREZ-GONZALEZ, JAIME MORENO-LOPEZ, RICKY HENRY
CISNEROS, IVAN GOMEZ-AVILA, SHANA LOUISE CLAYBOURN, CRIS ANTHONY
SANDOVAL, TODD JOSEPH TRUJILLO, KENNIE RAY SNYDER, CHRISTINA ROSE
MALMGREN, and DESIREE ROSE CEBALLES, shall forfeit to the United States, pursuant to
Title 21, United States Code, Section 853 any and all of the defendants right, title and interest in
all property constituting and derived from any proceeds obtained directly and indirectly as a
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result of such offense, and in all property used, or intended to be used, in any manner or part, to
commit, or to facilitate the commission of such offense, including, but not limited to a money
judgment in the amount of proceeds obtained by theconspiracyand by the defendants.
If any of the property 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
e) has been commingled with other property which
cannot be subdivided without difficulty;
it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to
seek forfeiture of any other property of said defendants up to the value of the forfeitable
property.
A TRUE BILL:
Ink signature on file in the Clerks Office__
FOREPERSON
APPROVED:
JOHN F. WALSH
United States Attorney
BY: __s/ Zachary Phillips____________
ZACHARY PHILLIPSAssistant United States Attorney
U.S. Attorneys Office
1225 17th Street, Suite 700Denver, CO. 80202
Telephone (303) 454-0118
Fax (303) 454-0401
[email protected] for Government
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BY: Kasandra R. CarletonKASANDRA R. CARLETON
Assistant U.S. Attorney
U.S. Attorneys Office
1225 17th St., Suite 700Denver, Colorado 80202
Telephone: (303) 454-0100Fax: (303) 454-0401
e-mail: [email protected]
Attorney for the Government
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DEFENDANT 1: REYNA MENDOZA-HARO,a/k/a Reyna Mendoza Reyna Reyna Gonzalez Amanda Gonzalez
YOB: 1980 or 1981
ADDRESS: Corcoran, CA
COMPLAINT FILED? YES T NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:IF NO, PROCEED TO OFFENSE SECTION
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES T NO
IF NO, A NEW WARRANT IS REQUIRED
OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and
841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent todistribute 50 grams or more of methamphetamine (actual), a Schedule IIcontrolled substance, or 500 grams or more of a mixture or substance containing adetectable amount of methamphetamine, a Schedule II controlled substance.
COUNT TWO: Title 21, United States Code, Sections 841(a)(1), and841(b)(1)(B)(viii), and Title 18, United States Code, Section 2 - knowingly andintentionally distribute and possess with the intent to distribute 5 grams or moreof methamphetamine (actual), a Schedule II controlled substance, and didknowingly and intentionally aid, abet, counsel, command, induce or procure thesame.
COUNT SIX: Title 21, United States Code, Sections 841(a)(1), and841(b)(1)(B)(viii) - knowingly and intentionally distribute and possess with theintent to distribute 5 grams or more of methamphetamine (actual), a Schedule IIcontrolled substance, and 50 grams or more of a mixture or substance containing
adetectable amount of methamphetamine, a Schedule II controlled substance.
COUNTS TWELVE, FOURTEEN, SEVENTEEN, TWENTY, TWENTY-
ONE, and TWENTY-TWO: Title 21, United States Code, Section 843(b) -knowingly and intentionally use a communication facility, the telephone, incommitting and in causing and facilitating the commission of a felony drugoffense.
LOCATIONOF OFFENSE(COUNTY/STATE): Denver County, Denver, CO
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PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both;NLT 5 years supervised release, $100 Special Assessment Fee.
COUNT TWO and SIX: NLT 5 years, NMT 40 years imprisonment, $5 millionfine, or both; NLT 4 years supervised release, $100 Special Assessment Fee
COUNTS TWELVE, FOURTEEN, SEVENTEEN, TWENTY, TWENTY-ONE, and TWENTY-TWO: NMT 4 years imprisonment, $250,000.00 fine, orboth; NMT 1 year supervised release; and a $100 Special Assessment Fee (percount).
AGENT: TFO Leonard A. HuskeyDrug Enforcement Administration
AUTHORIZED Zachary H. PhillipsBY: Kasandra R. Carleton
Assistant U.S. Attorneys
ESTIMATED TIME OF TRIAL: 5 days or more
THE GOVERNMENT will seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: T Yes No
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DEFENDANT 2: ARNALDO ALVAREZ-GONZALEZ,a/k/a Indio Monra
YOB: 1978
ADDRESS:
COMPLAINT FILED? YES T NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:IF NO, PROCEED TO OFFENSE SECTION
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES T NO
IF NO, A NEW WARRANT IS REQUIRED
OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and
841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent todistribute 50 grams or more of methamphetamine (actual), a Schedule IIcontrolled substance, or 500 grams or more of a mixture or substance containing adetectable amount of methamphetamine, a Schedule II controlled substance.
COUNTS SEVENTEEN and TWENTY-ONE: Title 21, United States Code,Section 843(b) - knowingly and intentionally use a communication facility, thetelephone, in committing and in causing and facilitating the commission of afelony drug offense.
LOCATION
OF OFFENSE(COUNTY/STATE): Denver County, Denver, CO
PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both;NLT 5 years supervised release, $100 Special Assessment Fee.
COUNTS SEVENTEEN and TWENTY-ONE: NMT 4 years imprisonment,$250,000.00 fine, or both; NMT 1 year supervised release; and a $100 SpecialAssessment Fee (per count).
AGENT: TFO Leonard A. HuskeyDrug Enforcement Administration
AUTHORIZED Zachary H. PhillipsBY: Kasandra R. Carleton
Assistant U.S. Attorneys
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ESTIMATED TIME OF TRIAL: 5 days or more
THE GOVERNMENT will seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: T Yes No
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DEFENDANT 3: JAIME MORENO-LOPEZ,a/k/a El Guapo Jaime Lopez Jaime MorenoAdrian Lopez-Villeda Alberto Torres-Trejo
YOB: 1981 or 1980
ADDRESS:
COMPLAINT FILED? YES T NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:IF NO, PROCEED TO OFFENSE SECTION
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES T NO
IF NO, A NEW WARRANT IS REQUIRED
OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent todistribute 50 grams or more of methamphetamine (actual), a Schedule IIcontrolled substance, or 500 grams or more of a mixture or substance containing adetectable amount of methamphetamine, a Schedule II controlled substance
COUNTS SEVEN and SIXTEEN: Title 21, United States Code, Section843(b) - knowingly and intentionally use a communication facility, thetelephone, in committing and in causing and facilitating the commission of afelony drug offense.
LOCATIONOF OFFENSE(COUNTY/STATE): Denver County, Denver, CO
PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine,or both; NLT 5 years supervised release, $100 Special Assessment Fee.
COUNTS SEVEN and SIXTEEN: NMT 4 years imprisonment,$250,000.00 fine, or both; NMT 1 year supervised release; and a $100 SpecialAssessment Fee (per count).
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AGENT: TFO Leonard A. HuskeyDrug Enforcement Administration
AUTHORIZED Zachary H. PhillipsBY: Kasandra R. Carleton
Assistant U.S. Attorneys
ESTIMATED TIME OF TRIAL: 5 days or more
THE GOVERNMENT will seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: T Yes No
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DEFENDANT 4: RICKY HENRY CISNEROS,a/k/a Ricky Cisneros
YOB: 1974
ADDRESS: Denver, Colorado
COMPLAINT FILED? YES T NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:IF NO, PROCEED TO OFFENSE SECTION
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES T NO
IF NO, A NEW WARRANT IS REQUIRED
OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and
841(b)(1)(A)(viii) - conspiracy to distribute and possess with the intent todistribute 50 grams or more of methamphetamine (actual), a Schedule IIcontrolled substance, or 500 grams or more of a mixture or substance containing adetectable amount of methamphetamine, a Schedule II controlled substance.
LOCATIONOF OFFENSE(COUNTY/STATE): Denver County, Denver, CO
PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine,or both; NLT 5 years supervised release, $100 Special Assessment Fee.
AGENT: TFO Leonard A. HuskeyDrug Enforcement Administration
AUTHORIZED Zachary H. PhillipsBY: Kasandra R. Carleton
Assistant U.S. Attorneys
ESTIMATED TIME OF TRIAL: 5 days or more
THE GOVERNMENT will seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: T Yes No
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DEFENDANT 5: IVAN GOMEZ-AVILA,a/k/a Ivan Avila Ivan Flores Jose Gomez
YOB: 1981 or 1980
ADDRESS: Denver, Colorado
COMPLAINT FILED? YES T NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:IF NO, PROCEED TO OFFENSE SECTION
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES T NO
IF NO, A NEW WARRANT IS REQUIRED
OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and
841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent todistribute 50 grams or more of methamphetamine (actual), a Schedule IIcontrolled substance, or 500 grams or more of a mixture or substance containing adetectable amount of methamphetamine, a Schedule II controlled substance
COUNT FOUR: Title 21, United States Code, Sections 841(a)(1) and841(b)(1)(A)(viii) and Title 18, United States Code, Section 2 - knowingly andintentionally distribute and possess with the intent to distribute 50 grams or moreof methamphetamine (actual), a Schedule II controlled substance, or 500 grams ormore of a mixture or substance containing a detectable amount ofmethamphetamine, a Schedule II controlled substance, and did knowingly and
intentionally aid, abet, counsel, command, induce or procure the same
LOCATIONOF OFFENSE(COUNTY/STATE): Denver County, Denver, CO
PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine,or both; NLT 5 years supervised release, $100 Special Assessment Fee.
COUNT FOUR: NLT 10 years, NMT life in prison, $10 million fine, or both;NLT 5 years supervised release, $100 Special Assessment Fee
AGENT: TFO Leonard A. HuskeyDrug Enforcement Administration
AUTHORIZED Zachary H. PhillipsBY: Kasandra R. Carleton
Assistant U.S. Attorneys
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ESTIMATED TIME OF TRIAL: 5 days or more
THE GOVERNMENT will seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: T Yes No
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DEFENDANT 7: CRIS ANTHONY SANDOVAL,a/k/a "Cris Sandoval" "Christopher Sandoval"
YOB: 1959
ADDRESS:
COMPLAINT FILED? YES T NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:IF NO, PROCEED TO OFFENSE SECTION
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES T NO
IF NO, A NEW WARRANT IS REQUIRED
OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and
841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent todistribute 50 grams or more of methamphetamine (actual), a Schedule IIcontrolled substance, or 500 grams or more of a mixture or substance containing adetectable amount of methamphetamine, a Schedule II controlled substance.
COUNTS THIRTEEN and FIFTEEN: Title 21, United States Code,Section 843(b) - knowingly and intentionally use a communication facility, thetelephone, in committing and in facilitating the commission of a felony drugoffense.
LOCATION
OF OFFENSE(COUNTY/STATE): Denver County, Denver, CO
PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine,or both; NLT 5 years supervised release, $100 Special Assessment Fee.
COUNTS THIRTEEN and FIFTEEN: NMT 4 years imprisonment,$250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00Special Assessment Fee (per count)
AGENT: TFO Leonard A. Huskey
Drug Enforcement Administration
AUTHORIZED Zachary H. PhillipsBY: Kasandra R. Carleton
Assistant U.S. Attorneys
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ESTIMATED TIME OF TRIAL: 5 days or more
THE GOVERNMENT will seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: T Yes No
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DEFENDANT 8: TODD JOSEPH TRUJILLO,a/k/a "Todd Trujillo" "Tracy Petterson" "Todd Jose Trujillo"
YOB: 1967
ADDRESS: Westminster, Colorado
COMPLAINT FILED? YES T NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:IF NO, PROCEED TO OFFENSE SECTION
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES T NO
IF NO, A NEW WARRANT IS REQUIRED
OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and
841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent todistribute 50 grams or more of methamphetamine (actual), a Schedule IIcontrolled substance, or 500 grams or more of a mixture or substance containing adetectable amount of methamphetamine, a Schedule II controlled substance.
COUNT FIVE: Title 21, United States Code, Sections 841(a)(1), and841(b)(1)(C) and Title 18, United States Code, Section 2 - knowingly andintentionally distribute and possess with the intent to distribute 5 grams or moreof a mixture or substance containing a detectable amount of methamphetamine, aSchedule II controlled substance, and did knowingly and intentionally aid, abet,counsel, command, induce or procure the same.
COUNT NINETEEN: Title 21, United States Code, Section 843(b) -knowingly and intentionally use a communication facility, the telephone, incommitting and in facilitating the commission of a felony drug offense.
LOCATIONOF OFFENSE(COUNTY/STATE): Denver County, Denver, CO
PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine,or both; NLT 5 years supervised release, $100 Special Assessment Fee.
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COUNT FIVE: NMT 20 years imprisonment, $1 million fine, or both; NLT 3years supervised release, $100 Special Assessment Fee
COUNT NINETEEN: NMT 4 years imprisonment, $250,000.00 fine, or both;NMT 1 year supervised release; and a $100.00 Special Assessment Fee.
AGENT: TFO Leonard A. HuskeyDrug Enforcement Administration
AUTHORIZED Zachary H. PhillipsBY: Kasandra R. Carleton
Assistant U.S. Attorneys
ESTIMATED TIME OF TRIAL: 5 days or more
THE GOVERNMENT will seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: T Yes No
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DEFENDANT 9: KENNIE RAY SNYDER,a/k/a "Kennie Snyder"
YOB: 1966
ADDRESS: Lakewood, Colorado
COMPLAINT FILED? YES T NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:IF NO, PROCEED TO OFFENSE SECTION
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES T NO
IF NO, A NEW WARRANT IS REQUIRED
OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and
841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent todistribute 50 grams or more of methamphetamine (actual), a Schedule IIcontrolled substance, or 500 grams or more of a mixture or substance containing adetectable amount of methamphetamine, a Schedule II controlled substance.
COUNT THREE: Title 21, United States Code, Sections 841(a)(1), and841(b)(1)(C) and Title 18, United States Code, Section 2 - knowingly andintentionally distribute and possess with the intent to distribute 5 grams or moreof a mixture or substance containing a detectable amount of methamphetamine, aSchedule II controlled substance, and did knowingly and intentionally aid, abet,counsel, command, induce or procure the same.
COUNT NINE: Title 21, United States Code, Section 843(b) -knowingly and intentionally use a communication facility, the telephone, incommitting and in facilitating the commission of a felony drug offense.
LOCATIONOF OFFENSE(COUNTY/STATE): Denver County, Denver, CO
PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine,or both; NLT 5 years supervised release, $100 Special Assessment Fee.
COUNT THREE: NMT 20 years imprisonment, $1 million fine, or both;NLT 3 years supervised release, $100 Special Assessment Fee.
COUNT NINE: NMT 4 years imprisonment, $250,000.00 fine,or both; NMT 1 year supervised release; and a $100.00 Special AssessmentFee.
AGENT: TFO Leonard A. Huskey
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Drug Enforcement Administration
AUTHORIZED Zachary H. PhillipsBY: Kasandra R. Carleton
Assistant U.S. Attorneys
ESTIMATED TIME OF TRIAL: 5 days or more
THE GOVERNMENT will seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: T Yes No
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DEFENDANT 10: CHRISTINA ROSE MALMGREN,a/k/a "Christina Malmgren"
YOB: 1987
ADDRESS:
COMPLAINT FILED? YES T NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:IF NO, PROCEED TO OFFENSE SECTION
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES T NO
IF NO, A NEW WARRANT IS REQUIRED
OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and
841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent todistribute 50 grams or more of methamphetamine (actual), a Schedule IIcontrolled substance, or 500 grams or more of a mixture or substance containing adetectable amount of methamphetamine, a Schedule II controlled substance.
COUNTS EIGHT and EIGHTEEN: Title 21, United States Code,Section 843(b) - knowingly and intentionally use a communication facility, thetelephone, in committing and in facilitating the commission of a felony drugoffense.
LOCATION
OF OFFENSE(COUNTY/STATE): Denver County, Denver, CO
PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine,or both; NLT 5 years supervised release, $100 Special Assessment Fee.
COUNTS EIGHT and EIGHTEEN: NMT 4 years imprisonment,$250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00Special Assessment Fee (per count)
AGENT: TFO Leonard A. Huskey
Drug Enforcement Administration
AUTHORIZED Zachary H. PhillipsBY: Kasandra R. Carleton
Assistant U.S. Attorneys
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DEFENDANT 11: DESIREE ROSE CEBALLES,a/k/a Desiree Rosa Allen Desiree Rose LucyDesiree Ceballes Desiree Rose Martinez
YOB: 1985
ADDRESS:
COMPLAINT FILED? YES T NO
IF YES, PROVIDE MAGISTRATE CASE NUMBER:IF NO, PROCEED TO OFFENSE SECTION
HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES T NO
IF NO, A NEW WARRANT IS REQUIRED
OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent todistribute 50 grams or more of methamphetamine (actual), a Schedule IIcontrolled substance, or 500 grams or more of a mixture or substance containing adetectable amount of methamphetamine, a Schedule II controlled substance.
COUNTS TWENTY and TWENTY-TWO: Title 21, United StatesCode, Section 843(b) - knowingly and intentionally use a communication facility,the telephone, in committing and in facilitating the commission of a felonydrug offense.
LOCATIONOF OFFENSE(COUNTY/STATE): Denver County, Denver, CO
PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine,or both; NLT 5 years supervised release, $100 Special Assessment Fee.
COUNTS TWENTY and TWENTY-TWO: NMT 4 years imprisonment,$250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00 SpecialAssessment Fee (per count).
AGENT: TFO Leonard A. HuskeyDrug Enforcement Administration
AUTHORIZED Zachary H. PhillipsBY: Kasandra R. Carleton
Assistant U.S. Attorneys
ESTIMATED TIME OF TRIAL: 5 days or more
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THE GOVERNMENT will seek detention in this case
The statutory presumption of detention is applicable to this defendant.
OCDETF CASE: T Yes No
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