District Court, City and County of Denver, Colorado City and County Building, Room 259 1437 Bannock Street Denver, CO 80202 Plaintiff: THE PEOPLE OF THE STATE OF COLORADO Defendants: PABLO BLEACHER NOAH FERRIS COURT USE ONLY JORDAN GOETSCH Case Number: JORY INGRAM MICHAEL RODGERS Grand Jury No. 17CR2A BREONNA GILBERT ASHTON LANE Div.: Criminal Ctrm:259/__ ANTONIO MADISON MARQUES MITCHELL CHEYENNE PIERCE | JONATHAN VILLALOBOS-REICHARDT SIERRA BYRNE BRIEN FINLEY ANDREW FINN KYLE HIBBARD BRITTANY SALAZAR MALAINA LUBY | KENNETH LUCAS | ANDRE GRIFFITH L INDICTMENT VIOLATION OF COLORADO ORGANIZED CRIME CONTROL ACT, CRS. 18-17-104(3), (F2) <37284> 1 (1 count) CONSPIRACY TO COMMIT SECOND DEGREE BURGLARY, CR.S, 18-4-203(1); 18-2-201 (F5) <06031C> 2 (1 count) CONSPIRACY TO COMMIT AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, C.R.S.18-4-409(2),(3)(2.5);18-2-201 (F5 ) 3 (1 count) AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, CRS. 18-4. 409(2),(3)(a) (FS ) <0804G > 4, 5, 8, 14, 21, 23, 24, 26, 33, 34, 38, 41, 42, 50, 57, 72, 74, 76, 79, 80, 83, 91, 95 (23 counts) AGGRAVATED MOTOR VEHICLE THEFT IN THE SECOND DEGREE, CRS.18-4- 409(4)(b) (F6) <0804E> 6, 7, 19, 22 (4 counts)SECOND DEGREE BURGLARY, C.R.S. 18-4-203(1) (F4) <06031> 9, 11, 12, 13, 15, 17, 20, 25, 27, 30, 32, 40, 49, 56, 62, 63, 66, 67, 71, 73, 75, 78, 82, 84, 85, 86, 88, 89, 90, 92, 94 31 counts) AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, CRS. 18-4- 409(2),(3)(a.5) (F4 ) 10, 16, 18, 45, 77 (5 counts) THEFT, CRS. 18-4-401(1),(2)(d) (M2) <08A11> 28, 43, 61, 87 (4 counts) CRIMINAL MISCHIEF, C.R.S. 18-4-501(1),(4)(c) QM ) <0901H > 29 (1 count) THEFT, C.R.S. 18-4-401(1),(2)(e) (M1) <08A12> 31, 47, 69, 93 (4 counts) IDENTITY THEFT, C.R.S. 18-5-902(1)(b) (F4) <1307H> 35, 36, 39, 53, 54, 55, 60, 70 (8 counts) IDENTITY THEFT, CRS. 18-5-902(1)(a) (F4) <1307G> 37, 51, 52, 58, 59, 64, 65, 81 (8 counts) SECOND DEGREE BURGLARY, C.R.S. 18-4-203(1),(2)(a) (F3) <06032> 44 (1 count) AGGRAVATED MOTOR VEHICLE THEFT IN THE SECOND DEGREE, C.R.S. 18-4- 409(4)(a) (F5) <0804D> 46 (1 count) POSSESSION OF A WEAPON BY PREVIOUS OFFENDER, C.R.S. 18-12-108(1) (F6) <3007A> 48, 68 (2 counts) VEHICULAR ELUDING, C.R.S. 18-9-116.5 (F5) <27162> 96 (1 count) PAWNBROKER'S ACT VIOLATION, CRS. 12-56-103(1);12-56-104(5) (F6) <32071> 97 (count) ASSAULT IN THE FIRST DEGREE, C.R.S. 18-3-202(1)(a) (F3) <02011> 98 (1 count) CRIMINAL ATTEMPT TO COMMIT AGGRAVATED ROBBERY, CRS. 18-4-302(1)(b);18- 2-101 (F4) <07022A> 99 (1 count)‘The Grand Jury presents the within Indictment and the same is ordered filed. Dated this Y* day of O opi » 2017. LLG -[_ Michael A. Martinez Chief Judge Denver District CourtBETH McCANN District Attorney BOYD, Reg. No. 37900 Denver District Attorney's Office 201 W. Colfax Ave., Dept. 801 Denver, CO 80202 720-913-9015 14iE VIOLATION OF COLORADO ORGANIZED CRIME CONTROL ACT, CRS. 18-17-1043), (F2) <37284> Between and including November 20, 2015 and July 7, 2017, at and triable in the City and County of Denver, State of Colorado, PABLO BLEACHER, NOAH FERRIS, JORDAN GOETSCH, JORY INGRAM, and MICHAEL RODGERS, while employed by or associated with an enterprise, namely: a group of individuals associated in fact, although not a legal entity, unlawfully, feloniously, and knowingly conducted or participated, directly or indirectly, in the enterprise through a pattem of racketeering activity; in violation of sections 18-17-104(3) and 18-17-105, CRS. ‘The Enterprise ‘The enterprise alleged in this count was a group of individuals, associated in fact, although not a legal entity. The enterprise included, but was not limited to, the following: SIERRA BYRNE, BRIEN FINLEY, ANDREW FINN, BREONNA GILBERT, ANDRE GRIFFITH, KYLE HIBBARD, ASHTON LANE, MALAINA LUBY, KENNETH LUCAS, ANTONIO MADISON, MARQUES MITCHELL, CHEYENNE PIERCE, BRITTANY SALAZAR, JONATHAN VILLALOBOS-REICHARDT, 7, persons known or unknown, who were associated from time to time in racketeering activity that was related to the conduct of the enterprise, For purposes of this count, the defendants engaged in acts related to the conduct of the enterprise, including: As to PABLO BLEACHER, the acts described in counts 2, 3, 4, 25, 26, 27, 28, 29, 30, 56, 57, 58, 62, 63, 66, 75, 76, 77, 78, 79, 81, 84, 86, 87, 88, and 89, including any lesser inchuded offenses of these counts, and Predicate Acts 100 and 101, As to NOAH FERRIS, the acts described in counts 2, 3, 18, 21, 22, 31, 32, 33, 40, 41, 49, 50, 52, $7, 59, 80, 82, 83, 85, and 94, including any lesser included offenses of these counts. As to JORDAN GOETSCH, the acts described in counts 2, 3, 14, 15, 16, 17, 32, 46, 47, 65, 86, and 87, including any lesser included offenses of these counts. As to JORY INGRAM, the acts described in counts 2, 3, 9, 10, 11, 12, 15, 16, 18, 20, 21, 67, 71, 72, 73, 74, 80, 81, 82, 83, 85, 90, 91, 92, 93, and 94, including any lesser included offenses of these counts, and Predicate Acts 102 and 103. As to MICHAEL RODGERS the acts described in counts 2, 3, 34, 35, 36, 44, 45, 62, and 95, 15including any lesser included offenses of these counts, and Predicate Acts 104 and 105. counrtwo CONSPIRACY TO COMMIT SECOND DEGREE BURGLARY, 18-4-203(1);18-2-201 C.R.S. (F5) <06031C> Between and including April 4, 2016 and June 17, 2017, at and triable in the City and County of Denver, State of Colorado, PABLO BLEACHER, NOAH FERRIS, JORDAN GOETSCH, JORY INGRAM, MICHAEL RODGERS, BREONNA GILBERT, ASHTON LANE, ANTONIO MADISON, MARQUES MITCHELL, CHEYENNE PIERCE, and JONATHAN VILLALOBOS-REICHARDT, with the intent to promote or facilitate the commission of the crime of Second Degree Burglary, unlawfully and feloniously agreed with Each Other and a person or persons to the Grand Jury unknown that one or more of them would engage in conduct which constituted that crime or an attempt to commit that crime, or agreed to aid the other person or persons in the planning or commission or attempted commission of that crime, and an overt act in pursuance of the conspiracy was committed by one or more of the conspirators; in violation of sections 18-4-203(1) and 18-2-201, C.R.S. COUNT CONSPIRACY TO COMMIT AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, 18-4-409(2),(3)(a.5);18-2-201 C.R.S. (FS) <0804HC> Between and including November 20, 2015 and June 17, 2017, at and triable in the City and County of Denver, State of Colorado, PABLO BLEACHER, NOAH FERRIS, JORDAN GOETSCH, JORY INGRAM, MICHAEL RODGERS, BREONNA GILBERT SIERRA BYRNE, BRIEN FINLEY, ANDREW FINN, KYLE HIBBARD, ASHTON LANE, ANTONIO MADISON, MARQUES MITCHELL, CHEYENNE. PIERCE, BRITTANY SALAZAR, and JONATHAN VILLALOBOS-REICHARDT with the intent to promote or facilitate the commission of the crime of Aggravated Motor Vehicle Theft In The First Degree, uniawiully and feloniously agreed with Each Other and a person or persons to the Grand Jury unknown that one or more of them would engage in conduct which constituted that crime or an attempt to commit that crime, or agreed to aid the other person or persons in the planning or commission or attempted commission of that crime, and an overt act in pursuance of the conspiracy was committed by one or more of the conspirators; in violation of sections 18-4- 409(2),@)(a.5) and 18-2-201, CRS, PREDICATE ACT ONE HUNDRED AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, CRS 18-4- 409(2),(3)(a) (FS) <0804G> On or about June 6, 2016, PABLO BLEACHER unlawfull obtained or exercised control over the motor vehicle of I without authorization, or by threat or deception, and retained possession or control over the motor vehicle for more than twenty-four hours, and the value of the motor vehicle was less than twenty thousand dollars; in violation of section 18-4-409(2),(3)(a), C.R.S. feloniously, and knowingly 16PREDICATE ACT ONE HUNDRED ONE AGGRAVATED MOTOR VEHICLE THEFT IN THE SECOND DEGREE, C.RS 18-4- 409(4)(a) (F5) <0804D> On or about September 9, 2016, PABLO BLEACHER unlawfillly, feloniously, and knowingly obtained or exercised control over the motor vehicle of TE, without authorization or by threat or deception, and the value of the motor vehicle was twenty thousand dollars or more; in violation of section 18-4-409(4)(a), CRS PREDICATE ACT ONE HUNDRED TWO AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, C.RS 18-4- 409(2),(3)(a) (F5) <0804G> On or about December 3, 2016, JORY M INGRAM unlawfully, feloniously, and knowingly obtained or exercised control over the motor vehicle of [TTT without authorization, or by threat or deception, and retained possession or control over the motor vehicle for more than twenty-four hours, and the value of the motor vehicle was less than twenty thousand dollars; in violation of section 18-4-409(2),(3)(a), CRS. PREDICATE ACT ONE HUNDRED THREE SECOND DEGREE BURGLARY, C.R.S 18-4-203(1) (F4) <06031> On or about January 2, 2017, JORY M INGRAM unlawfully, feloniously, and knowingly broke an entrance into, entered, or remained unlawfully after a lawful or unlawful entry in the building or occupied structure of (i, located at 1 On or about April 21, 2016, MICHAEL L RODGERS unlawfully, and knowingly, took a thing of value, namely: BICYCLES of @Q0I00000097, with the value of seven hundred fifty dollars or more but less than two thousand dollars; in violation of section 18-4-401 (1),(2)(e),(6) CRS. PREDICATE ACT ONE HUNDRED FIVE AGGRAVATED MOTOR VEHICLE THEFT IN THE SECOND DEGREE, 18-4-409(4)(C), CRS. (M1) <0804F> On or about November 28, 2016, MICHAEL L RODGERS unlawfully and knowingly obtained or exercised control over the motor vehicle of @7—''., without authorization or by threat or deception, and the value of the motor vehicles was less than one thousand dollars; in violation of section 18-4-409(4)(c), CRS. The facts supporting Counts | through 3 and Predicate Acts 100 through 105 are as follows: 171, The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. From at least November 20, 2015 through July 7, 2017, with various members joining at various times, Pablo Bleacher, Noah Ferris, Jordan Goetsch, Jory Ingram, Michael Rodgers, Sierra Byme, Brien Finley, Andrew Finn, Breonna Gilbert, Andre Griffith, Kyle Hibbard, Ashton Lane, Malaina Luby, Kenneth Lucas, Antonio Madison, Marques Mitchell, Cheyenne Pierce, Brittany Salazar, Jonathan Villalobos-Reichardt and other persons known or unknown, including, but not limited tc, I Ci, CT: us Cian) Gnu Gee, aap ED. (aes, See were a group of individuals associated in fact, though not a legal entity, with common goals. 3.___ The members of the enterprise described themselves as belonging to a “family” known as. “Gutter Punks,” specifically the “Gutter Punk Crew” or “GPC,” (hereinafter “GPC”). Some members of GPC also claimed allegiance to a sub-set of GPC known as “MOB.” “MOB” stands primarily for “Meth Over Bitches” and / or “Money Over Bitches” (hereinafter “MOB”). 4. GPC members were known and identified by the following names: Pablo Bleacher: “Uno” ‘Noah Fertis: “Ocean” Jordan Goetsch: “Ash” Jory Ingram: “OD” and “Odysseus” Michael Rodgers: “Tex” Sierra Byme: “Bubbles” ‘Andrew Finn: “Oso” Ashton Lane: “Jinx” and “Gutta Jinx” Malaina Luby: “Anchor” Kenneth Lucas: “Wood” Antonio Madison: “Milly” Cheyenne Pierce: “Giggles” Brittany Salazar: “Harley Quinn” SR: “Gutta Boy” SE “Pinky” SE “Diego” GREE “Nephew” Ee. “Tiny” GREER “Gypsy Queen” and “Perry” EE “Fat Fat.” 5. The common goals of the enterprise were to obtain, share, and distribute controlled substances, including, but not limited to, marijuana, methamphetamine, and heroin. Members of the enterprise paid for the marijuana, methamphetamine, heroin, and other controlled substances by selling or trading stolen property. Members of the enterprise sold, traded and shared the stolen property, including, but not limited to, stolen: a) money; 18) motor vehicles; ) weapons; & bicycles; ©) personal identifying information and documents; 4) financial identifying information and documents; 2) financial devices; h) electronic devices; ') clothes; i) jewelry; ) accessories; 1) and other stolen property. 6. Members of the enterprise obtained the stolen property primarily through burglarizing secured residential parking garages attached to apartment, condominium, and business complexes located in the Downtown Denver, LoDo, LoHi, and RiNo areas of the City and County of Denver, State of Colorado. Enterprise members often used stolen motor vehicles to facilitate those burglaries. 7. Members of the enterprise, including, but not limited to, Pablo Bleacher, Noah Ferris, Jordan Goetsch, Jory Ingram, Michael Rodgers, Sierra Byme, Brien Finley, Anérew Finn, Breonna Gilbert, Kyle Hibbard, Ashton Lene, Malaina Luby, Antonio Madison, Cheyenne Pierce, Brittany Salazar, and Jonathan Villalobos-Reichardt, working in concert with each other and/or with persons known and unknown to the Grand Jury, stole motor vehicles primarily from the Downtown Denver, LoDo, LoHi, and RiNo areas of the City and County of Denver, State of Colorado to use in the commission of other crimes, including burglary, theft, aggravated motor vehicle theft, and identity thett. 8 In order to burglarize a secured parking facility, enterprise members would circumvent security measures by several methods, including, but not limited to: a) following a tenant's vehicle into the garage, either on foot, or in a stolen motor vehicle; ») breaking entry into residential complexes by forcing open lobby doors; ) ramming stolen cars through garage entry and exit control arms and gates; 4) operating stolen garage door openers; ) using public entrances during regular business hours. 9. Once inside a secured garage area, enterprise members rapidly went through the garage and checked vehicle doors to determine if the doors were unlocked. If a vehicle door was unlocked, enterprise members would unlawfully enter the vehicle and steal property. Ifa key was located inside the vehicle, the enterprise members would then steal that vehicle. This process was known and described by enterprise members as “‘car-hopping.” 10, From time to time, enterprise members shared stolen motor vehicles as living end storage spaces. 1911. From time to time, enterprise members also shared living and storage spaces by squatting in foreclosed buildings, or vacant buildings awaiting demolition or rehabilitation, including, but not limited to, a house located at 2451 Lawrence Street in the City and County of Denver. That house was known to enterprise members as “The Mansion.” 12. From time to time, enterprise members shared living and storage spaces by utilizing fraudulent documents to obtain apartments, including but not limited to an apartment located at 1880 Arapahoe Street, Unit #2503, in the City and County of Denver, State of Colorado. 13, Members of the enterprise, including, but not limited to, Kenneth Lucas, retained possession and control of stolen items pending use, distribution, or sale of the stolen property. 14. Members of the enterprise sold stolen merchandise through various means, including, but not limited to, pawnshops. Enterprise members, including, but not limited to, Andre Griffith, pawned property that had been stolen by other enterprise members. 15. Enterprise members, including but not limited to, Pablo Bleacher, Noah Ferris, Jordan Goetsch, Jory Ingram, Sierra Byme, Brien Finley, Kyle Hibbard, and Jonathan Villalobos- Reichardt, used stolen financial devices to obtain goods and services for themselves and other enterprise members. 16. Enterprise members, including but not limited to, Michael Rodgers, Brien Finley, Andrew Finn, Kenneth Lucas, Brittany Salazar, and Jonathan Villalobos-Reichardt, possessed stolen personal identifying information, and / or financial identifying information, and / or financial devices, with the intent to use that information and /or those devices to obtain goods ‘and services for themselves and other enterprise members. 17. At all times relevant to this Indictment, members of the enterprise shared money, proceeds from the sale of stolen property, stolen property, stolen identification documents, stolen financial transaction devices, stolen automobiles, transportation, controlled substances, food, clothing, and living quarters to accomplish the enterprise’s goals. 18. At all times relevant to this Indictment, members of the enterprise stole an aggregate amount of more than $40,000.00 worth of property while committing garage burglaries, motor vehicle trespasses, identity theft, and other thefts. 19. At all times relevant to this Indictment, members of the enterprise caused an aggregate amount of more than $30,000.00 worth of property damage while committing garage burglaries and motor vehicle thefis. 20. At all times relevant to this Indictment, members of the enterprise stole an aggregate amount of more than $600,000.00 worth of motor vehicles. 21, As to Predicate Act 100: On or about June 6, 2016, Pablo Bleacher unlawfully, feloniously, and knowingly obtained or exercised control over the motor vehicle of SI (@QREEEEE, without authorization, or by threat or deception, and retained possession or control 20over the motor vehicle for more than twenty-four hours, and the value of the motor vehicle was less than twenty thousand dollars; in violation of section 18-4-409(2),(3)(a), C.R.S. Pablo Bleacher was charged for that offense and entered a guilty plea to one count of Aggravated Motor Vehicle in the First Degree, 18-4-409(2)(3)(a), C.R.S., a Class Five felony, in Denver County District Court Case Number 2016CR3782, on July 15, 2016. 22. _As to Predicate Act 101: On or about September 9, 2016, Pablo Bleacher unlawfully, feloniously, and knowingly obtained or exercised control over the motor vehicle of A {@EEED without authorization or by threat or deception, and the value of the motor vehicle was twenty thousand dollars or more; in violation of section 18-4-409(4)(a), C.R.S. Pablo Bleacher was charged for that offense and entered a guilty plea to one count of Aggravated Motor Vehicle in the Second Degree, 18-4-409(4)(a), C.R.S., a Class Five felony, in Denver County District Court Case Number 2016CR5855, on November 7, 2016. 23. As to Predicate Act 102: On or about December 3, 2016, Jory M. Ingram unlawfully, feloniously, and knowingly obtained or exercised control over the motor vehicle of GD. @EEEW, without authorization, or by threat or deception, and retained possession or control over the motor vehicle for more than twenty-four hours, and the value of the motor vehicle was less than twenty thousand dollars; in violation of section 18-4-409(2),(3)(a), C.R.S. Jory Ingram was charged for that offense and entered a guilty plea to one count of Aggravated Motor Vehicle in the First Degree, 18-4-409(2)(3)(a), C.R.S., a Class Five felony, in Denver County District Court Case Number 2017CR181, on February 13, 2017, 24, As to Predicate Act 103: On or about January 2, 2017, Jory M. Ingram unlawfully, feloniously, and knowingly broke an entrance into, entered, or remained unlawfully after a lawful or unlawful entry in the building or occupied structure 0f CAEN, located at 14@@ Little Raven Street with the intent to commit therein the crime of Theft; in violation of section 18-4-203(1), C.R.S. Jory Ingram was charged for that offense and entered a guilty plea to one count of Second Degree Burglary of a Building, 18-4-203(1), C.R.S., a Class Four felony, in Denver County District Court Case Number 2017CR184, on February 13, 2017. 25. _Asto Predicate Act 104: On or ebout April 21, 2016, Michael L. Rodgers unlawfully, and knowingly, took a thing of value, namely: Bicycles of (IMME, with the value of seven hundred fifty dollars or more but Jess than two thousand dollars; in violation of section 18-4 401(1),(2)(€),(6) C-R.S. Michael Rodgers was charged for that offense and entered a guilty plea to one count of Theft $720.00 to $2,000.00, 18-4-401(1) @2)(e), CRS. a Class One misdemeanor, in Denver County District Court Case Number 2016CR2543, on July 21, 2016. 26. —_Asto Predicate Act 105: On or about November 28, 2016, Michael L. Rodgers unlawfully and knowingly obtained or exercised control over the motor vehicle of GEER without authorization or by threat or deception, and the value of the motor vehicles was less than one thousand dollars; in violation of section 18-4-409(4)(c), CR.S. Michael Rodgers was charged for that offense and entered a guilty plea to one count of Aggravated Motor Vehicle Theft In The Second Degree, 18-4-409(4)(C), C.R.S., a Class One misdemeanor, in Denver County District Court Case Number 2016CR7861, on February 9, 2017. aCOUNT FOUR AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, 18-4~409(2),(3)(a) CRS. (F5 ) <0804G> Between and including April 4, 2016 and April 14, 2016, at and triable in the City and County of Denver, State of Colorado, PABLO BLEACHER unlawfully, feloniously, and knowingly obtained or exercised control over the motor Vehicle of (TTT, without authorization, or by threat or deception, and retained possession or control over the motor vehicle for more than twenty-four hours and the value of the motor vehicle was less than twenty thousand dollars; in violation of section 18-4-409(2),(3)(a), C.R.S. The facts supporting Count 4 are as follows: 1, The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about April 4, 2016, an as-yet unidentified enterprise member or members stole a 2001 Land Rover Discovery valued at $5,000.00 which was owned by mania, from the secured garage of the Ballpark Lofts located at 1451 24" Street in the City and County of Denver, State of Colorado. An additional $5,000.00 in personal property was inside the Land Rover when it was stolen. 3. On or about April 14, 2016 that stolen Land Rover Discovery was recovered in the 800 block of 21* Street in the City and County of Denver, State of Colorado. A cigarette stub containing the DNA of Pablo Bleacher was recovered inside the Land Rover. 4. _ Between and including April 4, 2016 and April 14, 2016, Pablo Bleacher, in association with the enterprise, unlawfully, feloniously, and knowingly retained possession or control over the stolen 2001 Land Rover Discovery of (2° without the owner'sCOUNT FIVE AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, 18-4-409(2),(3)(a) CRS. (F5) <0804G > Between and including June 18, 2016 and June 28, 2016, at and triable in the City and County of Denver, State of Colorado, ANDREW FINN unlawfully, feloniously, and knowingly obtained or exercised control over the motor vehicle of (ENED, without authorization, or by threat or deception, and retained possession or control over the motor vehicle for more than ‘twenty-four hours and the value of the motor vehicle was less than twenty thousand dollars; in violation of section 18-4-409(2),(3)(a), C.R.S. ‘The facts supporting Count 5 are as follows: 1, The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. Onor about June 18, 2016, an as-yet unidentified enterprise member or members stole a 1993 Honda Civic two door sedan valued at $1,500.00 which was owned by SIQIN, from 38§§ 68th Avenue in the City of Westminster, Adams County, State of Colorado. 3. Onor about June 28, 2016 that stolen 1993 Honda Civic sedan was recovered in the 2800 block of Arkins Court in the City and County of Denver, State of Colorado. Andrew Finn was in the driver's seat at that time. 4, Between and including June 18, 2016 and June 28 2016, Andrew Finn, in association with the enterprise, unlawfully, feloniously, and knowingly retained possession or control over the stolen 1993 Honda Civic sedan of $$ without the owner’s authorization. 23COUNT SIX AGGRAVATED MOTOR VEHICLE THEFT IN THE SECOND DEGREE, 18-4-409(4)(b) CRS. (F6) <0804E> On or about October 11, 2016, at and triable in the City and County of Denver, State of Colorado, ASHTON LANE unlawfully, feloniously, and knowingly obtained or exercised control over the motor vehicle of (]INENNRENNT, without authorization or by threat or deception, and the value of the motor vehicle was one thousand dollars or more but less than ‘twenty thousand dollars; in violation of section18-4-409(4)(b), CR.S. ‘The facts supporting Count 6 are as follows: The facts supporting all other counts in this Indictment arc incorporated herein by reference. 2. On or about October 10, 2016 at approximately 12:30 AM, an as-yet unidentified enterprise member or members stole a 2002 Toyota Tacoma pick-up truck valued at $5,000.00 which was owned by QUIRED, from 3169 Walnut Street in the City and County of Denver, State of Colorado. 3. On or about October 11, 2016 at approximately 9:10 AM, that stolen 2002 Toyota Tacoma pick-up truck was recovered at 1995 Sherman Street in the City and County of Denver, State of Colorado. Andrew Finn and Ashton Lane were in the truck at that time, 4, Ashton Lane admitted that he drove the stolen truck in Denver during the moming of October 11, 2016. 5. On or about October 11, 2016, Ashton Lane, in association with the enterprise, unlawfully, feloniously, and knowingly retained possession or control over the stolen 2002 Toyota Tacoma pick-up truck of (NG without the owner's authorization. 24COUNT SEVEN AGGRAVATED MOTOR VEHICLE THEFT IN THE SECOND DEGREE, 18-4-409(4)(b) CRS. (F6) <0804E> On or about October 27, 2016, at and triable in the City and County of Denver, State of Colorado, ASHTON LANE unlawfully, feloniously, and knowingly obtained or ‘exercised control over the motor vebicle of (TEED, without authorization or by threat or deception, and the value of the motor vehicles was one thousand dollars or more but less then ‘twenty thousand dollars; in violation of section! 8-4-409(4)(b), CRS. The facts supporting Count 7 are as follows: 1, The facts supporting all other counts in this Indictment are incorporated herein by reference, 2. On or about October 27, 2016 between 7:00 AM and 4:30 PM, an as-yet unidentified enterprise member or members stole a 1997 Subaru station wagon valued at $2,425.00 which was owned by QUEER, from the 500 block of 30" Street in the City and County of Denver, State of Colorado. 3. On or about October 27, 2016 at approximately 3:35 PM, that stolen 1997 Subaru station ‘wagon Was recovered in the 2000 block of Little Raven Street in the City and County of Denver, State of Colorado. Ashton Lane was in the Subaru at that time and had the keys to that vehicle with him. 4. On or about October 27, 2016, Ashton Lane, in association with the enterprise, unlawfully, feloniously, and knowingly retained possession or control over the stolen 1997 Subaru station wagon of SERENE without the owner's authorization. 25COUNT EIGHT AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, 18-4-409(2),(3)(a) CRS. (FS) <0804G > Between and including November 26, 2016 and November 28, 2016, at and triable in the City and County of Denver, State of Colorado, CHEYENNE PIERCE unlawfully, feloniously, and Knowingly obtained or exercised control over the motor vehicle of (i nar?, without authorization, or by threat or deception, and retained possession or control over the motor vehicle for more then twenty-four hours and the value of the motor vehicle was less than ‘twenty thousand dollars; in violation of section 18-4-409(2),(3)(a), CR.S. ‘The facts supporting Count 8 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. Between 9:30 AM and 4:30 PM on November 26, 2016 and 10:30 AM on November 27, 2016, an as-yet unidentified enterprise member or members stole a 2016 Hyundai Elantra sedan valued at $16,758.00 which was owned by @qaSmmmtmmtmmp, from the 2200 block of East 11" Avenue in the City and County of Denver, State of Colorado. 3. On or about November 28, 2016 at approximately 11:00 PM, that stolen 2016 Hyundai Elantra sedan was recovered at 2643 Stout Street in the City and County of Denver, State of Colorado. Michael Rodgers was in driver's seat and Cheyenne Pierce was asleep in the front ‘passenger seat at that time. 4, Michael Rodgers was charged with Aggravated Motor Vehicle Theft in Denver District Court case number 16CR7861 and subsequently pled guilty to one count of Aggravated Motor Vehicle Theft of less than $1,000.00 on February 9", 2017, as noted above in the Facts Supporting Predicate Act 105. 5. Between and including November 26, 2016 and November 28, 2016, Cheyenne Pierce, in association with the enterprise, unlawfully, feloniously, and knowingly retained possession or control over the stolen 2016 Hyundai Elantra sedan of @EMNEINER without the owner's authorization. 26COUNT NINE SECOND DEGREE BURGLARY, 18-4-203(1) C.R.S, (F4) <06031> On or about November 27, 2016, at and triable in the City and County of Denver, State of Colorado, JORY INGRAM unlawfully, feloniously, and knowingly broke an entrance into, entered, or remained unlawfully after a lawful or unlawful entry in the building or occupied structure of RIVER CLAY LOFTS, located at 2240 N. Clay Street with the intent to commit therein the crime of Theft; in violation of section 18-4-203(1), CR.S. ‘The facts supporting Count 9 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference, 2. On or about November 27, 2016, Jory Ingram, in association with the enterprise, unlawfully, feloniously, and knowingly, entered the River Clay Lofts located at 2240 N. Clay Street, in the City and County of Denver, State of Colorado. Jory Ingram stole items from a bicycle pack and attempted to unlawfully enter motor vehicles in the secured parking facility. ‘The value of the items stolen was approximately $5.00. 27COUNT TEN AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, 18-4-409(2),(3)(a.5) CRS. (F4 ) <0804H > Between and including November 28, 2016 and December 3, 2016, at and triable in the City and County of Denver, State of Colorado, JORY INGRAM and CHEYENNE PIERCE unlawfully, fetoniously, and knowingly obtained or exercised control over the motor vehicle of HERTZ RENTAL CARS, without authorization, or by threat or deception, and retained Possession or control over the motor vehicle for more than twenty-four hours, and the value of the motor vehicle was twenty thousand dollars or more but Jess than one hundred thousand dollars; in violation of section 18-4-409(2),(3)(a.5), C.R.S. COUNT ELE! SECOND DEGREE BURGLARY, 18-4-203(1) C.R.S. (F4) <06031> On or about November 29, 2016, at and triable in the City and County of Denver, State of Colorado, JORY INGRAM unlawfully, feloniously, and knowingly broke an entrance into, entered, or remained unlawfully after a lawful or unlawful entry in the building or occupied structure of MARION PARK CONDOMINIUMS, located at 420 S. Marion Parkway with ‘the intent to commit therein the crime of Theft; in violation of section 18-4-203(1), CRS. COUNT TWELVE SECOND DEGREE BURGLARY, 18-4-203(1) GR.S. (F4) <06031> ‘On or about November 29, 2016, at and triable in the City and County of Denver, State of Colorado, JORY INGRAM unlawfully, feloniously, and knowingly broke an entrance into, entered, or remained unlawfully after a lawful or unlawful entry in the building or occupied structure of STADIUM LOFTS, located at 2261 Blake Street with the intent to commit therein ‘the crime of Theft; in violation of section 18-4-203(1), CRS. The facts supporting Counts 10 through 12 are as follows: 1, The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. Onor about November 28, 2016, an as-yet unidentified enterprise member or members stole a 2016 Nissan Altima sedan valued at $22,500.00 which was owned by Hertz Rental Cars, from the parking garage of the Crowne Plaza Hotel located at 1650 Glenarm Place in the City and County of Denver, State of Colorado. 3. Onor about November 29, 2016, Jory Ingram and another, as-yet unidentified enterprise member, in association with the enterprise, unlawfully, feloniously, and knowingly, entered the Marion Park Condominiums located at 420 S. Marion Parkway in the City and County of Denver, State of Colorado. Jory Ingram was in the stolen 2016 Nissan Altima, Jory Ingram stole a bicycle, valued at $80.00 and owned by QUINN, from the secured parking facility of the 28Marion Park Condominiums. The other enterprise member drove the stolen Nissan Altima out of the parking facility. 4. On or about November 29, 2016, Jory Ingram, in association with the enterprise, unlawfully, feloniously, and knowingly, entered the Stadium Lofis located at 2261 Blake Street in the City and County of Denver, State of Colorado. Jory Ingram drove the stolen 2016 Nissan Altima into and out of the secured parking facility. Jory Ingram unlawfully entered the motor vehicle of QING and QUEEN and stole clothes and shoes valued at $275.00. 5. Onor about December 3, 2016, the stolen Nissan Altima sedan was recovered at 1115 N. Logan Street in the City and County of Denver, State of Colorado. Fingerprints belonging to Cheyenne Pierce were found on the inside driver's door. Court paperwork for Jory Ingram was recovered from the interior of the vehicle. Shoes stolen from (INNES were also recovered from the vehicle. 6. Between and including November 28, 2016 and December 3, 2016, Jory Ingram and Cheyenne Pierce, in association with the enterprise, unlawfully, feloniously, and knowingly retained possession or control over the stolen 2016 Nissan Altima sedan of Hertz Rental Cars without the owner’s authorization, 29COUNT THIRTEEN SECOND DEGREE BURGLARY, 18-4-203(1) C.R.S. (F4) <06031> On or about December 3, 2016, at and triable in the City and County of Denver, State of Colorado, MARQUES MITCHELL unlawfully, feloniously, and knowingly broke an entrance into, entered, ot remained unlawfully after a lawful or unlawful entry in the building or occupied structure of THE STATION AT RIVERFRONT, located at 1460 Little Raven Street with the intent to commit therein the crime of Theft; in violation of section 18-4-203(1), CRS. ‘The facts supporting Count 13 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about December 3, 2016, Marques Mitchell, Jory Ingram, and an as-yet unidentified female enterprise member, in association with the enterprise, unlawfully, feloniously, and knowingly, entered the Station at Riverfront apartment complex located at 1460 Little Raven Street, in the City and County of Denver, State of Colorado. Marques Mitchell, Jory Ingram, and an as-yet unidentified female enterprise member went through the secured parking facility and unlawfully entered motor vehicles, and attempted to unlawfully enter other vehicles. Jory Ingram stole a 2003 Crown Victoria from the garage. 3. Jory Ingram was charged with Aggravated Motor Vehicle Theft in Denver District Court case number 17CROOI81 and subsequently pled guilty to one count of Aggravated Motor Vehicle Theft of less than $1,000.00 on February 13", 2017, as noted above in the Facts Supporting Predicate Act 102. 30COUNT FOURTEEN AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, 18-4-409(2),(3)(a) CARS. (FS ) <0804G > Between and including December 3, 2016 and December 30, 2016, at and triable in the City and County of Denver, State of Colorado, JORDAN GOETSCH unlawfully, feloniously, and knowingly obtained or cxercised control over the motor vehicle of ©, without authorization, or by threat or deception, and retained possession or control over the motor vehicle for more than twenty-four hours, and used the motor vehicle in the commission of the crime of Second Degree Burglary of a Building as set forth in section 18-4-203(1), CRS., and the value of the motor vehicle was less than twenty thousand dollars; in violation of section 18-4-409(2),(3)(a), C.R.S. COUNT FIFTEEN SECOND DEGREE BURGLARY, 18-4-203(1) CRS. (F4) <06031> On or about December 17, 2016, at and triable in the City and County of Denver, State of Colorado, JORDAN GOETSCH and JORY INGRAM unlawfully, feloniously, and knowingly broke an entrance into, entered, or remained unlawfully after a lawful or unlawful entry in the building’ or occupied structure of 300 E. 17th Avenue Apartments, located at 300 B. 17th Avenue with the intent to commit therein the crime of Theft; in violation of section 18-4-203(1), CRS. co SIXTEEN AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, 18-4-409(2),(3)(2.5) CRS. (F4 ) <0804H > Between and including December 17, 2016 and December 27, 2016, at and triable in the City and County of Denver, State of Colorado, JORDAN GOETSCH and JORY INGRAM unlawfully, feloniously, and knowingly obtained or exercised control over the motor vehicle of QUEEN, without authorization, or by threat or deception, and retained possession or control over the motor vehicle for more than twenty-four hours, and the value of the motor vehicle was twenty thousand dollars or more but less than one hundred thousand dollars; in violation of section 18-4-409(2),(3)(a.5), C.R.S. COUNT SEVENTEEN SECOND DEGREE BURGLARY, 18-4-203(1) CRS. (F4) <06031> On or about December 22, 2016, at and triable in the City and County of Denver, State of Colorado, JORDAN GOETSCH unlawfully, feloniously, and knowingly broke an entrance into, entered, or remained unlawfully after a lawful or unlawful entry in the building or occupied structure of JACK KEROUAC LOFTS, located at 3100 N. Huron Street with the intent to commit therein the crime of Theft; in violation of section 18-4-203(1), C.R.S. ‘The facts supporting Counts 14 through 17 are as follows: 311. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. Onor about December 3, 2016, an as-yet unidentified enterprise member or members stole a 2013 Ford Fiesta sedan valued at $7,100.00 which was owned by (mm, from the apartment complex parking lot located at 5857 Pierce Street in the City of Arvada, Jefferson County, State of Colorado. 3. On or about December 17, 2016, Jory Ingram, Jordan Goetsch, and another, as-yet unidentified female enterprise member, in association with the enterprise, unlawfully, feloniously, and knowingly, entered the 300 E. 17" Avenue Apartments located at 300 E. 17" Avenue in the City and County of Denver, State of Colorado. Jordan Goetsch was a passenger in stolen 2013 Ford Fiesta. That Ford Fiesta was driven by the unidentified female enterprise member. Jory Ingram stole a 2012 Nissan X-Terra sport utility vehicle valued at $18,500.00 and owned by QS from the secured parking facility of the 300 B. 17" Avenue Apartments. Jory Ingram used KEN stolen X-Terra to smash through the ‘garage exit door. Jordan Goetsch and the unidentified female enterprise member followed Jory Ingram in QB stolen X-Terra out of the secured parking facility, through the destroyed garage exit door. 4. On or about December 22, 2016, Jordan Goetsch, and two as-yet unidentified enterprise ‘members, in association with the enterprise, unlawfully, feloniously, and knowingly, entered the Jack Kerouac Lofts located at 3100 N. Huron Street in the City and County of Denver, State of Colorado. Jordan Goetsch was a passenger in @NEMERNEEEGR stolen 2013 Ford Fiesta. That Ford Fiesta was driven by the unidentified male enterprise member. Jordan Goetsch and the unidentified male driver went quickly through the secured parking facility and unlawfully entered several motor vehicles, including @0008 2015 Subaru and CNB 2015 Honda. Approximately $6.00 in cash was stolen from Ms@§NB vehicle. A garage door opener worth $50.00 was stolen from Ms. 98 vehicle. Jordan Goetsch spray-painted “MOB” on the interior of the garage door prior to leaving the secured parking facility with the other enterprise members in (QE stolen Ford Fiesta. 5. Onor about December 30, 2016, (MERE stolen Ford Fiesta was involved in a hit and run traffic accident in the 1900 block of 29" Street in the City and County of Denver, State of Colorado. That Ford Fiesta was driven by an as-yet unidentified female enterprise member. That driver abandoned the Fiesta in the secured parking facility of the Dylan Rino apartment complex located at 3201 N. Brighton Boulevard in Denver. 6. The stolen Ford Fiesta was severely damaged, and had GPC and MOB related graffiti painted and /or marked on the interior and exterior. The vehicle was scrapped as a total loss due to the damage. 7. Between and including December 3, 2016 and December 30, 2016, Jordan Goetsch, in association with the enterprise, unlawfully, feloniously, and knowingly retained possession or control over the stolen 2013 Ford Fiesta sedan of QING without the owner’s authorization. 32COUNT EIGHTEEN AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE -18-4-409(2),(3)(a.5) CRS. (F4) <0804HT> On or about December 17, 2016, at and triable in the City and County of Denver, State of Colorado, NOAH FERRIS, JORY INGRAM and MALAINA LUBY unlawfully, feloniously, and knowingly obtained or exercised control over the motor vehicle of (i, without authorization, or by threat or deception, and retained possession or control over the motor vehicle for more than twenty-four hours, and the value of the motor vehicle was twenty ‘thousand dollars or more but less than one hundred thousand dollars; in violation of section 18-4- 4092),)(a.5), CRS. ‘The facts supporting Count 18 are as follows: 1, The facts supporting all other counts in this Indictment are incorporated herein by reference. 2, Onor about December 11, 2016, an as-yet unidentified enterprise member or members stole a 2016 Toyota 4 Runner sport utility vehicle valued at $35,000.00 which was owned by (Q@EEEEEEEEE from the secured parking facility of the AMLI Park Avenue Lofts located at 755 E. 19" Avenue in the City and County of Denver, State of Colorado. 3. On or about December 14, 2016, QS stolen 2016 Toyota 4 Runner was recovered at 3500 Rockmount Drive in Denver. That vehicle was occupied by Noah Ferris (driver), Jordan Goetsch, (passenger) and Malaina Luby (passenger). 4, Between and including December 11, 2016 and December 14, 2016, Nodh Ferris, Jordan Goetsch, and Malaina Luby, in association with the enterprise, unlawfully, feloniously, and knowingly retained possession or control over the stolen 2016 Toyota 4 Runner of (> without the owner’s authorization. 33COUNT NINETE) AGGRAVATED MOTOR VEHICLE THEFT IN THE SECOND DEGREE, 18-4-409(4)(b) CRS. (F6) <0804E> On or about December 27, 2016, at and triable in the City and County of Denver, State of Colorado, ANTONIO MADISON unlawfully, feloniously, and knowingly obtained or exercised control over the motor vehicle of qa. without authorization or by threat or deception, and the value of the motor vehicle was one thousand dollars or more but less than twenty, thousand dollars; in violation of section! 8-4-409(4)(b), C.R.S. ‘The facts supporting Count 19 are as follows: 1, The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. Between the evening of December 27, 2016 and the morning of December 28, 2016 @imm. 2010 Honda station wagon, valued at $11,000.00, was stolen from %™ Pearl Street in the City and County of Denver, State of Colorado. 3. On or about December 28, 2016, (RNID stolen 2010 Honda station wagon was recovered in the 2100 block of Stout Street in Denver. That vehicle was occupied by Antonio Madison (driver) and Maurice Harvey (passenger). 4. On of about December 28, 2016, Antonio Madison, in association with the enterprise, unlawfully, feloniously, and knowingly retained possession or control over the stolen 2010 Honda station wagon of 08 without the owner’s authorization, 34COUNT TWENTY SECOND DEGREE BURGLARY, 18-4-203(1) C.R.S. (F4) <06031> On or about December 27, 2016, at and triable in the City and County of Denver, State of Colorado, JORY INGRAM unlawfully, feloniously, and knowingly broke an entrance into, entered, or remained unlawfully after a lawful or unlawful entry in the building or occupied structure of DYLAN RINO APARTMENTS, located at 3201 N. Brighton Boulevard with the ‘intent to commit therein the crime of Theft; in violation of section 18-4-203(1), C.R.S. ‘The facts supporting Count 20 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about December 27, 2016, Jory Ingram, in association with the enterprise, unlawfully, feloniously, and knowingly, entered the Dylan Rino apartments located at 3201 N. Brighton Boulevard in the City and County of Denver, State of Colorado. Jory Ingram went quickly through the secured parking facility and unlawfully entered several motor vehicles, including QB 2015 Subaru and GAMER 2015 Nissan. Jory Ingram stole approximately $3,945.00 worth of electronic devices and personal property from Mr. mm vehicle. Jory Ingram also stole luggage and clothes of unknown valuc from Ms. @8 vehicle. 35COUNT TWE! AGGRAVATED MOTOR VEHICLE THEFT I! CRS. (FS) <0804G > Y-ONE THE FIRST DEGREE, 18-4-409(2),(3)(a) Between and including January 2, 2017 and January 4, 2017, at and triable in the City and County of Denver, State of Colorado, NOAH FERRIS and JORY INGRAM unlawfully, feloniously, and knowingly obtained or exercised control over the motor vehicle of PAYLESS CAR RENTAL, without authorization, or by threat or deception, and retained possession or control over the motor vehicle for more than twenty-four hours, and caused five hundred dollars or more property damage, including but not limited to property damage to the motor vehicle involved, in the course of obtaining control over or in the exercise of control of the motor vehicle, and the value of the motor vehicle was less than twenty thousand dollars; in violation of section 18-4-409(2),(3)(a), CR.S. ‘The facts supporting Count 21 are as follows: 1, The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. Onor about January 2, 2017, an as-yet unidentified enterprise member or members stole 2016 Toyota Corolla valued at $16,500.00 which was owned by Payless Car Rental, from the secured garage of the Curtis Hotel located at 1405 Curtis Street in the City and County of Denver, State of Colorado. 3. Onor about January 4, 2017 that stolen Toyota Corolla was recovered from 2749 Walnut Street in the City and County of Denver, State of Colorado, A cigarette stub containing the DNA. of Noah Ferris and a wooden stick containing the DNA of Jory Ingram were recovered inside the stolen Toyota Corolla, 4. That Toyota Corolla had been severely damaged after it was stolen and before it was recovered. The interior was torn up and was covered in GPC and MOB related graffiti. 5. Between and including January 2, 2017 and January 4, 2017, Noah Ferris and Jory Ingram, in association with the enterprise, unlawfully, feloniously, and knowingly retained possession or control over the stolen 2016 Toyota Corolla of Payless Car Rental without the ‘owner's authorization, and /or caused five hundred dollars or more property damage to that vehicle. 36COUNT TWENTY-TWO AGGRAVATED MOTOR VEHICLE THEFT IN THE SECOND DEGREE, 18-4-409(4)(b) CRS. (F6) <0804E> On or about January 8, 2017, at and triable in the City and County of Denver, State of Colorado, NOAH FERRIS unlawfully, feloniously, and knowingly obtained or exercised control over the motor vehicle of @AINENEE, without authorization or by threat or deception, and the value of the motor vehicle was one thousand dollars or more but less than twenty thousand dollars; in violation of section18-4-409(4)(b), CR.S. ‘The facts supporting Count 22 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about January 8, 2017, Noah Ferris, Jory Ingram and QD, in association with the enterprise, stole a 2013 Chevrolet Malibu valued at $12,040.00 which was owned by @IEEGEEB, from the secured garage of the Dylan Rino apartments located at 3201 Brighton Boulevard in the City and County of Denver, State of Colorado. 3. Onor about January 8, 2017, that stolen Chevrolet Malibu was recovered in the parking lot of the Northfield shopping center in northeast Denver. Noah Ferris and QUI were in the vehicle at that time. Jory Ingram was arrested nearby. 4, Jory Ingram was charged with Aggravated Motor Vehicle Theft in Denver District Court case number 17CR00184, and that case was resolved in a plea agreement in Denver District Court case #17CROO181 on February 13", 2017, as noted above in the Facts Supporting Predicate Acts 102 and 103. 5. Onor about January 8, 2017, Noah Ferris, in association with the enterprise, unlawfully, feloniously, and knowingly retained possession or control over the stolen 2013 Chevrolet Malibu of QED without the owner's authorization. 37