Hell's Lovers Indictment 2

Case 1:12-cr-00010-MSK Document 1 Filed 01/09/12 USDC Colorado Page 1 of 17
IN THE UNITED STATES DISTRICT COURT FOR 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, and 16. 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 1
(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 ONE Possession 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. 2
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 THREE Using 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).
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 FIVE Possession 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).
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 Cocaine 21 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, 5
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.
All in violation of Title 21, United States Code, Section 856(a)(1) and (2) and (b), Maintaining drug-involved premises.
COUNT TWELVE Possession 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 7
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 FIFTEEN Possession 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,
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 Cocaine 21 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, 9
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 Offense 18 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, 13
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. 15
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. defendants: a) b) cannot be located upon the exercise of due diligence; has been transferred or sold to, or deposited with, a third party; c) d) has been placed beyond the jurisdiction of the Court; has been substantially diminished in value; or 16 If any of the property described above, as a result of any act or omission of the
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. WALSH United States Attorney s/ Guy Till By: GUY TILL Assistant United States Attorney United States Attorneys Office District of Colorado 1225 17th Street, Suite 700 Denver, CO 80202 Telephone: (303) 454-0100 Fax: (303) 454-0409 Guy.Till@usdoj.gov
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Case 1:12-cr-00010-MSK Document 1-1 Filed 01/09/12 USDC Colorado Page 1 of 2
DEFENDANT:
1. GEORGE H. ASKEW
YEARS OF BIRTH: 1973, 1975 ADDRESS: Denver, Colorado YES X NO
COMPLAINT FILED:
IF YES, PROVIDE MAGISTRATE CASE NUMBER: HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? OFFENSE: Count One: Possession with Intent to Distribute More than 28 Grams of Crack Cocaine 21 U.S.C. 841(a)(1) and (b)(1)(B) Prohibited Person in Possession of Firearm 18 U.S.C. 922(g)(1), 924(a)(2) and 2 YES X NO
Count Two:
Count Three: Using a Residence for the Purpose of Distributing Controlled Substance 21 U.S.C. 856(a)(1) and (2) and (b) Count Four: Possession of Firearm in Furtherance of Drug Trafficking Felony 18 U.S.C. 924(c) 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
Count Thirty-Two:
LOCATION OF OFFENSE: Denver County, Colorado (COUNTY/CITY/STATE) PENALTY: Count One: Defendant has a prior PCS state felony conviction. NLT 10 years, NMT life imprisonment; 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 years supervised 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 years supervised release following any period of imprisonment; and a $100.00 special assessment.
Count Four: NLT 5 years imprisonment; a fine of NMT $250,000.00, or both; 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 special assessment.
NOTICE OF FORFEITURE AGENT: Special Agent Jason Cole Alcohol Tobacco and Firearms
AUTHORIZED BY: Guy Till Assistant U.S. Attorney ESTIMATED TIME OF TRIAL: five days or less THE GOVERNMENT X will seek detention in this case will not seek detention in this case X over five days other
The statutory presumption of detention is applicable to this defendant. OCDETF CASE: X Yes No
DEFENDANT: YEAR OF BIRTH: ADDRESS:
2. ROMELL E. BULLOCK 1975 Denver, Colorado YES X NO
COMPLAINT FILED:
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 Premises 21 U.S.C. 856(a)(1) and (2) and (b) Aiding and Abetting 18 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 5 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 special assessment. NOTICE OF FORFEITURE AGENT: Special Agent Jason Cole Alcohol Tobacco and Firearms
AUTHORIZED BY: Guy Till Assistant U.S. Attorney
ESTIMATED TIME OF TRIAL: five days or less THE GOVERNMENT X will seek detention in this case will not seek detention in this case X over five days other
3. GREGORY A. COLLINS 1954, 1958 Denver, Colorado YES X NO
COMPLAINT FILED:
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:
4. GEORGE A. GADDY 1945 Denver, Colorado YES X NO
COMPLAINT FILED:
Count Thirty-One:
Conspiracy to Use and Maintain Drug-Involved Premises 21 U.S.C. 846 and 856(a)(1) and (2) and (b) 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
Count Thirty-Two:
5. DELBERT J. GARDNER 1980 Denver, Colorado YES X NO
COMPLAINT FILED:
IF YES, PROVIDE MAGISTRATE CASE NUMBER: HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? OFFENSE: Count Five: Possession with Intent to Distribute Crack Cocaine 21 U.S.C. 841(a)(1) and (b)(1)(C) 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 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 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 special assessment. NOTICE OF FORFEITURE AGENT: Special Agent Jason Cole Alcohol Tobacco and Firearms YES X NO
Count Thirty-Two:
ESTIMATED TIME OF TRIAL:
five days or less THE GOVERNMENT X
over five days
other
will seek detention in this case
will not seek detention in this case
6. RICHARD W. JOHNSON 1955 Denver, Colorado YES X NO
COMPLAINT FILED:
OFFENSE: 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
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 special assessment NOTICE OF FORFEITURE AGENT: Special Agent Jason Cole Alcohol Tobacco and Firearms
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
7. SHEPS H. KHAMSAHU 1972 Denver, Colorado YES X NO
COMPLAINT FILED:
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:
over five days
other
The statutory presumption of detention is not applicable to this defendant. OCDETF CASE: X Yes No
8. ERIC LUGO 1976 Denver, Colorado YES X NO
COMPLAINT FILED:
OFFENSE: Count Six: Possession with Intent to Distribute Cocaine 21 U.S.C. 841(a)(1) and (b)(1)(C) Possession with Intent to Distribute Cocaine 21 U.S.C. 841(a)(1) and (b)(1)(C) 18 U.S.C. 2 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
Count Seven:
Count Thirty-Two:
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 years supervised 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 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 special assessment. NOTICE OF FORFEITURE AGENT: Special Agent Jason Cole
Alcohol Tobacco and Firearms AUTHORIZED BY: Guy Till Assistant U.S. Attorney
9. LAWRENCE T. MARTIN 1958 Denver, Colorado YES X NO
COMPLAINT FILED:
Count Thirty-One:
Count Thirty-Two:
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 5 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 special assessment NOTICE OF FORFEITURE AGENT: Special Agent Jason Cole Alcohol Tobacco and Firearms
10. JOHNIE A. MYERS 1954 Denver, Colorado YES X NO
COMPLAINT FILED:
Count Thirty-One:
Count Thirty-Two:
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 5 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 special assessment NOTICE OF FORFEITURE AGENT: Special Agent Jason Cole Alcohol Tobacco and Firearms
11. DARRELL R. PARKER 1947, 1949 Denver, Colorado YES X NO
COMPLAINT FILED:
OFFENSE: Count Eight: Prohibited Person in Possession of Firearm 18 U.S.C. 922(g)(1), 924(a)(2) and 2 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
Count Thirty-Two:
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 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 special assessment. NOTICE OF FORFEITURE AGENT: Special Agent Jason Cole Alcohol Tobacco and Firearms
AUTHORIZED BY: Guy Till
Assistant U.S. Attorney
12. CALVIN R. RILEY 1961 Denver, Colorado YES X NO
COMPLAINT FILED:
OFFENSE: Count Nine: Possession with Intent to Distribute Cocaine 21 U.S.C. 841(a)(1) and (b)(1)(C) Prohibited Person in Possession of Firearm 18 U.S.C. 922(g)(1), 924(a)(2) and 2 Conspiracy to Use and Maintain Drug-Involved Premises 21 U.S.C. 846 and 856(a)(1) and (2) and (b)
Count Ten:
Count Thirty-One:
Count Thirty-Two:
LOCATION OF OFFENSE: Denver County, Colorado (COUNTY/CITY/STATE) PENALTY: Count Nine: Defendant has a prior PCS state felony conviction. NMT 30 years imprisonment; a fine of NMT $2,000,000.00, or both; NLT 6 years supervised release following any period of imprisonment; and a $100.00 special assessment. Count Ten: NMT 10 years imprisonment; a fine of NMT $250,000.00, or both; NMT 3 years supervised 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 5 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 special assessment. NOTICE OF FORFEITURE AGENT: Special Agent Jason Cole Alcohol Tobacco and Firearms
13. COREY L. RILEY 1969 Denver, Colorado YES X NO
COMPLAINT FILED:
IF YES, PROVIDE MAGISTRATE CASE NUMBER: HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? OFFENSE: Count Eleven: 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)(C) Possession with Intent to Distribute Cocaine 21 U.S.C. 841(a)(1) and (b)(1)(C) Possession with Intent to Distribute Cocaine 21 U.S.C. 841(a)(1) and (b)(1)(C) Possession with Intent to Distribute Cocaine 21 U.S.C. 841(a)(1) and (b)(1)(C) Possession with Intent to Distribute Cocaine 21 U.S.C. 841(a)(1) and (b)(1)(C) Possession with Intent to Distribute Cocaine 21 U.S.C. 841(a)(1) and (b)(1)(C) Possession with Intent to Distribute Cocaine 21 U.S.C. 841(a)(1) and (b)(1)(C) Possession with Intent to Distribute Cocaine 21 U.S.C. 841(a)(1) and (b)(1)(C) Possession with Intent to Distribute Cocaine 21 U.S.C. 841(a)(1) and (b)(1)(C) YES X NO
Count Twelve:
Count Thirteen:
Count Fourteen:
Count Fifteen:
Count Sixteen:
Count Seventeen:
Count Eighteen:
Count Nineteen:
Count Twenty:
Count Twenty-One:
Possession with Intent to Distribute Cocaine
21 U.S.C. 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 Possession with Intent to Distribute Cocaine 21 U.S.C. 841(a)(1) and (b)(1)(C) Possession with Intent to Distribute Marijuana 21 U.S.C. 841(a)(1) and (b)(1)(D) Possessing Firearm in Furtherance of Drug Trafficking Felony Offense 18 U.S.C. 924(c) 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 Conspiracy to Distribute more than 5 Kilograms of Cocaine 21 U.S.C. 846 and 841(a)(1) and (b)(1)(A) Conspiracy to Use and Maintain Drug-Involved Premises 21 U.S.C. 846 and 856(a)(1) and (2) and (b)
Count Twenty-Three:
Count Twenty-Four:
Count Twenty-Five:
Count Twenty-Six:
Count Tenty-Seven:
Count Thirty-One:
Count Thirty-Two:
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 years supervised 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 3 years supervised release following any period of imprisonment; and a $100.00 special assessment. 2
Count Thirteen: 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 Fourteen: 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 Fifteen: 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 Sixteen: 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 Seventeen: 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 Eighteen: 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 Nineteen: 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 Twenty: 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 Twenty-One: 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 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 special assessment. Count Twenty-Three: 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. 3
Count Twenty-Four: NMT 5 years imprisonment; a fine of NMT $250,000, or both; NLT 2 years supervised release following any period of imprisonment; and a $100.00 special assessment. Count Twenty-Five: NLT 5 years imprisonment, consecutive to any other sentence; a fine of NMT $250,00.00, or both; NMT 3 years supervised release following any period of imprisonment; 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 $100.00 special 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 $100.00 special assessment. Count Thirty-One: NMT 20 years imprisonment; a fine of NMT $500,000, or both; NMT 5 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 special assessment. NOTICE OF FORFEITURE AGENT: Special Agent Jason Cole Alcohol Tobacco and Firearms
14. THOMAS A. SCHRAH, JR. 1948 Denver, Colorado YES X NO
COMPLAINT FILED:
Count Thirty-One:
Count Thirty-Two:
over five days
other
15. JAMES R. SWITZER 1983 Denver, Colorado YES X NO
COMPLAINT FILED:
IF YES, PROVIDE MAGISTRATE CASE NUMBER: HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? Count Twenty-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 Premises 21 U.S.C. 856(a)(1) and (2) and (b) Aiding and Abetting 18 U.S.C. 2 YES X NO
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; NMT 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 special assessment. NOTICE OF FORFEITURE AGENT: Special Agent Jason Cole Alcohol Tobacco and Firearms
16. CLIFFORD M. WRIGHT 1972 Denver, Colorado YES X NO
COMPLAINT FILED:
IF YES, PROVIDE MAGISTRATE CASE NUMBER: HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? OFFENSE: Count Twenty-Nine: Possession with Intent to Distribute Cocaine 21 U.S.C. 841(a)(1) and (b)(1)(C) Possession with Intent to Distribute Cocaine 21 U.S.C. 841(a)(1) and (b)(1)(C) 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 YES X NO
Count Thirty:
Count Thirty-Two:
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; NLT 3 years supervised release following any period of imprisonment; and a $100.00 special assessment. 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 special assessment. NOTICE OF FORFEITURE AGENT: Special Agent Jason Cole Alcohol Tobacco and Firearms

Hell&#39;s Lovers Indictment 2

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Case 1:12-cr-00010-MSK Document 1 Filed 01/09/12 USDC Colorado Page 1 of 17

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Case 1:12-cr-00010-MSK Document 1-1 Filed 01/09/12 USDC Colorado Page 1 of 2

YEARS OF BIRTH: 1973, 1975 ADDRESS: Denver, Colorado YES X NO

Case 1:12-cr-00010-MSK Document 1-1 Filed 01/09/12 USDC Colorado Page 2 of 2

Case 1:12-cr-00010-MSK Document 1-2 Filed 01/09/12 USDC Colorado Page 1 of 2

DEFENDANT: YEAR OF BIRTH: ADDRESS:

2. ROMELL E. BULLOCK 1975 Denver, Colorado YES X NO

AUTHORIZED BY: Guy Till Assistant U.S. Attorney

Case 1:12-cr-00010-MSK Document 1-2 Filed 01/09/12 USDC Colorado Page 2 of 2

Case 1:12-cr-00010-MSK Document 1-3 Filed 01/09/12 USDC Colorado Page 1 of 2

DEFENDANT: YEAR OF BIRTH: ADDRESS:

3. GREGORY A. COLLINS 1954, 1958 Denver, Colorado YES X NO

Case 1:12-cr-00010-MSK Document 1-3 Filed 01/09/12 USDC Colorado Page 2 of 2

AUTHORIZED BY: Guy Till Assistant U.S. Attorney

Case 1:12-cr-00010-MSK Document 1-4 Filed 01/09/12 USDC Colorado Page 1 of 2

DEFENDANT: YEAR OF BIRTH: ADDRESS:

4. GEORGE A. GADDY 1945 Denver, Colorado YES X NO

AUTHORIZED BY: Guy Till Assistant U.S. Attorney

Case 1:12-cr-00010-MSK Document 1-4 Filed 01/09/12 USDC Colorado Page 2 of 2

Case 1:12-cr-00010-MSK Document 1-5 Filed 01/09/12 USDC Colorado Page 1 of 2

DEFENDANT: YEAR OF BIRTH: ADDRESS:

5. DELBERT J. GARDNER 1980 Denver, Colorado YES X NO

AUTHORIZED BY: Guy Till Assistant U.S. Attorney

ESTIMATED TIME OF TRIAL:

Case 1:12-cr-00010-MSK Document 1-5 Filed 01/09/12 USDC Colorado Page 2 of 2

five days or less THE GOVERNMENT X

over five days

will seek detention in this case

will not seek detention in this case

Case 1:12-cr-00010-MSK Document 1-6 Filed 01/09/12 USDC Colorado Page 1 of 2

DEFENDANT: YEAR OF BIRTH: ADDRESS:

6. RICHARD W. JOHNSON 1955 Denver, Colorado YES X NO

AUTHORIZED BY: Guy Till Assistant U.S. Attorney

Case 1:12-cr-00010-MSK Document 1-6 Filed 01/09/12 USDC Colorado Page 2 of 2

Case 1:12-cr-00010-MSK Document 1-7 Filed 01/09/12 USDC Colorado Page 1 of 2

DEFENDANT: YEAR OF BIRTH: ADDRESS:

7. SHEPS H. KHAMSAHU 1972 Denver, Colorado YES X NO

AUTHORIZED BY: Guy Till Assistant U.S. Attorney

ESTIMATED TIME OF TRIAL:

Case 1:12-cr-00010-MSK Document 1-7 Filed 01/09/12 USDC Colorado Page 2 of 2

five days or less THE GOVERNMENT X

over five days

will seek detention in this case

will not seek detention in this case

Case 1:12-cr-00010-MSK Document 1-8 Filed 01/09/12 USDC Colorado Page 1 of 2

DEFENDANT: YEAR OF BIRTH: ADDRESS:

8. ERIC LUGO 1976 Denver, Colorado YES X NO

Hell's Lovers Indictment 2

Hell's Lovers Indictment 2