WIXLIB

COUNT 47:33A46Special Offender - Firearm;§ 18-18-407(1)(D)(II), C.R.S., (DF1)Jose Luis SALAS-LUGO a/k/a CABINCOUNT 48:8104BPossession with Intent to Distribute a Controlled Substance—Methamphetamine—More than 112 Grams;§ 18-18-405(1),(2)(a)(I)(B), C.R.S., (DF1)Adiel ACOSTA-LEYVAKarla VILLA-CEBALLOSCOUNT 49:81047Possession with Intent to Distribute a Controlled Substance—Schedule II—14 to 225 Grams;§ 18-18-405(1),(2)(b)(I)(A), C.R.S., (DF2)Adiel ACOSTA-LEYVAKarla VILLA-CEBALLOSCOUNT 50:81047Possession with Intent to Distribute a Controlled Substance—Schedule II—14 to 225 Grams;§ 18-18-405(1),(2)(b)(I)(A), C.R.S., (DF2)Adiel ACOSTA-LEYVACOUNT 51:12213Money Laundering;§ 18-5-309(1)(b)(I),(II) C.R.S., (F3)Adiel ACOSTA-LEYVACOUNT 52:81048Possession with Intent to Distribute a Controlled Substance—Schedule II—More than 225 Grams;§18-18-405(1),(2)(a)(I)(A), C.R.S. (DF1)Eladio MORENO-OLIVAS a/k/a LAYOCOUNT 53:8104APossession with Intent to Distribute a Controlled Substance—Methamphetamine—7 to 112 Grams;§ 18-18-405(1),(2)(b)(I)(B), C.R.S., (DF2)Eladio MORENO-OLIVAS a/k/a LAYO11

COUNT 54:33A49Special Offender - Distributing on School Grounds,Public Housing, or School Bus;§ 18-18-407(1)(G), C.R.S., (DF1)Eladio MORENO-OLIVAS a/k/a LAYOCOUNT 55:8104APossession with Intent to Distribute a Controlled Substance—Heroin—7 to 112 Grams;§ 18-18-405(1),(2)(b)(I)(B), C.R.S., (DF2)Ivan Felix QUINTERO a/k/a CHAYANNECOUNT 56:8104APossession with Intent to Distribute a Controlled Substance—Methamphetamine —7 to 112 Grams;§ 18-18-405(1),(2)(b)(I)(B), C.R.S., (DF2)Ivan Felix QUINTERO a/k/a CHAYANNECOUNT 57:81047Possession with Intent to Distribute a Controlled Substance—Schedule II—14 to 225 Grams;§ 18-18-405(1),(2)(b)(I)(A), C.R.S., (DF2)Ivan Felix QUINTERO a/k/a CHAYANNECOUNT 58:81048Possession with Intent to Distribute a Controlled Substance—Schedule II—More than 225 Grams;§18-18-405(1),(2)(a)(I)(A), C.R.S. (DF1)Ivan Felix QUINTERO a/k/a CHAYANNECOUNT 59:30011Possession of a Dangerous Weapon;§18-12-102(3), C.R.S. (F5)Ivan Felix QUINTERO a/k/a CHAYANNECOUNT 60:33A46Special Offender - Firearm;§ 18-18-407(1)(D)(II), C.R.S., (DF1)Ivan Felix QUINTERO a/k/a CHAYANNE12

COUNT 61:81048Possession with Intent to Distribute a Controlled Substance—Schedule II—More than 225 Grams;§18-18-405(1),(2)(a)(I)(A), C.R.S. (DF1)Jose Luis QUINTERO-SOLANOJaziel QUINTERO-SOLANOCOUNT 62:8104BPossession with Intent to Distribute a Controlled Substance—Methamphetamine—More than 112 Grams;§ 18-18-405(1),(2)(a)(I)(B), C.R.S., (DF1)Jose Luis QUINTERO-SOLANOJaziel QUINTERO-SOLANOCOUNT 63:8104APossession with Intent to Distribute a Controlled Substance—Heroin—7 to 112 Grams;§ 18-18-405(1),(2)(b)(I)(B), C.R.S., (DF2)Jose Luis QUINTERO-SOLANOJaziel QUINTERO-SOLANOCOUNT 64:30011Possession of a Dangerous Weapon;§18-12-102(3), C.R.S. (F5)Jose Luis QUINTERO-SOLANOJaziel QUINTERO-SOLANOCOUNT 65:33A46Special Offender - Firearm;§ 18-18-407(1)(D)(II), C.R.S., (DF1)Jose Luis QUINTERO-SOLANOJaziel QUINTERO-SOLANOCOUNT 66:12213Money Laundering;§ 18-5-309(1)(b)(I),(II) C.R.S., (F3)Jose Roberto MORENO-OLIVAS a/k/a PAULAnakaren PEREZCOUNT 67:12213CConspiracy to Commit Money Laundering;§ 18-2-201(1); 18-5-309(1)(b)(I),(II) C.R.S., (F4)Jose Roberto MORENO-OLIVAS a/k/a PAULAnakaren PEREZ13

COUNT 68:12213Money Laundering;§ 18-5-309(1)(b)(I),(II) C.R.S., (F3)Jose Roberto MORENO-OLIVAS a/k/a PAULMaximilliano ACOSTACOUNT 69:12213CConspiracy to Commit Money Laundering;§ 18-2-201(1); 18-5-309(1)(b)(I),(II) C.R.S., (F4)Jose Roberto MORENO-OLIVAS a/k/a PAULMaximilliano ACOSTACOUNT 70:12213Money Laundering;§ 18-5-309(1)(b)(I),(II) C.R.S., (F3)Jose Roberto MORENO-OLIVAS a/k/a PAULJanett SANCHEZ-RUIZCOUNT 71:12213CConspiracy to Commit Money Laundering;§ 18-2-201(1); 18-5-309(1)(b)(I),(II) C.R.S., (F4)Jose Roberto MORENO-OLIVAS a/k/a PAULJanett SANCHEZ-RUIZ14

Index of Charges:DEFENDANT NAMECOUNTJose Roberto MORENO-OLIVAS a/k/a PAULVictor BAUTISTA-CERVANTES a/k/a NEGRI1, 2, 3, 4, 5, 6, 11, 13, 14, 15,17, 18, 19, 20, 21, 22, 25, 26,66, 67, 68, 69, 70, 711, 2, 3, 4, 5, 6, 31, 32Jesus Alfredo VALDEZ-LEON a/k/a ALFREDO1, 2, 7, 11, 12, 29, 30Baltazar IBARRA-ALVAREZ a/k/a IBARRAGildardo VALDEZ-CRUZ a/k/a LAGRIMAS1, 2, 8, 9, 10, 33, 34, 35, 36, 40,41, 42, 431, 2, 7, 11, 25, 26Miriam RIVERA3, 4, 5, 6Tawnia WHITE3, 4, 5, 6, 14, 16, 17, 18, 39Denise RIVERA-REYES7Dolores IBARRA-ESPINOZA8, 9, 10, 33, 34Jose Ignacio VALDEZ-SOLISa/k/a Jesus URIAS-LOPEZ a/k/a PELONAnakaren PEREZ11, 12Janett SANCHEZ-RUIZ14, 17, 18, 70, 71Adiel ACOSTA-LEYVA14, 16, 17, 18, 48, 49, 50, 51Karla VILLA-CEBALLOS14, 16, 17, 18, 48, 49Maximilliano ACOSTA19, 20, 68, 69Samuel QUINONEZ-HERRERA21, 22, 23, 24FNU LNU a/k/a NARICLES25, 26Omar BAUTISTA-CUEVAS25, 26, 27, 28Alfredo NUNEZ-TARANGO25, 26, 27, 2811, 13, 66, 6715

Ivan ABOYTE-VALDEZ29, 30FNU LNU a/k/a Unidentified Male #120731Jesus Alberto LOPEZ-MEDINA31, 32Ossler MARQUEZ-GUZMAN a/k/a OLDER31Erubiel IBARRA-ALVAREZ a/k/a HUACHE33, 34FNU LNU a/k/a Unidentified Male #512333, 35, 36Jesus BARBA-OCHOA35, 36Ivan Felix QUINTERO a/k/a CHAYANNE37, 38, 55, 56, 5, 58, 59, 60Gerardo MURILLO a/k/a GERA37, 38Jose Luis SALAS-LUGO a/k/a CABIN44, 45, 46, 47Eladio MORENO-OLIVAS a/k/a LAYO52, 53, 54Jose Luis QUINTERO-SOLANO61, 62, 63, 64, 65Jaziel QUINTERO-SOLANO61, 62, 63, 64, 6516

COUNT 1VIOLATION OF THE COLORADO ORGANIZED CRIME CONTROL ACT —PATTERN OF RACKETEERING—PARTICIPATION IN AN ENTERPRISE, (F2)Between and including the dates of January 1, 2020, and February 11, 2021, in thestate of Colorado, Jose Roberto MORENO-OLIVAS a/k/a PAUL; Victor AntonioBAUTISTA-CERVANTES a/k/a NEGRI; Jesus Alfredo VALDEZ-LEON a/k/aALFREDO; Baltazar IBARRA-ALVAREZ a/k/a IBARRA; Gildardo VALDEZCRUZ a/k/a LAGRIMAS; and others both known and unknown, while employed byor associated with an enterprise, unlawfully, feloniously, and knowingly conducted orparticipated, directly or indirectly, in the enterprise through a pattern of racketeeringactivity; in violation of § 18-17-104(3) and § 18-17-105, C.R.S.COUNT 2VIOLATION OF THE COLORADO ORGANIZED CRIME CONTROL ACT —CONSPIRACY, (F2)Between and including the dates of January 1, 2020, and February 11, 2021, in thestate of Colorado, Jose Roberto MORENO-OLIVAS a/k/a PAUL; Victor AntonioBAUTISTA-CERVANTES a/k/a NEGRI; Jesus Alfredo VALDEZ-LEON a/k/aALFREDO; Baltazar IBARRA-ALVAREZ a/k/a IBARRA; Gildardo VALDEZCRUZ a/k/a LAGRIMAS; and others both known and unknown, unlawfully,knowingly, and feloniously conspired to conduct and participate, directly orindirectly, in an enterprise, through a pattern of racketeering activity; in violation of§ 18-17-104(4) and § 18-17-105, C.R.S.The offenses alleged in Counts One and Two were committed in the following manner:The EnterpriseThe criminal enterprise alleged in Counts One and Two was primarily a group ofindividuals, associated in fact, although not a legal entity. The enterprise included,but was not limited to, the following associated in fact individuals: Jose RobertoMORENO-OLIVAS a/k/a PAUL; Victor Antonio BAUTISTA-CERVANTESa/k/a NEGRI; Jesus Alfredo VALDEZ-LEON a/k/a ALFREDO; BaltazarIBARRA-ALVAREZ a/k/a IBARRA; Gildardo VALDEZ-CRUZ a/k/aLAGRIMAS; and others both known and unknown to the Grand Jury.The individuals associated with the enterprise had a primary objective and a commonpurpose to import illegal controlled substances, including heroin, methamphetamine,counterfeit Oxycodone, and cocaine into the state of Colorado, and to furtherdistribute these illegal controlled substances to various customers throughout theDenver Metro area. In order to support and facilitate this drug trafficking activity,17

members and associates of the criminal enterprise utilized motor vehicles totransport quantities of the illicit controlled substances.Each of the members of the criminal enterprise relied upon and utilized a complexsystem of cellular telephones and electronic communication devices to arrange andexecute the importation, transportation, and distribution of these illegal controlledsubstances and to facilitate the collection and transfer of the related criminalproceeds. Because the members of the criminal enterprise used telecommunicationdevices so extensively to conduct the operations of the enterprise, the members oftenutilized coded terminology when speaking to each other over the telephone in orderto conceal their criminal activities.Pattern of Racketeering ActivityJose Roberto MORENO-OLIVAS a/k/a PAUL; Victor Antonio BAUTISTACERVANTES a/k/a NEGRI; Jesus Alfredo VALDEZ-LEON a/k/a ALFREDO;Baltazar IBARRA-ALVAREZ a/k/a IBARRA; Gildardo VALDEZ-CRUZ a/k/aLAGRIMAS; and others both known and unknown to the Grand Jury directly and inconcert engaged in, attempted to engage in, conspired to engage in, or solicitedanother to engage in at least two predicate acts, including any lesser offenses, relatedto the conduct of the enterprise, with at least one of which took place in the state ofColorado after July 1, 1981, and the last of the acts of racketeering activity occurringwithin ten years after a prior act of racketeering activity and include:Conspiracy to Distribute a Controlled Substance (Colorado Revised Statutes)Possession with Intent to Distribute a Controlled Substance(Colorado Revised Statutes)Conspiracy to Commit Money Laundering (Colorado Revised Statutes)Money Laundering (Colorado Revised Statutes)Unlawful Use of a Telecommunications Facility (United States Code)Pursuant to C.R.S. § 18-17-103(5)(a), “Racketeering Activity” includes any conductdefined as “racketeering activity” under 18 U.S.C. 1961 (1)(A), (1)(B), (1)(C), and(1)(D), including the act of Unlawful Use of a Telecommunications Facility, inviolation of 21 U.S.C. § 843.Racketeering ActivityThe acts of racketeering activity that the above named persons committed, attemptedto commit, conspired to commit, or solicited, coerced, or intimidated another personto commit, consist of the following predicate acts, including any lesser includedoffenses:18

Predicate Act 1Conspiracy to Distribute a Controlled Substance—Methamphetamine—More than 112 Grams, (DF1)Between and including the dates of June 17, 2020, and June 20, 2020, in the state ofColorado, Jose Roberto MORENO-OLIVAS a/k/a PAUL, Victor AntonioBAUTISTA-CERVANTES a/k/a NEGRI, Miriam RIVERA, and Tawnia WHITEunlawfully, feloniously, and knowingly conspired with each other and others, bothknown and unknown to the Grand Jury, to sell or distribute methamphetamine, aSchedule II controlled substance. Further, the violation involved a materialcompound, mixture, or preparation that weighed more than one hundred twelvegrams; in violation of § 18-18-405(1),(2)(a)(I)(B), C.R.S.Predicate Act 2Possession with Intent to Distribute a Controlled Substance—Methamphetamine—More than 112 Grams, (DF1)Between and including the dates of June 17, 2020, and June 20, 2020, in the state ofColorado, Jose Roberto MORENO-OLIVAS a/k/a PAUL, Victor AntonioBAUTISTA-CERVANTES a/k/a NEGRI, Miriam RIVERA, and Tawnia WHITEunlawfully, feloniously, and knowingly possessed with intent to sell or distributemethamphetamine, a Schedule II controlled substance. Further, the violationinvolved a material compound, mixture, or preparation that weighed more than onehundred twelve grams; in violation of § 18-18-405(1),(2)(a)(I)(B), C.R.S.Predicate Act 3Conspiracy to Commit Money Laundering, (F4)Between and including the dates of June 17, 2020, and June 20, 2020, in the state ofColorado, Jose Roberto MORENO-OLIVAS a/k/a PAUL, Victor AntonioBAUTISTA-CERVANTES a/k/a NEGRI, Miriam RIVERA, and Tawnia WHITE,with the intent to promote or facilitate the commission of the crime of moneylaundering, agreed with each other and others, both known and unknown to theGrand Jury, that one or more of them will engage in conduct which constitutes thecrime of money laundering or an attempt to commit the crime of money laundering,and they agreed to aid that person or persons in the planning or commission of thecrime or the attempt to commit the crime of money laundering, in violation of § 18-2201(1); and § 18-5-309(1)(b)(I),(II), C.R.S.19

Predicate Act 4Money Laundering, (F3)Between and including the dates of June 17, 2020, and June 20, 2020, in the state ofColorado, Jose Roberto MORENO-OLIVAS a/k/a PAUL, Victor AntonioBAUTISTA-CERVANTES a/k/a NEGRI, Miriam RIVERA, and Tawnia WHITEunlawfully and feloniously transported, transmitted, or transferred a monetaryinstrument or moneys, with the intent to promote the commission of a criminaloffense, or with the knowledge or belief that the monetary instrument or moneysrepresent the proceeds of a criminal offense and that the transportation,transmission, or transfer is designed, in whole or in part to conceal or disguise thenature, location, source, ownership, or control of the proceeds of a criminal offense;in violation of §18-5-309(1)(b)(I),(II) C.R.S.Predicate Act 5Unlawful Use of a Communication FacilityBetween and including the dates of June 17, 2020, and June 20, 2020, in the state ofColorado, Jose Roberto MORENO-OLIVAS a/k/a PAUL and Victor AntonioBAUTISTA-CERVANTES a/k/a NEGRI, did knowingly or intentionally use acommunications facility, namely, a cellular telephone, to facilitate the commission ofa felony, namely, Conspiracy to Distribute a Controlled Substance, in violation of 21U.S.C. §§ 841 and 846, such use of a commmunications facility being unlawful, andin violation of 21 U.S.C. § 843.The offenses alleged in Predicate Acts 1-5 were committed in the manner described inCounts 3-6.Predicate Act 6Conspiracy to Distribute a Controlled Substance—Schedule II—More than 225 Grams, (DF1)Between and including the dates of August 1, 2020, and August 11, 2020, in the stateof Colorado, Jesus Alfredo VALDEZ-LEON a/k/a ALFREDO; GildardoVALDEZ-CRUZ a/k/a LAGRIMAS; and Denise RIVERA-REYES, unlawfully,feloniously, and knowingly conspired with each other and others, both known andunknown to the Grand Jury, to sell or distribute a Schedule II controlled substance,fentanyl and/or methamphetamine. Further, the violation involved a materialcompound, mixture, or preparation that weighed more than two hundred twenty-fivegrams; in violation of § 18-18-405(1),(2)(a)(I)(A), C.R.S.20

Predicate Act 7Unlawful Use of a Communication FacilityBetween and including the dates of August 1, 2020, and August 11, 2020, in the stateof Colorado, Jesus Alfredo VALDEZ-LEON a/k/a ALFREDO; GildardoVALDEZ-CRUZ a/k/a LAGRIMAS; and Denise RIVERA-REYES, did knowingly orintentionally use a communications facility, namely, a cellular telephone, to facilitatethe commission of a felony, namely, Conspiracy to Distribute a Controlled Substance,in violation of 21 U.S.C. §§ 841 and 846, such use of a commmunications facility beingunlawful, and in violation of 21 U.S.C. § 843.The offenses alleged in Predicate Acts 6-7 were committed in the manner described inCount 7.Predicate Act 8Possession with Intent to Distribute a Controlled Substance—Heroin—More than 112 Grams (DF1)Between and including the dates of August 6, 2020, and August 12, 2020, in the stateof Colorado, Baltazar IBARRA-ALVAREZ a/k/a IBARRA and Dolores IBARRAESPINOZA unlawfully, feloniously, and knowingly possessed with intent to sell ordistribute heroin, a Schedule I controlled substance. Further, the violation involveda material compound, mixture, or preparation that weighed more than one hundredtwelve grams; in violation of § 18-18-405(1),(2)(a)(I)(B), C.R.S.Predicate Act 9Possession with Intent to Distribute a Controlled Substance—Methamphetamine—More than 112 Grams (DF1)Between and including the dates of August 6, 2020, and August 12, 2020, in the stateof Colorado, Baltazar IBARRA-ALVAREZ a/k/a IBARRA and Dolores IBARRAESPINOZA unlawfully, feloniously, and knowingly possessed with intent to sell ordistribute methamphetamine, a Schedule II controlled substance. Further, theviolation involved a material compound, mixture, or preparation that weighed morethan one hundred twelve grams; in violation of § 18-18-405(1),(2)(a)(I)(B), C.R.S.21

Predicate Act 10Possession with Intent to Distribute a Controlled Substance—Schedule II—Between 14 and 225 Grams (DF2)Between and including the dates of August 6, 2020, and August 12, 2020, in the stateof Colorado, Baltazar IBARRA-ALVAREZ a/k/a IBARRA and Dolores IBARRAESPINOZA unlawfully, feloniously, and knowingly possessed with intent to sell ordistribute a Schedule II controlled substance, fentanyl and/or methamphetamine.Further, the violation involved a material compound, mixture, or preparation thatweighed more than fourteen grams but not more than two hundred twenty-fivegrams; in violation of §18-18-405(1),(2)(b)(I)(A), C.R.S.The offenses alleged in Predicate Acts 8-10 were committed in the manner describedin Counts 8-10.Predicate Act 11Conspiracy to Distribute a Controlled Substance—Methamphetamine—More than 112 Grams, (DF1)Between and including the dates of August 23, 2020, and August 29, 2020, in thestate of Colorado, Gildardo VALDEZ-CRUZ a/k/a LAGRIMAS; Jose RobertoMORENO-OLIVAS a/k/a PAUL; Jesus Alfredo VALDEZ-LEON a/k/aALFREDO; Jose Ignacio VALDEZ-SOLIS a/k/a Jesus URIAS-LOPEZ a/k/a PELON;and Anakaren PEREZ unlawfully, feloniously, and knowingly conspired with eachother and others, both known and unknown to the Grand Jury, to sell or distributemethamphetamine, a Schedule II controlled substance. Further, the violationinvolved a material compound, mixture, or preparation that weighed more than onehundred twelve grams; in violation of § 18-18-405(1),(2)(a)(I)(B), C.R.S.Predicate Act 12Possession with Intent to Distribute a Controlled Substance—Methamphetamine—More than 112 Grams (DF1)On or about August 27, 2020, in the state of Colorado, Jesus Alfredo VALDEZLEON a/k/a ALFREDO and Jose Ignacio VALDEZ-SOLIS a/k/a Jesus URIASLOPEZ a/k/a PELON unlawfully, feloniously, and knowingly possessed with intentto sell or distribute methamphetamine, a Schedule II controlled substance. Further,the violation involved a material compound, mixture, or preparation that weighedmore than one hundred twelve grams; in violation of § 18-18-405(1),(2)(a)(I)(B),C.R.S.22

Predicate Act 13Possession with Intent to Distribute a Controlled Substance—Methamphetamine—More than 112 Grams (DF1)Between and including the dates of August 27, 2020, and August 29, 2020, in thestate of Colorado, Jose Roberto MORENO-OLIVAS a/k/a PAUL; and AnakarenPEREZ unlawfully, feloniously, and knowingly possessed with intent to sell ordistribute methamphetamine, a Schedule II controlled substance. Further, theviolation involved a material compound, mixture, or preparation that weighed morethan one hundred twelve grams; in violation of § 18-18-405(1),(2)(a)(I)(B), C.R.S.Predicate Act 14Unlawful Use of a Communication FacilityBetween and including the dates of August 23, 2020, and August 29

Victor Antonio BAUTISTA-CERVANTES . a/k/a NEGRI . Jesus Alfredo VALDEZ-LEON a/k/a ALFREDO . Baltazar IBARRA-ALVAREZ a/k/a IBARRA . Gildardo VALDEZ-CRUZ a/k/a LAGRIMAS . Miriam RIVERA . Tawnia WHITE . Denise RIVERA-REYES . Dolores IBARRA-ESPINOZA . Jose Ignacio VALDEZ-SOLIS . a/k/a Jesus URIAS-LOPEZ a/k/a PELON . Anakaren PEREZ . Janett SANCHEZ .