Escolar Documentos
Profissional Documentos
Cultura Documentos
Plaintiff,
v.
1. BENJAMIN LOPES-ALVARADO,
a.k.a. “Juan,”
2. AZUSENA MARIBEL SIERRA,
a.k.a. “Suzy,”
3. HECTOR NUNEZ-SANDOVAL,
a.k.a. “Gordo,”
4. JORGE REYES CRUZ-GARCIA,
a.k.a. “Comino,”
5. BRADLEY MICHAEL WHITE,
a.k.a., Brian,”
6. MICHAEL IAN MILLS,
7. ANNA MARIE REBEKAH DAVIS,
a.k.a. “Green,”
8. FIRST NAME UNKNOWN, LAST NAME UNKNOWN,
a.k.a. “Tavo,”
9. FIRST NAME UNKNOWN, LAST NAME UNKNOWN,
a.k.a. “UM-2911,”
10. FIRST NAME UNKNOWN, LAST NAME UNKNOWN,
a.k.a. “UM-9465,”
11. KEVEN ALEXANDER PEREZ,
12. VICTORIANO HINOJOSA,
13. OSCAR MANUEL OLIVEROS,
14. FIRST NAME UNKNOWN, LAST NAME UNKNOWN,
a.k.a. “Vitamina,” and “Mario,”
15. DIEGO ROMERO-CRUZ,
a.k.a. “Enrique,”
16. FIRST NAME UNKNOWN, LAST NAME UNKNOWN,
a.k.a. “UM-6508,”
17. CHRISTIAN ANTHONY CARVER,
18. ABISAI ESCOBAR FLORES,
a.k.a. “Guerrero,”
19. FIRST NAME UNKNOWN, LAST NAME UNKNOWN,
a.k.a. “Primo,”
20. NICHO GARCIA,
1
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 2 of 25
Defendants.
______________________________________________________________________
INDICTMENT
______________________________________________________________________
COUNT 1
On or about and between June 1, 2019 and September 1, 2020, both dates
being approximate and inclusive, within the State and District of Colorado and
Brian,” MICHAEL IAN MILLS, ANNA MARIE REBEKAH DAVIS, a.k.a. “Green,” FIRST
NAME UNKNOWN, LAST NAME UNKNOWN, a.k.a. “Tavo,” FIRST NAME UNKNOWN,
LAST NAME UNKNOWN, a.k.a. “UM-2911,” FIRST NAME UNKNOWN, LAST NAME
CERVANTES, and VICTOR ALONSO CARREON, a.k.a. “Alonso,” and others known
and unknown to the Grand Jury, did knowingly and intentionally combine, conspire,
2
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 3 of 25
confederate and agree, with interdependence, to distribute and possess with the intent
to distribute one or more of the following controlled substances: (1) 1 kilogram and more
Controlled Substance, in violation of Title 21, United States Code, Sections 841(a)(1)
and (b)(1)(A)(i); and (2) 100 grams and more of a mixture and substance containing a
PENALTY ALLEGATIONS:
LAST NAME UNKNOWN, a.k.a. “Tavo,” FIRST NAME UNKNOWN, LAST NAME
LAST NAME UNKNOWN, a.k.a. “Primo,” NICHO GARCIA, JESSE CERVANTES, and
VICTOR ALONSO CARREON, a.k.a. “Alonso,” the amount involved in the conspiracy
attributable to these defendants as a result of their own conduct, and the conduct of
3
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 4 of 25
in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(A)(i).
MICHAEL IAN MILLS, ANNA MARIE REBEKAH DAVIS, a.k.a. “Green,” the amount
conduct, and the conduct of others reasonably foreseeable to them is 100 grams and
I controlled substance, in violation of Title 21, United States Code, Section 841(a)(1)
and (b)(1)(B)(i).
COUNT 2
On or about October 21, 2019, within the State and District of Colorado, the
WHITE, a.k.a. “Brian,” did knowingly and intentionally use a communications device,
of, a felony delineated in Title 21 of the United States Code, specifically the crime
All in violation of Title 21, United States Code, Sections 843(b) and (d).
COUNT 3
On or about October 21, 2019, within the State and District of Colorado, the
WHITE, a.k.a. “Brian,” did knowingly and intentionally distribute and possess with the
4
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 5 of 25
Schedule I Controlled Substance, and did knowingly and intentionally aid, abet, counsel,
All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C)
COUNT 4
On or about December 5, 2019, within the State and District of Colorado, the
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and MICHAEL IAN MILLS, did
committing, and in causing and facilitating the commission of, a felony delineated in
Title 21 of the United States Code, specifically the crime alleged in Count 1 of this
Indictment.
All in violation of Title 21, United States Code, Sections 843(b) and (d).
COUNT 5
On or about December 5, 2019, within the State and District of Colorado, the
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and MICHAEL IAN MILLS did
knowingly and intentionally distribute and possess with the intent to distribute 100
grams and more of a mixture and substance containing a detectable amount of heroin,
a Schedule I Controlled Substance, and did knowingly and intentionally aid, abet,
All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(B)(i)
5
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 6 of 25
COUNT 6
On or about December 26, 2019, within the State and District of Colorado, the
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and MICHAEL IAN MILLS did
knowingly and intentionally distribute and possess with the intent to distribute 100
grams and more of a mixture and substance containing a detectable amount of heroin,
a Schedule I Controlled Substance, and did knowingly and intentionally aid, abet,
All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(B)(i)
COUNT 7
On or about December 8, 2019, within the State and District of Colorado, the
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and ANNA MARIE REBEKAH
DAVIS, a.k.a. “Green,” did knowingly and intentionally use a communications device,
of, a felony delineated in Title 21 of the United States Code, specifically the crime
All in violation of Title 21, United States Code, Sections 843(b) and (d).
COUNT 8
On or about December 8, 2019, within the State and District of Colorado, the
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and ANNA MARIE REBEKAH
DAVIS, a.k.a. “Green,” did knowingly and intentionally distribute and possess with the
6
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 7 of 25
Schedule I Controlled Substance, and did knowingly and intentionally aid, abet, counsel,
All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C)
COUNT 9
On or about December 17, 2019, within the State and District of Colorado, the
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and JORGE REYES CRUZ-
GARCIA, a.k.a. “Comino,” did knowingly and intentionally use a communications device,
of, a felony delineated in Title 21 of the United States Code, specifically the crime
All in violation of Title 21, United States Code, Sections 843(b) and (d).
COUNT 10
On or about December 17, 2019, within the State and District of Colorado, the
defendants AZUSENA MARIBEL SIERRA, a.k.a. “Suzy,” and JORGE REYES CRUZ-
GARCIA, a.k.a. “Comino,” did knowingly and intentionally distribute and possess with
heroin, a Schedule I Controlled Substance, and did knowingly and intentionally aid,
All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C)
COUNT 11
On or about January 16, 2020, within the State and District of Colorado, the
7
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 8 of 25
commission of, a felony delineated in Title 21 of the United States Code, specifically the
All in violation of Title 21, United States Code, Sections 843(b) and (d).
COUNT 12
On or about January 27, 2020, within the State and District of Colorado, the
UNKNOWN, LAST NAME UNKNOWN, a.k.a. “Vitamina,” and “Mario,” did knowingly
and in causing and facilitating the commission of, a felony delineated in Title 21 of the
United States Code, specifically the crime alleged in Count 1 of this Indictment.
All in violation of Title 21, United States Code, Sections 843(b) and (d).
COUNT 13
On or about January 18, 2020, within the State and District of Colorado, the
UNKNOWN, LAST NAME UNKNOWN, a.k.a. “Tavo,” did knowingly and intentionally
and facilitating the commission of, a felony delineated in Title 21 of the United States
All in violation of Title 21, United States Code, Sections 843(b) and (d).
8
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 9 of 25
COUNT 14
On or about January 20, 2020, within the State and District of Colorado, the
in causing and facilitating the commission of, a felony delineated in Title 21 of the
United States Code, specifically the crime alleged in Count 1 of this Indictment.
All in violation of Title 21, United States Code, Sections 843(b) and (d).
COUNT 15
On or about January 20, 2020, within the State and District of Colorado, the
ALVARADO, a.k.a. “Juan,” FIRST NAME UNKNOWN, LAST NAME UNKNOWN, a.k.a.
“Tavo,” FIRST NAME UNKNOWN, LAST NAME UNKNOWN, a.k.a. “UM-2911,” did
knowingly and intentionally distribute and possess with the intent to distribute a mixture
Substance, and did knowingly and intentionally aid, abet, counsel, command, induce
All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C)
COUNT 16
On or about February 1, 2020, within the State and District of Colorado, the
9
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 10 of 25
in causing and facilitating the commission of, a felony delineated in Title 21 of the
United States Code, specifically the crime alleged in Count 1 of this Indictment.
All in violation of Title 21, United States Code, Sections 843(b) and (d).
COUNT 17
On or about February 1, 2020, within the State and District of Colorado, the
LAST NAME UNKNOWN, a.k.a. “Tavo,” FIRST NAME UNKNOWN, LAST NAME
knowingly and intentionally distribute and possess with the intent to distribute a mixture
Substance, and did knowingly and intentionally aid, abet, counsel, command, induce
All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C)
COUNT 18
On or about February 13, 2020, within the State and District of Colorado, the
delineated in Title 21 of the United States Code, specifically the crime alleged in Count
1 of this Indictment.
All in violation of Title 21, United States Code, Sections 843(b) and (d).
10
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 11 of 25
COUNT 19
On or about February 13, 2020, within the State and District of Colorado, the
delineated in Title 21 of the United States Code, specifically the crime alleged in Count
1 of this indictment.
All in violation of Title 21, United States Code, Sections 843(b) and (d).
COUNT 20
On or about February 13, 2020, within the State and District of Colorado, the
delineated in Title 21 of the United States Code, specifically the crime alleged in Count
1 of this indictment.
All in violation of Title 21, United States Code, Sections 843(b) and (d).
COUNT 21
On or about February 13, 2020, within the State and District of Colorado and
commerce with the intent to promote, manage, establish, carry on, and facilitate the
specifically violations of Title 21, United States Code, Sections 841(a)(1) and 846 as
11
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 12 of 25
perform an act to promote, manage, establish, carry on, and facilitate the promotion,
COUNT 22
On or about February 13, 2020, within the State and District of Colorado, the the
delineated in Title 21 of the United States Code, specifically the crime alleged in Count
1 of this indictment.
All in violation of Title 21, United States Code, Sections 843(b) and (d).
COUNT 23
On or about February 13, 2020, within the State and District of Colorado, the
ALVARADO, a.k.a. “Juan,” FIRST NAME UNKNOWN, LAST NAME UNKNOWN, a.k.a.
intentionally distribute and possess with the intent to distribute one kilogram and more
Controlled Substance, and did knowingly and intentionally aid, abet, counsel, command,
All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(A)(i)
12
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 13 of 25
COUNT 24
On or about May 21, 2020, within the State and District of Colorado, the
UNKNOWN, LAST NAME UNKNOWN, a.k.a. “UM-6508” did knowingly and intentionally
and facilitating the commission of a felony delineated in Title 21 of the United States
All in violation of Title 21, United States Code, Sections 843(b) and (d).
COUNT 25
On or about May 21, 2020, within the State and District of Colorado and
commerce with the intent to promote, manage, establish, carry on, and facilitate the
specifically violations of Title 21, United States Code, Sections 841(a)(1) and 846 as
perform an act to promote, manage, establish, carry on, and facilitate the promotion,
COUNT 26
On or about May 21, 2020, within the State and District of Colorado, the
LAST NAME UNKNOWN, a.k.a. “Tavo,” FIRST NAME UNKNOWN, LAST NAME
13
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 14 of 25
and intentionally distribute and possess with the intent to distribute one kilogram and
I Controlled Substance, and did knowingly and intentionally aid, abet, counsel,
All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(A)(i)
COUNT 27
On or about June 7, 2020, within the State and District of Colorado, the
CRUZ, a.k.a. “Enrique,” did knowingly and intentionally use a communications device,
a felony delineated in Title 21 of the United States Code, specifically the crime alleged
All in violation of Title 21, United States Code, Sections 843(b) and (d).
COUNT 28
On or about June 7, 2020, within the State and District of Colorado, the
a.k.a. “Enrique,” KEVEN ALEXANDER PEREZ, and FIRST NAME UNKNOWN, LAST
NAME UNKNOWN, a.k.a. “Tavo,” did knowingly and intentionally distribute and possess
with the intent to distribute one kilogram and more of a mixture and substance
knowingly and intentionally aid, abet, counsel, command, induce and procure the same.
14
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 15 of 25
All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(A)(i)
COUNT 29
On or about June 10, 2020, within the State and District of Colorado, the
delineated in Title 21 of the United States Code, specifically the crime alleged in Count
1 of this indictment.
All in violation of Title 21, United States Code, Sections 843(b) and (d).
COUNT 30
On or about June 10, 2020, within the State and District of Colorado, the
defendants KEVEN ALEXANDER PEREZ and FIRST NAME UNKNOWN, LAST NAME
commission of a felony delineated in Title 21 of the United States Code, specifically the
All in violation of Title 21, United States Code, Sections 843(b) and (d).
COUNT 31
On or about June 10, 2020, within the State and District of Colorado and
elsewhere, the defendant NICHO GARCIA did travel in interstate commerce with the
intent to promote, manage, establish, carry on, and facilitate the promotion,
15
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 16 of 25
violations of Title 21, United States Code, Sections 841(a)(1) and 846 as alleged in
Count 1 of this Indictment, and thereafter performed and attempted to perform an act to
promote, manage, establish, carry on, and facilitate the promotion, management,
COUNT 32
On or about June 10, 2020, within the State and District of Colorado, the
NICHO GARCIA, FIRST NAME UNKNOWN, LAST NAME UNKNOWN, a.k.a. “Tavo,”
ABISAI ESCOBAR FLORES, a.k.a. “Guerrero” and FIRST NAME UNKNOWN, LAST
NAME UNKNOWN, a.k.a. “Primo,” did knowingly and intentionally distribute and
possess with the intent to distribute one kilogram and more of a mixture and substance
knowingly and intentionally aid, abet, counsel, command, induce and procure the same,
in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(A)(i) and Title
COUNT 33
On or about July 18, 2020, within the State and District of Colorado, the
defendants KEVEN ALEXANDER PEREZ and JESSE CERVANTES did knowingly and
in causing and facilitating the commission of a felony delineated in Title 21 of the United
All in violation of Title 21, United States Code, Sections 843(b) and (d).
16
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 17 of 25
COUNT 34
On or about July 18, 2020, within the State and District of Colorado and
elsewhere, the defendant JESSE CERVANTES did travel in interstate commerce with
the intent to promote, manage, establish, carry on, and facilitate the promotion,
violations of Title 21, United States Code, Sections 841(a)(1) and 846 as alleged in
Count 1 of this Indictment, and thereafter performed and attempted to perform an act to
promote, manage, establish, carry on, and facilitate the promotion, management,
COUNT 35
On or about July 18, 2020, within the State and District of Colorado, the
distribute and possess with the intent to distribute one kilogram and more of a mixture
Substance, and did knowingly and intentionally aid, abet, counsel, command, induce
All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(A)(i)
COUNT 36
On or about August 3, 2020, within the State and District of Colorado, the
17
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 18 of 25
commission of a felony delineated in Title 21 of the United States Code, specifically the
All in violation of Title 21, United States Code, Sections 843(b) and (d).
COUNT 37
On or about and between June 1, 2019 and September 1, 2020, both dates
being approximate and inclusive, within the State and District of Colorado and
CRUZ, a.k.a. “Enrique,” VICTOR ALONSO CARREON, a.k.a. “Alonso,” and ADRIANNA
RAFAELA HOLGUIN, a.k.a. “Fela,” did knowingly combine, conspire, confederate and
agree with other persons known and unknown to the Grand Jury, to commit offenses
against the United States in violation of Title 18, United States Code, Section 1956, in
that the defendants did knowingly conspire to conduct and attempt to conduct a financial
transaction affecting interstate and foreign commerce knowing that the transaction
involved the proceeds of a specified unlawful activity (“SUA”), that SUA specifically being
the conspiracy charged in Count 1 of this Indictment, with the intent to promote the
carrying on of the SUA, in violation of Title 18, United States Code, Sections
1956(a)(1)(A)(i), and with the intent to conceal or disguise the nature, the location, the
18
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 19 of 25
source, the ownership, and the control of the proceeds of the SUA in violation of Title 18,
(“hereinafter TAVO”) on a routine and consistent basis, arranged for, supplied, and sent
a.k.a. “Enrique.”
DIEGO ROMERO-CRUZ, a.k.a. “Enrique,” also received heroin from other sources of
supply located in Mexico, Colorado, and other locations within the United States.
on a routine and consistent basis, collected and possessed large sums of money (“bulk-
cash drug proceeds”) generated from the sale of heroin supplied by TAVO and other
19
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 20 of 25
on a routine and consistent basis, used bulk-cash drug proceeds to pay for physical
items and monetary costs associated with maintaining their heroin trafficking operations.
Such costs included, but were not limited to, money spent on apartments, vehicles,
communicating with each other and arranging in-person meetings. During these
meetings, defendants either personally or directing others, collected and combined bulk-
routine and consistent basis, were transporting bulk-cash drug proceeds to Money
20
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 21 of 25
RAFAELA HOLGUIN, a.k.a. “Fela,” either personally or using others, on a routine and
consistent basis, wire-transferred bulk cash drug proceeds from Colorado MSBs to
9. It was part of this money laundering conspiracy that the bulk cash drug
proceeds sent via wire-transfers represented payment for heroin supplied by TAVO and
other heroin sources. The wire-transfers promoted the conspiracy alleged in Count 1
because TAVO and other sources used the bulk-cash proceeds to purchase more
10. It was part of this money laundering conspiracy that the defendants
activities designed to disguise the nature, location, source, ownership, and control of the
bulk-cash drug proceeds. Such activities included, but were not limited to the following:
21
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 22 of 25
FORFEITURE ALLEGATION
re-alleged and incorporated by reference for the purpose of alleging forfeiture pursuant
to the provisions of Title 21, United States Code, Section 853. Upon conviction of the
BENJAMIN LOPES-ALVARADO,
a.k.a. “Juan,”
AZUSENA MARIBEL SIERRA,
a.k.a. “Suzy,”
HECTOR NUNEZ-SANDOVAL,
a.k.a. “Gordo,”
JORGE REYES CRUZ-GARCIA,
a.k.a. “Comino,”
BRADLEY MICHAEL WHITE,
a.k.a., Brian,”
MICHAEL IAN MILLS,
ANNA MARIE REBEKAH DAVIS,
a.k.a. “Green,”
FIRST NAME UNKNOWN, LAST NAME UNKNOWN,
a.k.a. “Tavo,”
FIRST NAME UNKNOWN, LAST NAME UNKNOWN,
a.k.a. “UM-2911,”
FIRST NAME UNKNOWN, LAST NAME UNKNOWN,
a.k.a. “UM-9465,”
KEVEN ALEXANDER PEREZ,
VICTORIANO HINOJOSA,
OSCAR MANUEL OLIVEROS,
FIRST NAME UNKNOWN, LAST NAME UNKNOWN,
a.k.a. “Vitamina,” and “Mario,”
DIEGO ROMERO-CRUZ,
a.k.a. “Enrique,”
FIRST NAME UNKNOWN, LAST NAME UNKNOWN,
a.k.a. “UM-6508,”
CHRISTIAN ANTHONY CARVER,
22
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 23 of 25
shall forfeit to the United States pursuant to Title 21, United States Code, Section 853
any and all of the defendant’s 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, including, but not limited to: a money
If any of the property described in the paragraph above, as a result of any act or
it is the intent of the United States, pursuant to Title 21, United States Code, Section
853(p), to seek forfeiture of any other property of said defendant up to the value of the
forfeitable property.
23
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 24 of 25
BENJAMIN LOPES-ALVARADO,
a.k.a. “Juan,”
AZUSENA MARIBEL SIERRA,
a.k.a. “Suzy,”
HECTOR NUNEZ-SANDOVAL,
a.k.a. “Gordo,”
JORGE REYES CRUZ-GARCIA,
a.k.a. “Comino,”
FIRST NAME UNKNOWN, LAST NAME UNKNOWN,
a.k.a. “Tavo,”
KEVEN ALEXANDER PEREZ,
DIEGO ROMERO-CRUZ,
a.k.a. “Enrique,”
VICTOR ALONSO CARREON,
a.k.a. “Alonso,” and
ADRIANNA RAFAELA HOLGUIN,
a.k.a. “Fela,”
shall forfeit to the United States, pursuant to Title 18, United States Code, Section
982(a)(1) any and all of the defendant’s 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, including, but not limited to: a
If any of the property described above, as a result of any act or omission of the
defendant;
(1) cannot be located upon the exercise of due diligence;
(2) has been transferred or sold to, or deposited with, a third
party;
(3) has been placed beyond the jurisdiction of the Court;
(4) has been substantially diminished in value; or
(5) has been commingled with other property which cannot be
subdivided without difficulty;
it is the intent of the United States, pursuant to Title 21, United States Code, Section
853(p), incorporated by Title 18, United States Code, Section 982, to seek forfeiture of
any other property of said defendant[s] up to the value of the forfeitable property.
24
Case 1:20-cr-00292-WJM Document 1 Filed 09/03/20 USDC Colorado Page 25 of 25
All in violation of Title 18, United States Code, Section 982(a)(1) and Title 21,
A TRUE BILL:
JASON R. DUNN
United States Attorney
25