dark angel indictment 2

7/31/2019 Dark Angel Indictment 2

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IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO

Criminal Action No.

UNITED STATES OF AMERICA,

Plaintiff,

v.

1. REYNA MENDOZA-HARO,a/k/a Reyna Mendoza, Reyna, Reyna Gonzalez, Amanda Gonzalez,

2. ARNALDO ALVAREZ-GONZALEZ,

a/k/a Indio, Monra,3. JAIME MORENO-LOPEZ,

a/k/a El Guapo, Jaime Lopez, Jaime Moreno, Adrian Lopez-Villeda,Alberto Torres-Trejo4. RICKY HENRY CISNEROS,

a/k/a Ricky Cisneros,

5. IVAN GOMEZ-AVILA,

a/k/a Ivan Avila, Ivan Flores, Jose Gomez,6. SHANA LOUISE CLAYBOURN,

a/k/a Melissa Renee Rodriguez, Becky Smith, Shana Claybourn, Tiffany

Claybourn, Shana Contreras, Shana Louise Contreras-Pineda,7. CRIS ANTHONY SANDOVAL,

a/k/a Cris Sandoval, Christopher Sandoval,

8. TODD JOSEPH TRUJILLO,a/k/a Todd Trujillo, Tracy Petterson, Todd Jose Trujillo,

9. KENNIE RAY SNYDER,

a/k/a Kennie Snyder,10. CHRISTINA ROSE MALMGREN,

a/k/a Christina Malmgren, and

11. DESIREE ROSE CEBALLES,

a/k/a Desiree Rosa Allen, Desiree Rose Lucy, Desiree Ceballes, DesireeRose Martinez,

Defendants.

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Case 1:12-cr-00242-WJM Document 1 Filed 05/23/12 USDC Colorado Page 1 of 15

12-cr-00242 WJM


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______________________________________________________________________________

INDICTMENT

21 U.S.C. 846

21 U.S.C. 841(a)(1), 841(b)(1)(A)(viii), 841(b)(1)(B)(viii), and 841(b)(1)(C)

21 U.S.C. 843(b)18 U.S.C. 2

______________________________________________________________________________

THE GRAND JURY CHARGES:

COUNT ONE

From on or about October 21, 2010, through on or about May 23, 2012, both dates being

approximate and inclusive, within the State and District of Colorado and elsewhere, the

defendants;

REYNA MENDOZA-HARO,

ARNALDO ALVAREZ-GONZALEZ,

JAIME MORENO-LOPEZ,RICKY HENRY CISNEROS,

IVAN GOMEZ-AVILA,

SHANA LOUISE CLAYBOURN,CRIS ANTHONY SANDOVAL,

TODD JOSEPH TRUJILLO,

KENNIE RAY SNYDER,CHRISTINA ROSE MALMGREN,

DESIREE ROSE CEBALLES,

did knowingly and intentionally conspire with each other and with others known and unknown to

the Grand Jury, to knowingly and intentionally distribute and possess with the intent to distribute

50 grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500

grams or more of a mixture or substance containing a detectable amount of methamphetamine, a

Schedule II controlled substance.

All in violation of Title 21, United States Code, Sections 846 and 841(a)(1), and

841(b)(1)(A)(viii).

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COUNT TWO

On or about January 23, 2011, within the State and District of Colorado, the defendant,

REYNA MENDOZA-HARO did knowingly and intentionally distribute and possess with the

intent to distribute 5 grams or more of actual of methamphetamine, a Schedule II controlled

substance, and did knowingly and intentionally aid, abet, counsel, command, induce or procure

the same.

All in violation of Title 21, United States Code, Sections 841(a)(1), and

841(b)(1)(B)(viii) and Title 18, United States Code, Section 2.

COUNT THREE

On or about July 8, 2011, within the State and District of Colorado, the defendant,

KENNIE RAY SNYDER did knowingly and intentionally distribute and possess with the intent

to distribute 5 grams or more of a mixture or substance containing a detectable amount of

methamphetamine, a Schedule II controlled substance, and did knowingly and intentionally aid,

abet, counsel, command, induce or procure the same.

All in violation of Title 21, United States Code, Sections 841(a)(1), and 841(b)(1)(C) and

Title 18, United States Code, Section 2.

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COUNT FOUR

On or about July 14, 2011, within the State and District of Colorado, the defendants,

IVAN GOMEZ-AVILA and SHANA LOUISE CLAYBOURN, did knowingly and intentionally

distribute and possess with the intent to distribute 50 grams or more of methamphetamine

(actual), a Schedule II controlled substance, or 500 grams or more of a mixture or substance

containing a detectable amount of methamphetamine, a Schedule II controlled substance, and did

knowingly and intentionally aid, abet, counsel, command, induce or procure the same.

All in violation of Title 21, United States Code, Sections 841(a)(1) and 841(b)(1)(A)(viii)

and Title 18, United States Code, Section 2.

COUNT FIVE

On or about August 3, 2011, within the State and District of Colorado, the defendant,

TODD JOSEPH TRUJILLO did knowingly and intentionally distribute and possess with the

intent to distribute 5 grams or more of a mixture or substance containing a detectable amount of

methamphetamine, a Schedule II controlled substance, and did knowingly and intentionally aid,

abet, counsel, command, induce or procure the same.

All in violation of Title 21, United States Code, Sections 841(a)(1), and 841(b)(1)(C) and

Title 18, United States Code, Section 2.

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COUNT SIX

On or about May 19, 2012, within the State and District of Colorado, the defendant,

REYNA MENDOZA-HARO did knowingly and intentionally distribute and possess with the

intent to distribute 5 grams or more of methamphetamine (actual), a Schedule II controlled

substance, or 50 grams or more of a mixture or substance containing a detectable amount of

methamphetamine, a Schedule II controlled substance.

All in violation of Title 21, United States Code, Sections 841(a)(1), and

841(b)(1)(B)(viii).

COUNT SEVEN


JAIME MORENO-LOPEZ, did knowingly and intentionally use a communication facility, the

telephone, in committing and in facilitating the commission of the offense of conspiracy to

knowingly and intentionally distribute and possess with the intent to distribute 50 grams or more

of methamphetamine (actual), a Schedule II controlled substance, or 500 grams or more of a

mixture or substance containing a detectable amount of methamphetamine, a Schedule II

controlled substance, as alleged in Count One of this Indictment.

All in violation of Title 21, United States Code, Section 843(b).

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COUNT EIGHT


CHRISTINA ROSE MALMGREN, did knowingly and intentionally use a communication

facility, the telephone, in committing and in facilitating the commission of the offense of

conspiracy to knowingly and intentionally distribute and possess with the intent to distribute 50

grams or more of methamphetamine (actual), a Schedule II controlled substance, or 500 grams

or more of a mixture or substance containing a detectable amount of methamphetamine, a

Schedule II controlled substance, as alleged in Count One of this Indictment.


COUNT NINE


KENNIE RAY SNYDER, did knowingly and intentionally use a communication facility, the







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COUNT TEN


SHANA LOUISE CLAYBOURN, did knowingly and intentionally use a communication







COUNT ELEVEN


SHANA LOUISE CLAYBOURN, did knowingly and intentionally use a communication







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COUNT TWELVE


REYNA MENDOZA-HARO, did knowingly and intentionally use a communication facility, the







COUNT THIRTEEN

On or about July 13, 2011, within the State and District of Colorado, the defendant, CRIS

ANTHONY SANDOVAL, did knowingly and intentionally use a communication facility, the







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COUNT FOURTEEN


REYNA MENDOZA-HARO, did knowingly and intentionally use a communication facility, the







COUNT FIFTEEN

On or about July 17, 2011, within the State and District of Colorado, the defendant, CRIS

ANTHONY SANDOVAL, did knowingly and intentionally use a communication facility, the







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COUNT SIXTEEN


JAIME MORENO-LOPEZ, did knowingly and intentionally use a communication facility, the







COUNT SEVENTEEN


REYNA MENDOZA-HARO and ARNALDO ALVAREZ-GONZALEZ, did knowingly and

intentionally use a communication facility, the telephone, in committing and in facilitating the

commission of the offense of conspiracy to knowingly and intentionally distribute and possess

with the intent to distribute 50 grams or more of methamphetamine (actual), a Schedule II

controlled substance, or 500 grams or more of a mixture or substance containing a detectable

amount of methamphetamine, a Schedule II controlled substance, as alleged in Count One of this

Indictment.


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COUNT EIGHTEEN


CHRISTINA ROSE MALMGREN, did knowingly and intentionally use a communication







COUNT NINETEEN


TODD JOSEPH TRUJILLO, did knowingly and intentionally use a communication facility, the







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COUNT TWENTY


REYNA MENDOZA-HARO and DESIREE ROSE CEBALLES, did knowingly and






Indictment.


COUNT TWENTY-ONE


REYNA MENDOZA-HARO and ARNALDO ALVAREZ-GONZALEZ, did knowingly and






Indictment.


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COUNT TWENTY-TWO

On or about August 5, 2011, within the State and District of Colorado, the defendants,

REYNA MENDOZA-HARO and DESIREE ROSE CEBALLES, did knowingly and






Indictment.


FORFEITURE ALLEGATION

The allegations contained in Counts One through Twenty-two of this Indictment are

hereby re-alleged and incorporated by reference for the purpose of alleging forfeiture pursuant to

the provisions of 21 U.S.C. 853.

Upon conviction of the violations alleged in Counts One through Twenty-two of this

Indictment involving violations of 21 U.S.C. 846, 841(a)(1), 841(b)(1)(A)(ii)(II), and

841(b)(1)(B)(ii)(II), 21 U.S.C. 843(b), the defendants; REYNA MENDOZA-HARO,

ARNALDO ALVAREZ-GONZALEZ, JAIME MORENO-LOPEZ, RICKY HENRY

CISNEROS, IVAN GOMEZ-AVILA, SHANA LOUISE CLAYBOURN, CRIS ANTHONY

SANDOVAL, TODD JOSEPH TRUJILLO, KENNIE RAY SNYDER, CHRISTINA ROSE

MALMGREN, and DESIREE ROSE CEBALLES, shall forfeit to the United States, pursuant to

Title 21, United States Code, Section 853 any and all of the defendants right, title and interest in

all property constituting and derived from any proceeds obtained directly and indirectly as a

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result of such offense, and in all property used, or intended to be used, in any manner or part, to

commit, or to facilitate the commission of such offense, including, but not limited to a money

judgment in the amount of proceeds obtained by theconspiracyand by the defendants.

If any of the property as a result of any act or omission of the defendants:

a) cannot be located upon the exercise of due diligence;

b) has been transferred or sold to, or deposited with, a third

party;

c) has been placed beyond the jurisdiction of the Court;d) has been substantially diminished in value; or

e) has been commingled with other property which

cannot be subdivided without difficulty;

it is the intent of the United States, pursuant to Title 21, United States Code, Section 853(p), to

seek forfeiture of any other property of said defendants up to the value of the forfeitable

property.

A TRUE BILL:

Ink signature on file in the Clerks Office__

FOREPERSON

APPROVED:

JOHN F. WALSH

United States Attorney

BY: __s/ Zachary Phillips____________

ZACHARY PHILLIPSAssistant United States Attorney

U.S. Attorneys Office

1225 17th Street, Suite 700Denver, CO. 80202

Telephone (303) 454-0118

Fax (303) 454-0401

[email protected] for Government

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BY: Kasandra R. CarletonKASANDRA R. CARLETON

Assistant U.S. Attorney

U.S. Attorneys Office

1225 17th St., Suite 700Denver, Colorado 80202

Telephone: (303) 454-0100Fax: (303) 454-0401

e-mail: [email protected]

Attorney for the Government

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DEFENDANT 1: REYNA MENDOZA-HARO,a/k/a Reyna Mendoza Reyna Reyna Gonzalez Amanda Gonzalez

YOB: 1980 or 1981

ADDRESS: Corcoran, CA

COMPLAINT FILED? YES T NO

IF YES, PROVIDE MAGISTRATE CASE NUMBER:IF NO, PROCEED TO OFFENSE SECTION

HAS DEFENDANT BEEN ARRESTED ON COMPLAINT? YES T NO

IF NO, A NEW WARRANT IS REQUIRED

OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and

841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent todistribute 50 grams or more of methamphetamine (actual), a Schedule IIcontrolled substance, or 500 grams or more of a mixture or substance containing adetectable amount of methamphetamine, a Schedule II controlled substance.

COUNT TWO: Title 21, United States Code, Sections 841(a)(1), and841(b)(1)(B)(viii), and Title 18, United States Code, Section 2 - knowingly andintentionally distribute and possess with the intent to distribute 5 grams or moreof methamphetamine (actual), a Schedule II controlled substance, and didknowingly and intentionally aid, abet, counsel, command, induce or procure thesame.

COUNT SIX: Title 21, United States Code, Sections 841(a)(1), and841(b)(1)(B)(viii) - knowingly and intentionally distribute and possess with theintent to distribute 5 grams or more of methamphetamine (actual), a Schedule IIcontrolled substance, and 50 grams or more of a mixture or substance containing

adetectable amount of methamphetamine, a Schedule II controlled substance.

COUNTS TWELVE, FOURTEEN, SEVENTEEN, TWENTY, TWENTY-

ONE, and TWENTY-TWO: Title 21, United States Code, Section 843(b) -knowingly and intentionally use a communication facility, the telephone, incommitting and in causing and facilitating the commission of a felony drugoffense.

LOCATIONOF OFFENSE(COUNTY/STATE): Denver County, Denver, CO

Case 1:12-cr-00242-WJM Document 1-1 Filed 05/23/12 USDC Colorado Page 1 of 3


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PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both;NLT 5 years supervised release, $100 Special Assessment Fee.

COUNT TWO and SIX: NLT 5 years, NMT 40 years imprisonment, $5 millionfine, or both; NLT 4 years supervised release, $100 Special Assessment Fee

COUNTS TWELVE, FOURTEEN, SEVENTEEN, TWENTY, TWENTY-ONE, and TWENTY-TWO: NMT 4 years imprisonment, $250,000.00 fine, orboth; NMT 1 year supervised release; and a $100 Special Assessment Fee (percount).

AGENT: TFO Leonard A. HuskeyDrug Enforcement Administration

AUTHORIZED Zachary H. PhillipsBY: Kasandra R. Carleton

Assistant U.S. Attorneys

ESTIMATED TIME OF TRIAL: 5 days or more

THE GOVERNMENT will seek detention in this case

The statutory presumption of detention is applicable to this defendant.

OCDETF CASE: T Yes No

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DEFENDANT 2: ARNALDO ALVAREZ-GONZALEZ,a/k/a Indio Monra

YOB: 1978

ADDRESS:







COUNTS SEVENTEEN and TWENTY-ONE: Title 21, United States Code,Section 843(b) - knowingly and intentionally use a communication facility, thetelephone, in committing and in causing and facilitating the commission of afelony drug offense.

LOCATION

OF OFFENSE(COUNTY/STATE): Denver County, Denver, CO

PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine, or both;NLT 5 years supervised release, $100 Special Assessment Fee.

COUNTS SEVENTEEN and TWENTY-ONE: NMT 4 years imprisonment,$250,000.00 fine, or both; NMT 1 year supervised release; and a $100 SpecialAssessment Fee (per count).






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DEFENDANT 3: JAIME MORENO-LOPEZ,a/k/a El Guapo Jaime Lopez Jaime MorenoAdrian Lopez-Villeda Alberto Torres-Trejo

YOB: 1981 or 1980

ADDRESS:





OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent todistribute 50 grams or more of methamphetamine (actual), a Schedule IIcontrolled substance, or 500 grams or more of a mixture or substance containing adetectable amount of methamphetamine, a Schedule II controlled substance

COUNTS SEVEN and SIXTEEN: Title 21, United States Code, Section843(b) - knowingly and intentionally use a communication facility, thetelephone, in committing and in causing and facilitating the commission of afelony drug offense.


PENALTY: COUNT ONE: NLT 10 years, NMT life in prison, $10 million fine,or both; NLT 5 years supervised release, $100 Special Assessment Fee.

COUNTS SEVEN and SIXTEEN: NMT 4 years imprisonment,$250,000.00 fine, or both; NMT 1 year supervised release; and a $100 SpecialAssessment Fee (per count).



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DEFENDANT 4: RICKY HENRY CISNEROS,a/k/a Ricky Cisneros

YOB: 1974

ADDRESS: Denver, Colorado






841(b)(1)(A)(viii) - conspiracy to distribute and possess with the intent todistribute 50 grams or more of methamphetamine (actual), a Schedule IIcontrolled substance, or 500 grams or more of a mixture or substance containing adetectable amount of methamphetamine, a Schedule II controlled substance.












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DEFENDANT 5: IVAN GOMEZ-AVILA,a/k/a Ivan Avila Ivan Flores Jose Gomez

YOB: 1981 or 1980

ADDRESS: Denver, Colorado






841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent todistribute 50 grams or more of methamphetamine (actual), a Schedule IIcontrolled substance, or 500 grams or more of a mixture or substance containing adetectable amount of methamphetamine, a Schedule II controlled substance

COUNT FOUR: Title 21, United States Code, Sections 841(a)(1) and841(b)(1)(A)(viii) and Title 18, United States Code, Section 2 - knowingly andintentionally distribute and possess with the intent to distribute 50 grams or moreof methamphetamine (actual), a Schedule II controlled substance, or 500 grams ormore of a mixture or substance containing a detectable amount ofmethamphetamine, a Schedule II controlled substance, and did knowingly and

intentionally aid, abet, counsel, command, induce or procure the same



COUNT FOUR: NLT 10 years, NMT life in prison, $10 million fine, or both;NLT 5 years supervised release, $100 Special Assessment Fee






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DEFENDANT 7: CRIS ANTHONY SANDOVAL,a/k/a "Cris Sandoval" "Christopher Sandoval"

YOB: 1959

ADDRESS:







COUNTS THIRTEEN and FIFTEEN: Title 21, United States Code,Section 843(b) - knowingly and intentionally use a communication facility, thetelephone, in committing and in facilitating the commission of a felony drugoffense.

LOCATION



COUNTS THIRTEEN and FIFTEEN: NMT 4 years imprisonment,$250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00Special Assessment Fee (per count)

AGENT: TFO Leonard A. Huskey

Drug Enforcement Administration





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DEFENDANT 8: TODD JOSEPH TRUJILLO,a/k/a "Todd Trujillo" "Tracy Petterson" "Todd Jose Trujillo"

YOB: 1967

ADDRESS: Westminster, Colorado







COUNT FIVE: Title 21, United States Code, Sections 841(a)(1), and841(b)(1)(C) and Title 18, United States Code, Section 2 - knowingly andintentionally distribute and possess with the intent to distribute 5 grams or moreof a mixture or substance containing a detectable amount of methamphetamine, aSchedule II controlled substance, and did knowingly and intentionally aid, abet,counsel, command, induce or procure the same.

COUNT NINETEEN: Title 21, United States Code, Section 843(b) -knowingly and intentionally use a communication facility, the telephone, incommitting and in facilitating the commission of a felony drug offense.





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COUNT FIVE: NMT 20 years imprisonment, $1 million fine, or both; NLT 3years supervised release, $100 Special Assessment Fee

COUNT NINETEEN: NMT 4 years imprisonment, $250,000.00 fine, or both;NMT 1 year supervised release; and a $100.00 Special Assessment Fee.








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DEFENDANT 9: KENNIE RAY SNYDER,a/k/a "Kennie Snyder"

YOB: 1966

ADDRESS: Lakewood, Colorado







COUNT THREE: Title 21, United States Code, Sections 841(a)(1), and841(b)(1)(C) and Title 18, United States Code, Section 2 - knowingly andintentionally distribute and possess with the intent to distribute 5 grams or moreof a mixture or substance containing a detectable amount of methamphetamine, aSchedule II controlled substance, and did knowingly and intentionally aid, abet,counsel, command, induce or procure the same.

COUNT NINE: Title 21, United States Code, Section 843(b) -knowingly and intentionally use a communication facility, the telephone, incommitting and in facilitating the commission of a felony drug offense.



COUNT THREE: NMT 20 years imprisonment, $1 million fine, or both;NLT 3 years supervised release, $100 Special Assessment Fee.

COUNT NINE: NMT 4 years imprisonment, $250,000.00 fine,or both; NMT 1 year supervised release; and a $100.00 Special AssessmentFee.




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DEFENDANT 10: CHRISTINA ROSE MALMGREN,a/k/a "Christina Malmgren"

YOB: 1987

ADDRESS:







COUNTS EIGHT and EIGHTEEN: Title 21, United States Code,Section 843(b) - knowingly and intentionally use a communication facility, thetelephone, in committing and in facilitating the commission of a felony drugoffense.

LOCATION



COUNTS EIGHT and EIGHTEEN: NMT 4 years imprisonment,$250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00Special Assessment Fee (per count)







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DEFENDANT 11: DESIREE ROSE CEBALLES,a/k/a Desiree Rosa Allen Desiree Rose LucyDesiree Ceballes Desiree Rose Martinez

YOB: 1985

ADDRESS:





OFFENSE: COUNT ONE: Title 21, United States Code, Sections 846 and 841(a)(1), and841(b)(1)(A)(viii) - Conspiracy to distribute and possess with the intent todistribute 50 grams or more of methamphetamine (actual), a Schedule IIcontrolled substance, or 500 grams or more of a mixture or substance containing adetectable amount of methamphetamine, a Schedule II controlled substance.

COUNTS TWENTY and TWENTY-TWO: Title 21, United StatesCode, Section 843(b) - knowingly and intentionally use a communication facility,the telephone, in committing and in facilitating the commission of a felonydrug offense.



COUNTS TWENTY and TWENTY-TWO: NMT 4 years imprisonment,$250,000.00 fine, or both; NMT 1 year supervised release; and a $100.00 SpecialAssessment Fee (per count).







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dark angel indictment 2

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