District Court, City and County of Denver, Colorado City and County Building, Room 256 1437 Bannock Street Denver, CO 80202 Plaintiff: THE PEOPLE OF THE STATE OF

COLORADO

Defendants: AZIMDZHON MAZHIDOV FIRUZI SHARIFI BOBOKALON SHARIPOV FIRDAVSI URUNOV SHODMON BILOLOV PARVIZ CHORSANBIEV KHISRAV CHUTOV AZIM GOLUBOV FARIDUM JABBOROV BAKHTIYOR KADIROV NODIR KHODZHAEV MAKHMADRIZO KHOLOV KARIMDZHON MANSUROV BAKHTIYORKHUJA MIRZOKHOJAEV DMITRIY ORLOVSKIY OBID VAPAEV

? COURT USE ONLY ?

Case Number:

Grand Jury No. 10CR2 A

Div.: Criminal Ctrm: 9 / ____

INDICTMENT

VIOLATION OF COLORADO ORGANIZED CRIME CONTROL ACT, 18-17-104(3) C.R.S. (F2) <37284> 1 (1 count) CONSPIRACY TO COMMIT THEFT, 18-4-401(1),(2)(c);18-2-201 C.R.S. (F5) <0801UC> 2 (1 count) THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> 3 – 10, 12, 14, 16, 17, 19, 21, 23, 24, 25, 27, 28, 30, 31, 37 - 41 (26 counts) FORGERY, 18-5-102(1)(c) C.R.S. (F5) <1001C> 13, 33 (2 counts) POSSESSION OF FORGED INSTRUMENT, 18-5-105 C.R.S. (F6) <10040> 35, 36 (2 counts) CRIMINAL IMPERSONATION, 18-5-113(1)(e) C.R.S. (F6) <1011A> 15, 18, 20, 22, 26, 29, 34 (7 counts) CRIMINAL ATTEMPT TO COMMIT THEFT, 18-4-401(1),(2)(c); 18-2-101, C.R.S (F5) <0801UA> 32 (1 count) THEFT, 18-4-401(1),(2)(b.5) C.R.S. (M1) <0801T> 11 (1 count)

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COUNT ONE

VIOLATION OF COLORADO ORGANIZED CRIME CONTROL ACT, 18-17-104(3) C.R.S. (F2) <37284> Between and including August 1, 2009, and November 10, 2010, at and triable in the City and County of Denver, State of Colorado, AZIMDZHON MAZHIDOV, FIRUZI SHARIFI, BOBOKALON SHARIPOV, and FIRDAVSI URUNOV, while employed by or associated with an enterprise, namely: a group of individuals associated in fact, although not a legal entity, unlawfully, feloniously, and knowingly conducted or participated, directly or indirectly, in the enterprise through a pattern of racketeering activity; in violation of sections 18-17-104(3) and 18-17-105, C.R.S.

The Enterprise The enterprise alleged in this count was a group of individuals, associated in fact, although not a legal entity. The enterprise included, but was not limited to, the following: AZIMDZHON MAZHIDOV; FIRUZI SHARIFI; BOBOKALON SHARIPOV; FIRDAVSI URUNOV; SHODMON BILOLOV; PARVIZ CHORSANBIEV; KHISRAV CHUTOV; AZIM GOLUBOV; FARIDUM JABBOROV; BAKHTIYOR KADIROV; NODIR KHODZHAEV; MAKHMADRIZO KHOLOV; KARIMDZHON MANSUROV; BAKHTIYORKHUJA MIRZOKHOJAEV; DMITRIY ORLOVSKIY; OBID VAPAEV; MUKHAMMAD ABDUSALMOV; MUKHAMADI RAUPOV, and other persons known or unknown, who were associated from time to time in racketeering activity that was related to the conduct of the enterprise.

Pattern of Racketeering Activity For purposes of this count, the defendants engaged in acts related to the conduct of the enterprise, including: As to AZIMDZHON MAZHIDOV, the acts described in counts 2, 6, 12, 13, 27 and 37, including any lesser included offenses of these counts. As to FIRUZI SHARIFI, the acts described in counts 2, 8, 14, 15, 17, 21, 22, 24, 25, 26, 31 and 40, including any lesser included offenses of these counts. As to BOBOKALON SHARIPOV, the acts described in counts 2, 17, 18, 19, 20, 28 and 29, including any lesser included offenses of these counts. As to FIRDAVSI URUNOV, the acts described in counts 2, 7, and 9, including any lesser included offenses of these counts, and Predicate Act 42 of this Indictment.

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PREDICATE ACT FORTY-TWO CRIMINAL ATTEMPT TO COMMIT THEFT, 18-4-401(1),(2)(c); 18-2-101, C.R.S (F5) <0801UA> Between and including March 12, 2010, and March 27, 2010, at and triable in the City and County of Denver, State of Colorado, by engaging in conduct constituting a substantial step toward the commission of theft, FIRDAVSI URUNOV, unlawfully, feloniously, and knowingly attempted to obtain or exercise control over a thing of value, namely: MONEY, of WELLS FARGO BANK and URUNOV DUSHANBE, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK and URUNOV DUSHANBE permanently of its use or benefit; in violation of sections 18-4-401(1)(2)(c) and 18-2-101, C.R.S.

COUNT TWO CONSPIRACY TO COMMIT THEFT, 18-4-401(1),(2)(c) C.R.S.; 18-2-201 C.R.S. (F5) <0801UC> Between and including August 1, 2009, and November 10, 2010, at and triable in the City and County of Denver, State of Colorado, AZIMDZHON MAZHIDOV; FIRUZI SHARIFI; BOBOKALON SHARIPOV; FIRDAVSI URUNOV; SHODMON BILOLOV; PARVIZ CHORSANBIEV; KHISRAV CHUTOV; AZIM GOLUBOV; FARIDUM JABBOROV; BAKHTIYOR KADIROV; NODIR KHODZHAEV; MAKHMADRIZO KHOLOV; KARIMDZHON MANSUROV; BAKHTIYORKHUJA MIRZOKHOJAEV; DMITRIY ORLOVSKIY; and OBID VAPAEV, with the intent to promote or facilitate the commission of the crime of theft, unlawfully and feloniously agreed with each other and with MUKHAMMAD ABDUSALMOV, MUKHAMADI RAUPOV, and a person or persons to the Grand Jury unknown that one or more of them would engage in conduct which constituted that crime or an attempt to commit that crime, or agreed to aid the other person or persons in the planning or commission or attempted commission of that crime, and an overt act in pursuance of the conspiracy was committed by one or more of the conspirators; in violation of sections 18-4-401(1),(2)(c) and 18-2-201, C.R.S. The facts supporting Counts 1 and 2 and Predicate Act 42 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. From at least August 1, 2009, through November 10, 2010, Azimdzhon Mazhidov, Firuzi Sharifi, Bobokalon Sharipov, Firdavsi Urunov, Shodmon Bilolov, Parviz Chorsanbiev, Khisrav Chutov, Azim Golubov, Faridum Jabborov, Bakhtiyor Kadirov, Nodir Khodzhaev, Makhmadrizo Kholov, Karimdzhon Mansurov, Bakhtiyorkhuja Mirzokhojaev, Dmitriy Orlovskiy, and Obid Vapaev, and others, including but not limited to: Mukhammad Abdusalmov and Mukhamadi Raupov, were a group of individuals associated in fact, though not a legal entity, with a common goal. The common goal of the members of the enterprise was to steal money from financial institutions.

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3. Azimdzhon Mazhidov, Firuzi Sharifi, Bobokalon Sharipov, Firdavsi Urunov, Shodmon Bilolov, Parviz Chorsanbiev, Khisrav Chutov, Azim Golubov, Faridum Jabborov, Bakhtiyor Kadirov, Nodir Khodzhaev, Makhmadrizo Kholov, Karimdzhon Mansurov, Bakhtiyorkhuja Mirzokhojaev, Dmitriy Orlovskiy, Obid Vapaev, Mukhammad Abdusalmov, Mukhamadi Raupov, and other members of the enterprise, opened accounts at various financial institutions with the knowledge and intent that the accounts would be used to steal money from the financial institutions through a check kiting scheme. Members of the enterprise would use their own names and/or false names to open an account. Members of the enterprise would deposit a substantial amount of cash, then knowingly deposit or cash insufficient funds or closed account checks with the intent to steal money from the financial institution. Members of the enterprise would withdraw cash from their account before the insufficient funds or closed account checks were returned, unpaid, to the financial institution. 4. To accomplish the goals of the enterprise, members shared money, checks and financial transaction devices from the accounts they opened, as well as financial information, money, property, automobiles, transportation and living quarters. 5. At all times relevant to this Indictment, Azimdzhon Mazhidov, Firuzi Sharifi, Bobokalon Sharipov, and Firdavsi Urunov were the primary members of the enterprise who, knowingly and with the intent to defraud, recruited, transported, and instructed other members of the enterprise in the scheme. 6. Azimdzhon Mazhidov, Firuzi Sharifi, Bobokalon Sharipov, and Firdavsi Urunov, working independently or in concert with each other and/or with persons unknown to the Grand Jury, recruited new members into the enterprise and instructed those members how to open accounts, and how to deposit or cash bad checks and withdraw cash before the bad checks were returned, unpaid, to the financial institution. 7. Accounts used for fraudulent transactions were opened by members of the enterprise at various locations in the State of Colorado, including locations within the City and County of Denver. Accounts were opened at the First Bank of Cherry Creek, 100 Saint Paul Street, City and County of Denver, State of Colorado under the following names: Somon Corporation; Murado Dental; Nushervon Kalandarov; Timuri Khuseyn; Payravi Fraydin; and Ravshan Muradov. 8. Accounts used for fraudulent transactions listed addresses in the City and County of Denver, State of Colorado, including but not limited to: 840 S. Oneida #A312 (Somon Corporation, Ravshon Muradov and Murado Dental); 7135 Leetsdale Drive #H-15 (Payravi Fraydin); and 7005 Leetsdale Drive #A26 (Obid Vapaev, Firdavsi Urunov, and Bakhtiyor Kadirov). 9. At all times relevant to this Indictment, Azimdzhon Mazhidov, Firuzi Sharifi, Bobokalon Sharipov, and Firdavsi Urunov, directly or indirectly, expected to receive and did receive compensation in the form of money, transportation, food and lodging from other members of the enterprise in payment for directing the scheme. 10. As a result of the activities of the enterprise members, Wells Fargo Bank, with Colorado headquarters located in the City and County of Denver, State of Colorado, suffered an aggregate

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monetary loss in excess of $130,000.00. 11. As a result of the activities of the enterprise members, JP Morgan Chase Bank suffered an aggregate monetary loss in excess of $56,000.00 through branches located in the State of Colorado, including branches within the City and County of Denver. 12. As a result of the activities of the enterprise members, US Bank, with Colorado headquarters located in the City and County of Denver, State of Colorado, suffered an aggregate monetary loss in excess of $15,000.00. 13. As a result of the activities of the enterprise members, Key Bank, with Colorado headquarters located in the City and County of Denver, State of Colorado, suffered an aggregate monetary loss in excess of $900.00. 14. As to Predicate Act 42: Between and including March 12, 2010, and March 27, 2010, Firdavsi Urunov, using the name Urunov Dushanbe, cashed and/or deposited fraudulent checks on the account names of Nushervon Kalandarov and Farruh Odilov at Wells Fargo Bank. Firdavsi Urunov obtained more than $9,000.00 in cash from Wells Fargo Bank. Firdavsi Urunov was charged for that offense and entered a guilty plea to one count of Criminal Attempt To Commit Theft, 18-4-401(1),(2)(c); 18-2-101, C.R.S, a class five felony, in Denver County District Court case number 2010CR4151.

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COUNT THREE

THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including August 15, 2009 and September 4, 2009, at and triable in the City and County of Denver, State of Colorado, OBID VAPAEV unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive WELLS FARGO BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S. The facts supporting Count 3 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about August 15, 2009, in association with the enterprise, Obid Vapaev opened Wells Fargo Bank checking account #7885981220 at the Buckingham Square Convenience Center in Aurora, Arapahoe County, Colorado. Obid Vapaev used a Russian passport, #0663114 and an alien registration card, #96328369, as identification documents when he opened the account. Obid Vapaev listed his address as 11275 E. Alameda Avenue, #4, Aurora, Colorado, 80012-1007. 3. Between August 15, 2009 and September 4, 2009, Obid Vapaev, in association with the enterprise, cashed Murado Dental checks through his Wells Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Many of the transactions occurred within the City and County of Denver, State of Colorado. Among those transactions, Obid Vapaev cashed Murado Dental check #1128 for $1,010.00 at the Wells Fargo Bank branch located at 1001 S. Monaco Parkway on August 26, 2009. 4. The Murado Dental checks were returned, unpaid, to Wells Fargo Bank. 5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of approximately $3,700.00.

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COUNT FOUR THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including August 27, 2009 and October 15, 2009, at and triable in the City and County of Denver, State of Colorado, BAKHTIYOR KADIROV and OBID VAPAEV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of US BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive US BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive US BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S. The facts supporting Count 4 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about August 27, 2009, in association with the enterprise, Obid Vapaev opened US Bank account #103679258162. Obid Vapaev used a Russian passport, #0663114 as an identification document when he opened the account. Obid Vapaev listed his address as 11275 E. Alameda Avenue, #4, Aurora, Colorado, 80012-1007. 3. On or about September 10, 2009, in association with the enterprise, Bakhtiyor Kadirov opened Wells Fargo Bank checking account #9942909962 at the Monaco branch, located at 1001 S. Monaco Parkway, City and County of Denver, Colorado. Bakhtiyor Kadirov used a Colorado Driver’s License, #09-059-0715, and a Tajik passport, #T223309, as identification documents when he opened the account. Bakhtiyor Kadirov listed 7005 Leetsdale Drive #A26, Denver, Colorado 80224, as his home address. 4. Bakhtiyor Kadirov, in association with the enterprise, gave checks from that account to other enterprise members to use for fraudulent transactions. 5. Between August 27, 2009 and October 15, 2009, Obid Vapaev, in association with the enterprise, transacted Bakhtiyor Kadirov checks through his US Bank account, withdrew cash, and made purchases with the account’s check card. Many of the transactions occurred within the City and County of Denver, State of Colorado. Among those transactions, Obid Vapaev deposited Bakhtiyor Kadirov’s Wells Fargo Bank check #1026 for $1,700.00 at the US Bank branch located at 444 17th Street on October 1, 2009. 4. The Bakhtiyor Kadirov checks were returned, unpaid, to US Bank. 7. As a result of the fraudulent activity, US Bank, with Colorado headquarters located at 950 17th Street, City and County of Denver, State of Colorado, suffered a loss of approximately $6,400.00.

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COUNT FIVE

THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including August 27, 2009 and September 28, 2009, at and triable in the City and County of Denver, State of Colorado, DMITRIY ORLOVSKIY, and OBID VAPAEV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of JP MORGAN CHASE BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive JP MORGAN CHASE BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive JP MORGAN CHASE BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S. The facts supporting Count 5 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about August 27, 2009, in association with the enterprise, Obid Vapaev opened JP Morgan Chase Bank account #638743466. Obid Vapaev used a Russian passport, #0663114 as an identification document when he opened the account. Obid Vapaev listed his address as 11275 E. Alameda Avenue, #4, Aurora, Colorado, 80012-1007. 3. Between August 27, 2009 and September 28, 2009, Obid Vapaev, in association with Dmitriy Orlovskiy and the enterprise, transacted Murado Dental and Ravshon Muradov checks through his JP Morgan Chase Bank account, withdrew cash, and made purchases with the account’s check card. Many of the transactions occurred within the City and County of Denver, State of Colorado. Among those transactions, Obid Vapaev deposited Murado Dental check #1144 for $1,950.00 at the branch located at 2696 S. Colorado Blvd. on September 4, 2009. 4. The Murado Dental and Ravshon Muradov checks were returned, unpaid, to JP Morgan Chase Bank. 5. As a result of the fraudulent activity, JP Morgan Chase Bank suffered a loss of approximately $4,700.00.

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COUNT SIX THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including September 10, 2009 and October 8, 2009, at and triable in the City and County of Denver, State of Colorado, AZIMDZHON MAZHIDOV, BAKHTIYOR KADIROV and OBID VAPAEV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive WELLS FARGO BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S. The facts supporting Count 6 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about September 10, 2009, in association with the enterprise, Bakhtiyor Kadirov opened Wells Fargo Bank checking account #9942909962 at the Monaco branch, located at 1001 S. Monaco Parkway, City and County of Denver, Colorado. Bakhtiyor Kadirov used a Colorado Driver’s License, #09-059-0715, and a Tajik passport, #T223309, as identification documents when he opened the account. Bakhtiyor Kadirov listed 7005 Leetsdale Drive #A26, Denver, Colorado 80224, as his home address. 3. On or about September 2, 2009, in association with the enterprise, Obid Vapaev opened TCF Bank checking account #9877283603. Obid Vapaev used a Russian passport, #0663114 as an identification document when he opened the account. Obid Vapaev listed his address as 7005 Leetsdale Drive #A26, Denver, Colorado 80224. 4. Between September 10, 2009 and October 8, 2009, Bakhtiyor Kadirov, in association with Azimdzhon Mazhidov and Obid Vapaev, transacted Obid Vapaev, Murado Dental and Ravshan Muradov checks through his Wells Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Many of the transactions occurred within the City and County of Denver, State of Colorado. Among those transactions, Bakhtiyor Kadirov cashed Murado Dental check #1129 for $1,100.00 at the branch located at 7150 Leetsdale Drive on September 18, 2009. 5. All of the checks were returned, unpaid, to Wells Fargo Bank. 6. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of approximately $9,100.00.

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COUNT SEVEN THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including October 8, 2009 and December 8, 2009, at and triable in the City and County of Denver, State of Colorado, FIRDAVSI URUNOV, BAKHTIYOR KADIROV, and BAKHTIYORKHUJA MIRZOKHOJAEV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of US BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive US BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive US BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 7 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about October 8, 2009, Bakhtiyorkhuja Mirzokhojaev, in association with the enterprise and under the direction of Firdavsi Urunov, opened US Bank checking account #103679464364 at the Thornton Parkway branch, 771 Thornton Parkway, Adams County, Colorado. Bakhtiyorkhuja Mirzokhojaev used a Tajik passport, #T490783, as an identification document when he opened the account. Bakhtiyorkhuja Mirzokhojaev listed 2880 S. Federal Blvd. #305, Denver, Colorado 80236, as his home address. 3. Bakhtiyorkhuja Mirzokhojaev, in association with the enterprise, also opened Wells Fargo Bank checking account #9372998105. Bakhtiyorkhuja Mirzokhojaev listed 2880 S. Federal Blvd. #305, Denver, Colorado 80236, as his home address. 4. Bakhtiyor Kadirov, in association with the enterprise, opened Key Bank checking account #760102039855, and gave checks from that account to other enterprise members to use for fraudulent transactions. Bakhtiyor Kadirov listed 7005 Leetsdale Drive #A26, Denver, Colorado, 80224 as his home address for that account. 5. Firdavsi Uronov, in association with the enterprise, opened Wachovia (later subsumed by Wells Fargo Bank) checking account, #1010247887907, and gave checks from that account to other enterprise members to use for fraudulent transactions. Firdavsi Uronov listed 7005 Leetsdale Drive #A26, Denver, Colorado 80224 as his home address for that account. 6. Between October 8, 2009 and December 8, 2009, Bakhtiyorkhuja Mirzokhojaev, in association with the enterprise, transacted checks drawn on his own Wells Fargo Bank account, and checks from Bakhtiyor Kadirov and Firdavsi Urunov, through his US Bank account, withdrew cash, and made purchases with the account’s check card. Many of the transactions occurred within the City and County of Denver, State of Colorado. Among those transactions, Bakhtiyorkhuja Mirzokhojaev deposited Firdavsi Urunov check #1092 for $3,000.00 at the ATM located at 999 S. Monaco Parkway on November 12, 2009. 7. All of the checks were returned, unpaid, to US Bank.

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8. As a result of the fraudulent activity, US Bank, with Colorado headquarters located at 950 17th Street, City and County of Denver, State of Colorado, suffered a loss of approximately $8,600.00.

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COUNT EIGHT THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including September 22, 2009 and December 14, 2009, at and triable in the City and County of Denver, State of Colorado, FIRUZI SHARIFI, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive WELLS FARGO BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 8 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about September 22, 2009, in association with the enterprise, Firuzi Sharifi opened Wachovia Bank checking account #1010231864800. Firuzi Sharifi used a Tajik passport, #T486854, as identification documents when he opened the account. Firuzi Sharifi listed 4600 E. Kentucky Avenue, #508, Denver, Colorado 80246, as his home address. Wachovia was later subsumed by Wells Fargo Bank, and the account became a Wells Fargo Bank account with the same number. 3. Between September 22, 2009 and December 14, 2009, Firuzi Sharifi, in association with the enterprise, transacted Somon Corporation checks through his Wells Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Many of the transactions occurred within the City and County of Denver, State of Colorado. Among those transactions, Firuzi Sharifi deposited $6,700.00 cash at the branch located at 7150 Leetsdale Drive on December 9, 2009. This cash deposit inflated the apparent balance of the account. Within a few hours of making that deposit, Firuzi Sharifi cashed two fraudulent Somon Corporation checks for more than $9,000.00, and withdrew $6,200.00 cash . 4. All of the checks were returned, unpaid, to Wells Fargo Bank. 5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of approximately $8,500.00.

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COUNT NINE THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including October 7, 2009 and November 17, 2009, at and triable in the City and County of Denver, State of Colorado, FIRDAVSI URUNOV, BAKHTIYOR KADIROV, and BAKHTIYORKHUJA MIRZOKHOJAEV unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive WELLS FARGO BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 9 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about October 7, 2009, Bakhtiyorkhuja Mirzokhojaev, in association with the enterprise and under the direction of Firdavsi Urunov, opened Wells Fargo Bank checking account #9372998105 at the Northglenn branch, 10701 Melody Drive, Northglenn, Adams County, Colorado. Bakhtiyorkhuja Mirzokhojaev used a Tajik passport, #T490783, as an identification document when he opened the account. Bakhtiyorkhuja Mirzokhojaev listed 2880 S. Federal Blvd. #305, Denver, Colorado 80236, as his home address. 3. Bakhtiyor Kadirov, in association with the enterprise, opened Key Bank checking account, #760102039855, and gave checks from that account to other enterprise members to use for fraudulent transactions. Bakhtiyor Kadirov listed 7005 Leetsdale Drive #A26, Denver, Colorado, 80224 as his home address for that account. 4. Between October 7, 2009 and November 17, 2009, Bakhtiyorkhuja Mirzokhojaev, in association with the enterprise, transacted checks from Bakhtiyor Kadirov through his Wells Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Many of the transactions occurred within the City and County of Denver, State of Colorado. Among those transactions, Bakhtiyorkhuja Mirzokhojaev withdrew $2,500.00 at the Wells Fargo Bank branch located at 1001 S. Monaco Parkway on November 13, 2009. 5. All of the checks were returned, unpaid, to Wells Fargo Bank. 6. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of approximately $5,000.00.

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COUNT TEN THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including November 10, 2009 and December 15, 2009, at and triable in the City and County of Denver, State of Colorado, DMITRIY ORLOVSKIY, and OBID VAPAEV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of JP MORGAN CHASE BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive JP MORGAN CHASE BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive JP MORGAN CHASE BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S

The facts supporting Count 10 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about November 10, 2009, in association with the enterprise, Dmitriy Orlovskiy opened JP Morgan Chase Bank account #638948503. Dmitriy Orlovskiy used a Permanent Resident Card (“Green card”), #A071160539, and Colorado Driver’s License #09-187-0233 as identification documents when he opened the account. Dmitriy Orlovskiy listed his home address for the account as 11275 E. Alameda Avenue, #4, Aurora, Colorado, 80012-1007. 3. Obid Vapaev, in association with the enterprise, opened Wachovia checking account, #1010232795127, and gave checks from that account to other enterprise members to use for fraudulent transactions. Obid Vapaev listed 7005 Leetsdale Drive #A26, Denver, Colorado, 80224 as his home address for that account. 4. On or about September 2, 2009, in association with the enterprise, Obid Vapaev opened TCF Bank checking account #9877283603. Obid Vapaev used a Russian passport, #0663114 as an identification document when he opened the account. Obid Vapaev listed his address as 7005 Leetsdale Drive #A26, Denver, Colorado, 80224. 5. Between November 10, 2009 and December 15, 2009, Dmitriy Orlovskiy, in association with Obid Vapaev and the enterprise, transacted Obid Vapaev TCF Bank and Wachovia checks through his JP Morgan Chase Bank account, withdrew cash, and made purchases with the account’s check card. Many of the transactions occurred within the City and County of Denver, State of Colorado. Among those transactions, withdrawals were made from the account at 2757 North Speer Boulevard on November 23, 2009. 6. The Obid Vapaev TCF and Wachovia checks were returned, unpaid, to JP Morgan Chase Bank. 7. As a result of the fraudulent activity, JP Morgan Chase Bank suffered a loss of approximately $3,900.00.

15

COUNT ELEVEN

THEFT, 18-4-401(1),(2)(b.5) C.R.S. (M1) <0801T> Between and including November 10, 2009 and December 28, 2009, at and triable in the City and County of Denver, State of Colorado, DMITRIY ORLOVSKIY and OBID VAPAEV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of KEY BANK, with the value of five hundred dollars or more but less than one thousand dollars, without authorization, or by threat or deception, and intended to deprive KEY BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive KEY BANK, of its use or benefit; in violation of section 18-4-401(1),(2)(b.5) C.R.S. The facts supporting Count 11 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about November 10, 2009, Dmitriy Orlovskiy, in association with the enterprise, opened Key Bank account #766492006131 at the Key Bank located at 829 16th Street, City and County of Denver, State of Colorado. Dmitriy Orlovskiy used a Permanent Resident Card (“green card”), #A071160539, and Colorado Driver’s License #09-187-0233 as identification documents when he opened the account. Dmitriy Orlovskiy listed his home address for the account as 1001 16th Street #301, Denver, CO 80265. 3. Obid Vapaev, in association with the enterprise, opened Wells Fargo Bank checking account, #7885981220, and gave checks from that account to other enterprise members to use for fraudulent transactions. Obid Vapaev listed his home address for that account as 11275 E. Alameda Avenue, #4, Aurora, Colorado, 80012-1007. 4. Between November 10, 2009 and December 28, 2009, Dmitriy Orlovskiy, in association with Obid Vapaev and the enterprise, transacted Obid Vapaev Wells Fargo Bank checks through his Key Bank account, withdrew cash, and made purchases with the account’s check card. Many of the transactions occurred within the City and County of Denver, State of Colorado. Among those transactions, Dmitriy Orlovskiy cashed Obid Vapaev check #152 for $450.00 at the Key Bank located at 1675 Broadway on December 12, 2009. 5. The Obid Vapaev checks were returned, unpaid, to Key Bank. 6. As a result of the fraudulent activity, Key Bank suffered a loss of $944.45.

16

COUNT TWELVE THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including November 30, 2009 and March 4, 2010, at and triable in the City and County of Denver, State of Colorado, AZIMDZHON MAZHIDOV and SHODMON BILOLOV unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive WELLS FARGO BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

COUNT THIRTEEN FORGERY, 18-5-102(1)(c) C.R.S. (F5) <1001C> On or about February 3, 2010, at and triable in the City and County of Denver, State of Colorado, AZIMDZHON MAZHIDOV, with the intent to defraud WALKER STAPLETON and WELLS FARGO BANK, unlawfully, feloniously, and falsely made, completed, altered, or uttered a written instrument which was or which purported to be, or which was calculated to become or to represent if completed, CHECK #371 of WALKER STAPLETON in violation of section 18-5-102(1)(c), C.R.S. The facts supporting Counts 12 and 13 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about November 30, 2009, Shodmon Bilolov, in association with the enterprise, opened Wells Fargo Bank checking account #8736111520 at the Englewood branch, 3333 S. Bannock Street, Englewood, Arapahoe County, Colorado. Shodmon Bilolov used a Colorado Driver’s License, #08-107-0943, as an identification document when he opened the account. Shodmon Bilolov listed his home address for the account as 1306 S. Parker Road, Denver, CO 80231-2150. 3. Between November 30, 2009 and March 4, 2010, Shodmon Bilolov and Azimdzhon Mazhidov, in association with the enterprise, transacted Somon Corporation checks through Shodmon Bilolov’s Wells Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Many of the transactions occurred within the City and County of Denver, State of Colorado. Among those transactions, Shodmon Bilolov and Azimdzhon Mazhidov deposited Somon Corporation check #1028 for $3,200.00 and withdrew $3,200.00 in cash at the branch located at 2043 S. Colorado Boulevard on February 6, 2010. 4. On February 3, 2010, Azimdzhon Mazhidov, in association with the enterprise, identified himself as Shodmon Bilolov and cashed a stolen check from the account of Walker Stapleton (check #371) for $4,500.00 at the branch located at 2043 S. Colorado Boulevard, located within the City and County of Denver, State of Colorado.

17

5. All of the checks were returned, unpaid, to Wells Fargo Bank. 6. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of approximately $4,500.00.

18

COUNT FOURTEEN THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including December 31, 2009 and April 6, 2010, at and triable in the City and County of Denver, State of Colorado, FIRUZI SHARIFI, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive WELLS FARGO BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

COUNT FIFTEEN CRIMINAL IMPERSONATION, 18-5-113(1)(e) C.R.S. (F6) <1011A> Between and including December 31, 2009 and April 6, 2010, at and triable in the City and County of Denver, State of Colorado, FIRUZI SHARIFI, unlawfully, feloniously, and knowingly assumed a false or fictitious identity or capacity, namely: SHOKHIN T. KHAKIMOV, and in such identity or capacity did an act with intent to unlawfully gain a benefit for himself or another or to injure or defraud another; in violation of section 18-5-113(1)(e), C.R.S. The facts supporting Counts 14 and 15 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about December 31, 2009, a person using the name “Shokhin T. Khakimov,” in association with the enterprise, opened Wells Fargo Bank checking account #9200909720 at the Monaco branch, 1001 S. Monaco Parkway, City and County of Denver, State of Colorado. A counterfeit Tajik passport, #T455249 in that name was used as an identification document when the account was opened. “Shokhin T. Khakimov” listed his home address for the account as 7474 E. Arkansas Avenue #1005, Denver, CO 80231-2540. The address was later changed by the account holder to 875 S. Dexter Street #309, Denver, CO 80246-2126. 3. Between December 31, 2009 and April 6, 2010, Firuzi Sharifi, using the name “Shokhin T. Khakimov,” transacted Payravi Fraydin checks through his Wells Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Among those transactions, Firuzi Sharifi deposited Payravi Fraydin check #175 for $2,700.00 at the ATM located at 1001 S. Monaco Parkway, City and County of Denver, State of Colorado, on March 4, 2010. 4. All of the checks were returned, unpaid, to Wells Fargo Bank. 5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of approximately $9,000.00.

19

COUNT SIXTEEN THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including January 12, 2010 and February 11, 2010, at and triable in the City and County of Denver, State of Colorado, KHISRAV CHUTOV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive WELLS FARGO BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 16 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about January 12, 2010, Khisrav Chutov, in association with the enterprise, opened Wells Fargo Bank checking account #3013338714 at the Leetsdale branch, 7150 Leetsdale Drive, City and County of Denver, State of Colorado. Khisrav Chutov used a Colorado Driver’s License, #08-017-0799, as an identification document when he opened the account. Khisrav Chutov listed his home address for the account as 860 S. Oneida Street #C107, Denver, CO 80224-1725. 3. Between January 12, 2010 and February 11, 2010, Khisrav Chutov, in association with the enterprise, transacted Somon Corporation checks through his Wells Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Many of the transactions occurred within the City and County of Denver, State of Colorado. Among those transactions, Khisrav Chutov withdrew $1,900.00 in cash at the branch located at 8980 E. Hampden Avenue on January 22, 2010. 4. All of the checks were returned, unpaid, to Wells Fargo Bank. 5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of approximately $7,500.00.

20

COUNT SEVENTEEN THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including January 16, 2010 and February 8, 2010, at and triable in the City and County of Denver, State of Colorado, FIRUZI SHARIFI and BOBOKALON SHARIPOV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive WELLS FARGO BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

COUNT EIGHTEEN CRIMINAL IMPERSONATION, 18-5-113(1)(e) C.R.S. (F6) <1011A> Between and including January 16, 2010 and February 8, 2010, at and triable in the City and County of Denver, State of Colorado, BOBOKALON SHARIPOV, unlawfully, feloniously, and knowingly assumed a false or fictitious identity or capacity, namely: BUNYOD RUZIEV, and in such identity or capacity did an act with intent to unlawfully gain a benefit for himself or another or to injure or defraud another; in violation of section 18-5-113(1)(e), C.R.S.

The facts supporting Counts 17 and 18 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about January 16, 2010, a person using the name “Bunyod Ruziev,” in association with the enterprise, opened Wells Fargo Bank checking account #1278481302 at the Aurora South branch, 2550 S. Parker Road, Aurora, Arapahoe County, Colorado. A Tajik passport, #T298015 in that name was used as an identification document when the account was opened. “Bunyod Ruziev” listed his home address for the account as 1045 S. Dahlia Street #B6, Denver, CO 80246-2815. 3. Firuzi Sharifi, in association with the enterprise, opened US Bank checking account #103679448797 and gave checks from that account to other enterprise members to use for fraudulent transactions. 4. Between January 16, 2009 and February 8, 2010, Bobokalon Sharipov, using the name “Bunyod Ruziev,” transacted Murado Dental and Firuzi Sharifi checks through the Wells Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Among those transactions, Bobokalon Sharipov withdrew $200.00 from the ATM located at 1001 S. Monaco Parkway, City and County of Denver, State of Colorado, on February 5, 2010. 5. All of the checks were returned, unpaid, to Wells Fargo Bank.

21

6. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of approximately $8,800.00.

22

COUNT NINETEEN THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including February 15, 2010 and April 6, 2010, at and triable in the City and County of Denver, State of Colorado, BOBOKALON SHARIPOV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive WELLS FARGO BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

COUNT TWENTY CRIMINAL IMPERSONATION, 18-5-113(1)(e) C.R.S. (F6) <1011A> Between and including February 15, 2010 and April 6, 2010, at and triable in the City and County of Denver, State of Colorado, BOBOKALON SHARIPOV, unlawfully, feloniously, and knowingly assumed a false or fictitious identity or capacity, namely: NUSHERVON KALANDAROV, and in such identity or capacity did an act with intent to unlawfully gain a benefit for himself or another or to injure or defraud another; in violation of section 18-5-113(1)(e), C.R.S. The facts supporting Counts 19 and 20 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about February 15, 2010, a person using the name “Nushervon Kalandarov,” in association with the enterprise, opened Wells Fargo Bank checking account #7913708751 at the Aurora South branch, 2550 S. Parker Road, Aurora, Arapahoe County, Colorado. A Tajik passport, #T581630, in that name was used as an identification document when the account was opened. “Nushervon Kalandarov” listed his home address for the account as 1039 S. Parker Road #U7, Denver, CO 80231-7801. 3. Between February 15, 2010 and April 6, 2010, Bobokalon Sharipov, using the name “Nushervon Kalandarov,” transacted Payravi Fraydin checks through the Wells Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Among those transactions, Bobokalon Sharipov withdrew $6,000.00 cash from the branch located at 8980 E. Hampden Avenue, City and County of Denver, State of Colorado, on March 16, 2010. 4. All of the checks were returned, unpaid, to Wells Fargo Bank. 5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of approximately $4,900.00.

COUNT TWENTY-ONE

23

THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including February 17, 2010 and March 22, 2010, at and triable in the City and County of Denver, State of Colorado, FIRUZI SHARIFI, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive WELLS FARGO BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

COUNT TWENTY-TWO

CRIMINAL IMPERSONATION, 18-5-113(1)(e) C.R.S. (F6) <1011A> Between and including February 17, 2010 and March 22, 2010, at and triable in the City and County of Denver, State of Colorado, FIRUZI SHARIFI, unlawfully, feloniously, and knowingly assumed a false or fictitious identity or capacity, namely: FARIZ BURIEV, and in such identity or capacity did an act with intent to unlawfully gain a benefit for himself or another or to injure or defraud another; in violation of section 18-5-113(1)(e), C.R.S.

The facts supporting Counts 21 and 22 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about February 17, 2010, a person using the name “Fariz Buriev,” in association with the enterprise, opened Wells Fargo Bank checking account #3547799787 at the Englewood branch, 3333 S. Bannock Street, Englewood, Arapahoe County, Colorado. A Tajik passport, #T441101 in that name was used as an identification document when the account was opened. “Fariz Buriev” listed his home address for the account as 1039 S. Parker Road #U7, Denver, CO 80231-7801. 3. Between February 17, 2010 and March 22, 2010, Firuzi Sharifi, using the name “Fariz Buriev,” transacted Nushervon Kalandarov checks through the Wells Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Among those transactions, Firuzi Sharifi withdrew $1,000.00 cash from the branch located at 2500 E. 2nd Avenue, City and County of Denver, State of Colorado, on March 9, 2010. 4. All of the checks were returned, unpaid, to Wells Fargo Bank. 5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of approximately $2,900.00.

24

COUNT TWENTY-THREE THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including February 17, 2010 and April 8, 2010, at and triable in the City and County of Denver, State of Colorado, MAKHMADRIZO KHOLOV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of JP MORGAN CHASE BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive JP MORGAN CHASE BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive JP MORGAN CHASE BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 23 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about February 17, 2010, Makhmadrizo Kholov, in association with the enterprise, opened JP Morgan Chase Bank checking account #878533389 at the Brighton Beach, New York, branch, located at 722 Brighton Beach Avenue, Brooklyn, Kings County, State of New York. Makhmadrizo Kholov used a Tajik passport, #T167698, and a Maryland Driver’s License, #K410578008919, as identification documents when he opened the account. Makhmadrizo Kholov listed his home address for the account as 3009 Fallstaff Road #K, Baltimore, MD, 21209-2955. 3. Between February 17, 2010 and April 8, 2010, Makhmadrizo Kholov, in association with the enterprise, transacted Ravshon Muradov checks through his JP Morgan Chase Bank account, withdrew cash, and made purchases with the account’s check card. Many of the transactions occurred within the City and County of Denver, State of Colorado. Among those transactions, Makhmadrizo Kholov cashed Ravshon Muradov check #1136 for $7,200.00 at the branch located at 1125 17th Street on April 6, 2010. 4. All of the checks were returned, unpaid, to JP Morgan Chase Bank. 5. As a result of the fraudulent activity, JP Morgan Chase Bank, suffered a loss of approximately $7,300.00.

25

COUNT TWENTY-FOUR THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including February 18, 2010 and April 8, 2010, at and triable in the City and County of Denver, State of Colorado, FIRUZI SHARIFI and AZIM GOLUBOV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of JP MORGAN CHASE BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive JP MORGAN CHASE BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive JP MORGAN CHASE BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S. The facts supporting Count 24 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about February 18, 2010, Azim Golubov, in association with the enterprise, opened JP Morgan Chase Bank checking account #881903835 at the Rego Park, New York, branch, located at 9538 Queens Boulevard, Rego Park, Queens County, State of New York. Azim Golubov used a Tajik passport, #N817088, and a Georgia Driver’s License, #056572824, as identification documents when he opened the account. Azim Golubov listed his home address for the account as 4112 Crowder Drive NW, Kennesaw, GA 30152-6446. 3. Firuzi Sharifi, in association with the enterprise, opened US Bank checking account #103679448797 and gave checks from that account to other enterprise members to use for fraudulent transactions. 4. Azim Golubov, in association with the enterprise, cashed a Nushervon Kalandarov check for $4,700.00 on March 22, 2010, at the JP Morgan Chase Bank branch located at 4704 Harlan Street, Lakeside, Jefferson County, Colorado. 5. Between February 18, 2010 and April 8, 2010, Azim Golubov and Firuzi Sharifi transacted Nushervon Kalandarovl and Firuzi Sharifi checks through Azim Golubov’s JP Morgan Chase Bank account, withdrew cash, and made purchases with the account’s check card. Many of the transactions took place within the City and County of Denver, State of Colorado. Among those transactions, Firuzi Sharifi deposited Nushervon Kalandarov check #1080 for $4,100.00 at the ATM located at 100 Detroit Street, on March 23, 2010. 6. All of the checks were returned, unpaid, to JP Morgan Chase Bank. 7. As a result of the fraudulent activity, JP Morgan Chase Bank suffered a loss of approximately $4,800.00.

26

COUNT TWENTY-FIVE THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including February 20, 2010 and March 25, 2010, at and triable in the City and County of Denver, State of Colorado, FIRUZI SHARIFI, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive WELLS FARGO BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

COUNT TWENTY-SIX CRIMINAL IMPERSONATION, 18-5-113(1)(e) C.R.S. (F6) <1011A> Between and including February 20, 2010 and March 25, 2010, at and triable in the City and County of Denver, State of Colorado, FIRUZI SHARIFI, unlawfully, feloniously, and knowingly assumed a false or fictitious identity or capacity, namely: FARRUH ODILOV, and in such identity or capacity did an act with intent to unlawfully gain a benefit for himself or another or to injure or defraud another; in violation of section 18-5-113(1)(e), C.R.S.

The facts supporting Counts 25 and 26 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about February 20, 2010, a person using the name “Farruh Odilov,” in association with the enterprise, opened Wells Fargo Bank checking account #3547799787 at the Downing Street branch, 2150 S. Downing Street, City and County of Denver, State of Colorado. An Uzbek passport, #CB1951500 in that name was used as an identification document when the account was opened. “Farruh Odilov” listed his home address for the account as 878 S. Oneida Street #J114, Denver, CO 80224-1783. 3. Between February 20, 2010 and March 25, 2010, Firuzi Sharifi, using the name “Farruh Odilov,” transacted Payravi Fraydin checks through the Wells Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Among those transactions, Firuzi Sharifi withdrew $1,800.00 cash from the branch located at 2043 S. Colorado Boulevard, City and County of Denver, State of Colorado, on March 6, 2010. 4. All of the checks were returned, unpaid, to Wells Fargo Bank. 5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of approximately $11,200.00.

27

COUNT TWENTY-SEVEN THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including February 22, 2010 and April 20, 2010, at and triable in the City and County of Denver, State of Colorado, AZIMDZHON MAZHIDOV and FARIDUM JABBOROV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of JP MORGAN CHASE BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive JP MORGAN CHASE BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive JP MORGAN CHASE BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 27 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about February 22, 2010, a person using the name “Azim Golubov,” in association with the enterprise, opened Wells Fargo Bank checking account #3215826068 at the Cherry Creek branch, 1st Avenue and Steele Street, City and County of Denver, State of Colorado. “Azim Golubov” used a Tajik passport, #58729086, and a Georgia Driver’s License, #056572824, as identification documents when he opened the account. “Azim Golubov” listed his home address for the account as 1039 S. Parker Road #4-07, Denver, CO 80231-2532. 3. Between February 22, 2010 and April 20, 2010, Azimdzhon Mazhidov and Faridum Jabborov, in association with the enterprise, transacted Rob & Max Corporation and Nushervon Kalandarov checks through “Azim Golubov’s” Wells Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Many of the transactions occurred within the City and County of Denver, State of Colorado. Among those transactions, Azimdzhon Mazhidov and Faridum Jabborov deposited Nushervon Kalandarov check #1061 for $4,200.00 at the branch located at 8980 E. Hampden Avenue on March 8, 2010. On March 9, 2010, Faridum Jabborov cashed Nushervon Kalandarov check #1063 for $1,100.00 at the branch located at 2500 E. 2nd Avenue. 4. All of the checks were returned, unpaid, to Wells Fargo Bank. 5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of approximately $7,800.00.

28

COUNT TWENTY-EIGHT THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including March 10, 2010 and April 26, 2010, at and triable in the City and County of Denver, State of Colorado, BOBOKALON SHARIPOV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive WELLS FARGO BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

COUNT TWENTY-NINE CRIMINAL IMPERSONATION, 18-5-113(1)(e) C.R.S. (F6) <1011A> Between and including March 10, 2010 and April 26, 2010, at and triable in the City and County of Denver, State of Colorado, BOBOKALON SHARIPOV, unlawfully, feloniously, and knowingly assumed a false or fictitious identity or capacity, namely: PARVIZ Y. ESHONZHONOV, and in such identity or capacity did an act with intent to unlawfully gain a benefit for himself or another or to injure or defraud another; in violation of section 18-5-113(1)(e), C.R.S. The facts supporting Counts 28 and 29 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about March 10, 2010, a person using the name “Parviz Y. Eshonzhonov,” in association with the enterprise, opened Wells Fargo Bank checking account #873626078 at the branch located at 2043 S. Colorado Boulevard, City and County of Denver, State of Colorado. A Tajik passport, #T959518, in that name was used as an identification document when the account was opened. “Parviz Y. Eshonzhonov” listed his home address for the account as 7535 E. Harvard Avenue #201, Denver, CO 80231-6732. 3. Between March 10, 2010 and April 26, 2010, Bobokalon Sharipov, using the name “Parviz Y. Eshonzhonov,” transacted Nushervon Kalandarov checks through the Wells Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Among those transactions, Bobokalon Sharipov cashed Nushervon Kalandarov check #1082 for $4,600.00 at the branch located at 2164 35th Avenue, Greeley, Weld County, Colorado, on March 25, 2010. 4. All of the checks were returned, unpaid, to Wells Fargo Bank. 5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of approximately $8,800.00.

29

COUNT THIRTY

THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including March 11, 2010 and April 13, 2010, at and triable in the City and County of Denver, State of Colorado, PARVIZ CHORSANBIEV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of JP MORGAN CHASE BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive JP MORGAN CHASE BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive JP MORGAN CHASE BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 30 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about March 11, 2010, Parviz Chorsanbiev, in association with the enterprise, opened JP Morgan Chase Bank checking account #895141174 at the Villa Monaco branch, 2223 S. Monaco Parkway, City and County of Denver, State of Colorado. Parviz Chorsanbiev used a Tajik passport, #T492199, as identification document when he opened the account. Parviz Chorsanbiev listed his home address for the account as 878 Oneida Street #J114, Denver, CO 80224-1783. 3. Between March 11, 2010 and April 13, 2010, Parviz Chorsanbiev, in association with the enterprise, transacted Nushervon Kalandarov checks through his JP Morgan Chase Bank account, withdrew cash, and made purchases with the account’s check card. Many of the transactions occurred within the City and County of Denver, State of Colorado. Among those transactions, Nushervon Kalandarov check #1089 for $3,700.00 was deposited at the ATM located at 2980 W. Evans Avenue on March 31, 2010. On that same day, Parviz Chorsanbiev withdrew $6,500.00 in cash from the branch located at 1301 Canyon Boulevard in Boulder, Colorado. 4. All of the checks were returned, unpaid, to JP Morgan Chase Bank. 5. As a result of the fraudulent activity, JP Morgan Chase Bank, suffered a loss of approximately $6,200.00.

30

COUNT THIRTY-ONE THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including March 12, 2010 and April 8, 2010, at and triable in the City and County of Denver, State of Colorado, FIRUZI SHARIFI and PARVIZ CHORSANBIEV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive WELLS FARGO BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 31 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about March 12, 2010, Parviz Chorsanbiev, in association with the enterprise, opened Wells Fargo Bank checking account #8073106752 at the branch located at 1601 Blake Street Suite 105, City and County of Denver, State of Colorado. A Tajik passport, #T959518 in that name was used as an identification document when the account was opened. Parviz Chorsanbiev listed his home address for the account as 1090 S. Parker Road #318, Denver, CO 80231-2010. 3. Between March 12, 2010 and April 8, 2010, Firuzi Sharifi and Parviz Chorsanbiev, in association with the enterprise, transacted Nushervon Kalandarov checks through the Wells Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Among those transactions, Parviz Chorsanbiev cashed Nushervon Kalandarov check #1085 for $5,100.00 at the branch located at 410 S. Cascade Avenue, Colorado Springs, El Paso County, Colorado, on March 30, 2010. 4. On March 30, 2010, Firuzi Sharifi withdrew $300.00 cash from the ATM located at 3155 E. 1st Avenue in the City and County of Denver, State of Colorado. 5. All of the checks were returned, unpaid, to Wells Fargo Bank. 6. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of approximately $9,600.00.

31

COUNT THIRTY-TWO CRIMINAL ATTEMPT TO COMMIT THEFT, 18-4-401(1),(2)(c); 18-2-101, C.R.S (F5) <0801UA> Between and including April 7, 2010, and May 27, 2010, at and triable in the City and County of Denver, State of Colorado, by engaging in conduct constituting a substantial step toward the commission of theft, KARIMDZHON MANSUROV, unlawfully, feloniously, and knowingly attempted to obtain or exercise control over a thing of value, namely: MONEY, of WELLS FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK permanently of its use or benefit; in violation of sections 18-4-401(1)(2)(c) and 18-2-101, C.R.S.

COUNT THIRTY-THREE FORGERY, 18-5-102(1)(c) C.R.S. (F5) <1001C> On or about May 7, 2010, at and triable in the City and County of Denver, State of Colorado, KARIMDZHON MANSUROV, with the intent to defraud WELLS FARGO BANK, unlawfully, feloniously, and falsely made, completed, altered, or uttered a written instrument which was or which purported to be, or which was calculated to become or to represent if completed, CHECK #1009 of MURADO DENTAL; in violation of section 18-5-102(1)(c), C.R.S.

COUNT THIRTY-FOUR

CRIMINAL IMPERSONATION, 18-5-113(1)(e) C.R.S. (F6) <1011A> Between and including April 7, 2010, and May 27, 2010, at and triable in the City and County of Denver, State of Colorado, KARIMDZHON MANSUROV, unlawfully, feloniously, and knowingly assumed a false or fictitious identity or capacity, namely: KARIMI MANSURRY, and in such identity or capacity did an act with intent to unlawfully gain a benefit for himself or another or to injure or defraud another; in violation of section 18-5-113(1)(e), C.R.S.

COUNT THIRTY-FIVE

POSSESSION OF FORGED INSTRUMENT, 18-5-105 C.R.S. (F6) <10040> On or about May 19, 2010, at and triable in the City and County of Denver, State of Colorado, KARIMDZHON MANSUROV, unlawfully and feloniously possessed a forged instrument, namely: PENNSYLVANIA DRIVER’S LICENSE #76350390 IN THE NAME OF KOMIL DZOGBESSI, with knowledge that it was forged and with intent to use the instrument to defraud; in violation of section 18-5-105, C.R.S.

32

COUNT THIRTY-SIX POSSESSION OF FORGED INSTRUMENT, 18-5-105 C.R.S. (F6) <10040> On or about May 19, 2010, at and triable in the City and County of Denver, State of Colorado, KARIMDZHON MANSUROV, unlawfully and feloniously possessed a forged instrument, namely: PENNSYLVANIA DRIVER’S LICENSE #44356389 IN THE NAME OF ELPID BERGANIO, with knowledge that it was forged and with intent to use the instrument to defraud; in violation of section 18-5-105, C.R.S. The facts supporting Counts 32 through 36 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about April 7, 2010, a person using the name “Karimi Mansurry,” in association with the enterprise, opened Wells Fargo Bank checking account #8430287378 at the Glendale branch located at 400 S. Colorado Boulevard, Glendale, Arapahoe County, State of Colorado. A Turkish passport, #A3767406, and a New Jersey Driver’s License, #M87831171086227, in that name was used as an identification document when the account was opened. “Karimi Mansurry” listed his home address for the account as 1039 S. Parker Road #Y03, Denver, CO 80231-2599. 3. Between April 7, 2010 and May 27, 2010, Karimdzhon Mansurov, using the name “Karimi Mansurry,” transacted Friendly Auto and Murado Dental checks through the Wells Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Many of those transactions took place at branches located within the City and County of Denver, State of Colorado. 4. On or about May 7, 2010 Karimdzhon Mansurov, using the name “Karim Mansurry,” attempted to cash Murado Dental check #1009 for $6,900.00 at the branch located at 635 Coffman Street, Longmont, Larimer County, Colorado. Karimdzhon Mansurov presented a counterfeit New Jersey driver’s license #M87831171086227 with his photo on it as identification when he tried to cash that check. Wells Fargo Bank personnel refused to cash the check and Karimdzhon Mansurov left the branch. 5. On or about May 19, 2010, Denver Police Officers contacted Karimdzhon Mansurov at 900 S. Quince Street, #B4-423 in the City and County of Denver, State of Colorado. Karimdzhon Mansurov had two counterfeit Pennsylvania driver’s licenses in his possession, #76350390 in the name of Komil Dzogbessi and #44356389 in the name of Elpid Berganio. Both counterfeit licenses bore Karimdzhon Mansurov’s photo. 6. On or about May 21, 2010, Wells Fargo Bank closed the “Karimi Mansurry” account and issued “Karimi Mansurry” a cashier’s check for the remaining balance of $7,417.56. Karimdzhon Mansurov, using the name “Karimi Mansurry”, cashed that check at 2043 S. Colorado Boulevard, in the City and County of Denver, State of Colorado, on May 27, 2010.

33

COUNT THIRTY-SEVEN

THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including May 10, 2010 and June 10, 2010, at and triable in the City and County of Denver, State of Colorado, AZIMDZHON MAZHIDOV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of JP MORGAN CHASE BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive JP MORGAN CHASE BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive JP MORGAN CHASE BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 37 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about May 10, 2010, Azimdzhon Mazhidov, in association with the enterprise, opened JP Morgan Chase Bank checking account #869651349 at a branch in the State of Colorado. Azimdzhon Mazhidov used a Tajik passport, #T167919, as identification document when he opened the account. Azimdzhon Mazhidov listed his home address for the account as 3001 S. Federal Boulevard, Denver, CO 80236-2711. 3. Between May 10, 2010 and June 10, 2010, Azimdzhon Mazhidov, in association with the enterprise, transacted Timuri Khuseyn checks through his JP Morgan Chase Bank account, withdrew cash, and made purchases with the account’s check card. Many of the transactions occurred within the City and County of Denver, State of Colorado. Among those transactions, Azimdzhon Mazhidov withdrew $7,150.00 in cash from the branch located at 2696 S. Colorado Boulevard on May 15, 2010. 4. All of the checks were returned, unpaid, to JP Morgan Chase Bank. 5. As a result of the fraudulent activity, JP Morgan Chase Bank, suffered a loss of approximately $6,500.00.

34

COUNT THIRTY-EIGHT

THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including May 15, 2010 and June 8, 2010, at and triable in the City and County of Denver, State of Colorado, NODIR KHODZHAEV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive WELLS FARGO BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 38 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about May 15, 2010, Nodir Khodzhaev, in association with the enterprise, opened Wells Fargo Bank checking account #2909452621 at the branch located at 7150 Leetsdale Drive, City and County of Denver, State of Colorado. A Colorado Driver’s License, #07-134-0874, in that name was used as an identification document when the account was opened. Nodir Khodzhaev listed his home address for the account as 1150 Syracuse Street #2-8, Denver, CO 80220-3236. 3. Between May 15, 2010 and June 8, 2010, Nodir Khodzhaev, in association with the enterprise, transacted Timuri Khuseyn checks through the Wells Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Among those transactions, Nodir Khodzhaev cashed Timuri Khuseyn check #1039 for $5,300.00 at the branch located at 1050 Ken Pratt Boulevard, Longmont, Larimer County, Colorado, on May 14, 2010. 4. All of the checks were returned, unpaid, to Wells Fargo Bank. 5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of approximately $17,100.00.

35

COUNT THIRTY-NINE THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including May 10, 2010 and June 8, 2010, at and triable in the City and County of Denver, State of Colorado, NODIR KHODZHAEV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of JP MORGAN CHASE BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive JP MORGAN CHASE BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive JP MORGAN CHASE BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 39 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about April 10, 2010, Nodir Khodzhaev, in association with the enterprise, opened JP Morgan Chase Bank checking account #877362459 at the branch located at 1627 S. Havana Street, Aurora, Arapahoe County, of Colorado. A Colorado Driver’s License, #07-134-0874, in that name was used as an identification document when the account was opened. Nodir Khodzhaev listed his home address for the account as 3001 S. Federal Boulevard #325, Denver, CO 80236-2711. 3. Between May 10, 2010 and June 8, 2010, Nodir Khodzhaev, in association with the enterprise, transacted Timuri Khuseyn checks through his JP Morgan Chase Bank account, withdrew cash, and made purchases with the account’s check card. Many of the transactions occurred within the City and County of Denver, State of Colorado. Among those transactions, Nodir Khodzhaev cashed Timuri Khuseyn check #1048 for $6,600.00 at the branch located at 100 Detroit Street on May 17, 2010. 4. All of the other checks were returned, unpaid, to JP Morgan Chase Bank. 5. As a result of the fraudulent activity, JP Morgan Chase Bank, suffered a loss of approximately $6,600.00.

36

COUNT FORTY THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including April 10, 2010 and June 8, 2010, at and triable in the City and County of Denver, State of Colorado, FIRUZI SHARIFI and MAKHMADRIZO KHOLOV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of JP MORGAN CHASE BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive JP MORGAN CHASE BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive JP MORGAN CHASE BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S. The facts supporting Count 40 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about April 10, 2010, a person using the name “Algirdas Zakarauskas” opened JP Morgan Chase Bank checking account #881903835 at the Rego Park, New York, branch, located at 9538 Queens Boulevard, Rego Park, Queens County, State of New York. “Algirdas Zakarauskas” used a Latvian passport, #705958, as an identification document to open the account. “Algirdas Zakarauskas” listed his home address for the account as 10106 Martense Avenue #4, Corona, NY 11368-7800. 3. Between April 10, 2010 and June 8, 2010, Firuzi Sharifi and Makhmadrizo Kholov, in association with the enterprise, transacted Timuri Khuseyn, Payravi Fraydin and Ravshon Muradov checks through the “Algirdas Zakarauskas” JP Morgan Chase Bank account and withdrew cash. Some of the fraudulent transactions took place within the City and County of Denver, State of Colorado. Among those transactions, Firuzi Sharifi cashed Timuri Khuseyn check #1036 for $7,500.00 at the branch located at 747 S. Colorado Boulevard on May 14, 2010. On May 15, 2010, Firuzi Sharifi and Makhmadrizo Kholov deposited Ravshon Muradov check #1140 for $3,900.00 at the ATM located at 100 Detroit Street. 4. All of the checks were returned, unpaid, to JP Morgan Chase Bank. 5. As a result of the fraudulent activity, JP Morgan Chase Bank suffered a loss of approximately $8,200.00.

37

COUNT FORTY-ONE

THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> Between and including April 27, 2010 and July 15, 2010, at and triable in the City and County of Denver, State of Colorado, MAKHMADRIZO KHOLOV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: MONEY of JP MORGAN CHASE BANK, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive JP MORGAN CHASE BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to permanently deprive JP MORGAN CHASE BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 41 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. On or about April 27, 2010, a person using the name “Biloliddin Lashkarov” opened JP Morgan Chase Bank checking account #889196747 at the Bensonhurst Bay, New York, branch, located at 8418 Bay Parkway, Brooklyn, State of New York. “Biloliddin Lashkarov” used a Tajik passport, #T075400, as an identification document to open the account. “Biloliddin Lashkarov” listed his home address for the account as 10106 Martense Avenue #4, Corona, NY 11368-7800. 3. Between April 27, 2010 and July 15, 2010, Makhmadrizo Kholov, in association with the enterprise, transacted Elena Loganova and Timuri Khuseyn checks through the “Biloliddin Lashkarov” JP Morgan Chase Bank account, and withdrew cash. Some of the fraudulent transactions took place within the City and County of Denver, State of Colorado. Among those transactions, Makhmadrizo Kholov deposited Elena Logvanova check #130 for $4,600.00 at the ATM located at 2696 S. Colorado Boulevard on June 25, 2010. 4. On or about June 25, 2010, Makhmadrizo Kholov cashed Elena Logvanova check #129 for $6,900.00 at the JP Morgan Chase Bank branch located at 10414 Town Center Drive, Westminster, Colorado. 5. All of the checks were returned, unpaid, to JP Morgan Chase Bank. 6. As a result of the fraudulent activity, JP Morgan Chase Bank suffered a loss of approximately $7,200.00.