COLORADO STATE GRAND JURY INDICTMENT

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1 DISTRICT COURT, CITY AND COUNTY OF DENVER, COLORADO 1437 Bannock Street Denver, CO THE PEOPLE OF THE STATE OF COLORADO, v. JOSEPH HOPPER (A.K.A. JOEY HOPS ) DARA WHEATLEY (A.K.A. BOSS LADY ) ADAM DONALDSON (A.K.A. POPS, POPZ ) JOSEPH SERGIO CRIVICI (A.K.A. JOSEPH CRAVICI ) HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP ) DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX ) NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE ) VICTORIA FERNANDEZ (A.K.A. TORI ) MARCEE SMITH (A.K.A. MARLEY ) ALEJANDRA GONZALEZ (A.K.A. ALE ) RAYLENE RUBIO (A.K.A. RAY, RAE, RAYLEEN, RAYLEAN ) NICOLE SANDOVAL (A.K.A. NIKKI ) ASHLEY HEFNER MELISSA COLMUS Defendants. CYNTHIA COFFMAN, Attorney General MICHAEL W. MELITO Senior Assistant Attorney General 1300 Broadway, 9 th Floor Denver, CO Reg. No COURT USE ONLY Grand Jury Case No.: 16CR01 Ctrm: 259 JON W. IPPOLITO Special Assistant Attorney General 105 E. Vermijo Ave. Colorado Springs, CO (719) Reg. No ANDREW S. VAUGHAN Special Assistant Attorney General 105 E. Vermijo Ave. Colorado Springs, CO (719) Reg. No COLORADO STATE GRAND JURY INDICTMENT Of the term of the Denver District Court in the year 2017; the Colorado State Grand Jurors, chosen, selected and sworn in the name and by the authority of the People of the State of Colorado, upon their oaths, present the following:

2 COUNT 1 COUNT 2 Violation of the Colorado Organized Crime Control Act Pattern of Racketeering- Participation in Enterprise, (3) and , C.R.S. (F2) Violation of the Colorado Organized Crime Control Act Conspiracy/Endeavoring, (4), C.R.S. (F2) COUNT 3 Violation of the Colorado Organized Crime Control Act Pattern of Racketeering Acquire Interest in Enterprise, (2) C.R.S. (F2) COUNT 4 Distribution Of Marijuana (50 LBS) or Marijuana Concentrate (25 LBS), (2)(B)(I),(III)(A), C.R.S. (DF1) 8802P COUNT 5 COUNT 6 COUNT 7 COUNT 8 COUNT 9 COUNT 10 COUNT 11 COUNT 12 COUNT 13 COUNT 14 COUNT 15 Possession with Intent to Manufacture or Distribute Marijuana (50 LBS) or Marijuana Concentrate (25 LBS), (2)(B)(I),(III)(A), C.R.S. (DF1) 8802U Conspiracy to Distribute, or Possess with Intent to Manufacture or Distribute, Marijuana (50 LBS) or Marijuana Concentrate (25LBS), (2)(B)(I),(III)(A), C.R.S. (DF1) 8802Z Money Laundering Conduct Financial Transaction with Intent to Promote Crime, (1)(A)(I), C.R.S. (F3) Conspiracy to Commit Money Laundering Conduct Financial Transaction with Intent to Promote Crime, (1)(A)(I) and , C.R.S. (F4) CON Money Laundering Transfer Monetary Instrument with Intent to Promote Crime, (1)(B)(I), C.R.S. (F3) Conspiracy to Commit Money Laundering Transfer Monetary Instrument with Intent to Promote Crime, (1)(B)(I) and , C.R.S. (F4) CON Keeping Property for Unlawful Distribution of Controlled Substances, (1), C.R.S. (DM1) Evasion of Taxes Administered by the Colorado Department of Revenue, (1), C.R.S. (F5) Conspiracy to Commit Evasion of Taxes Administered by the Colorado Department of Revenue, (1) and , C.R.S. (F6) CON Evasion of Taxes Administered by the Colorado Department of Revenue, (1), C.R.S. (F5) Conspiracy to Commit Evasion of Taxes Administered by the Colorado Department of Revenue, (1) and , C.R.S. (F6) CON COUNT 16 Failure to File Return or Pay Tax, (3), C.R.S. (M) COUNT 17 Filing a False Tax Return, (4), C.R.S. (F5) COUNT 18 Forgery, (1)(C), C.R.S. (F5) 2

3 COUNT 19 Attempt To Influence A Public Servant, , C.R.S. (F4) COUNT 20 Attempt To Influence A Public Servant, , C.R.S. (F4) COUNT 21 Attempt To Influence A Public Servant, , C.R.S. (F4) COUNT 22 Attempt To Influence A Public Servant, , C.R.S. (F4) COUNT 23 COUNT 24 COUNT 25 Special Offender Conspiracy Pattern of Sale, (1)(b), C.R.S. (DF-1) 33A43 Special Offender Organizer in Series of Violations with Others, (1)(F), C.R.S. (DF1) 33A48 Special Offender Firearm, C.R.S (1)(d)(II), C.R.S. (DF1) 33A45 COUNT 26 Filing a False Tax Return, (4), C.R.S. (F5) COUNT 27 Evasion of Taxes Administered by the Colorado Department of Revenue, (1), C.R.S. (F5)

4 INDEX OF DEFENDANTS Defendant Date of Birth Counts DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, 03/22/1989 1,2,4-16, 25 PHOENIXX UGRILLA, PHEONUAX ) NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY 01/11/1980 1,2,4-16, 25 LEONE, FRANKIE, NATE ) MELISSA COLMUS 01/18/1984 1,2,4-16, 18 JOSEPH SERGIO CRIVICI (A.K.A. JOSEPH 11/25/ , 20, 23, 24 CRAVICI ) ADAM DONALDSON (A.K.A. POPS, POPZ ) 06/23/ , 23, 24 VICTORIA FERNANDEZ (A.K.A. TORI ) 02/07/1995 1,2,4-16, 18, 21 ALEJANDRA GONZALEZ (A.K.A. ALE ) 3/18/1995 1,2,4-16, 18 ASHLEY HEFNER 04/25/1988 1,2,4-16, 18, 22 JOSEPH HOPPER (A.K.A. JOEY HOPS ) 06/16/ , 18, 23, 24 HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A N/A 1-18, 20 MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP ) RAYLENE RUBIO (A.K.A. RAY, RAE, 02/07/1995 1,2,4-16, 19 RAYLEEN, RAYLEAN ) NICOLE SANDOVAL (A.K.A. NIKKI ) 10/13/1995 1,2,4-16, 18, 21 MARCEE SMITH (A.K.A. MARLEY ) 03/27/1994 1,2,4-16, 18 DARA WHEATLEY (A.K.A. BOSS LADY ) 12/16/ , 23, 24, 26, 27 4

5 COUNT 1 Violation of the Colorado Organized Crime Control Act Pattern of Racketeering- Participation in Enterprise, (3) and , C.R.S. (F2) On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX ), NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE ), VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH (A.K.A. MARLEY ), ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS and others known and unknown to the Grand Jury, 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 (3) and , C.R.S. (F2), and against the peace and dignity of the People of the State of Colorado. COUNT 2 Violation of the Colorado Organized Crime Control Act Conspiracy/Endeavoring, (4), C.R.S. (F2) On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX ), NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE ), VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH (A.K.A. MARLEY ), ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS and others known and unknown to the Grand Jury did unlawfully, knowingly, and feloniously conspire to conduct and participate, directly or indirectly, in an enterprise, through a pattern of racketeering activity in violation of C.R.S (4) and (3), C.R.S. (F2), and against the peace and dignity of the People of the State of Colorado. COUNT 3 Violation of the Colorado Organized Crime Control Act Pattern of Racketeering Acquire Interest in Enterprise, (2) C.R.S. (F2) On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP) and others known and unknown to the Grand Jury, did unlawfully, feloniously, and knowingly acquired or maintained, directly or indirectly, an interest in or control of an enterprise, namely: HOPPZ CROPZ through a pattern of racketeering activity or through the collection of an unlawful debt; in violation of (2), C.R.S. (F2), and against the peace and dignity of the People of the State of Colorado. 5

6 The offenses alleged in Counts One, Two and Three were committed in the following manner: The Enterprise The enterprise alleged in Counts One, Two and Three consisted of a group of individuals, associated in fact, and at least one legal entity. The enterprise included, the following associated in fact individuals, a group of individuals, along with a legal entity and/or other entities: JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX ), NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE ), VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH (A.K.A. MARLEY ), ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS and others both known and unknown to the Grand Jury, who were associated from time to time in the racketeering activity related to the conduct of the enterprise. The above persons and entity that associated with the enterprise, and the enterprise itself, engaged in a scheme whereby the members conspired to purchase medical marijuana from licensed facilities and resell it for profit under the guise the marijuana was being offerred as a free giveaway with the purchase of a dramatically overpriced, yet low cost, item. In essence, the enterprise possessed and distributed marijuana -and conspired to do the same- in Colorado Springs, Colorado while simultaneously engaging in tax evasion, money laundering, attempts to influence public servants, filing false tax information and failing to pay over taxes. Joseph Hopper, his fiancée Dara Wheatley, Joseph Sergio Crivici and Adam Donaldson opened or joined in the ownership of marijuana distributing franchises. Under the brand Hoppz Cropz these individuals leased storefronts at 2402 East Boulder St., Colorado Springs, Colorado and 2549 Delta Dr., Colorado Springs, Colorado. Acting as owners and high managerial agents, the four owners used the Hoppz Cropz storefronts and Hoppz Cropz employees 1 to sell marijuana along with paraphernalia. The owner-managers and their employees engaged in a free giveaway ruse combining sales of drug-related tangible personal property along with marijuana itself. 2 Members of the enterprise routinely hand out a Hoppz Cropz form deceitfully acknowledging the store is gifting patrons -without remuneration- less than two ounces of marijuana pursuant to Amendment 64. Despite local ordinances against retail recreational marijuana stores, the drug trafficking organization ( DTO ) through the Hoppz Cropz stores, skirted civil enforcement by the City of Colorado Springs and ultimately trafficked nearly 200 pounds of finished/refined marijuana since its July of 2016 inception. Detectives calculated the aggregate amount of nearly 200 pounds of illegally distributed marijuana by Hoppz Cropz owners and employees using inventory records seized during the execution of search warrants in the two Hoppz Cropz stores. Inventories from Hoppz Delta indicated the daily amount of marijuana sold averaged grams. By significantly underestimating this average amount at 200 grams and multiplying it by the number of days Hoppz Delta has been 1 The employees of Hoppz Cropz managed by Joseph Hopper, Dara Wheatley, Adam Donaldson and Joseph Sergio Crivici, include but are not limited to: Derrick Bernard, Nathan Bernheisel, Victoria Fernandez, Marcee Smith, Alejandra Gonzalez, Raylene Rubio, Nicole Sandoval Ashley Hefner, Melissa Colmus, Tim, Mike, Alan, Nikki, Kelsey, Ashlie, Bree, Shay, Dejanique Trashai, Patricia, Justin, John, Laura and Felicia. 2 By way of limited example, the members of the enterprise sold cheap lighters -worth a few cents- for $15 and employed the ruse that the business was giving away one gram of marijuana for free along with the $15 lighter. The street value of one gram of marijuana is approximately $15. 6

7 open (July 15, 2016, to May 6, 2017 = 42 weeks = 294 days), the total amount of marijuana sold can be estimated at approximately 58,800 grams, or pounds at the Hoppz Delta store alone. Inventories from the Hoppz Boulder indicated the monthly amount of marijuana sold averaged at 4, grams. By significantly underestimating this average amount at 4,000 grams and multiplying it by the number of months Hoppz Boulder has been open (October, 2016, to April, 2017 = 7 months), the total amount of marijuana sold can be estimated at approximately 28,000 grams, or 61.7 pounds. This results in an approximate, conservatively estimated total of marijuana sold through both stores at 86,800 grams, or pounds. With this ruse in place, Hoppz Cropz succesfully evaded paying fees regularly associated with retail recreational marijuana dispensary licensure and evaded excise taxes that an otherwise fully licensed retail recreational dispensary would normally be required to pay to the Department of Revenue. In effect, Hoppz Cropz, LLC, its owners and employees contributed to the recreational marijuana black market. Despite opening a sales tax account with the Colorado Department of Revenue in July of 2016 and engaging in conventional retail sales of parphernalia and clothing (as well as illicit marijuana sales), Hoppz Cropz, LLC, its owner-managers and employees failed to report the proper figures on nearly half a million dollars in retail sales. Moreover, the managers and lower level members of the enterprise engaged in a second form of tax evasion by promoting and receiving under the table payments of wages, thereby evading the associated wage withholding taxes otherwise due to the Colorado Department of Revenue. Indeed, managers instructed the workers to engage in deceit and inform any government officials who inquired that they the salespersons- were merely volunteers working at their respective stores without pay. Pattern of Racketeering Activity For purposes of Counts One, Two and Three, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX ), NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE ), VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH (A.K.A. MARLEY ), ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS and others known and unknown to the Grand Jury, directly and in concert, engaged in, attempted to engage in, conspired to engage in, or solicited another to engage in at least two predicate acts, and any lesser included offenses as permitted in , related to the conduct of the enterprise, at least one of which took place in the State of Colorado after July 1, 1981 and the last of the acts of racketeering activity occurring within ten years after a prior act of racketeering activity and include: Distribution of Marijuana or Marijuana Concentrate Conspiracy to Distribute or Possess with Intent to Manufacture or Distribute Marijuana or Marijuana Concentrate Possession with Intent to Manufacture or Distribute Marijuana or Marijuana Concentrate Money Laundering Evasion of Taxes Administered by the Colorado Department of Revenue Conspiracy to Commit Evasion of Taxes Administered by the Colorado Department of Revenue Failure to File a Return or Pay Tax Filing of a False Return 7

8 Keeping Property for Unlawful Distribution of Controlled Substances Attempt to Influence a Public Servant And the Predicate Act of: Unlawful Use of a Communications Facility. RACKETEERING ACTIVITY The acts of racketeering activity that the above named persons and/or entities committed, attempted to commit, conspired to commit, or solicited, coerced, or intimidated another person to commit, consist of the following predicate acts, including any lesser included offenses permitted to be used as predicates under this statute: Counts Four through Twenty Two and all other identified Predicate Act(s) set forth the essential relevant acts of racketeering and are incorporated in these Counts One, Two and Three by this reference. The relevant acts of racketeering activity include any lesser included offenses of Counts Four through Twenty Two and all other identified Predicate Acts. COUNT 4 Distribution Of Marijuana (50 LBS) or Marijuana Concentrate (25 LBS), (2)(B)(I),(III)(A), C.R.S. (DF1) 8802P On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX ), NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE ), VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH (A.K.A. MARLEY ), ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS, and others known and unknown to the Grand Jury, unlawfully, feloniously, and knowingly sold or distributed, or attempted to sell or distribute marijuana or marijuana concentrate. Further, the amount of marijuana was more than fifty pounds or the marijuana concentrate was more than twenty five pounds, in violation of (2)(b)(I),(III)(A), C.R.S. (DF1), and against the peace and dignity of the People of the State of Colorado. COUNT 5 Possession with Intent to Manufacture or Distribute Marijuana (50 LBS) or Marijuana Concentrate (25 LBS), (2)(B)(I),(III)(A), C.R.S. (DF1) 8802U On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX ), NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE ), VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH (A.K.A. MARLEY ), ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS and others known and unknown to the Grand Jury, unlawfully, feloniously, and knowingly possessed, or attempted to possess, with intent to manufacture, sell or distribute, marijuana or marijuana concentrate. Further, the amount of marijuana 8

9 was more than fifty pounds or the amount of marijuana concentrate was more than twenty five pounds; in violation of (2)(b)(I),(III)(A), C.R.S. (DF1), and against the peace and dignity of the People of the State of Colorado. COUNT 6 Conspiracy to Distribute, or Possess with Intent to Manufacture or Distribute, Marijuana (50 LBS) or Marijuana Concentrate (25LBS), (2)(B)(I),(III)(A), C.R.S. (DF1) 8802Z On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX ), NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE ), VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH (A.K.A. MARLEY ), ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS, and others known and unknown to the Grand Jury, unlawfully, feloniously, and knowingly conspired with one another and with a person or persons known and unknown to the Grand Jury, to sell, distribute, or possess with intent to manufacture, sell or distribute marijuana or marijuana concentrate. Further, the amount of marijuana was more than fifty pounds or the amount of marijuana concentrate was more than twenty five pounds, in violation of (2)(b)(I),(III)(A), C.R.S. (DF1), and against the peace and dignity of the People of the State of Colorado. COUNT 7 Money Laundering Conduct Financial Transaction with Intent to Promote Crime, (1)(A)(I), C.R.S. (F3) On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX ), NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE ), VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH (A.K.A. MARLEY ), ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS and others known and unknown to the Grand Jury, unlawfully and feloniously, conducted or attempted to conduct a financial transaction that involved money or any other thing of value that the defendant knew or believed to be the proceeds, in any form, of a criminal offense, with the intent to promote the commission of a criminal offense; in violation of (1)(A)(I), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado. 9

10 COUNT 8 Conspiracy to Commit Money Laundering Conduct Financial Transaction with Intent to Promote Crime, (1)(A)(I) and , C.R.S. (F4) CON On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX ), NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE ), VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH (A.K.A. MARLEY ), ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS, and others known and unknown to the Grand Jury, with the intent to promote or facilitate the commission of the crime of Money Laundering Conduct Financial Transaction with Intent to Promote Crime, unlawfully and feloniously agreed with one another 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 (1)(A)(I) and , C.R.S. (F4), and against the peace and dignity of the People of the State of Colorado. COUNT 9 Money Laundering Transfer Monetary Instrument with Intent to Promote Crime, (1)(B)(I), C.R.S. (F3) On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX ), NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE ), VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH (A.K.A. MARLEY ), ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS and others known and unknown to the Grand Jury, unlawfully and feloniously transported, transmitted, or transferred a monetary instrument or moneys, with the intent to promote the commission of a criminal offense, in violation of (1)(B)(I), C.R.S. (F3) and against the peace and dignity of the People of the State of Colorado. COUNT 10 Conspiracy to Commit Money Laundering Transfer Monetary Instrument with Intent to Promote Crime, (1)(B)(I) and , C.R.S. (F4) CON On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX ), NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE ), 10

11 VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH (A.K.A. MARLEY ), ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS and others known and unknown to the Grand Jury, with the intent to promote or facilitate the commission of the crime of Money Laundering Transfer Monetary Instrument with Intent to Promote Crime, unlawfully and feloniously agreed with one another 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 (1)(B)(I) and , C.R.S. (F4), and against the peace and dignity of the People of the State of Colorado. COUNT 11 Keeping Property for Unlawful Distribution of Controlled Substances, (1), C.R.S. (DM1) On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX ), NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE ), VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH (A.K.A. MARLEY ), ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS and others known and unknown to the Grand Jury, knowingly or intentionally kept, maintained, controlled, rented, leased, or made available for use a store, shop, warehouse, dwelling, building, vehicle, vessel, aircraft, room, enclosure, or other structure or place, which the defendant knew was resorted to for the purpose of keeping for distribution, transporting for distribution, or distribution of a controlled substance; in violation of (1), C.R.S. (DM1), and against the peace and dignity of the People of the State of Colorado. COUNT 12 Evasion of Taxes Administered by the Colorado Department of Revenue, (1), C.R.S. (F5) On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX ), NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE ), VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH (A.K.A. MARLEY ), ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS, and others known and unknown to the Grand Jury, did unlawfully, feloniously and willfully attempt to evade and defeat a tax administered by the Colorado Department of Revenue, or a payment thereof namely, state wage withholding tax in violation of (1), C.R.S. (F-5), and against the peace and dignity of the People of the State of Colorado. 11

12 COUNT 13 Conspiracy to Commit Evasion of Taxes Administered by the Colorado Department of Revenue, (1) and , C.R.S. (F6) CON On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX ), NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE ), VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH (A.K.A. MARLEY ), ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS, and others known and unknown to the Grand Jury, with the intent to promote or facilitate the commission of the crime of Evasion of Taxes Administered by the Colorado Department of Revenue, unlawfully and feloniously agreed with one another 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 (1) and , C.R.S. (F6), and against the peace and dignity of the People of the State of Colorado. COUNT 14 Evasion of Taxes Administered by the Colorado Department of Revenue, (1), C.R.S. (F5) On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX ), NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE ), VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH (A.K.A. MARLEY ), ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS, and others known and unknown to the Grand Jury, did unlawfully, feloniously and willfully attempt to evade and defeat a tax administered by the Colorado Department of Revenue, or a payment thereof namely, state sales tax in violation of (1), C.R.S. (F-5), and against the peace and dignity of the People of the State of Colorado. COUNT 15 Conspiracy to Commit Evasion of Taxes Administered by the Colorado Department of Revenue, (1) and , C.R.S. (F6) CON On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX ), NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE ), 12

13 VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH (A.K.A. MARLEY ), ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS, and others known and unknown to the Grand Jury, with the intent to promote or facilitate the commission of the crime of Evasion of Taxes Administered by the Colorado Department of Revenue, unlawfully and feloniously agreed with one another 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 (1) and , C.R.S. (F6), and against the peace and dignity of the People of the State of Colorado. COUNT 16 Failure to File Return or Pay Tax, (3), C.R.S. (M) On or about and between August 21, 2016 and May 21, 2017, in and triable in the State of Colorado, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP) and others known and unknown to the Grand Jury, unlawfully and willfully failed to pay a tax or estimated tax, make a return, keep tax records, or supply tax information as required; in violation of (3), C.R.S. (M), and against the peace and dignity of the People of the State of Colorado. COUNT 17 Filing a False Tax Return, (4), C.R.S. (F5) On or about April 16, 2017 in and triable in the State of Colorado, DARA WHEATLEY and HOPPZ CROPZ, LLC, unlawfully, feloniously, and willfully made and subscribed returns, statements, or other documents, which contained or were verified by a written declaration that they were made under the penalties of perjury, and which the defendant did not believe to be true and correct as to every material matter; in violation of (4), C.R.S. (F5), and against the peace and dignity of the People of the State of Colorado. COUNT 18 Forgery, (1)(C), C.R.S. (F5) On or about and between July 1, 2016 and May 25, 2017, in the State of Colorado, JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH (A.K.A. MARLEY ), ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS, with the intent to defraud Hoppz Cropz customers including but not limited to Michael Adam Hughes, Chace Passanante, Joey Harris and those individual customers identified below in Attachment A, 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, a deed, will, codicil, contract, assignment, commercial instrument, promissory note, or other instrument which document did or may have evidenced, created, transferred, terminated, or otherwise affected a legal right, interest, obligation, or status, namely: a contract pertaining to Hoppz Cropz customers 13

14 Amendment 64 rights; in violation of (1)(c), C.R.S. (F-5), and against the peace and dignity of the People of the State of Colorado. COUNT 19 Attempt To Influence A Public Servant, , C.R.S. (F4) On or about November 17, 2016, in and triable in the State of Colorado, RAYLENE RUBIO unlawfully and feloniously attempted to influence Colorado Springs Police Department Detective Nick Bayne, who is a public servant, by means of deceit, with the intent thereby to alter or affect the public servant s decision, vote, opinion, or action concerning a matter which was to be considered or performed by the public servant or the agency or body of which the public servant was a member; in violation of , C.R.S. (F-4), and against the peace and dignity of the People of the State of Colorado. COUNT 20 Attempt To Influence A Public Servant, , C.R.S. (F4) On or about May 2, 2017, in and triable in the State of Colorado, JOSEPH SERGIO CRIVICI and HOPPZ CROPZ, LLC unlawfully and feloniously attempted to influence Colorado Springs Police Department Sergeant Roger Vargason and or Colorado Springs Police Department Detective Nick Bayne, who are public servants, by means of deceit, with the intent thereby to alter or affect the public servants decisions, votes, opinions, or actions concerning a matter or matters which were to be considered or performed by the public servants or the agency or body of which the public servants were members; in violation of , C.R.S. (F-4), and against the peace and dignity of the People of the State of Colorado. COUNT 21 Attempt To Influence A Public Servant, , C.R.S. (F4) On or about May 2, 2017, in and triable in the State of Colorado, NICOLE SANDOVAL and VICTORIA FERNANDEZ unlawfully and feloniously attempted to influence Colorado Springs Police Department Sergeant Roger Vargason, who is a public servant, by means of deceit, with the intent thereby to alter or affect the public servant s decision, vote, opinion, or action concerning a matter which was to be considered or performed by the public servant or the agency or body of which the public servant was a member; in violation of , C.R.S. (F-4), and against the peace and dignity of the People of the State of Colorado. COUNT 22 Attempt To Influence A Public Servant, , C.R.S. (F4) On or about May 2, 2017, in and triable in the State of Colorado, ASHLEY HEFNER unlawfully and feloniously attempted to influence Colorado Springs Police Department Detective Nick Bayne, who is a public servant, by means of deceit, with the intent thereby to alter or affect the public servant s decision, vote, opinion, or action concerning a matter which was to be considered or performed by the public servant or the agency or body of which the public servant was a member; in violation of , C.R.S. (F-4), and against the peace and dignity of the People of the State of Colorado. 14

15 COUNT 23 Special Offender Conspiracy Pattern of Sale, (1)(b), C.R.S. (DF-1) 33A43 On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado, DARA WHEATLEY committed the felony offenses charged in counts 4, 5 and 6; ADAM DONALDSON committed the felony offenses charged in counts 4, 5 and 6; which was, or was in furtherance of, a conspiracy with one or more persons to engage in a pattern of manufacturing, sale, or distributing a controlled substance, and the defendant did, or agreed that defendant would initiate, organize, plan, finance, direct, manage, or supervise part or all of the conspiracy or manufacture, sale, or distributing, in violation of (1)(b), C.R.S. (DF-1), and against the peace and dignity of the People of the State of Colorado. COUNT 24 Special Offender Organizer in Series of Violations with Others, (1)(F), C.R.S. (DF1) 33A48 On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado, JOSEPH HOPPER committed the felony offenses charged in counts counts 4, 5 and 6; DARA WHEATLEY committed the felony offenses charged in counts 4, 5 and 6; ADAM DONALDSON committed the felony offenses charged in counts counts 4, 5 and 6; JOSEPH SERGIO CRIVICI committed the felony offenses charged in counts counts 4, 5 and 6; engaged in a continuing criminal enterprise by violating (3), (4), (2), , (2)(B)(I),(III)(A), namely: Violation of the Colorado Organized Crime Control Act Conspiracy/Endeavoring, Violation of the Colorado Organized Crime Control Act Pattern of Racketeering- Participation in Enterprise, Violation of the Colorado Organized Crime Control Act Pattern of Racketeering Acquire Interest in Enterprise, Distribution Of Marijuana (50 LBS) or Marijuana Concentrate (25 LBS), Possession with Intent to Manufacture or Distribute Marijuana (50 LBS) or Marijuana Concentrate (25 LBS), Conspiracy to Distribute, or Possess with Intent to Manufacture or Distribute, Marijuana (50 LBS) or Marijuana Concentrate (25LBS), and this violation was a part of a continuing series of two or more violations of part 4 of article 18 of title 18, C.R.S., on separate occasions, namely: Distribution Of Marijuana (50 LBS) or Marijuana Concentrate (25 LBS) in violation of (2)(B)(I),(III)(A), C.R.S. and any lesser included offenses on two or more separate occasions on or about and between July 1, 2016 and May 25, 2017, Possession with Intent to Manufacture or Distribute Marijuana (50 LBS) or Marijuana Concentrate (25 LBS), in violation of (2)(B)(I),(III)(A), C.R.S and any lesser included offenses on two or more separate occasions on or about and between July 1, 2016 and May 25, 2017, and Conspiracy to Distribute, or Possess with Intent to Manufacture or Distribute, Marijuana (50 LBS) or Marijuana Concentrate (25LBS) in violation of (2)(B)(I),(III)(A), C.R.S. and any lesser included offenses on two or more separate occasions on or about and between July 1, 2016 and May 25, 2017, and the defendants undertook the continuing series of violations in concert with at least five other persons with respect to whom the defendant occupied a position of organizer, or supervisor, or other position of management, and the defendant obtained substantial income or resources from the continuing series of violations; in violation of section (1)(f), C.R.S. 15

16 COUNT 25 Special Offender Firearm, C.R.S (1)(d)(II), C.R.S. (DF1) 33A45 On or about and between November 17, 2016 and May 25, 2017 in and triable in the State of Colorado, DERRICK BERNARD committed the felony offenses charged in counts 4, 5 and 6; NATHAN BERNHEISEL committed the felony offenses charged in counts 4, 5, and 6; and the defendant or a confederate of the defendant possessed a firearm to which: the defendant or confederate had access in a manner that posed a risk to others; or in a vehicle the defendant was occupying, during the commission of the offense; in violation of (1)(d)(II), C.R.S. (DF1), and against the peace and dignity of the People of the State of Colorado. COUNT 26 Filing a False Tax Return, (4), C.R.S. (F5) On or about and between April 1, 2017 and May 25, 2017, in and triable in the State of Colorado, DARA WHEATLEY unlawfully, feloniously, and willfully made and subscribed returns, statements, or other documents, which contained or were verified by a written declaration that they were made under the penalties of perjury, and which the defendant did not believe to be true and correct as to every material matter; in violation of (4), C.R.S. (F5), and against the peace and dignity of the People of the State of Colorado. COUNT 27 Evasion of Taxes Administered by the Colorado Department of Revenue, (1), C.R.S. (F5) On or about and between April 1, 2017 and May 25, 2017, in and triable in the State of Colorado, DARA WHEATLEY, did unlawfully, feloniously and willfully attempt to evade and defeat a tax administered by the Colorado Department of Revenue, or a payment thereof namely, Colorado Income Tax in violation of (1), C.R.S. (F-5), and against the peace and dignity of the People of the State of Colorado. The offenses alleged in Counts 1 through 27 and the below Predicate Acts (connected to Counts 1, 2 & 3) incorporate any and all above asserted facts and dates. The below essential facts of the crimes were committed in the following manner and occurred either entirely or partly in the State of Colorado: Starting in January of 2014, the State of Colorado enacted a marijuana excise tax. Retail marijuana became subject to a 15% excise tax based on the average market price of retail marijuana. The tax is calculated on the basis of the category of the retail marijuana product 3 being sold or transferred. Neither JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC, DERRICK BERNARD, NATHAN BERNHEISEL, VICTORIA FERNANDEZ, MARCEE SMITH, ALEJANDRA GONZALEZ, RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS, nor any of their co-conspirators paid this excise tax or filed any returns associated with the excise tax. The members of the enterprise were able to increase profits by purchasing medical marijuana -which is taxed at a substantially lower rate 3 i.e., Flower, Trim, or Immature Plant. 16

17 compared to recreational- from licensed dispensaries by illegally using the patient red cards of fellow co-conspirators. This effectively created a lower priced, black market marijuana sold by Hoppz Cropz and its employees. Furthermore, none of the members of the enterprise paid or collected and remitted the proper amount of sales tax due from the numerous retail sales made in the Hoppz Cropz stores. On July 29, 2016, Colorado Springs law enforcement agents assigned to the Metro Vice, Narcotics, and Intelligence Division ( MVNI ) received anonymous information from a Crime Stopper tip regarding the address 2549 Delta Drive ( Hoppz Delta ). The complaint stated Hoppz Delta employees were selling marijuana to people without medical marijuana cards. MVNI detectives soon learned employees at a second related store located at 2402 East Boulder Street ( Hoppz Boulder ) conducted similar illegal distributions of marijuana. A records check of Hoppz Cropz through the Colorado Secretary of State revealed the business entity s formation in July of 2016 and listed its registered agent as Dara Wheatley. Later, the Secretary of State s website listed Adam Donaldson as the registered agent beginning October, 2016, ultimately followed by another change which listed Joseph Sergio Crivici as the registered agent as of March, All parties provided their registered agent address as 750 East Cimarron Street. Detectives soon became aware of Hoppz Cropz presence through social media and a television news report featuring Dara Wheatley s fiancée, Mr. Joseph Hopper. Eventually, the detectives learned that Mr. Hopper self-identified as the stores owner in both social media and on a television interview with KRDO News. After taking initial investigative steps and discovering social links between numerous Hoppz Cropz owners and employees, MVNI detectives commenced an investigation involving undercover operations. Undercover Marijuana Purchases at Hoppz Delta: On Thursday, August 18, 2016, Detective Michael Adam Hughes was assigned to act in an undercover capacity to purchase marijuana from Hoppz Delta to help verify the validity of the Crime Stopper tip. Detective Hughes entered the store and was asked for identification by an employee who provided a typed form. Detective Hughes proceeded to fill out a typed form 4 purporting to explain Amendment 64 and the store s sales model of gifting marijuana during a purchase. Hughes was told he could purchase a memo (which appeared to be a rolling paper) for $5, a sticker ($10), or various other items, and he would be gifted either a joint (a marijuana cigarette) or a gram or more of marijuana (depending on how much he spent). He was also told he could smoke in the store if he purchased a $3 gift. Detective Hughes opted to spend $15 and was given a lighter (which retails for as low as 14 cents) and 1.35 grams of Dark Horse, a green, leafy substance which later tested positive for Tetrahydrocannabinol (THC), the chemical ingredient in marijuana responsible for the high. On Wednesday, November 9, 2016, Detective Joey Harris was assigned to act in an undercover capacity to enter Hoppz Delta and attempt to purchase marijuana. Detective Harris entered the store 4 This form and the others like it described throughout this document- was a contract uttered for the purpose of deceiving the customers of Hoppz Cropz by providing false information as to the status of the marijuana the Hoppz Cropz customer purchased in conjunction with various tangible items such as lighters, stickers, rolling papers and the like. All of the members of the enterprise including JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBER S ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), VICTORIA FERNANDEZ (A.K.A. TORI ), MARCEE SMITH, ALEJANDRA GONZALEZ (A.K.A. ALE ), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS, conspired and or stood complicit in completing or uttering these forgeries as it advanced the enterprise as a whole and each member eventually profited personally. A larger list of customers defrauded by the employees and owner managers is listed below at ATTACHMENT A 17

18 and was greeted by Hoppz Cropz owner/employee Dara Wheatley who asked him if he had his identification card with him. Ms. Wheatley instructed Detective Harris to complete one of forms stating he understood Amendment 64, is over 21 years of age, and is becoming a member of Hoppz Cropz (at both locations). Once Wheatley took possession of the form she told Detective Harris he could be gifted marijuana in exchange for purchasing a small item, such as a rolling paper or lighter. After being shown some marijuana products, Detective Harris purchased a (14 cent) lighter for $15 and was gifted 1.03g of a green, leafy substance labelled Kandy Kush. This so called gift field tested positive for THC. On Friday, November 11, 2016, Detective Chace Passanante was assigned to act in an undercover capacity to enter Hoppz Delta in attempts to purchase marijuana. At 1508 hours on that date, Detective Passanante entered the store and was greeted by Hoppz Cropz employee Melissa Colmus. The employee asked the detective to complete the form stating he understood Amendment 64, was over 21, and he was joining Hoppz Cropz as a member. Colmus then told Detective Passanante they do not sell marijuana, they gift it with a purchase of another item. She showed Detective Passanante three shelves containing different marijuana products (buds, extract, etc.). Melissa Colmus told him he could buy a paper for $10 and she would gift him a gram of marijuana, a lighter for $15 with a gram, or a small pipe for $20 with a gram of marijuana. Colmus said, That shows you the level of shelves we have, but we do gift up to 14 grams. Detective Passanante bought a (14 cent) lighter for $15 and a baggie weighing 2.94 grams (including the baggie), containing a green, leafy substance which field tested positive for THC. Undercover Marijuana Purchases at Hoppz Boulder: On Wednesday, November 9, 2016, Detective J. Harris entered Hoppz Boulder and attempted to purchase marijuana. At approximately 1411 hours on that date, Hoppz Cropz employee Raylene Rubio greeted Detective Harris as he entered the store. Rubio asked him if he had been to the store before. Raylene Rubio next asked Detective Harris to complete one of the forms stating he understood Amendment 64, he is over 21 years of age, and he is becoming a member of Hoppz Cropz. When he had completed the form, the employee, Raylene Rubio, went on to say, We are more like a gift shop rather than a dispensary, so we gift weed we do not sell it. Rubio showed Detective Harris some marijuana and told he could purchase a lighter or a small, glass pipe and be gifted some marijuana. She also told him the detective he could buy a $5 memo (which appeared to be a small baggie of marijuana) or he could buy a sticker. Raylene Rubio then told him she was out of stickers so she could give him a rolling paper, or, she stated, You are purchasing the bag and I am gifting you a memo. Detective Harris purchased a small glass pipe for $20 and was gifted 0.97 grams of Gorilla Glue, a green, leafy substance which field tested positive for THC. On Friday, November 11, 2016, Detective C. Passanante visited Hoppz Boulder to try to purchase marijuana. At 1540 hours, Detective Passanante entered the store and Hoppz Cropz employee Marcee Smith asked the undercover detective to complete the form stating he understood Amendment 64, was over 21, and that he was joining Hoppz Cropz as a member. Marcee Smith told Detective Passanante the marijuana would be gifted with another purchase. She showed Detective Passanante three shelves of marijuana products with different THC levels. Detective Passanante selected the Jelly Bean variety of marijuana and Marcee Smith then asked if he wanted to do a $15 small pipe. Detective Passanante purchased a pipe and received a baggie weighing 3.15 grams (including the baggie), holding a green, leafy substance which tested positive for THC. 18

19 First Search Warrant On November 16, 2016, Detective Kerry Linfoot completed a search warrant for both Hoppz Cropz locations. The search warrants were reviewed and signed by Judge Walter on November 16, 2016, and executed on November 17, During the searches of the Hoppz Cropz stores, detectives seized approximately 2198 grams of marijuana and marijuana products, along with a handgun and $3290 in U.S. currency. Ledgers at the store put the daily sales for the Boulder store at $700-$1500 and the daily sales at the Delta store from $2000-$3500. During the execution of these warrants, receipts and financial documentation obtained by law enforcement officials indicated several sources for the marijuana sold in the Hoppz Cropz stores were medical marijuana dispensaries. Receipts showed quantities of marijuana and marijuana concentrate being purchased from, among other stores, Altitude Organic Medicine. Some of the receipts recovered specifically indicated Adam Donaldson was purchasing medical marijuana from Altitude Organic Medicine for later illegal resale at the Hoppz Cropz stores. Close in time to the execution of the November 16, 2016 search warrants, Raylene Rubio attempted to influence Colorado Springs Police Department Detective Nick Bayne, by means of deceit and with the intent thereby to alter or affect the detective s decision, vote, opinion, or action concerning his investigation into the Hoppz Cropz drug distribution conspiracy. When asked by the detective who had identified himself as law enforcement - Ms. Rubio stated that she was a volunteer working at the Hoppz Cropz store, when in fact she was a paid employee working under the table to help the business avoid paying wage withholding taxes to the Colorado Department of Revenue. Further Investigation On December 8, 2016, undercover MVNI detectives conducted buys at both Hoppz Cropz locations. Undercover MVNI detectives successfully purchased marijuana from both stores under what the employees, including both Marcee Smith and Raylene Rubio, referred to as a reimbursement process. The detectives were advised they were joining the Hoppz Cropz club and they were permitting Hoppz Cropz to grow their six plants which are permitted under Amendment 64. They were told they were paying to reimburse Hoppz Cropz for the time, labor, and resources used to grow their plants. The marijuana products purchased at both stores later field tested positive for the presence of THC. On the morning of Friday, April 7, 2017, detectives from MVNI noticed Joseph Sergio Crivici s vehicle parked outside the home of Hopper. Crivici and Donaldson left the residence and entered a silver Lincoln carrying backpacks. The men drove to Hoppz Boulder where they remained for just over one hour. Both Crivici and Donaldson then left the Boulder store and drove to Hoppz Delta. When they arrived, both men went into the store and remained while several customers came and went. Later that same morning, Crivici and Donaldson left the Delta store and travelled to 2354 E. Platte Avenue, a medical marijuana dispensary called Altitude Organic Medicine. The reader should note that receipts from this store were found during the search warrants previously executed on the Hoppz Cropz stores. Altitude Organic Medicine appeared to be a source of supply where employees and or supervisor level employees, such as Crivici and Donaldson, purchased marijuana for resale at the Hoppz Cropz stores. 19

20 Tax Evasion As MVNI detectives continued their investigation it became increasingly clear from the undercover buys, information retrieved during search warrants, and data from electronics retrieved during the search, that Hoppz Cropz, LLC, and its owner managers Joseph Hopper, Adam Donaldson, Dara Wheatley or Joseph Sergio Crivici paid little to no state or local taxes on retail sales. 5 Accordingly, MVNI detectives reached out to and began working with special agents 6 from the Colorado Department of Revenue (CDOR). CDOR records indicated Dara Wheatley applied for a sales tax license in July of 2016 using the Colorado Business Express portal and received a sales tax license for Hoppz Cropz. The application stated Hoppz Cropz would be conducting retail sales and specifically listed products being sold as suckers, papers, memos, playing cards, bongs, pipes rigs, sports memorabilia and bottled water. At the time of the application, Wheatley estimated monthly sales at $15/month or less, which would have made the business an annual filer. The business should have filed a sales tax return on January 20, 2017 for sales in If no sales had occurred in 2016 the business should have filed a zero dollar return on January 20, However, Hoppz Cropz never filed a return showing either sales or no sales as required. Even though Hoppz Cropz and its coconspirator owners, managers and employees conducted significant retail sales, Dara Wheatley closed the sales tax account on February 6, Due to the business having failed to file any returns, including a zero amount return, the CDOR sent a non-filer notice on March 8, On March 17, 2017 a Notice of Deficiency was sent to the business based on the CDOR generating an estimated return. Despite the warning inherent in these notices and Wheatley s earlier registration for a sales tax license, no payments or amended returns have been filed by either managers, owners or employees of Hoppz Cropz. As the MVNI detectives coordinated their investigation with CDOR special agents the questioning of Hoppz Cropz employees shifted subtly and they began inquiring into tax liabilities during undercover operations. On Friday, April 14, 2017, undercover Detective Michael Hughes again made purchases of marijuana at both Hoppz Cropz stores. At Hoppz Boulder, Detective Hughes again contacted Ms. Marcee Smith, and explained that he had not been to the store before. Ms. Smith asked for Detective Hughes ID and photocopied it. She next brought out a single sheet of paper with typed information on it stating that he the customer was over the age of 21 and understood Amendment 64. She then said Detective Hughes was a now a member of Hoppz Cropz and he was asked to sign the form. Hoppz Cropz employee Marcee Smith explained a reimbursement process through which the customer reimburses the store for the electricity, nutrients, and everything that actually goes into the growth of the plants. When the detective handed the Hoppz employee two $20 bills to pay for a $40 purchase, he asked her, No taxes on that? The employee laughed and responded, No taxes. The detective purchased marijuana with an approximate weight of 1.66 grams and suspected marijuana concentrate with an approximate weight of 1.4 grams. 5 A person or business having a permanent location where retail sales are conducted on a regular basis must obtain a standard sales tax license. The filing frequency is determined by the amount of sales tax collected monthly. The following are the required filing frequencies based on monthly sales for the State of Colorado as published on the Colorado Department of Revenue website: $15 or less per month: sales tax returns may be filed annually; Under $300 per month: sales tax returns may be filed quarterly; $300 or more per month: sales tax returns must be filed monthly; Businesses that pay more than $75,000 per year in state sales tax must pay by Electronic Funds Transfer. Sales tax returns are to be filed based on the reporting requirement. Annual sales tax filers must file on January 20th of the year preceding the reporting year. Quarterly sales tax filers must file on the 20th day of the month following the reporting quarter. Monthly sales tax filers must file on the 20th of the month following the reporting month. If the due date falls on a weekend or holiday then the return is due the next business day. If there are no taxable sales during a filing period, a zero return must be filed. Failure to file will result in a non-filer notice being sent, which will be filed by an estimated bill. 6 CDOR special agents possess access to a database of sales tax returns submitted by individuals and organizations to the CDOR itself. 20

21 At the Delta store on this date, the undercover detective again made a purchase of marijuana. When he gave Hoppz Cropz employee Raylene Rubio the cash to pay for this purchase, the detective remarked that he did not like paying taxes for marijuana. The employee replied, No taxes. The detective purchased marijuana with a total approximate weight of 3.2 grams, called Gilz Nilz. Second Search Warrant On May 2, 2017, Detective Kerry Linfoot once again completed a search warrant for both Hoppz Cropz locations and the residence of Donaldson and Crivici. The search warrants were reviewed and signed by Judge Wilson, on May 2, 2017, and executed on May 2, During the searches of the Hoppz Cropz stores and the residence, detectives seized approximately 10, grams of marijuana and marijuana products, along with a shotgun, 26 marijuana-infused vape cartridges, 0.6 grams of methamphetamines, and $8, in U.S. currency. Daily totals from register receipts found at the three locations put the daily proceeds for the Boulder and Delta stores combined at $82,549 for Additionally, a cumulative total for sales taken from a single daily receipt dated April 30, 2017, indicated the total amount of sales at $417,265. On some daily receipts for 2017 there is a tax category on the receipt, which reflects $4,865 in tax was collected at the retail stores but not remitted. The receipt books seized during the second search warrant had purchase receipts written for shake and edibles in the amount of $2,675 and approximately $1,051 dollars in raw cones, silicone dabbers, and similar items. Further, the receipt books showed $6,136 dollars had been paid to employees in The $6,136 does not include receipts written to employees when a date was not noted. During the execution of these warrants, receipts and financial documentation obtained by law enforcement officials indicated several sources for the marijuana sold in the Hoppz Cropz stores were medical marijuana dispensaries. Receipts showed quantities of marijuana and marijuana concentrate being purchased from, among other stores, Altitude Organic Medicine. Some of the receipts recovered continued to indicate Adam Donaldson purchased medical marijuana from Altitude Organic Medicine. Close in time to the execution of the May 2, 2017 search warrants, detectives interviewed a co-owner and several employees of the Hoppz Cropz stores. On or about May 2, 2017, Joseph Sergio Crivici, in his capacity as owner and high managerial agent of Hoppz Cropz, attempted to influence Colorado Springs Police Department Detective Nick Bayne, by means of deceit and with the intent thereby to alter or affect the detective s decision, vote, opinion, or action concerning his investigation into the Hoppz Cropz drug distribution conspiracy. When questioned by the detective who had identified himself as law enforcement - Mr. Crivici stated that he was a new owner at the Hoppz Cropz store who had only been working at and only owned the store for a few days, when in fact he had been working at the store and a part owner for several months. Indeed, Mr. Crvici told another law enforcement officer that he had only been an owner of the store for six weeks. On or about May 2, 2017, Nicole Sandoval and Victoria Fernandez both attempted to influence Colorado Springs Police Department Sergeant Roger Vargason, by means of deceit and with the intent thereby to alter or affect the detective s decision, vote, opinion, or action concerning his investigation into the Hoppz Cropz drug distribution conspiracy. When questioned by Vargason who had identified himself as law enforcement - Both Ms. Sandoval and Ms. Fernandez explained that they were volunteers working at the Hoppz Cropz store, when in fact they were each paid employees working under the table to help the business avoid paying wage withholding taxes to the Colorado Department of Revenue. 21

22 On or about May 2, 2017, Ashley Hefner attempted to influence Colorado Springs Police Department Detective Nick Bayne, by means of deceit and with the intent thereby to alter or affect the detective s decision, vote, opinion, or action concerning his investigation into the Hoppz Cropz drug distribution conspiracy. When questioned by the Detective Bayne who had identified himself as law enforcement - Ms. Hefner stated that she was a volunteer working at the Hoppz Cropz store, when in fact she was a paid employee working under the table to help the business avoid paying wage withholding taxes to the Colorado Department of Revenue. After executing the search warrants, the detectives viewed security footage from the stores showing many instances of unlawful distribution of marijuana by the employees of and an owner of Hoppz Cropz. Just a handful of these illegal distributions include but are not limited to the sales by the below listed individuals at the times, dates and locations listed in the chart immediately below: Name Date of Sale 1 Date of Sale 2 Date of Sale 3 Date of Sale 4 Date of Sale 5 Alejandra Gonzalez Ashley Hefner 4/30/ hrs. (Delta - Sec. Cam) 5/2/ hrs. (Boulder - Sec. Cam) 4/30/ hrs. (Delta - Sec. Cam) 5/2/ hrs. (Boulder - Sec. Cam) 4/30/ hrs. (Delta - Sec. Cam) 5/2/ hrs. (Boulder - Sec. Cam) 4/30/ hrs. (Delta - Sec. Cam) 5/2/ hrs. (Boulder - Sec. Cam) 5/17/ hrs. (Delta - UC) 5/2/ hrs. (Boulder - Sec. Cam) Victoria Fernandez 4/29/ hrs. (Delta - Sec. Cam) 4/29/ hrs. (Delta - Sec. Cam) 4/29/ hrs. (Delta - Sec. Cam) 4/29/ hrs. (Delta - Sec. Cam) 4/29/ hrs. (Delta - Sec. Cam) Nicole Sandoval 4/30/ hrs. (Delta - Sec. Cam) 4/30/ hrs. (Delta - Sec. Cam) 4/30/ hrs. (Delta - Sec. Cam) 4/30/ hrs. (Delta - Sec. Cam) 4/30/ hrs. (Delta - Sec. Cam) Melissa Colmus 11/11/ hrs. (Delta - UC) 11/16/ hrs. (Delta - Sec. Cam) 11/16/ hrs. (Delta - Sec. Cam) 11/16/ hrs. (Delta - Sec. Cam) 11/16/ hrs. (Delta - Sec. Cam) Raylene Rubio 11/9/ hrs. (Boulder - UC) 11/16/ hrs. (Boulder - Sec. Cam) 11/16/ hrs. (Boulder - Sec. Cam) 11/9/ hrs. (Boulder - UC) 12/8/ hrs. (Delta - UC) Marcee Smith 11/11/ hrs. (Boulder - UC) 11/16/ hrs. (Boulder - Sec. Cam) 11/16/ hrs. (Boulder - Sec. Cam) 12/8/ hrs. (Boulder - UC) 5/17/ hrs. (Boulder - UC) Dara Wheatley 11/15/ hrs. (Delta - Sec. Cam) 11/15/ hrs. (Delta - Sec. Cam) 11/15/ hrs. (Delta - Sec. Cam) 11/15/ hrs. (Delta - Sec. Cam) 11/15/ hrs. (Delta - Sec. Cam) Money Laundering Activity by Members of the Enterprise Financial investigators examined banking transactions of certain members of the Hoppz Cropz enterprise. The investigators discovered that from July of 2016 until the present day Dara Wheatley and Adam Donaldson engaged in various money laundering transactions with the apparent proceeds derived from the illegal distribution of marijuana at the Hoppz Cropz stores. The other members of the enterprise including JOSEPH HOPPER, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC, DERRICK BERNARD, NATHAN BERNHEISEL, VICTORIA FERNANDEZ, MARCEE SMITH, ALEJANDRA GONZALEZ, RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS, conspired and or stood complicit in this money laundering behavior as it advanced the enterprise as a whole and each member profited personally from their co-conspirators money laundering behavior. 22

23 An example of this behavior includes, but is not limited to, multiple financial transactions involving United States currency. These are known to be transfers of money by members of the enterprise, and Dara Wheatley and Adam Donaldson in particular, made with the intent to promote the commission of the criminal offense including, but not limited to, the illegal distribution of marijuana and marijuana concentrate. Specifically, Ms. Wheatley and Mr. Donaldson transferred or transmitted moneys and proceeds of illegal distributions to pay bills and to keep utility services active for the Hoppz Cropz business locations. Moreover, Ms. Wheatley and Mr. Donaldson transmitted or transferred moneys, including some proceeds of illegal distributions, to purchase supplies for future sales and pay advertising costs for the commission of future illegal activity, including the illegal distribution of marijuana and marijuana concentrate. Adam Donaldson Pueblo Bank and Trust, Account # XXXXX9943 Between July of 2016 and the present, as demonstrated below with specific examples, Mr. Donaldson transferred proceeds of the illegal marijuana distribution or by: a) Making payments to ADT, Colorado Springs Utilities and Springs Waste Systems. Bills addressed to the store show utility payments being made for security monitoring, electrical and waste removal. These services help the business to run by keeping the power on, removing waste from the stores, and keeping the stores secure; b) Making payments/purchases to CA Wholesale, Oriental Imports and East Grow Warehouse for supplies for the store, such as marijuana paraphernalia and t-shirts. These purchases aid in keeping the business operating and assists in advertising to obtain future revenue; c) Making a payment to the landlord of the Hoppz Cropz location on Boulder Street, thereby keeping the doors open to enable the DTO to do business; d) Making purchases to Adobe Creative Cloud and Vista Print for the purpose of website and business card advertising. This assists in advertising for the business to increase visibility and customer base for continued and future sales; e) Making purchases from Modern Medicine, a marijuana dispensary in Colorado Springs, Colorado, for the gifted marijuana given as the free gift with purchase. Cash In / Cash Out Analysis of Mr. Donaldson s account also revealed that, between July 18, 2016, and February 18, 2017, Mr. Donaldson made forty six cash deposits totaling $62, These were all cash and not deposited by a known employer in the form of payroll, nor could these be tied to a legitimate source. There are several cash withdrawals from Mr. Donaldson s account between July 18, 2016, and September 28, 2016, totaling $21, Since there appears to be no other legitimate source of income for Mr. Donaldson, in looking at both his bank account and Federal Wage/Income Transcripts (i.e.w-2 and 1099 information) for income, it would appear that his money is coming from the Hoppz Cropz stores, at which he occupies a high level managerial role and/or an ownership tie to the company. In a period of time between July, 2016, and May, 2017, Donaldson by way of his red card- was identified as having purchased $20, of medical marijuana at Altitude Organic Medicine, LivWell, and Pain Management Solutions. This marijuana was resold through Hoppz Cropz. 23

24 Finally, statements from the landlords for 750 E. Cimarron, the address at which Mr. Donaldson resides, indicate that rent payments were made in cash. This may account for some of the cash withdrawals made by Mr. Donaldson. Eleven cash withdrawals between 7/18/16 and 9/28/16 totaling $21, Monthly payments to Adobe Creative Cloud, a business software expert company, for $19.99 between 8/26/16 and 01/26/17 Two payments to ADT Security: 8/12/16 for $ and 8/22/16 for $ One payment to Bonicelli-Hinton LLC (Hoppz Landlord Boulder Location) for $ One payment to CA Wholesale on 9/13/16 for $ One payment to Colorado Springs Utilities on 9/25/16 for $ Four payments to East Grow Warehouse (2 in August 2016 and 2 in September, 2016) totaling $ Eighteen total payments to Modern Medicine (d/b/a Altitude Organic Medicine) between 8/16/16 and 11/3/16 totaling $3, One payment to Oriental Imports on 9/26/16 for $3, One payment to Purple Mountain Hydro on 9/22/16 for $45.95 One payment to Springs Waste Systems on 8/9/16 for $62.00 Nine payments to Vista Print between 7/22/16 and 12/8/16 totaling $ Dara Wheatley JPMorgan Chase, Account # XXXXX0335 As demonstrated below with specific examples, between July of 2016 and the present, Ms. Wheatley shows behaviors of transmitting or transferring proceeds and/or other money by: a) Making payments to Colorado Springs Utilities and Springs Waste Systems for bills addressed to and of the store. These records show utility payments being made for electrical and waste removal, which helps enable the business to run by keeping the power on, removing waste from the stores; b) Making a payment to the Colorado Secretary of State s Office to register Hoppz Cropz, LLC as a Colorado business; c) Making payments/purchases Oriental Imports and West Grow Warehouse for supplies for the store, such as marijuana paraphernalia and t-shirts. These purchases aid in keeping the business operating and assist in advertising to acquire future business and revenue; d) Making purchases to Vista Print for the purpose of advertising. This assists in advertising for the business to increase visibility and the customer base; e) Making payments to Comcast for service at the stores. Cash In / Cash Out Analysis of Ms. Wheatley s account also revealed that, between January 7, 2016 and March 21, 2017, Ms. Wheatley made ninety six cash deposits (including ATM and transfers) totaling $68, These were all cash or transfer and not deposited by a known employer in the form of payroll nor could these be tied to a legitimate source. $ was in the form of electronic transfer from the following: Joseph Hopper with fourteen transfers totaling $10,255.92; Alejandro Gonzalez 24

25 (believed to actually be Alejandra Gonzalez) with four transfers totaling $625.00; one transfer from Joseph Crivici totaling $1, and seven transfers from an unidentified party totaling $7, There are several cash withdrawals from Ms. Wheatley s account, including ATM and transfers, between January 4, 2014 and December 10, 2016 totaling $18, $4, was in the form of electronic transfer to the following: My Love (presumably her fiancée Joseph Hopper) with six transfers totaling $3,030.00; one transfer to Vegas Joe (presumably Joseph Crivici, as he had previously resided in Las Vegas) for $1,050.00; and two transfers to Poppo/PDppo (presumably Adam Donaldson (A.K.A. Popz )) for $ There appears to be no other legitimate source of income for Ms. Wheatley, other than approximately $2, In looking at both her bank account (which showed only $ deposited) and the 2016 income tax return she filed in Colorado, it appears that the vast majority of her money came from the Hoppz Cropz stores revenue, in which she occupies a high level managerial and/or ownership position. The landlords for 750 E. Cimarron, Ms. Wheatley s residence, indicate that rent payments were made in cash which may account for some of the cash withdrawals made by Ms. Wheatley. Thirty two cash withdrawals between 1/4/16 and 12/12/16 totaling $18, One payment to the Colorado Secretary of State for $50.00 Nine payments to Comcast between 11/2/16 and 2/3//17 totaling $2, Seventeen payments to Colorado Springs Utilities between 1/8/16 and 3/2/17 totaling $6, Three payments to West Grow Warehouse on 2/22/16, 6/9/16 and 6/20/16 totaling $ One payment to Oriental Imports on 1/3/17 for $ Nine payments to Century Link between 3/2/16 and 1/8/17 totaling $ Seven payments to Springs Waste Systems between 2/16/16 and 1/25/17 totaling $ One payment to Vista Print on 10/26/16 for $ On numerous occasions, as described in greater detail in the below Predicate Acts, specific members of the enterprise unlawfully used their cell phones text messaging or via social media platforms such as Face Book- to facilitate distribution of marijuana or the conspiracy to distribute a marijuana from the stores. PREDICATE ACT 1 Unlawful Use of a Communication Facility, 21 U.S.C. 843 On or about March 29, 2017, at 10:38:48 a.m. (UTC-6) in and triable in the State of Colorado, Nicole Sandoval and a person known to the Grand Jury did knowingly or intentionally use a communications facility, namely, a wire, telephone and/or other means of communication, to facilitate the commission of a felony, namely, distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C

26 PREDICATE ACT 2 Unlawful Use of a Communication Facility, 21 U.S.C. 843 On or about April 19, 2017, at 4:04:10 p.m. (UTC-6) in and triable in the State of Colorado, Nicole Sandoval did knowingly or intentionally use a communications facility, namely, a wire, telephone and/or other means of communication, to facilitate the commission of a felony, namely, distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C PREDICATE ACT 3 Unlawful Use of a Communication Facility, 21 U.S.C. 843 On or about April 20, 2017, at 12:16:41 p.m. (UTC-6) in and triable in the State of Colorado, Nicole Sandoval did knowingly or intentionally use a communications facility, namely, a wire, telephone and/or other means of communication, to facilitate the commission of a felony, namely, distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C PREDICATE ACT 4 Unlawful Use of a Communication Facility, 21 U.S.C. 843 On or about April 23, 2017, at 11:12:25 a.m. (UTC-6) in and triable in the State of Colorado, Nicole Sandoval did knowingly or intentionally use a communications facility, namely, a wire, telephone and/or other means of communication, to facilitate the commission of a felony, namely, distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C PREDICATE ACT 5 Unlawful Use of a Communication Facility, 21 U.S.C. 843 On or about May 2, 2017, at 10:09:14 a.m. (UTC-6) in and triable in the State of Colorado, Nicole Sandoval did knowingly or intentionally use a communications facility, namely, a wire, telephone and/or other means of communication, to facilitate the commission of a felony, namely, distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C PREDICATE ACT 6 Unlawful Use of a Communication Facility, 21 U.S.C. 843 On or about October 25, 2016, at 2:34:37 p.m. (UTC-7) in and triable in the State of Colorado, Nathan Bernheisel did knowingly or intentionally use a communications facility, namely, a wire, telephone and/or other means of communication, to facilitate the commission of a felony, namely, 26

27 distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C PREDICATE ACT 7 Unlawful Use of a Communication Facility, 21 U.S.C. 843 On or about November 6, 2016, at 1:59:17 p.m. (UTC-7) in and triable in the State of Colorado, Nathan Bernheisel and Adam Donaldson did knowingly or intentionally use a communications facility, namely, a wire, telephone and/or other means of communication, to facilitate the commission of a felony, namely, distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C PREDICATE ACT 8 Unlawful Use of a Communication Facility, 21 U.S.C. 843 On or about November 16, 2016, at 12:06:57 p.m. (UTC-6) in and triable in the State of Colorado, Nathan Bernheisel and Dara Wheatley did knowingly or intentionally use a communications facility, namely, a wire, telephone and/or other means of communication, to facilitate the commission of a felony, namely, distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C PREDICATE ACT 9 Unlawful Use of a Communication Facility, 21 U.S.C. 843 On or about November 17, 2016, at 01:42:08 p.m. (UTC-7) in and triable in the State of Colorado, Nathan Bernheisel did knowingly or intentionally use a communications facility, namely, a wire, telephone and/or other means of communication, to facilitate the commission of a felony, namely, distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C PREDICATE ACT 10 Unlawful Use of a Communication Facility, 21 U.S.C. 843 On or about November 17, 2016, at 1:51:08 p.m. (UTC-7) in and triable in the State of Colorado, Nathan Bernheisel and Adam Donaldson did knowingly or intentionally use a communications facility, namely, a wire, telephone and/or other means of communication, to facilitate the commission of a felony, namely, distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C

28 PREDICATE ACT 11 Unlawful Use of a Communication Facility, 21 U.S.C. 843 On or about April 29, 2017, at 9:05 p.m in and triable in the State of Colorado, Raylene Rubio, Victoria Fernandez, Marcee Smith, Alejandra Gonzalez and Nicole Sandoval did knowingly or intentionally use a communications facility, namely, a wire, telephone and/or other means of communication, to facilitate the commission of a felony, namely, distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C PREDICATE ACT 12 Unlawful Use of a Communication Facility, 21 U.S.C. 843 On or about May 2, 2017, at 9:05 p.m in and triable in the State of Colorado, Raylene Rubio and Victoria Fernandez did knowingly or intentionally use a communications facility, namely, a wire, telephone and/or other means of communication, to facilitate the commission of a felony, namely, distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C PREDICATE ACT 13 Unlawful Use of a Communication Facility, 21 U.S.C. 843 On or about July 8, 2016, at 4:22:51 p.m (UTC-6) in and triable in the State of Colorado, Victoria Fernandez did knowingly or intentionally use a communications facility, namely, a wire, telephone and/or other means of communication, to facilitate the commission of a felony, namely, distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance in violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C On or about March 29, 2017, at the times listed below, Nicole Sandoval and a party unknown to the Grand Jury took part in the below text message conversation with one another in order to facilitate the felony distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance. The entire text conversation has been included for context. 28

29 29

30 30

31 31

32 On or about April 19, 2017, at the times listed below, Nicole Sandoval and a party unknown to the Grand Jury took part in the below text message conversation with one another in order to facilitate the felony distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance. The entire text conversation has been included for context. 32

33 On or about April 20, 2017, at the time listed below, Nicole Sandoval and a party unknown to the Grand Jury took part in the below text message conversation with one another in order to facilitate the felony distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance. 33

34 On or about April 23, 2017, at the time listed below, Nicole Sandoval and a party unknown to the Grand Jury took part in the below text message conversation with one another in order to facilitate the felony distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance. On or about May 2, 2017, at the time listed below, Nicole Sandoval and Chase Andrisko took part in the below text message conversation with one another in order to facilitate the felony distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance. 34

35 Between on or about October 25, 2016, and November 4, 2016, at the times listed below, Nathan Bernheisel and a party unknown to the Grand Jury took part in the below Facebook message exchange in order to facilitate the felony distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance. The entire Facebook message conversation has been included for context. 35

36 Between on or about November 6, 2016, and November 16, 2016, at the times listed below, Nathan Bernheisel and a party unknown to the Grand Jury took part in the below Facebook message exchange in order to facilitate the felony distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance. The entire Facebook message conversation has been included for context. 36

37 37

38 On or about November 16, 2016, at the times listed below, Nathan Bernheisel and Dara Wheatley took part in the below text message conversation with one another in order to facilitate the felony distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance. 38

39 On or about November 17, 2016, at the time listed below, Nathan Bernheisel sent the following text message to Adam Donaldson in order to facilitate the felony distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance. This message references an incident when Derrick Bernard and Nathan Bernheisel were sleeping at Hoppz Boulder and Bernard confronted some people outside the store with a firearm. On or about November 17, 2016, at the times listed below, Nathan Bernheisel and Adam Donaldson took part in the below text message conversation with one another (referring to another employee, Raylene Rubio) in order to facilitate the felony distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance. The entire text conversation has been included for context. 39

40 On or about April 29, 2017, at the times listed below, Raylene Rubio, Victoria Fernandez, Marcee Smith, Alejandra Gonzalez, Nicole Sandoval, and parties unknown to the Grand Jury took part in the below text message conversation with one another in order to facilitate the felony distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance. The entire text conversation has been included for context. 40

41 41

42 On or about May 2, 2017, at the times listed below, Raylene Rubio and Victoria Fernandez took part in the below text message conversation with one another in order to facilitate the felony distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance. The entire text conversation has been included for context. 42

43 Between on or about July 8, 2016, and October 3, 2016, at the times listed below, Victoria Fernandez and a party unknown to the Grand Jury took part in the below conversation via Twitter with one another in order to facilitate the felony distribution of a controlled substance, possession with the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance. The entire Twitter conversation has been included for context. 43

44 Dara Wheatley s Income Tax Evasion and Filing of a False Return The CDOR maintains a database of income tax returns submitted by individuals and organizations. During May of 2017, an examination was performed for records contained in the CDOR database for Dara Wheatley who had filed Colorado individual income tax returns for 2016 on or about April 18, CDOR records indicate that Wheatley had not previously filed income tax in the State of Colorado. Included in the CDOR data base is the Federal income tax filing, including: a schedule C, Schedule SE, and W-2 forms. The schedule C is the profit and loss from a business and is used when the profit or loss of said business is to flow through to the individual. Wheatley s Schedule C forms included with her return stated the business to be Hoppz Cropz LLC. The CDOR has access to certain federal information. During May of 2017, a request of Wheatley s Federal Income tax returns was submitted to the Internal Revenue Service (IRS) including transcripts for tax year 2016 with a request for the certified returns (not yet received). Wheatley s 2016 Federal income tax return was recalculated based on the best information available, with Wheatley as the sole member of Hoppz Cropz LLC. This resulted in re-calculating the Profit or Loss from a Business on Schedule C and Self-Employment Tax on Schedule SE on the Federal income tax return. The recalculation was based on the Gross Receipts reported of $36,452 being under reported. The assertion that the gross receipts were under reported is due to the information contained in a ledger/journal during a search warrant executed in November of 2016 that listed daily sales totals from July 15, 2016 through November 4, The ledger/journal entries for daily sales totaled $410,608. As the gross receipts were adjusted to reflect the amounts in the ledger/journal the expenses and cost of goods were also adjusted reflecting higher amounts to offset the higher gross receipts. 44

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