Steven Taylor Et. Al. Indictment

7/28/2019 Steven Taylor Et. Al. Indictment

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District Court, City and County of Denver, ColoradoCity and County Building, Room 2151437 Bannock StreetDenver, CO 80202

Plaintiff: THE PEOPLE OF THE STATE OFCOLORADO

Defendants:

STEVEN CHADWICK TAYLOR

DESIREE KALENE JORDAN

CHRISTOPHER LEACH

JUSTIN CHARLES MURDOCK

RENEE ROSE SWENSON

COURT USE ONLY

Case Number:

Grand Jury No. 13CR2B

Div.: Criminal Ctrm: 215 / ____

INDICTMENT

VIOLATION OF COLORADO ORGANIZED CRIME CONTROL ACT, C.R.S. 18-17-104(3)(F2) <37284> 1 (1 count)

CONSPIRACY TO COMMIT AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRSTDEGREE, C.R.S. 18-4-409(2),(3)(a);18-2-201 C.R.S. (F5) <0804CC> 2 (1 count)

CONSPIRACY TO COMMIT FORGERY, C.R.S. 18-5-102(1)(c);18-2-201 (F6) <1001CC> 3(1 count)

AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, C.R.S. 18-4-409(2),(3)(a) (F4) <0804C> 4, 7, 9, 10, 11, 12, 13, 20, 21 (9 counts)

THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> 5, 6, 22 (3 counts)

AGGRAVATED MOTOR VEHICLE THEFT IN THE SECOND DEGREE, C.R.S. 18-4-409(4)(c) (M1) <0804F> 8 (1 count)

AGGRAVATED MOTOR VEHICLE THEFT IN THE SECOND DEGREE, C.R.S. 18-4-

409(4)(b) (F6) <0804E> 14, 15, 16 (3 counts)

THEFT, C.R.S. 18-4-401(1),(2)(c), (F4) <0801U> 17 (1 count)

POSSESSION OF BURGLARY TOOLS, C.R.S. 18-4-205(1) (F5) <06051> 18 (1 count)

POSSESSION OF METHAMPHETAMINE - 2 GRAMS OR LESS, C.R.S. 18-18-403.5(1),(2)(b)(I) (F6) < 8201B> 19 (1 count)



IDENTITY THEFT, C.R.S. 18-5-902(1)(b) (F4) <1307H> 23, 25, 26, 27, 28 (5 counts)

IDENTITY THEFT, C.R.S. 18-5-902(1)(c) (F4) <1307J> 24 (1 count)

FORGERY, C.R.S. 18-5-102(1)(c) C.R.S. (F5) <1001C> 29, 30 (2 counts)

CRIMINAL POSSESSION OF AN IDENTIFICATION DOCUMENT, C.R.S. 18-5-903.5(1),(2)(b) (F6) <13087> 31 (1 count)

POSSESSION OF IDENTITY THEFT TOOLS, C.R.S. 18-5-905 (F5) <13085> 32 (1 count)

CRIMINAL POSSESSION OF AN IDENTIFICATION DOCUMENT, C.R.S. 18-5-903.5(1),(2)(a) (M1) <13086> 33 (1 count)

The Grand Jury presents the within Indictment and the same is ordered filed.

Dated this _________ day of ____________________, 2013.

_________________________________________

Martin F. Egelhoff Presiding JudgeDenver District Court



COUNT ONE

VIOLATION OF COLORADO ORGANIZED CRIME CONTROL ACT, C.R.S. 18-17-104(3),(F2) <37284>

Between and including August 1, 2012, and June 12, 2013, at and triable in the City and Countyof Denver, State of Colorado, STEVEN CHADWICK TAYLOR, while employed by or associated with an enterprise, namely: a group of individuals associated in fact, although not alegal 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 alegal entity. The enterprise included, but was not limited to, the following: STEVEN

CHADWICK TAYLOR, DESIREE KALENE JORDAN, CHRISTOPHER LEACH,JUSTIN CHARLES MURDOCK, RENEE ROSE SWENSON, KRYSTAL BALL, KENT

CLEMENTS, PETER CLINE, SARAH DOYLE, JOSHUA JOHNSON, PAUL

LAMBERT, JOSEPH MENZOR, SARAH RADIS, KIMBERLY ZORDEL, and other persons known or unknown, who were associated from time to time in racketeering activity thatwas 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 theenterprise, including:

As to STEVEN CHADWICK TAYLOR, the acts described in counts 2, 4 through 17, 19 and21, including any lesser included offenses of these counts, and Predicate Act 34 of thisIndictment.



PREDICATE ACT THIRTY FOUR

AGGRAVATED MOTOR VEHICLE THEFT IN THE SECOND DEGREE, C.R.S. 18-4-409(4),(b) (F6) <0804E>

On August 16, 2012, STEVEN CHADWICK TAYLOR, unlawfully, feloniously, andknowingly obtained or exercised control over the motor vehicle of RAYMOND JOHN

LOFFER , without authorization, or by threat or deception, and the value of the motor vehiclewas one thousand dollars or more, but less than twenty thousand dollars; in violation of section18-4-409(2),(3)(a), C.R.S.

COUNT TWO CONSPIRACY TO COMMIT AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRSTDEGREE, C.R.S. 18-4-409(2),(3)(a);18-2-201 (F5) <0804CC>

Between and including August 1, 2012 and June 12, 2013, at and triable in the City and County

of Denver, State of Colorado, STEVEN CHADWICK TAYLOR, DESIREE KALENEJORDAN, CHRISTOPHER LEACH, and JUSTIN CHARLES MURDOCK , with the intentto promote or facilitate the commission of the crime of AGGRAVATED MOTOR VEHICLE

THEFT IN THE FIRST DEGREE, unlawfully and feloniously agreed with each other and a person or persons to the Grand Jury unknown that one or more of them would engage in conductwhich constituted that crime or an attempt to commit that crime, or agreed to aid the other personor persons in the planning or commission or attempted commission of that crime, and an overtact in pursuance of the conspiracy was committed by one or more of the conspirators; inviolation of sections 18-4-409(2),(3)(a) and 18-2-201, C.R.S.

COUNT THREE CONSPIRACY TO COMMIT FORGERY, C.R.S. 18-5-102(1)(c);18-2-201 (F6) <1001CC>

On or about September 25, 2012, at and triable in the City and County of Denver, State of Colorado, DESIREE KALENE JORDAN, JUSTIN CHARLES MURDOCK, and RENEE

ROSE SWENSON, with the intent to promote or facilitate the commission of the crime of FORGERY, unlawfully and feloniously agreed with each other and a person or persons to theGrand Jury unknown that one or more of them would engage in conduct which constituted thatcrime 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 18-5-102(1)(c) and 18-2-201. C.R.S.

The facts supporting Counts 1 through 3 and Predicate Act 34 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein byreference.

2. From at least August 1, 2012, through June 12, 2013, Steven Chadwick Taylor, DesireeKalene Jordan, Christopher Leach, Justin Charles Murdock, Renee Rose Swenson, Krystal Ball,



Kent Clements, Peter Cline, Sarah Doyle, Joshua Johnson, Paul Lambert, Joseph Menzor, SarahRadis, Kimberly Zordel, and others, known and unknown to the Grand Jury, were a group of individuals associated in fact, though not a legal entity, with common goals. The common goalsof the members of the enterprise were to obtain, distribute and use controlled substances; to steal

automobiles; and to steal money, personal identifying information, financial identifyinginformation, consumer electronics, and other property, primarily through breaking into motor vehicles.

3. At all times relevant to this Indictment, Steven Chadwick Taylor, Desiree Kalene Jordan,Christopher Leach, Justin Charles Murdock, Renee Rose Swenson, Krystal Ball, Kent Clements,Peter Cline, Sarah Doyle, Joshua Johnson, Paul Lambert, Joseph Menzor, Sarah Radis, KimberlyZordel, and other members of the enterprise, associated with each other from time to time to buy,sell, trade and barter stolen property and/or money in exchange for controlled substances, primarily, but not limited to, methamphetamine.

4. At all times relevant to this Indictment, members of the enterprise, including but notlimited to Steven Chadwick Taylor, Desiree Kalene Jordan, Christopher Leach, Justin CharlesMurdock, Renee Rose Swenson, Krystal Ball, Kent Clements, Peter Cline, Sarah Doyle, SarahRadis, and Kimberly Zordel, stole motor vehicles and/or knowingly and unlawfully obtainedcontrol over stolen motor vehicles, including vehicles in the City and County of Denver, State of Colorado. Members of the enterprise also stole license plates from other vehicles and affixedthose stolen plates to stolen vehicles to conceal the origin of the stolen vehicles from lawenforcement officers. Members of the enterprise shared the stolen vehicles and the contents fromthose stolen vehicles, including checks, personal identifying information and financialidentifying information, to obtain money, services and products.

5. At all times relevant to this Indictment, as yet unidentified members of the enterpriseunlawfully gained entry into motor vehicles and stole items from those trespassed vehicles,including consumer electronics, tools, checks, personal identifying information, and financialidentifying information. Members of the enterprise, including but not limited to Desiree KaleneJordan, Justin Charles Murdock, and Renee Rose Swenson, shared stolen checks, personal andaccount information, and stolen identification documents to pass, or attempt to pass, forgedchecks.

6. Members of the enterprise shared money, stolen property, stolen personal and financialidentifying information, stolen checks, controlled substances, stolen automobiles, transportation,food, clothing, and living quarters to accomplish the enterprise’s goals.

7. As to Predicate Act 34, on or about August 16, 2012, Steven Chadwick Taylor unlawfully exercised control over the motor vehicle of Raymond John Loffer, and the vehiclewas valued at one thousand dollars or more, but less than twenty thousand dollars. StevenChadwick Taylor was charged for that offense, entered a guilty plea on March 11, 2013, to onecount of Aggravated Motor Vehicle Theft In The Second Degree, C.R.S. 18-4-409(4),(b), a classsix felony, in Jefferson County Court case number 2012CR2644, and was sentenced on May 20,2013.



COUNT FOUR AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, C.R.S. 18-4-409(2),(3)(a) (F4) <0804C>

Between and including August 21, 2012 and October 12, 2012, at and triable in the City andCounty of Denver, State of Colorado, STEVEN CHADWICK TAYLOR, unlawfully,feloniously, and knowingly obtained or exercised control over the motor vehicle of PAUL A.

GUMMERSON (2008 SUZUKI MOTORCYCLE #JS1GP74A282102285), withoutauthorization, or by threat or deception and retained possession or control over the motor vehiclefor more than twenty-four hours, and the value of the motor vehicle was twenty thousand dollarsor less; in violation of section 18-4-409(2),(3)(a), C.R.S.

The facts supporting Count 4 are as follows:

1. All facts in support of all other counts are incorporated herein by reference.

2. On or about August 21, 2012, Steven Chadwick Taylor, in association with theenterprise, unlawfully obtained control of a 2008 Suzuki motorcycle, vehicle identificationnumber JS1GP74A282102285, belonging to Paul A. Gummerson, from 8643 W. 65th Place, Cityof Arvada, Jefferson County, State of Colorado.

3. On or about August 31, 2012, Steven Chadwick Taylor used that motorcycle to interferewhen Arvada Police officers attempted to stop Kimberly Zordel and Peter Cline, who were in astolen vehicle, in Arvada, Jefferson County, Colorado. Steven Chadwick Taylor wasunsuccessful in drawing the police away from Zordel and Cline. Steven Chadwick Taylor fledthe scene and eventually hid the motorcycle at the home of Jason Dodge, 4752 S. Ouray Street,Aurora, Arapahoe County, Colorado.

4. On or about October 12, 2012, Paul A. Gummerson’s stolen motorcycle was recoveredfrom 4752 S. Ouray Street, Aurora, Arapahoe County, Colorado.

5. Paul A. Gummerson’s stolen motorcycle was valued at $5,000.00.



COUNT FIVE

THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K>

Between and including September 14, 2012 and September 30, 2012, at and triable in the City

and County of Denver, State of Colorado, STEVEN CHADWICK TAYLOR, unlawfully andfeloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value,namely: 1996 ACURA VEHICLE IDENTIFICATION NUMBER JH4DC445XTS023539

OF ELIZABETH BENNETT, and the defendant knew or believed the thing of value had beenstolen and intended to deprive the lawful owner permanently of its use or benefit, and the valueof the property was one thousand dollars or more but less than twenty thousand dollars; inviolation of section 18-4-410(1),(4), C.R.S.



2. On or about September 14, 2012, as yet unidentified members of the enterpriseunlawfully obtained control of a 1996 Acura, vehicle identification number JH4DC445XTS023539 of Elizabeth Bennett, from 18965 E. Baltic Place, City of Aurora,Arapahoe County, State of Colorado.

3. On or about September 30, 2012, Steven Chadwick Taylor admitted that he knew thevehicle was stolen and had used it. Steven Chadwick Taylor showed police officers where to findit. The vehicle was recovered in the 3200 Block of Shoshone Street in the City and County of Denver, State of Colorado.

4. Elizabeth Bennett’s stolen Acura was valued at $5,000.00.



COUNT SIX

THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K>


and County of Denver, State of Colorado, STEVEN CHADWICK TAYLOR, unlawfully andfeloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value,namely: 1998 DODGE TRUCK VEHICLE IDENTIFICATION NUMBER

1B7KF2367WJ240880 OF TOD HILL, and the defendant knew or believed the thing of valuehad been stolen and intended to deprive the lawful owner permanently of its use or benefit, andthe value of the property was one thousand dollars or more but less than twenty thousand dollars;in violation of section 18-4-410(1),(4), C.R.S.



2. On or about September 17, 2012, as yet unidentified members of the enterpriseunlawfully obtained control of a 1998 Dodge truck, vehicle identification number 1B7KF2367WJ240880 of Tod Hill, from 3254 S. Truckee Way, City of Aurora, ArapahoeCounty, State of Colorado.

3. On or about September 30, 2012, Steven Chadwick Taylor admitted that he knew wherethe stolen vehicle was located, and that it was in the process of being altered for resale. StevenChadwick Taylor showed police officers where to find it. The vehicle was recovered on West Ninth Avenue and Mariposa Street in the City and County of Denver, State of Colorado.

4. Colorado license plate 599TDY was recovered from Tod Hill’s stolen Dodge truck. Thatlicense plate was stolen from Robert and Emily Thate’s 2000 Dodge truck as shown in the factssupporting Count Seven.

5. Tod Hill’s stolen Dodge truck was valued at $8,000.00.



COUNT SEVEN

AGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, C.R.S. 18-4-409(2),(3)(a) (F4) <0804C>

Between and including September 23, 2012 and October 11, 2012, at and triable in the Cityand County of Denver, State of Colorado, STEVEN CHADWICK TAYLOR and

CHRISTOPHER LEACH, unlawfully, feloniously, and knowingly obtained or exercisedcontrol over the motor vehicle of ROBERT AND EMILY THATE (2000 DODGE TRUCK

#3B7KF2360YG115191), without authorization, or by threat or deception, and retained possession or control over the motor vehicle for more than twenty-four hours, and the value of the motor vehicle was twenty thousand dollars or less; in violation of section 18-4-409(2),(3)(a),C.R.S.



2. On or about September 23, 2012, Steven Chadwick Taylor, in association with theenterprise and in the presence of Sarah Radis, unlawfully obtained control of a 2000 Dodgetruck, vehicle identification number 3B7KF2360YG115191, belonging to Robert and EmilyThate, from 8870 W. 49th Place, unincorporated Jefferson County, State of Colorado.

3. Steven Chadwick Taylor told police officers that he had given the stolen 2000 Dodgetruck to Christopher “Cracker” Leach.

4. On or about October 10, 2012, Denver Police officers were called to the alleyway between W. 35th Avenue and W. 36th Avenue in the 4500 block to check on two prowlers.Officers contacted Christopher Leach and Kent Leroy Clements. Clements had business cardsfrom the Thate’s stolen truck in his possession. Clements later told officers that he was a passenger in a white Dodge truck with a broken ignition switch that Christopher Leach wasdriving.

5. On or about October 11, 2012, Denver Police officers recovered Robert and EmilyThate’s stolen white Dodge truck from that alleyway. The ignition switch was broken.

6. On or about September 25, 2012, personal identifying information and other items takenfrom the Thate’s stolen white Dodge truck were recovered from Desiree Kalene Jordan andJustin Charles Murdock ’s residence, 8468 W. 53rd Avenue, City of Arvada, Jefferson County,Colorado.

7. On or about September 30, 2012, one of the license plates from the Thate’s stolen whiteDodge truck was recovered in Tod Hill’s stolen truck as noted in the facts supporting Count Sixof this Indictment.

8. Robert and Emily Thate’s stolen Dodge truck was valued at $10,000.00.



COUNT EIGHT

AGGRAVATED MOTOR VEHICLE THEFT IN THE SECOND DEGREE, C.R.S. 18-4-409(4)(c) (M1) <0804F>

Between and including September 23, 2012 and September 26, 2013, at and triable in the Cityand County of Denver, State of Colorado, STEVEN CHADWICK TAYLOR, unlawfully andknowingly obtained or exercised control over the motor vehicle of JAMES HEIDEN (1993

FORD PROBE #1ZVCT2J0AXP5177660), without authorization or by threat or deception,and the value of the motor vehicles was less than one thousand dollars; in violation of section 18-4-409(4)(c), C.R.S.



2. On or about September 23, 2012, Steven Chadwick Taylor, in association with theenterprise, unlawfully obtained control of a 1993 Ford Probe, vehicle identification number 1ZVCT2J0AXP5177660, belonging to James Heiden, from 5383 Carr Street, City of Arvada,Jefferson County, State of Colorado.

3. On or about September 25, 2012, property from James Heiden’s stolen 1993 Ford Probewas recovered in another stolen vehicle in front of Desiree Kalene Jordan and Justin CharlesMurdock’s residence, 8468 W. 53rd Avenue, City of Arvada, Jefferson County, Colorado. Theother stolen car was taken from Marco Azevedo as shown in the facts supporting Count Nineteen.

4. Steven Chadwick Taylor told police officers that he had stolen the 1993 Probe.

5. James Heiden’s stolen 1993 Ford Probe was valued at $750.00.



COUNT NINE


Between and including September 23, 2012 and September 25, 2012, at and triable in the Cityand County of Denver, State of Colorado, STEVEN CHADWICK TAYLOR, unlawfully,feloniously, and knowingly obtained or exercised control over the motor vehicle of CARLOS

TREJO (1968 FORD TRUCK #F25YRD03488), without authorization, or by threat or deception, and retained possession or control over the motor vehicle for more than twenty-four hours, and the value of the motor vehicle was twenty thousand dollars or less; in violation of section 18-4-409(2),(3)(a), C.R.S.

COUNT TENAGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, C.R.S. 18-4-409(2),(3)(a) (F4) <0804C>

Between and including September 23, 2012 and September 25, 2012, at and triable in the Cityand County of Denver, State of Colorado, STEVEN CHADWICK TAYLOR, unlawfully,feloniously, and knowingly obtained or exercised control over the motor vehicle of CARLOS

TREJO (1992 KAWASAKI MOTORCYCLE #16353624740001), without authorization, or by threat or deception, and retained possession or control over the motor vehicle for more thantwenty-four hours, and the value of the motor vehicle was twenty thousand dollars or less; inviolation of section 18-4-409(2),(3)(a), C.R.S.

The facts supporting Counts 9 and 10 are as follows:


2. On or about September 23, 2012, Steven Chadwick Taylor, in association with theenterprise and in the presence of Sarah Radis, unlawfully obtained control of a 1968 Ford truck,vehicle identification number F25YRD03488, belonging to Carlos Trejo, from 1056 S. SalemStreet, City of Aurora, Arapahoe County, State of Colorado.

3. A 1992 Kawasaki motorcycle, vehicle identification number 16353624740001, belongingto Mr. Trejos, was in the truck bed when Steven Chadwick Taylor stole the truck.

4. After stealing the truck and motorcycle, Steven Chadwick Taylor, in association with theenterprise and in the presence of Sarah Radis, brought both vehicles to Desiree Kalene Jordanand Justin Charles Murdock’s residence, 8468 W. 53rd Avenue, City of Arvada, JeffersonCounty, Colorado.

5. On or about September 25, 2102, Arvada Police officers recovered the truck parked onthe street near Desiree Kalene Jordan and Justin Charles Murdock’s residence, 8468 W. 53rdAvenue, Arvada, Colorado. Officers also recovered the actual Colorado driver’s license andinstruction permits of Homero Navarro, Jr., inside the stolen truck. Mr. Navarro’s 1995 Honda



Accord, containing those documents, had been stolen on or about September 24, 2012, from2991 W. Centennial Drive, City of Littleton, Arapahoe County, Colorado.

6. Officers also recovered a checkbook belonging to Rochelle A. Henneman. That

checkbook was in a car stolen from 5340 Carr Street on or about September 23, 2012, as noted inthe facts supporting Count Twenty-One of this Indictment.

7. The stolen Kawasaki motorcycle was recovered in the garage of Desiree Kalene Jordanand Justin Charles Murdock’s residence, 8468 W. 53rd Avenue, Arvada, Jefferson County,Colorado.

8. Steven Chadwick Taylor told police officers that he had stolen the truck and motorcycle,and that the motorcycle was moved out of the truck and into the garage by Desiree KaleneJordan and/or Justin Charles Murdock.

9. Carlos Trejo’s stolen Ford truck was valued at $8,300.00.

10. Carlos Trejo’s stolen Kawasaki motorcycle was valued at $1,725.00.



COUNT ELEVEN


Between and including September 27, 2012 and September 30, 2012, at and triable in the Cityand County of Denver, State of Colorado, STEVEN CHADWICK TAYLOR, unlawfully,feloniously, and knowingly obtained or exercised control over the motor vehicle of KEVIN

FERGUSON (2001 FORD VAN #1FTNE24L41HA12940), without authorization, or by threator deception, and retained possession or control over the motor vehicle for more than twenty-four hours, and the value of the motor vehicle was twenty thousand dollars or less; in violation of section 18-4-409(2),(3)(a), C.R.S.



2. On or about September 27, 2012, Steven Chadwick Taylor, in association with theenterprise, unlawfully obtained control of a 2001 Ford van, vehicle identification number 1FTNE24L41HA12940, belonging to Kevin Ferguson, from 10255 Dover Street, City of Westminster, Jefferson County, State of Colorado.

3. On or about September 30, 2012, Steven Chadwick Taylor showed police officers whereto find it. The vehicle was recovered at 12100 W. 44th Avenue, City of Wheat Ridge, JeffersonCounty, State of Colorado.

4. Steven Chadwick Taylor told police officers that he had stolen the 2001 Ford van.

5. K evin Ferguson’s stolen 2001 Ford van was valued at $2,500.00.



COUNT TWELVE


Between and including September 27, 2012 and September 30, 2012, at and triable in the Cityand County of Denver, State of Colorado, STEVEN CHADWICK TAYLOR, unlawfully,feloniously, and knowingly obtained or exercised control over the motor vehicle of JOHN

STALTER (2003 VOLKSWAGEN JETTA #WVWSP61J93W584155), withoutauthorization, or by threat or deception and retained possession or control over the motor vehiclefor more than twenty-four hours, and the value of the motor vehicle was twenty thousand dollarsor less; in violation of section 18-4-409(2),(3)(a), C.R.S.



2. On or about September 27, 2012, Steven Chadwick Taylor, in association with theenterprise, unlawfully obtained control of a 2003 Volkswagen Jetta TDI, vehicle identificationnumber WVWSP61J93W584155, belonging to John Stalter, from 11153 103rd Circle, City of Westminster, Jefferson County, State of Colorado.

3. On or about September 30, 2012, Steven Chadwick Taylor showed police officers whereto find it. The vehicle was recovered at 10255 Dover Street, Westminster, Jefferson County,State of Colorado.

4. Steven Chadwick Taylor told police officers that he had stolen the 2003 Volkswagen.

5. John Stalter’s stolen 2003 Volkswagen Jetta TDI was valued at $10,000.00.



COUNT THIRTEEN


Between and including September 28, 2012 and September 30, 2012, at and triable in the Cityand County of Denver, State of Colorado, STEVEN CHADWICK TAYLOR, unlawfully,feloniously, and knowingly obtained or exercised control over the motor vehicle of DONALD

KUNZ (1995 HARLEY DAVIDSON MOTORCYCLE #1HD1CAP10SY226994), withoutauthorization, or by threat or deception and retained possession or control over the motor vehiclefor more than twenty-four hours, and the value of the motor vehicle was twenty thousand dollarsor less; in violation of section 18-4-409(2),(3)(a), C.R.S.



2. On or about September 28, 2012, Steven Chadwick Taylor, in association with theenterprise, unlawfully obtained control of a 1995 Harley Davidson motorcycle, vehicleidentification number 1HD1CAP10SY226994, belonging to Donald Kunz, from 2905 N.Osceola Street, City and County of Denver, State of Colorado.

3. On or about September 30, 2012, Steven Chadwick Taylor showed police officers whereto find it. The vehicle was recovered at 9201 Oberon Road, Arvada, Jefferson County, State of Colorado.

4. Steven Chadwick Taylor told police officers that he had stolen the 1995 Harley Davidsonmotorcycle.

5. Donald Kunz’s stolen 1995 Harley Davidson motorcycle was valued at $5,000.00.



COUNT FOURTEEN

AGGRAVATED MOTOR VEHICLE THEFT IN THE SECOND DEGREE, C.R.S. 18-4-409(4)(b) (F6) <0804E>

Between and including September 29, 2012 and September 30, 2012, at and triable in the Cityand County of Denver, State of Colorado, STEVEN CHADWICK TAYLOR, unlawfully,feloniously, and knowingly obtained or exercised control over the motor vehicle of PAUL

LINDHAL (1992 HARLEY DAVIDSON MOTORCYCLE #1HD4CEM10NY203020),without authorization or by threat or deception, and the value of the motor vehicle was onethousand dollars or more but less than twenty thousand dollars; in violation of section18-4-409(4)(b), C.R.S.



2. On or about September 29, 2012, Steven Chadwick Taylor, in association with theenterprise, unlawfully obtained control of a 1992 Harley Davidson motorcycle, vehicleidentification number 1HD4CEM10NY203020, belonging to Paul Lindhal, from 2839 IngallsStreet, City of Edgewater, Jefferson County, State of Colorado.

3. On or about September 30, 2012, Steven Chadwick Taylor showed police officers whereto find it. The vehicle was recovered at 6920 W. 47 th Place, Wheat Ridge, Jefferson County,State of Colorado.

4. Steven Chadwick Taylor told police officers that he had stolen the 1995 Harley Davidsonmotorcycle.

5. Paul Lindhal’s stolen 1992 Harley Davidson motorcycle was valued at $4,000.00.



COUNT FIFTEEN


Between and including September 29, 2012 and September 30, 2012, at and triable in the Cityand County of Denver, State of Colorado, STEVEN CHADWICK TAYLOR, unlawfully,feloniously, and knowingly obtained or exercised control over the motor vehicle of CHRISTOPHER CEDILLO (1999 DODGE RAM 250 TRUCK #1B7KF2364XJ522654),without authorization or by threat or deception, and the value of the motor vehicle was onethousand dollars or more but less than twenty thousand dollars; in violation of section18-4-409(4)(b), C.R.S.



2. On or about September 29, 2012, Steven Chadwick Taylor, in association with theenterprise, unlawfully obtained control of a 1999 Dodge Ram 250 truck, vehicle identificationnumber 1B7KF2364XJ522654, belonging to Christopher Cedillo, from 4745 Reed Street, City of Wheat Ridge, Jefferson County, State of Colorado.

3. Steven Chadwick Taylor took this truck to the Motel Six, 9920 W. 49th Avenue, City of Wheat Ridge, Jefferson County, State of Colorado, and left it there when he stole the truck andtrailer listed in counts Sixteen and Seventeen of this Indictment. Steven Chadwick Taylor took personally identifying information of Christopher Cedillo from this truck with him when he stolethe truck and trailer noted in Counts Sixteen and Seventeen.

4. Steven Chadwick Taylor told police officers that he had stolen the 1999 Dodge Ram 250truck.

5. Christopher Cedlillo’s stolen 1999 Dodge Ram 250 truck was valued at $12,000.00.



COUNT SIXTEEN


Between and including September 29, 2012 and September 30, 2012, at and triable in the Cityand County of Denver, State of Colorado, STEVEN CHADWICK TAYLOR, unlawfully,feloniously, and knowingly obtained or exercised control over the motor vehicle of RALPH

MENKE (2006 FORD TRUCK #1FTSW21566EA26854), without authorization or by threator deception, and the value of the motor vehicle was one thousand dollars or more but less thantwenty thousand dollars; in violation of section18-4-409(4)(b), C.R.S.

COUNT SEVENTEENTHEFT, C.R.S. 18-4-401(1),(2)(c), (F4) <0801U>


and County of Denver, State of Colorado, STEVEN CHADWICK TAYLOR, unlawfully,feloniously, and knowingly obtained or exercised control over a thing of value, namely:

HAULMARK TRAILER, SERIAL NUMBER 4RACS16237N054036, AND CONTENTS, OF RALPH MENKE, with the value of $1,000.00 dollars or more but less than $20,000.00dollars, without authorization, or by threat or deception, and intended to deprive RALPH

MENKE permanently of its use or benefit, or knowingly used, concealed, or abandoned thething of value in such manner as to permanently deprive RALPH MENKE of its use or benefit,or knowingly used, concealed, or abandoned the thing of value intending that such use,concealment, or abandonment would deprive RALPH MENKE permanently of its use or benefit; in violation of section 18-4-401(1)(a)-(c),(2)(c), C.R.S.

COUNT EIGHTEENPOSSESSION OF BURGLARY TOOLS, C.R.S. 18-4-205(1) (F5) <06051>

On or about September 30, 2012, at and triable in the City and County of Denver, State of Colorado, STEVEN CHADWICK TAYLOR, unlawfully and feloniously possessed anexplosive, tool, instrument, or other article, namely: ALTERED IGNITION KEYS, adapted,designed, or commonly used for committing or facilitating the commission of an offenseinvolving forcible entry into premises or theft by physical taking, and the defendant intended touse the thing possessed in the commission of such an offense; in violation of section 18-4-205(1), C.R.S.



COUNT NINETEEN

POSSESSION OF METHAMPHETAMINE - 2 GRAMS OR LESS, C.R.S. 18-18-403.5(1),(2)(b)(I) (F6) < 8201B> On or about September 30, 2012, at and triable in the City and County of Denver, State of Colorado, STEVEN CHADWICK TAYLOR, unlawfully, feloniously, and knowingly possessed two grams or less of a material, compound, mixture, or preparation that containedMethamphetamine, a controlled substance; in violation of section 18-18-403.5(1),(2)(b)(I),C.R.S.

The facts supporting Counts 16 through 19 are as follows:


On or about September 29, 2012, Steven Chadwick Taylor, in association with the enterprise,

unlawfully obtained control of a 2006 Ford truck, vehicle identification number 1FTSW21566EA26854, belonging to Ralph Menke, from the parking lot at the Motel Six, 9920W. 49th Avenue, City of Wheat Ridge, Jefferson County, State of Colorado.

3. Ralph Menke’s Haulmark Trailer, Serial Number 4RACS16237N054036, filled with personal property, including firearms, was attached to the 2006 Ford truck when StevenChadwick Taylor stole the truck.

4. Steven Chadwick Taylor took this truck and trailer to the north 3200 block of ShoshoneStreet in the City and County of Denver, State of Colorado. There, Steven Chadwick Taylor wasarrested by Denver Police officers in the possession of the truck and trailer.

5. Personal and financial identifying information form Christopher Cedillo was recoveredfrom the truck, as noted in the facts supporting Count Fifteen of this Indictment.

6. Steven Chadwick Taylor had in his possession altered ignition keys, known as “jiggler keys”, that are commonly used for stealing motor vehicles.

7. Steven Chadwick Taylor had in his possession less than two grams of methamphetamine.

8. Steven Chadwick Taylor told police officers that he had stolen the 2006 Ford truck andtrailer.

9. Ralph Menke’s stolen 2006 Ford truck was valued at $10,000.00.

10. Ralph Menke’s stolen Haulmark trailer and contents was valued at $3,000.00.



COUNT TWENTY


Between and including September 20, 2012 and September 25, 2012, at and triable in the Cityand County of Denver, State of Colorado, DESIREE KALENE JORDAN and JUSTIN

CHARLES MURDOCK, unlawfully, feloniously, and knowingly obtained or exercised controlover the motor vehicle of MAYRA SOTO (1993 HONDA ACCORD

#1HGCB7285PA001914), without authorization, or by threat or deception, and retained possession or control over the motor vehicle for more than twenty-four hours, and the value of the motor vehicle was twenty thousand dollars or less; in violation of section 18-4-409(2),(3)(a),C.R.S.

COUNT TWENTY-ONEAGGRAVATED MOTOR VEHICLE THEFT IN THE FIRST DEGREE, C.R.S. 18-4-

409(2),(3)(a) (F4) <0804C>

Between and including September 23, 2012 and September 25, 2012, at and triable in the Cityand County of Denver, State of Colorado, STEVEN CHADWICK TAYLOR, DESIREE

KALENE JORDAN, and JUSTIN CHARLES MURDOCK, unlawfully, feloniously, andknowingly obtained or exercised control over the motor vehicle of MARCO AZEVEDO (1996

HONDA ACCORD #1HGCE667XTA027308), without authorization, or by threat or deception, and retained possession or control over the motor vehicle for more than twenty-four hours, and the value of the motor vehicle was twenty thousand dollars or less; in violation of section 18-4-409(2),(3)(a), C.R.S.

COUNT TWENTY-TWOTHEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K>

Between and including September 23, 2012 and September 25, 2012, at and triable in the Cityand County of Denver, State of Colorado, DESIREE KALENE JORDAN and JUSTIN

CHARLES MURDOCK, unlawfully and feloniously received, retained, loaned money by pawnor pledge, or disposed of a thing of value, namely: 1992 KAWASAKI MOTORCYCLE

VEHICLE IDENTIFICATION NUMBER 16353624740001, OF CARLOS TREJO, and thedefendant knew or believed the thing of value had been stolen and intended to deprive the lawfulowner permanently of its use or benefit, and the value of the property was one thousand dollarsor more but less than twenty thousand dollars; in violation of section 18-4-410(1),(4), C.R.S.



COUNT TWENTY-THREE

IDENTITY THEFT, C.R.S. 18-5-902(1)(b) (F4) <1307H>

On or about September 25, 2012, at and triable in the City and County of Denver, State of

Colorado, DESIREE KALENE JORDAN and JUSTIN CHARLES MURDOCK, unlawfully,feloniously, and knowingly possessed the personal identifying information, financial identifyinginformation, or financial device of ERICA MICHELLE ORTEGA without permission or lawful authority, with the intent to use or to aid or permit another person to use the informationor device to obtain cash, credit, property, services, or any other thing of value or to make afinancial payment; in violation of section 18-5-902(1)(b), C.R.S.

COUNT TWENTY-FOUR IDENTITY THEFT, C.R.S. 18-5-902(1)(c) (F4) <1307J>


Colorado, DESIREE KALENE JORDAN and JUSTIN CHARLES MURDOCK, unlawfully,feloniously, and with the intent to defraud, falsely made, completed, altered, or uttered a writteninstrument or financial device containing personal identifying information or financialidentifying information of ERICA MICHELLE ORTEGA; in violation of section 18-5-902(1)(c), C.R.S.

COUNT TWENTY-FIVE


On or about September 25, 2012, at and triable in the City and County of Denver, State of Colorado, DESIREE KALENE JORDAN, and JUSTIN CHARLES MURDOCK, unlawfully, feloniously, and knowingly possessed the personal identifying information, financialidentifying information, or financial device of ROCHELLE A. HENNEMAN without permission or lawful authority, with the intent to use or to aid or permit another person to use theinformation or device to obtain cash, credit, property, services, or any other thing of value or tomake a financial payment; in violation of section 18-5-902(1)(b), C.R.S.

COUNT TWENTY-SIXIDENTITY THEFT, C.R.S. 18-5-902(1)(b) (F4) <1307H>

On or about September 25, 2012, at and triable in the City and County of Denver, State of Colorado, DESIREE KALENE JORDAN, JUSTIN CHARLES MURDOCK, and RENEE

ROSE SWENSON, unlawfully, feloniously, and knowingly possessed the personal identifyinginformation, financial identifying information, or financial device of EMIL J. ERICKSON without permission or lawful authority, with the intent to use or to aid or permit another personto use the information or device to obtain cash, credit, property, services, or any other thing of value or to make a financial payment; in violation of section 18-5-902(1)(b), C.R.S.



COUNT TWENTY-SEVEN



Colorado, DESIREE KALENE JORDAN and JUSTIN CHARLES MURDOCK, unlawfully,feloniously, and knowingly possessed the personal identifying information, financial identifyinginformation, or financial device of WAYNE HERRICK without permission or lawful authority,with the intent to use or to aid or permit another person to use the information or device to obtaincash, credit, property, services, or any other thing of value or to make a financial payment; inviolation of section 18-5-902(1)(b), C.R.S.

COUNT TWENTY-EIGHTIDENTITY THEFT, C.R.S. 18-5-902(1)(b) (F4) <1307H>


Colorado, DESIREE KALENE JORDAN and JUSTIN CHARLES MURDOCK, unlawfully,feloniously, and knowingly possessed the personal identifying information, financial identifyinginformation, or financial device of JARED WHALEN without permission or lawful authority,with the intent to use or to aid or permit another person to use the information or device to obtaincash, credit, property, services, or any other thing of value or to make a financial payment; inviolation of section 18-5-902(1)(b), C.R.S.

COUNT TWENTY-NINEFORGERY, C.R.S. 18-5-102(1)(c) (F5) <1001C>

On or about September 25, 2012, at and triable in the City and County of Denver, State of Colorado, DESIREE KALENE JORDAN, with the intent to defraud EMIL J. ERIKSON and TARGET, unlawfully, feloniously, and falsely made, completed, altered, or uttered a writteninstrument which was or which purported to be, or which was calculated to become or torepresent if completed, A CHECK , which document did or may have evidenced, created,transferred, terminated, or otherwise affected a legal right, interest, obligation, or status, namely:CHECK NUMBER 1217 OF EMIL J. ERICKSON; in violation of section 18-5-102(1)(c),C.R.S.

COUNT THIRTY

FORGERY, C.R.S. 18-5-102(1)(c) (F5) <1001C>

On or about September 25, 2012, at and triable in the City and County of Denver, State of Colorado, JUSTIN CHARLES MURDOCK, with the intent to defraud WAYNE HERRICK

and TARGET, unlawfully, feloniously, and falsely made, completed, altered, or uttered awritten instrument which was or which purported to be, or which was calculated to become or torepresent if completed, A CHECK , which document did or may have evidenced, created,transferred, terminated, or otherwise affected a legal right, interest, obligation, or status, namely:CHECKS OF WAYNE HERRICK ; in violation of section 18-5-102(1)(c), C.R.S.



COUNT THIRTY-ONE

CRIMINAL POSSESSION OF AN IDENTIFICATION DOCUMENT, C.R.S. 18-5-903.5(1),(2)(b) (F6) <13087>

On or about September 25, 2012, at and triable in the City and County of Denver, State of Colorado, DESIREE KALENE JORDAN and JUSTIN CHARLES MURDOCK, unlawfully,knowingly, and feloniously had in their possession or under their control actual driver's licenses,actual government-issued identification cards, actual social security cards, or actual passports of

HOMERO NAVARRO, JR., TOMIE EILERS, ANDREW JOHNS WILLIAMS, AND

DONALD ARTHUR RIGGS, knowing that the defendants did so without permission or lawfulauthority; in violation of section 18-5-903.5(1),(2)(b), C.R.S.

COUNT THIRTY-TWOPOSSESSION OF IDENTITY THEFT TOOLS, C.R.S. 18-5-905 (F5) <13085>

On or about September 25, 2012, at and triable in the City and County of Denver, State of Colorado, DESIREE KALENE JORDAN and JUSTIN CHARLES MURDOCK, unlawfullyand feloniously possessed tools, equipment, computer, computer network, scanner, printer, or other article adapted, designed, or commonly used for committing or facilitating the commissionof the offense of identity theft, and intended to use the thing possessed, or knew that a personintended to use the thing possessed, in the commission of the offense of identity theft; inviolation of section 18-5-905, C.R.S.

COUNT THIRTY-THREECRIMINAL POSSESSION OF AN IDENTIFICATION DOCUMENT, C.R.S. 18-5-903.5(1),(2)(a) (M1) <13086>

On or about September 25, 2012, at and triable in the City and County of Denver, State of Colorado, RENEE ROSE SWENSON, unlawfully and knowingly had in her possession or under her control an actual driver's license, actual government-issued identification card, actualsocial security card, or actual passport of CONSTANCE LOUISE GUARNERO, knowing thatthe defendant did so without permission or lawful authority; in violation of section 18-5-903.5(1),(2)(a), C.R.S.

The facts supporting Counts 20 through 33 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein byreference.

2. On September 25, 2012, Desiree Kalene Jordan and Justin Charles Murdock resided at8468 W. 53rd Avenue, City of Arvada, Jefferson County, State of Colorado.

3. On or about September 20, 2012, an as yet unidentified member of the enterpriseunlawfully obtained control of a 1993 Honda Accord, vehicle identification number 1HGCB7285PA001914, belonging to Mayra Soto, from 9600 W. 51st Place, City of Wheat



Ridge, Jefferson County, State of Colorado. That vehicle was valued at $1,900.00.

4. On September 25, 2012, Desiree Kalene Jordan, Justin Charles Murdock, and ReneeRose Swenson used Mayra Soto’s stolen vehicle for transportation to various Target stores,

where they attempted to buy cell phones with forged checks, as noted below.

5. On September 25, 2012, Arvada Police officers arrested Desiree Kalene Jordan, JustinCharles Murdock, and Renee Rose Swenson after they exited Mayra Soto’s stolen vehicle atDesiree Kalene Jordan and Justin Charles Murdock’s residence, 8468 W. 53rd Avenue, Arvada,Jefferson County, Colorado. Justin Murdock had been driving the car. Justin Murdock toldofficers that he knew the car was stolen, and that he had received it from Sarah Radis inexchange for controlled substances.

6. The following property and personal identifying information and documents wererecovered from Mayra Soto’s stolen vehicle on September 25, 2012:

A. Emil Erickson forged check #1217, torn up;B. Actual Arapahoe Community College official employee identification for

Tomie Eilers;C. Actual United States Passport for Donald Arthur Riggs;D. Actual Social Security card for Andrew J. Williams;E. Actual Colorado automobile registration card for Andrew J. and Kimberly

J. Williams;F. Justin Charles Murdock’s Acer computer.

7. Automobiles owned by Emil Erickson, Tomie Eilers, and Andrew J. Williams had been broken into by as-yet unidentified members of the enterprise within one week of the recovery of their property from Mayra Soto’s stolen car on September 25, 2012.

8. On or about September 23, 2012, Steven Chadwick Taylor, in association with theenterprise, unlawfully obtained control of a 1996 Honda Accord, vehicle identification number 1HGCE667XTA027308, belonging to Marco Azevedo, from 5340 Carr Street, City of Arvada,Jefferson County, State of Colorado. That vehicle was valued at $2,400.00. Rochelle A.Henneman had her personal checks in Marco Azevedo’s vehicle when it was stolen.

9. Between September 23, 2012, and September 25th, 2012, Steven Chadwick Taylor brought the car to Desiree Kalene Jordan and Justin Charles Murdock’s residence, 8468 W. 53rd Avenue, Arvada, Jefferson County, Colorado. On September 25, 2012, Arvada Police officersrecovered Marco Azevedo’s stolen 1996 Honda Accord from the street in front of DesireeKalene Jordan and Justin Charles Murdock ’s residence on W. 53rd Avenue.

10. The following personal property was recovered from Marco Azevedo’s stolen vehicle onSeptember 25, 2012:

A. Clothing and other property belonging to Desiree Kalene Jordan;



B. At least fourteen “jiggler keys”; C. Sam’s Club identification in the name of Kelsie Holden;D. James Heiden and Derrick Booco work coats that had been stolen from

Mr. Heiden’s 1993 Ford Probe, as noted in the facts supporting Count

Eight of this Indictment.

11. As noted in the facts supporting Counts Nine and Ten of this Indictment, StevenChadwick Taylor stole a Ford truck and a Kawasaki motorcycle belonging to Carlos Trejos.Steven Chadwick Taylor brought those stolen vehicles to Desiree Kalene Jordan and JustinCharles Murdock ’s residence on W. 53rd Avenue. Desiree Kalene Jordan and/or Justin CharlesMurdock took Trejo’s stolen motorcycle from the truck bed and moved it into the garage at 8468W. 53rd Avenue, Arvada, Jefferson County, Colorado. That motorcycle was recovered from thegarage on September 25, 2012.

12. On or about September 14, 2012, Erica Michelle Ortega’s purse was stolen from the

MGM Lounge, 4800 Morrison Road, City and County of Denver, State of Colorado. That pursecontained personal and financial identifying information of Erica Michelle Ortega, includingCommunity Financial Credit Union checks, account number 3661402.

13. On September 25, 2012, a counterfeit computer generated check with Erica MichelleOrtega’s personal identifying information was recovered from Desiree Kalene Jordan and JustinCharles Murdock’s residence on W. 53rd Avenue. A printer/scanner, computer speakers andlaptop charger were recovered in the same area as the counterfeit check.

14. Images of Erica Michelle Ortega’s Community Financial Credit Union checks containingthe account information were recovered from Justin Charles Murdock’s Acer laptop computer.That computer was found in Mayra Soto’s stolen vehicle as noted above. Justin Charles Murdock told officers that he had made counterfeit checks with that computer.

15. As noted above, Rochelle A. Henneman’s personal checks were in Marco Azevedo’svehicle when it was stolen by Steven Chadwick Taylor on or about September 23, 2012.

16. On or about September 24, 2012, check number 1094 from that account was passed for $100.59 by an as-yet unidentified member of the enterprise at King Soopers, 12350 W. 64th Avenue, Arvada, Jefferson County, Colorado.

17. Some of those checks were recovered from Mr. Trejo’s stolen 1968 Ford truck onSeptember 25, 2012 in front of Desiree Kalene Jordan and Justin Charles Murdock’s residenceon W. 53rd Avenue. Additional checks from that account were recovered from the basement of Desiree Kalene Jordan and Justin Charles Murdock’s residence, including check number 1091that had a forged “Rochelle Henneman” signature.

18. Between September 24, 2012, and September 25, 2012, Emil J. Erickson’s personalWells Fargo Bank checks were stolen from his vehicle while it was parked at his residence, 3450Estes Street, City of Wheat Ridge, Jefferson County, State of Colorado. On September 25, 2012



at approximately 9:25 AM, Desiree Kalene Jordan uttered forged Emil J. Erickson check number 1217 in the amount of $325.65 at the Target store, 5071 Kipling Street, City of Wheat Ridge,Jefferson County, State of Colorado. That transaction was not successful and the check wasreturned to Desiree Kalene Jordan. That check was recovered from Mayra Soto’s stolen car as

noted above.

19. On September 25, 2012, Renee Rose Swenson possessed, without authorization, Emil J.Erickson’s check #1220. That check was filled out to “Constance Guarnero” in the amount of $650.00 with “rent” written in the memo line. Renee Rose Swenson also possessed, withoutauthorization, the actual Colorado driver’s license for Constance Louise Guarnero. Ms.Guarnero’s driver’s license was stolen while she was at the Hangar Bar, 8001 East ColfaxAvenue, City and County of Denver, State of Colorado, on an unspecified date prior toSeptember 25, 2012.

20. Desiree Kalene Jordan and Justin Charles Murdock came into unauthorized possession of

Wayne Herrick’s personal Wachovia checks. On September 25, 2012 at approximately 10:20AM, Justin Charles Murdock uttered forged Wayne Herrick check number 140 in the amount of $327.50 at the Target store, 1985 Sheridan Boulevard, City of Edgewater, Jefferson County,State of Colorado. Justin Charles Murdock identified himself as “Jared Whalen”. Thattransaction was not successful and the check was returned to Justin Charles Murdock. That check was recovered from Justin Charles Murdock on September 25, 2012, when he was arrested byArvada Police officers as noted above.

21. On September 25, 2012, Wayne Herrick ’s personal checks and a prescription bottle wererecovered from Desiree Kalene Jordan and Justin Charles Murdock’s residence on W. 53rd Avenue.

22. When Justin Charles Murdock was contacted by Arvada Police on September 25, 2012,he had in his possession the actual Colorado identification card and Social Security card for Jared Whalen. Jared Whalen was in the custody of the Colorado Department of Corrections atthe time and did not give Justin Charles Murdock authorization to possess Whalen’s identification documents. Jared Whalen did not authorize Justin Charles Murdock to identifyMurdock as Jared Whalen.

23. When Justin Charles Murdock was contacted by Arvada Police on September 25, 2012;he had in his possession the actual Colorado driver’s license for Andrew Johns Williams. Mr.William’s vehicle had been broken into and his documents stolen as noted above in paragraph 7.

Steven Taylor Et. Al. Indictment

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Transcript of Steven Taylor Et. Al. Indictment