hoskins et al indictment

7/28/2019 Hoskins Et Al Indictment

http://slidepdf.com/reader/full/hoskins-et-al-indictment 1/65

DISTRICT COURT, CITY AND COUNTY OF DENVER,COLORADO

1437 Bannock StreetDenver, CO 80202

THE PEOPLE OF THE STATE OF COLORADO,

v.

CONLEY HOSKINSDALLAN DIRKMAATDAVID KRAUSE (A.K.A. “Filthy Frank”)BRENDEN JOYCE (A.K.A. “Meat”) NATHAN NEWMAN (A.K.A. “Nate Newman”)KURT CRITER YESENIA MELENDEZ (A.K.A. “Yessie Melendez”)CARLOS MEZARYAN TRIPP

DIALYNE PARKER GERALD SEARLEAUDRA WIMER

5105 E. 39th AVE., LLCJANE MEDICALS, LLCALL CARE WELLNESS, LLC (D.B.A. “JANE MEDICALS”)THE PEOPLE’S LAW FIRM (A.K.A. THE PEOPLE’S LAWFIRM, LLC)RAINMAKER MANAGEMENT, LLC

Defendants. COURT USE ONLY

JOHN W. SUTHERS, Attorney GeneralMICHAEL W. MELITO*Senior Assistant Attorney General1300 Broadway, 9th Floor Denver, CO 80203720 508 6702Registration Number: 36059*Counsel of Record

Grand Jury Case No.: 12CR01

Ctrm: 209

COLORADO STATE GRAND JURY INDICTMENT

Of the 2012-2013 term of the Denver District Court in the year 2013; the 2012-2013

Colorado State Grand Jurors, chosen, selected and sworn in the name and by the authority of thePeople of the State of Colorado, upon their oaths, present the following:

COUNT ONE: COCCA-Pattern of Racketeering – Participation in anEnterprise, §18-17-104(3), C.R.S. (F2) 37284

COUNT TWO: COCCA-Conspiracy/Endeavoring, §18-17-104(4), C.R.S. (F2) 37285



2

COUNT THREE: Violation of the Colorado Organized Crime Control Act – Pattern of Racketeering – Acquire Interest in Enterprise, 18-17-104(2), C.R.S.(F2) 37283

COUNT FOUR: Cultivation of Marijuana, More than Thirty Plants,§18-18-406(7.5)(c), C.R.S. (F4) 88033

COUNT FIVE: Conspiracy to Commit Cultivation of Marijuana, More than ThirtyPlants, §18-18-406(7.5)(c), §18-2-201, C.R.S. (F5) CON

COUNT SIX: Distribution of Marijuana – Five to One Hundred Pounds,§18-18-406(6)(b)(I),(III)(B), C.R.S. (F4) 88023

COUNT SEVEN: Conspiracy to Distribute, or Possess with Intent to Manufacture or Distribute, Marijuana – Five to One Hundred Pounds,§18-18-406(6)(b)(I),(III)(B), C.R.S. (F4) 88052

COUNT EIGHT: Money Laundering – Conduct Financial Transaction with Intent to

Promote Crime, §18-5-309(1)(a)(I), C.R.S. (F3) 12211

COUNT NINE: Computer Crime – Scheme /Defraud - $20,000 or More,C.R.S. §18-5.5-102(1)(b), C.R.S. (F3) 1502T

COUNT TEN: Theft - $20,000 Or More, §18-4-401(1),(2)(d), C.R.S. (F3) 0801V

COUNT ELEVEN: Securities Fraud – Fraud or Deceit, §11-51-501(1)(c), C.R.S. (F3) 50053

COUNT TWELVE: Securities Fraud – Untrue Statement or Omission,§11-51-501(1)(b), C.R.S. (F3) 50052

COUNT THIRTEEN: Keeping Property for Unlawful Distribution of Controlled Substances, §18-18-411(1), C.R.S. (M1) 33511

COUNT FOURTEEN: Managing or Controlling Property for Manufacture of Controlled Substances, §18-18-411(2)(b), C.R.S. (M1) 33513

COUNT FIFTEEN: Cultivation of Marijuana, More than Thirty Plants,§18-18-406(7.5)(c), C.R.S. (F4) 88033

COUNT SIXTEEN: Conspiracy to Commit Cultivation of Marijuana, More than ThirtyPlants, §18-18-406(7.5)(c), §18-2-201, C.R.S. (F5) CON

COUNT SEVENTEEN: Distribution of Marijuana – Five to One Hundred Pounds§18-18-406(6)(b)(I),(III)(B), C.R.S. (F4) 88023



3

COUNT EIGHTEEN: Conspiracy to Distribute, or Possess with Intent to Manufacture or Distribute, Marijuana – Five to One Hundred Pounds,§18-18-406(6)(b)(I),(III)(B), C.R.S. (F4) 88052

COUNT NINETEEN: Keeping Property for Unlawful Distribution of Controlled Substances, C.R.S. 18-18-411(1), C.R.S. (M1) 33511

COUNT TWENTY: Managing or Controlling Property for Manufacture of Controlled Substances, C.R.S. 18-18-411(2)(b), C.R.S. (M1) 33513

COUNT TWENTY ONE: Evasion of Taxes Administered by the Colorado Department of Revenue, §39-21-118 (1), C.R.S. (F-5) 40021

COUNT TWENTY TWO: Theft - $20,000 Or More, §18-4-401(1),(2)(d), C.R.S. (F-3) 0801V

COUNT TWENTY THREE: Evasion of Taxes Administered by the Colorado Department of Revenue, §39-21-118 (1), C.R.S. (F-5) 40021

COUNT TWENTY FOUR: Conspiracy to Commit Evasion of Taxes Administered by theColorado Department of Revenue, §39-21-118 (1), §18-2-201,C.R.S. (F-6) CON

COUNT TWENTY FIVE: Evasion of Taxes Administered by the Colorado Department of Revenue, §39-21-118 (1), C.R.S. (F-5) 40021

COUNT TWENTY SIX: Conspiracy to Distribute, or Possess with Intent to Manufacture or Distribute, Marijuana – Five to One Hundred Pounds,§18-18-406(6)(b)(I),(III)(B), C.R.S. (F4) 88052

COUNT TWENTY SEVEN: Distribution of Marijuana,– Five to One Hundred Pounds

§18-18-406(6)(b)(I),(III)(B), C.R.S. (F4) 88023

COUNT TWENTY EIGHT: Computer Crime – Scheme /Defraud - $20,000 or More,§18-5.5-102(1)(b), C.R.S. (F3) 1502T

COUNT TWENTY NINE: Tax Violation - Failure to Collect/Pay Trust Tax,§39-21-118(2), C.R.S. (F5) 40022

COUNT THIRTY: Theft - $20,000 Or More, §18-4-401(1),(2)(d), C.R.S. (F3) 0801V

COUNT THIRTY ONE: Theft - $1,000 - $20,000, §18-4-401(1),(2)(c), C.R.S. (F4) 0801U

COUNT THIRTY TWO: Filing a False Tax Return, §39-21-118(4), C.R.S. (F5) 40024

COUNT THIRTY THREE: Forgery of Checks or Commercial Instruments, §18-5-102(1)(c),C.R.S. (F5) 1001C

COUNT THIRTY FOUR: Theft - $20,000 Or More, §18-4-401(1),(2)(d), C.R.S. (F3) 0801V



4

COUNT THIRTY FIVE: Conspiracy to Commit Theft - $20,000 Or More,§18-4-401(1),(2)(d), C.R.S. (F4) CON

COUNT THIRTY SIX: Cultivation of Marijuana, More than Thirty Plants§18-18-406(7.5)(c), C.R.S. (F4) 88033

COUNT THIRTY SEVEN: Conspiracy to Commit Cultivation of Marijuana, More than ThirtyPlants §18-18-406(7.5)(c), §18-2-201, C.R.S. (F5) CON

COUNT THIRTY EIGHT: Distribution of Marijuana – More than One Hundred Pounds§18-18-406(6)(b)(I),(III)(B), C.R.S. (F3) 88024

COUNT THIRTY NINE: Conspiracy to Distribute, or Possess with Intent to Manufacture or Distribute, Marijuana – More than One Hundred Pounds,§18-18-406(6)(b)(I),(III)(B), C.R.S. (F3) 88053

COUNT FORTY: Keeping Property for Unlawful Distribution of Controlled

Substances, §18-18-411(1), C.R.S. (M1) 33511

COUNT FORTY ONE: Managing or Controlling Property for Manufacture of Controlled Substances, §18-18-411(2)(b), C.R.S. (M1) 33513

COUNT FORTY TWO: Theft - $20,000 Or More, §18-4-401(1),(2)(d), C.R.S. (F3) 0801V

COUNT FORTY THREE: Conspiracy to Commit Theft - $20,000 Or More,§18-4-401(1),(2)(d), C.R.S. (F4) CON

COUNT FORTY FOUR: Theft - $20,000 Or More, §18-4-401(1),(2)(d), C.R.S. (F3) 0801V

COUNT FORTY FIVE: Conspiracy to Commit Theft - $20,000 Or More,§18-4-401(1),(2)(d), C.R.S. (F4) CON

COUNT FORTY SIX: Theft - $20,000 Or More, §18-4-401(1),(2)(d), C.R.S. (F3) 0801V

COUNT FORTY SEVEN: Computer Crime – Scheme /Defraud - $20,000 or More,18-5.5-102(1)(b), C.R.S. (F3) 1502T

COUNT FORTY EIGHT: Conspiracy to Commit Theft - $20,000 Or More,§18-4-401(1),(2)(d), C.R.S. (F4) CON

COUNT FORTY NINE: Theft - $20,000 Or More, §18-4-401(1),(2)(d), C.R.S. (F3) 0801V

COUNT FIFTY: Conspiracy to Commit Theft - $20,000 Or More,§18-4-401(1),(2)(d), C.R.S. (F4) CON

COUNT FIFTY ONE: Theft - $20,000 Or More, §18-4-401(1),(2)(d), C.R.S. (F3) 0801V



5

COUNT FIFTY TWO: Securities Fraud – Fraud or Deceit, §11-51-501(1)(c), C.R.S. (F3)50053

COUNT FIFTY THREE: Securities Fraud – Untrue Statement or Omission, §11-51-501(1)(b),C.R.S. (F3) 50052

COUNT FIFTY FOUR: Forgery of Checks or Commercial Instruments,§18-5-102(1)(c), C.R.S. (F5) 1001C

COUNT FIFTY FIVE: Attempt To Influence A Public Servant, §18-8-306, C.R.S. (F4)24051

COUNT FIFTY SIX: Offering a False Instrument Instrument for Recording in the FirstDegree, §18-5-114(1), C.R.S. (F5) 10121

COUNT FIFTY SEVEN: Failure to File Return or Pay Tax, 39-21-118(3), C.R.S. (M) 40023

COUNT FIFTY EIGHT: Forgery of Checks or Commercial Instruments, §18-5-102(1)(c),C.R.S. (F5) 1001C

COUNT FIFTY NINE: Securities Fraud – Untrue Statement or Omission, §11-51-501(1)(b),C.R.S. (F3) 50052

COUNT SIXTY: Medical Marijuana – Unlawful Acts, §12-43.3-901(6), C.R.S. (M2)88086

COUNT SIXTY ONE: Medical Marijuana – Unlawful Acts, §12-43.3-901(6), C.R.S. (M2)88086

COUNT SIXTY TWO: Attempt To Influence A Public Servant, §18-8-306, C.R.S. (F4)24051

COUNT SIXTY THREE: Special Offender - Source of Income, §18-18-407(1)(b), C.R.S. (SE)33442

COUNT SIXTY FOUR: Special Offender – Conspiracy – Pattern of Sale, §18-18-407(1)(c),C.R.S. (SE) 33443

COUNT SIXTY FIVE: Special Offender – 100 Pounds of Marijuana or MarijuanaConcentrate, §18-18-407(1)(e), C.R.S. (SE) 3344A

COUNT SIXTY SIX: Special Offender – Conspiracy – Pattern of Sale, §18-18-407(1)(c),C.R.S. (SE) 33443

COUNT SIXTY SEVEN: Special Offender - Source of Income, §18-18-407(1)(b), C.R.S. (SE)33442

COUNT SIXTY EIGHT: Special Offender – Conspiracy – Pattern of Sale, §18-18-407(1)(c),C.R.S. (SE) 33443



6

COUNT SIXTY NINE: Special Offender – Conspiracy – Pattern of Sale, §18-18-407(1)(c),C.R.S. (SE) 33443

COUNT SEVENTY: Special Offender – Conspiracy – Pattern of Sale, §18-18-407(1)(c),C.R.S. (SE) 33443

COUNT SEVENTY ONE: Special Offender – 100 Pounds of Marijuana or MarijuanaConcentrate, §18-18-407(1)(e), C.R.S. (SE) 3344A



7

INDEX OF COUNTS

Defendant Charges

CRITER, KURT 1, 2, 58, 59

DIRMAAT, DALLAN 1, 2, 3, 4, 5, 6, 7, 33, 34, 35, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52,

53, 54, 66HOSKINS, CONLEY 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22,

23, 24, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42,43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 60, 63, 64, 65

JOYCE, BRENDEN 1, 2, 36, 37, 38, 39, 41, 70, 71

KRAUSE, DAVID 1, 2, 36, 37, 38, 39, 40, 41, 69

MELENDEZ, YESENIA 1, 2, 24, 25, 26, 27, 28

MEZA, CARLOS 1, 2, 24, 25, 26, 27, 28

NEWMAN, NATHAN 1, 2, 15, 16, 17, 18, 19, 20, 24, 25, 26, 27, 28, 67, 68

PARKER, DIALYNE 1, 2, 26, 27, 28

SEARLE, GERALD 61

TRIPP, RYAN 1, 2, 24, 25, 26, 27, 28,WIMER, AUDRA 1, 2, 24, 25, 26, 27, 28, 62

5105 E. 39th AVE., LLC 1, 2, 36, 37, 38, 39, 40, 41

ALL CARE WELLNESSCENTERS, LLC

1, 2, 21, 22, 23, 29, 31, 32, 37, 38, 39, 40, 41, 42

JANE MEDICALS, LLC 1, 2, 4, 5, 6, 7, 8, 9, 10, 11, 12, 15, 16, 17, 18, 21, 22, 23, 24, 25, 26,27, 28, 29, 30, 32, 36, 37, 38, 39, 42

THE PEOPLE’S LAWFIRM

1, 2, 3, 4, 5, 6, 7, 33, 34, 35, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52,53, 54

RAINMAKER MANAGEMENT, LLC

1, 2, 21, 22



8

COUNT 1

Violation of the Colorado Organized Crime Control Act – Pattern of Racketeering- Participation inEnterprise, §18-17-104(3) and §18-17-105 C.R.S. (F2) 37284

On or about and between January 1, 2008 and April 30, 2013, in and triable in the counties of

Adams, Arapahoe, Denver, Douglas, Jefferson and Larimer, in the State of Colorado, ConleyHoskins, Dallan Dirkmaat, David Krause, Brenden Joyce, Yesenia Melendez, Audra Wimer, KurtCriter, Nathan Newman, Ryan Tripp, Carlos Meza, Dialyne Parker, Jane Medicals, LLC, All CareWellness Centers, LLC, Rainmaker Management, LLC, 5105 E. 39th Ave., LLC, The People’s LawFirm, LLC and others both known and unknown, 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 §18-17-104(3) and §18-17-105, 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, §18-17-104(4),C.R.S. (F2) 37285

On or about and between January 1, 2008 and April 30, 2013, in and triable in the counties of Adams, Arapahoe, Denver, Douglas, Jefferson and Larimer, in the State of Colorado, ConleyHoskins, Dallan Dirkmaat, David Krause, Brenden Joyce, Yesenia Melendez, Audra Wimer, KurtCriter, Nathan Newman, Ryan Tripp, Carlos Meza, Dialyne Parker, Jane Medicals, LLC, All CareWellness Centers, LLC, Rainmaker Management, LLC, 5105 E. 39th Ave., LLC, The People’s LawFirm, LLC and others both known and unknown, did unlawfully, knowingly, and feloniously conspireand endeavor to conduct and participate, directly or indirectly, in an enterprise, through a pattern of racketeering activity in violation of C.R.S. §18-17-104(4) and §18-17-104(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 Interestin Enterprise, §18-17-104(2) C.R.S. (F2) 37283

On or about and between January 1, 2008 and April 30, 2013, in and triable in the counties of Adams, Arapahoe, Denver, Douglas, Jefferson and Larimer, in the State of Colorado, ConleyHoskins, Dallan Dirkmaat, and The People’s Law Firm, LLC, unlawfully, feloniously, and knowinglyacquired or maintained, directly or indirectly, an interest in or control of an enterprise or real property, namely: Higher Health Medical, a legal entity and limited liability company, located at 527E. Mississippi Avenue in Denver, Colorado through a pattern of racketeering activity or through the

collection of an unlawful debt; in violation of §18-17-104(2), C.R.S. (F2), and against the peace and dignity of the People of the State of Colorado.



9

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 groups of individuals,associated in fact, and multipe legal entities. The enterprise included, the following associated in fact

individuals, a group of individuals, along with legal entities and/or other entities:

Conley Hoskins, Dallan Dirkmaat, David Krause, Brenden Joyce, Yesenia Melendez, Audra Wimer,Kurt Criter, Nathan Newman, Ryan Tripp, Carols Meza, Dialyne Parker, Jane Medicals, LLC, AllCare Wellness Centers, LLC, Rainmaker Management, LLC, 5105 E. 39th Ave., LLC, The People’sLaw Firm, LLC and others both known and unknown to the Grand Jury, who were associated fromtime to time in the racketeering activity that was related to the conduct of the enterprise.

The above persons and entities that associated with the enterprise, and the enterprise itself,engaged in a scheme including: receiving, buying, selling, dealing, cultivating and/or distributingmarijuana in Colorado, and at least one other state, while engaging in securities fraud, theft, forgery,evading taxes and attempting to influence public servants through deceit. The enterprise evolved into

a distribution ring, in part, because many members established personal and business connectionswith one another throughout the preceding years.

In fact, Mr. Hoskins, Mr. Dirkmaat and Dr. Searle grew up together in Idaho. Mr. Hoskins’and Mr. Dirkmaat’s longstanding friendship led them to participate in business ventures together inthe following fields: construction, car washes and medical marijuana dispensaries (also known asmedical marijuana centers). In particular, the medical marijuana dispensaries that Hoskins owned and managed occasionally utilized the legal services of Mr. Dirkmaat and were co-located in the same building as his law firm. These dispensaries included: Jane Medicals, LLC, Higher Health Medicaland All Care Wellness Centers, LLC. Mr. Dirkmaat, an attorney, was the managing member of ThePeople’s Law Firm (A.K.A., The People’s Law Firm, LLC) which interacted frequently with Mr.Hoskins’ businesses. Dr. Searle’s connection with both Hoskins and Dirkmaat lead to the

development of a business relationship where Dr. Searle moved part of his medical practice to anoffice located nearby the Jane Medicals building. While practicing at that office, Dr. Searle made patient referrals to Jane Medicals, LLC. Contemporaneously, Conley Hoskins paid the rent of Dr.Searle while he made the above mentioned patient referrals to Jane Medicals, LLC.

Over the course of time, Mr. Hoskins’ business interests migrated from those related toconstruction and car washes to those which included several ventures into the medical marijuanaindustry. Drawing on past business experiences in raising capital, Hoskins utilized the help of friendsand acquaintances to seek out investors for expansion into the marijuana industry. Later Mr.Hoskins’ plan to expand his marijuana businesses through investments took a turn down the criminal path. This path included defrauding those same individuals who sought to partner or invest with Mr.Hoskins as he expanded his marijuana businesses.

One component of Mr. Hoskins’ investment scheme utilized the services of an established businessman named Kurt Criter. Mr. Criter, a supplier of car wash chemicals, and Mr. Hoskinsoriginally knew one another from conducting business transactions related to the car wash industry.Given Mr. Criter’s business background and experience, Mr. Hoskins consulted with him to draft a prospectus aimed at gaining investors for his medical marijuana businesses. In fact, Mr. Criter took earnings and projected earnings figures supplied by Mr. Hoskins and incorporated them into a prospectus that was later provided to investors and potential partners. Mr. Criter was specificallyassigned to seek out money from investors located outside the state of Colorado and ultimately



10

supplied a prospectus to these same investors containing false information. This prospectus included false sales figures, assets and liabilities and made numerous material omissions. Further, during thesearch for investors both Mr. Criter and Mr. Hoskins falsely portrayed Mr. Criter as a current officer and or executive of the various medical marijuana businesses owned and operated by Mr. Hoskins.

A second stage of this investment scheme involved Mr. Hoskins and Mr. Dirkmaat

cooperating with one another to fraudulently gain investors and business partners. Much of themoney from investors and potential partners was falsely presented by Hoskins and Dirkmaat as beingdestined to expand the various marijuana businesses. Instead, the money that investors sought toinvest in Mr. Hoskins’ marijuana businesses was fraudulently diverted for other unrelated purposes,including but not limited to, paying off personal debts and business debts on the likes of car washesowned by Mr. Hoskins. Mr. Dirkmaat and Mr. Hoskins, individually and through the use of their businesses, engaged in numerous fraudulent behaviors to gain investors and stave off outsidefinancial pressures. On one occasion, Mr. Hoskins and Mr. Dirkmaat, transferred a piece of construction machinery to an auction house, purportedly through a “straw-buyer/seller” whilefraudulently claiming the construction equipment lacked a lien. The lien and forged paperwork used during this ruse were later discovered by the auction house and the purchaser. On another occasionthese two men, individually and through their LLC’s used false documentation and deceit to seek and

secure in state and out of state investors for Mr. Hoskins’ marijuana businesses. Ultimately, the twofraudulently diverted a significant portion of the incoming investment moneys for purposes other thanthat which their prospectus had promised.

During the winter of 2010, Mr. Chuck Frase, an investor in Mr. Hoskins’ car wash business,introduced Mr. Jerrod Martin to Mr. Hoskins and Mr. Dirkmaat. Eventually, Mr. Frase’s introductionof these two lead to Jerrod Martin moving to Colorado in order to grow marijuana for ConleyHoskins. Mr. Hoskins and Mr. Jerrod Martin then engaged in an ongoing conspiracy to illegallycultivate marijuana in the basement of a home located in Larimer County and occupied by Jerrod Martin. Conley Hoskins, through his then solvent company Denali Custom Homes, LLC, had anownership interest in this very home which was rented and occupied by Jerrod Martin. Mr. Martin’srole in this portion of the enterprise was to serve as the grower who tended to the crop of marijuana.

Mr. Martin frequently contacted Mr. Hoskins and Mr. Dirkmaat via text, instant message, email, phone or wire and ordered marijuana for the purposes of distributing it to Jane Medicals, LLC for sale.

After seeing potential for financial growth, Mr. Martin invested nearly $50,000.00 in JaneMedicals, LLC in order to help pay for a warehouse expansion designed to increase marijuana production. Shortly after making his own investment, and with the consent of Conley Hoskins, Mr.Martin sought out his friends and their acquaintances with the financial wherewithal to invest in Mr.Hoskins’ marijuana businesses. These investors included individuals from Texas named John Lemak and Gary Pool. Investments from these two and Mr. Martin totaled nearly six hundred thousand dollars. Despite this influx of investment money, Conley Hoskins, with occasional assistance fromDallan Dirkmaat, continued to seek out investors and partners for his medical marijuana dispensaries.

Eventually, Mr. Hoskins, and occasionally Mr. Dirkmaat, would go on to defraud these and other investors, partners and or business associates.

To conceal their criminal activities several members of the enterprise engaged in moneylaundering and tax evasion. These actions allowed enterprise members to hide their illicit proceedsfrom law enforcement and or taxing authorities and to expand their marijuana production capabilities.Despite taxable earnings and or taxable sales, others achieved similar goals of hiding their illegalmarijuana proceeds or collected sales tax from law enforcement and or taxing authorities by filingfalse returns or simply failing to collect or pay over trust taxes. Some members even used portions of



11

the proceeds from their illegal sales of marijuana and tax schemes to pay for personal items, including but not limited to vehicles and debt on other businesses.

While each member occupied different roles within the enterprise, they relied upon thecriminal acts of one another to achieve individual success in the context of the overall enterprise.

Pattern of Racketeering Activity

For purposes of Counts One, Two and Three, Conley Hoskins, Dallan Dirkmaat, David Krause, Brenden Joyce, Yesenia Melendez, Audra Wimer, Kurt Criter, Nathan Newman, Ryan Tripp,Carlos Meza, Dialyne Parker, Jane Medicals, LLC, All Care Wellness Centers, LLC, Rainmaker Management, LLC, Tea Alchemy, LLC, 5105 E. 39th Ave., LLC, The People’s Law Firm, LLC and others both known and unknown to the Grand Jury, directly and in concert, engaged in, attempted toengage in, conspired to engage in, or solicited another to engage in at least two predicate acts,including any lesser offenses as permitted in §18-17-103, related to the conduct of the enterprise, withat 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:

Securities Fraud Computer CrimeConspiracy to Commit Cultivation of MarijuanaCultivation of MarijuanaConspiracy to Commit Distribution of MarijuanaDistribution of MarijuanaConspiracy to Distribute, or Possess with Intent to Manufacture or DistributeMarijuanaMoney Laundering

Unlawful Use of a Communications FacilityConspiracy to Commit Evasion of Taxes Administered by the Colorado Department of Revenue

Evasion of Taxes Administered by the Colorado Department of RevenueFiling a False Tax ReturnTax Violation - Failure to Collect/Pay Trust TaxForgeryOffering a False Instrument for RecordingConspiracy to Commit TheftTheftAttempt To Influence a Public ServantKeeping Property for Unlawful Distribution of Controlled SubstancesManaging or Controlling Property for Manufacture of Controlled SubstancesCultivation of Cannabis, F.S. 893.13(1)(a), Third Degree FelonyPossession of Cannabis - Over 20 Grams, F.S. 893.13(6)(a), Third Degree Felony

Possession of Paraphernalia, F.S. 893.147, First Degree Misdemeanor



12

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 tocommit, consist of the following predicate acts, including any lesser included offenses permitted to be

used as predicates under this statute:

PREDICATE ACT 1

Cultivation of Marijuana, More than Thirty Plants §18-18-406(7.5)(c), C.R.S. (F4) 88033

On or about and between June 1, 2010 and May 15, 2011, CONLEY HOSKINS, DALLAN

DIRKMAAT, JANE MEDICALS, LLC, THE PEOPLE’S LAW FIRM and others known to the

Grand Jury unlawfully, feloniously, and knowingly cultivated, grew, or produced marijuana plants,or allowed marijuana plants to be cultivated, grown, or produced on land owned, occupied, or controlled by the defendants. Further, the number of marijuana plants was thirty or more; in violationof §18-18-406(7.5)(c), C.R.S. (F4), and against the peace and dignity of the People of the State of

Colorado.

PREDICATE ACT 2

Conspiracy to Commit Cultivation of Marijuana, More than Thirty Plants §18-18-406(7.5)(c), C.R.S.§18-2-201 (F5) CON



Grand Jury with the intent to promote or facilitate the commission of the crime of Cultivation of Marijuana, More than Thirty Plants §18-18-406(7.5)(c), unlawfully and feloniously agreed with oneanother and persons known to the Grand Jury 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 §18-18-406(7.5)(c), C.R.S. and §18-2-201, C.R.S. (F5), and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT 3

Distribution of Marijuana – Five to One Hundred Pounds, §18-18-406(6)(b)(I),(III)(B), C.R.S. (F4)88023

On or about and between June 1, 2010 and May 15, 2011, in the State of Colorado,

CONLEY HOSKINS, DALLAN DIRKMAAT, JANE MEDICALS, LLC, THE PEOPLE’SLAW FIRM and others known to the Grand Jury unlawfully, feloniously, and knowingly sold or distributed, or attempted to sell or distribute, marijuana or marijuana concentrate. Further, theamount of marijuana was at least five pounds but not more than one hundred pounds; in violation of §18-18-406(6)(b)(I),(III)(B), C.R.S. (F4), and against the peace and dignity of the People of the Stateof Colorado.



13

PREDICATE ACT 4

Conspiracy to Distribute, or Possess with Intent to Manufacture or Distribute, Marijuana – Five toOne Hundred Pounds, §18-18-406(6)(b)(I),(III)(B), C.R.S. (F4) 88052


CONLEY HOSKINS, DALLAN DIRKMAAT, JANE MEDICALS, LLC, THE PEOPLE’SLAW FIRM and others known to the Grand Jury unlawfully, feloniously, and knowinglyconspired with one another and with and person or persons known and unknown to the Grand Jury, tosell, distribute, or possess with intent to manufacture, sell or distribute marijuana. Further, theamount of marijuana was at least five pounds but not more than one hundred pounds; in violation of §18-18-406(6)(b)(I),(III)(B), C.R.S (F4), and against the peace and dignity of the People of the Stateof Colorado.

PREDICATE ACT 5

Unlawful Use of a Communication Facility, 21 U.S.C. §843

On or about and between June 1, 2010 and May 15, 2011, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and others 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 todistribute a controlled substance in violation of 21 U.S.C. §§841 and 846, such use of acommmunications facility being unlawful, and in violation of 21 U.S.C. §843.

PREDICATE ACT 6

Money Laundering – Conduct Financial Transaction with Intent to Promote Crime, §18-5-309(1)(a)(I), C.R.S. (F3) 12211

On or about and between August 15, 2010 and May 15, 2011, in the State of Colorado,CONLEY HOSKINS and JANE MEDICALS, LLC, unlawfully and feloniously, conducted or attempted to conduct a financial transaction that involved money or any other thing of value that thedefendant 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 §18-5-309(1)(a)(I), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT 7

Computer Crime – Scheme /Defraud - $20,000 or More, §18-5.5-102(1)(b), C.R.S. (F3) 1502T

On or about and between March 1, 2011 and September 30, 2011, in the State of Colorado,CONLEY HOSKINS and JANE MEDICALS, LLC unlawfully, feloniously, and knowinglyaccessed a computer, computer network, or computer system, or any part thereof, for the purpose of devising or executing a scheme or artifice to defraud, and the loss, damage, value of services, or thingof value taken, or cost of restoration or repair was twenty thousand dollars or more; in violation of §18-5.5-102(1)(b), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.



14

PREDICATE ACT 8

Theft - $20,000 Or More, §18-4-401(1),(2)(d), C.R.S. (F3) 0801V

On or about and between March 1, 2011 and June 30, 2012, in the State of Colorado,CONLEY HOSKINS and JANE MEDICALS, LLC, unlawfully, feloniously, and knowingly

obtained or exercised control over a thing of value, namely: money of Jerrod Martin, Gary Pool and or John Lemak with a value of more than twenty thousand dollars, without authorization, or by threator deception, and intended to deprive Jerrod Martin, Gary Pool and or John Lemak permanently of itsuse or benefit; in violation of §18-4-401(1)(a),(2)(d), C.R.S. (F3) and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT 9

Securities Fraud – Fraud or Deceit, §11-51-501(1)(c), C.R.S. (F3) 50053

On or about and between February 1, 2011 and June 30, 2012, in the State of Colorado,CONLEY HOSKINS and JANE MEDICALS, LLC, in connection with the offer, sale, or purchase

of a security, directly or indirectly, unlawfully, feloniously, and willfully engaged in any act, practice,or course of business which operated or would have operated as fraud or deceit upon any person; inviolation of §11-51-501(1)(c) and §11-51-603(1), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT 10

Securities Fraud – Untrue Statement or Omission, § 11-51-501(1)(b), C.R.S. (F3) 50052

On or about and between February 1, 2011 and June 30, 2012, in the State of Colorado,CONLEY HOSKINS and JANE MEDICALS, LLC, in connection with the offer, sale, or purchaseof a security, directly or indirectly, unlawfully, feloniously, and willfully made an untrue statement of

a material fact or omitted to state a material fact necessary in order to make the statements made, inthe light of the circumstances under which they were made, not misleading; in violation of §11-51-501(1)(b) and §11-51-603(1), C.R.S. (F3), and against the peace and dignity of the People of the Stateof Colorado.

PREDICATE ACT 11

Keeping Property for Unlawful Distribution of Controlled Substances, §18-18-411(1), C.R.S. (M1)33511

On or about and between June 1, 2010 and May 15, 2011, in the State of Colorado,CONLEY HOSKINS and others known 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 defendantknew was resorted to for the purpose of keeping for distribution, transporting for distribution, or distribution of a controlled substance; in violation of §18-18-411(1), C.R.S. (M1), and against the peace and dignity of the People of the State of Colorado.



15

PREDICATE ACT 12

Managing or Controlling Property for Manufacture of Controlled Substances, §18-18-411(2)(b),C.R.S. (M1) 33513


CONLEY HOSKINS and others known to the Grand Jury unlawfully managed or controlled a building, room, or enclosure as an owner, lessee, agent, employee, or mortgagee and knowingly or intentionally rented, leased, or made it available for use, and the defendant knew it was resorted to for the purpose of unlawfully manufacturing a controlled substance; in violation of §18-18-411(2)(b),C.R.S. (M1), and against the peace and dignity of the People of the State of Colorado.

The offenses alleged in Predicate Acts 1 through 12 were committed in the following manner and occurred in the State of Colorado:

From June of 2010 until May of the following year, Mr. Jerrod Martin, a conspirator of bothConley Hoskins and Dallan Dirkmaat, cultivated over thirty plants of marijuana in the basement of aresidence located in Windsor, Colorado without being properly licensed by the state. This Windsor

residence was owned by a company named Denali Custom Homes, LLC, which in turn was owned and managed by Mr. Hoskins. Mr. Hoskins provided the Windsor house to Mr. Martin for the purposes of cultivating marijuana and Mr. Hoskins paid bills associated with the marijuana grow.Both Mr. Hoskins and Mr. Dirkmaat, who were high managerial agents for Jane Medicals, LLC,conspired with Mr. Martin to cultivate marijuana and deliver it to the dispensary Jane Medicals, LLCfor sale. In order to effectuate their conspiracy to distribute, Mr. Hoskins, Mr. Dirkmaat and Mr.Martin used cell phones and or email to coordinate production and delivery of this illegally grownmarijuana. Mr. Hoskins and Mr. Dirkmaat both authorized and knowingly tolerated this conduct of using unlicensed and illegally grown marijuana for the benefit of Jane Medicals, LLC, a companyoperating as a medical marijuana dispensary in Denver.

Mr. Hoskins, Mr. Dirkmaat and Mr. Martin were aware that the grow house in Windsor

lacked a state license to grow marijuana. In exchange for U.S. currency and as rent on the house inWindsor, Mr. Martin delivered an estimated ten to twenty pounds of marijuana to Conley Hoskinsand his company Jane Medicals, LLC. Once delivered, Conley Hoskins as owner of Jane Medicals,LLC instituted a policy where his employees sold the illegally grown marijuana employing the rusethat the marijuana had been grown and sold in accordance with Colorado state law. Furthermore,Mr. Hoskins and Jane Medicals, LLC used profits from Mr. Martin’s ongoing grow, amongst other things, in order to fund various aspects of subsequent illegal marijuana cultivation.

In the beginning of March of 2011, Mr. Martin was provided, via email, a prospectus for JaneMedicals, LLC by Mr. Hoskins entitled “Jane Medicals Business Plan, February 2011”. The JaneMedicals Business Plan materially misrepresented and omitted certain financial information including but not limited to sales figures, business liabilities and tax liabilities. Specifically, the sales numbers

Mr. Hoskins provided to Mr. Martin were inflated compared to the sales numbers Mr. Hoskins provided to the Colorado Department of Revenue during the same and relevant time period. Based onthe false information and omissions in the prospectus, Mr. Martin invested nearly $50,000.00 withMr. Hoskins for his various medical marijuana businesses.

At the direction of Mr. Hoskins, Mr. Martin solicited additional investors in Jane Medicals,LLC by emailing the above mentioned prospectus and personally contacting potential investors. Mr.Martin emailed the fabricated prospectus to potential and eventual business investors such as Mr.John Lemak and Mr. Gary Pool. In August of 2011, Mr. John Lemak requested additional sales



16

information about Jane Medicals, LLC. Mr. Conley Hoskins met the request. The subsequentinformation and the original “Jane Medicals Business Plan, February 2011” prospectus materiallymisrepresented and omitted certain financial information including but not limited to sales figures, business liabilities and tax liabilities. The sales numbers Mr. Hoskins provided to Mr. Lemak and Mr. Pool were inflated compared to the sales numbers Mr. Hoskins provided to the ColoradoDepartment of Revenue during the same and relevant time period. On a repeated basis from August

1, 2011 until June 30, 2012 and based on the false information and omissions in the prospectus, Mr.Lemak invested approximately $600,000.00 with Mr. Hoskins for his various medical marijuana businesses. Based on the false information and omissions in the prospectus, Mr. Pool invested approximately $50,000.00 with Mr. Hoskins for his various medical marijuana businesses.Furthermore, Mr. Hoskins fraudulently diverted a significant portion of the investments of Mr.Lemak, Mr. Martin and Mr. Pool for unrelated purposes, including but not limited to, paying off personal debts and business debts on car washes owned by Mr. Hoskins.



17

PREDICATE ACT 13


On or about and between May 1, 2010 and December 31, 2011, CONLEY HOSKINS,

NATHAN NEWMAN, JANE MEDICALS, LLC and others known to the Grand Jury

unlawfully, feloniously, and knowingly cultivated, grew, or produced marijuana plants, or allowed marijuana plants to be cultivated, grown, or produced on land owned, occupied, or controlled by thedefendants. Further, the number of marijuana plants was thirty or more; in violation of §18-18-406(7.5)(c), C.R.S. (F4), and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT 14



NATHAN NEWMAN, JANE MEDICALS, LLC and others known to the Grand Jury with the

intent to promote or facilitate the commission of the crime of Cultivation of Marijuana, More thanThirty Plants §18-18-406(7.5)(c), unlawfully and feloniously agreed with one another and personsknown to the Grand Jury 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 planningor commission or attempted commission of that crime, and an overt act in pursuance of theconspiracy was committed by one or more of the conspirators; in violation of §18-18-406(7.5)(c),C.R.S. and §18-2-201, C.R.S. (F5), and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT 15

Distribution of Marijuana– Five to One Hundred Pounds, §18-18-406(6)(b)(I),(III)(B), C.R.S. (F4)

88023

On or about and between May 1, 2010 and December 31, 2011, in the State of Colorado,CONLEY HOSKINS, NATHAN NEWMAN, JANE MEDICALS, LLC and others known 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 at least five pounds but not more than one hundred pounds; in violation of §18-18-406(6)(b)(I),(III)(B), C.R.S.(F4), and against the peace and dignity of the People of the State of Colorado.



18

PREDICATE ACT 16



Grand Jury unlawfully, feloniously, and knowingly conspired with one another and with and personor persons known and unknown to the Grand Jury, to sell, distribute, or possess with intent tomanufacture, sell or distribute marijuana. Further, the amount of marijuana was at least five pounds but not more than one hundred pounds; in violation of §18-18-406(6)(b)(I),(III)(B), C.R.S (F4), and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT 17


On or about and between May 1, 2010 and December 31, 2011, in the State of Colorado,CONLEY HOSKINS and NATHAN NEWMAN did knowingly or intentionally use acommunications facility, namely, a wire, telephone and/or other means of communication, tofacilitate the commission of a felony, namely, distribution of a controlled substance, possession withthe intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance inviolation of 21 U.S.C. §§841 and 846, such use of a commmunications facility being unlawful, and inviolation of 21 U.S.C. §843.

PREDICATE ACT 18

Keeping Property for Unlawful Distribution of Controlled Substances, § 18-18-411(1), C.R.S. (M1)33511

On or about and between May 1, 2010 and December 31, 2011, in the State of Colorado, CONLEY HOSKINS and NATHAN NEWMAN, 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 wasresorted to for the purpose of keeping for distribution, transporting for distribution, or distribution of a controlled substance; in violation of §18-18-411(1), C.R.S. (M1), and against the peace and dignityof the People of the State of Colorado.

PREDICATE ACT 19

Managing or Controlling Property for Manufacture of Controlled Substances, §18-18-411(2)(b),

C.R.S. (M1) 33513

On or about and between May 1, 2010 and December 31, 2011, in the State of Colorado,CONLEY HOSKINS and NATHAN NEWMAN unlawfully managed or controlled a building,room, or enclosure as an owner, lessee, agent, employee, or mortgagee and knowingly or intentionallyrented, leased, or made it available for use, and the defendant knew it was resorted to for the purposeof unlawfully manufacturing a controlled substance; in violation of §18-18-411(2)(b), C.R.S. (M1),and against the peace and dignity of the People of the State of Colorado.



19

The offenses alleged in Predicate Acts 13 through 19 incorporate the above mentioned facts, werecommitted in the following manner and occurred in the State of Colorado:

From May of 2010 until December of 2011, Mr. Nathan Newman and Conley Hoskinsconspired to cultivate over thirty plants of marijuana in the basement of a residence located inBrighton, Colorado without being properly licensed by the state. This Brighton residence was owned

by Conley Hoskins and his wife Alycia Hoskins. Mr. Hoskins provided the Brighton house to Mr. Newman for the purposes of growing marijuana and paid bills associated with the marijuana grow.As described previously, Mr. Hoskins during this time frame was a high managerial agent for JaneMedicals, LLC. Mr Hoskins conspired with Mr. Newman to cultivate marijuana and deliver it to thedispensary Jane Medicals, LLC for sale. In order to effectuate their conspiracy to distribute, Mr.Hoskins and Mr. Newman used cell phones to coordinate cultivation and delivery of this illegallygrown marijuana. Mr. Hoskins authorized and knowingly tolerated this conduct of using unlicensed and illegally grown marijuana for the benefit of Jane Medicals, LLC, a company operating as amedical marijuana dispensary in Denver.

Mr. Hoskins and Mr. Newman were aware that the grow house in Brighton lacked a statelicense to grow marijuana. In exchange for U.S. currency and as rent on the house in Brighton, Mr.

Newman delivered over five pounds of marijuana to Conley Hoskins and his company Jane Medicals,LLC. Once delivered, Conley Hoskins as owner of Jane Medicals, LLC instituted a policy where hisemployees sold the illegally grown marijuana employing the ruse that the marijuana had been grownand sold in accordance with Colorado state law. Furthermore, Mr. Hoskins and Jane Medicals, LLCused profits from Mr. Newman’s ongoing grow, amongst other things, in order to fund variousaspects of subsequent illegal marijuana cultivation.



20

PREDICATE ACT 20

Evasion of Taxes Administered by the Colorado Department of Revenue, §39-21-118(1), C.R.S.(F5) 40021

On or about and between January 1, 2008 and February 29, 2012, in the State of Colorado,

CONLEY HOSKINS, RAINMAKER MANAGEMENT, LLC, JANE MEDICALS, LLC, andALL CARE WELLNESS CENTERS, LLC, did unlawfully, feloniously and willfully attempt toevade and defeat a tax administered by the Colorado Department of Revenue, or a payment thereof namely, wage withholdings, in violation of §39-21-118(1), C.R.S. (F-5), and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT 21


On or about and between January 1, 2008 and February 29, 2012, in the State of Colorado,CONLEY HOSKINS, RAINMAKER MANAGEMENT, LLC, JANE MEDICALS, LLC, and

ALL CARE WELLNESS CENTERS, LLC, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: money of the Colorado Department of Revenue, witha value of more than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive the Colorado Department of Revenue, permanently of its use or benefit; inviolation of §18-4-401(1)(a),(2)(d), C.R.S. (F-3), and against the peace and dignity of the People of the State of Colorado.

The offenses alleged in Predicate Acts 20 through 21 incorporate the above mentioned facts and werecommitted in the following manner and occurred in the State of Colorado:

Between January 1, 2008 and February 29, 2012, Mr. Hoskins, the owner and highmanagerial agent of Rainmaker Management, LLC, Jane Medicals, LLC and All Care Wellness

Centers, LLC, withheld wages from employees of his various carwashes and employees of hismedical marijuana businesses. In comparing the aggregate amounts withheld from employees and reported by employees on their individual income tax returns to the amounts of wage withholdingsremitted by Mr. Hoskins’ various business entities, Mr. Hoskins falsely under reported wagewithholdings to the Colorado Department of Revenue by approximately $30,000.00 in order todeprive the Department of Revenue of that money.



21

PREDICATE ACT 22

Evasion of Taxes Administered by the Colorado Department of Revenue, §39-21-118(1), C.R.S.(F5) 40021

On or about and between January 1, 2010 and July 20, 2011, in the State of Colorado,

CONLEY HOSKINS, JANE MEDICALS, LLC and ALL CARE WELLNESS CENTERS,LLC, did unlawfully, feloniously and willfully attempt to evade and defeat a tax administered by theColorado Department of Revenue, or a payment thereof namely, Colorado Sales Tax, in violation of §39-21-118(1), C.R.S. (F5), and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT 23

Conspiracy to Commit Evasion of Taxes Administered by the Colorado Department of Revenue, §39-21-118 (1), §18-2-201 (F6) CON

On or about and between January 1, 2010 and July 20, 2011, in the State of Colorado,CONLEY HOSKINS, YESENIA MELENDEZ, AUDRA WIMER, CARLOS MEZA, NATHAN

NEWMAN, RYAN TRIPP and JANE MEDICALS, LLC, with the intent to promote or facilitatethe 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 engagein 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 overtact in pursuance of the conspiracy was committed by one or more of the conspirators; in violation of sections §39-21-118 (1) and §18-2-201, C.R.S. (F6), and against the peace and dignity of the Peopleof the State of Colorado.

PREDICATE ACT 24

Evasion of Taxes Administered by the Colorado Department of Revenue,

§39-21-118 (1), C.R.S. (F-5) 40021

On or about and between January 1, 2010 and July 20, 2011, in the State of Colorado,YESENIA MELENDEZ, AUDRA WIMER, CARLOS MEZA, NATHAN NEWMAN, RYAN

TRIPP and JANE MEDICALS, LLC, did unlawfully, feloniously and willfully attempt to evadeand defeat a tax administered by the Colorado Department of Revenue, or a payment thereof namely,State of Colorado Sales Tax, in violation of §39-21-118(1), C.R.S. (F5), and against the peace and dignity of the People of the State of Colorado.



22

PREDICATE ACT 25


On or about and between January 1, 2010 and September 30, 2012, in the State of Colorado,CONLEY HOSKINS, YESENIA MELENDEZ, AUDRA WIMER, DIALYNE PARKER,

CARLOS MEZA, NATHAN NEWMAN, RYAN TRIPP and JANE MEDICALS, LLC,

unlawfully, feloniously, and knowingly conspired with one another and with and person or personsknown and unknown to the Grand Jury, to sell, distribute, or possess with intent to manufacture, sellor distribute marijuana. Further, the amount of marijuana was at least five pounds but not more thanone hundred pounds; in violation of §18-18-406(6)(b)(I),(III)(B), C.R.S (F4), and against the peaceand dignity of the People of the State of Colorado.

PREDICATE ACT 26


88023



unlawfully, feloniously, and knowingly sold or distributed, or attempted to sell or distribute,marijuana or marijuana concentrate. Further, the amount of marijuana was at least five pounds but notmore than one hundred pounds; in violation of §18-18-406(6)(b)(I),(III)(B), C.R.S. (F4), and againstthe peace and dignity of the People of the State of Colorado.

PREDICATE ACT 27


On or about and between January 1, 2010 and September 30, 2012, and discovered on or aboutSeptember 5, 2012, in the State of Colorado, CONLEY HOSKINS, YESENIA MELENDEZ,

AUDRA WIMER, DIALYNE PARKER, CARLOS MEZA, NATHAN NEWMAN, RYAN

TRIPP and JANE MEDICALS, LLC, unlawfully, feloniously, and knowingly accessed acomputer, computer network, or computer system, or any part thereof, for the purpose of devising or executing a scheme or artifice to defraud, and the loss, damage, value of services, or thing of valuetaken, or cost of restoration or repair was twenty thousand dollars or more; in violation of §18-5.5-102(1)(b), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.



23

PREDICATE ACT 28

Tax Violation - Failure to Collect/Pay Trust Tax, §39-21-118(2), C.R.S. (F5) 40022

On or about and between February 21, 2010 and July 21, 2011, in the State of Colorado,CONLEY HOSKINS, JANE MEDICALS, LLC, and ALL CARE WELLNESS CENTERS,

LLC, who were required by law to collect, account for, or pay over a tax, unlawfully, feloniously,and willfully failed to collect or truthfully account for or pay over the tax; to wit: sales tax; inviolation of §39-21-118(2), C.R.S. (F5), and against the peace and dignity of the People of the Stateof Colorado.

PREDICATE ACT 29


On or about and between February 21, 2010 and July 21, 2011, and discovered on or aboutSeptember 5, 2012, in the State of Colorado, CONLEY HOSKINS and JANE MEDICALS, LLC, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely:

money of the Colorado Department of Revenue, with a value of more than twenty thousand dollars,without authorization, or by threat or deception, and intended to deprive the Colorado Department of Revenue, permanently of its use or benefit; in violation of §18-4-401(1)(a),(2)(d), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT 30

Theft - $1,000 - $20,000, §18-4-401(1),(2)(c), C.R.S. (F4) 0801U

On or about and between February 21, 2011 and July 21, 2011, and discovered on or aboutSeptember 5, 2012, in the State of Colorado, CONLEY HOSKINS and ALL CARE WELLNESS

CENTERS, LLC, unlawfully, feloniously, and knowingly obtained or exercised control over a thing

of value, namely: money of The Colorado Department of Revenue, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception,and intended to deprive The Colorado Department of Revenue permanently of its use or benefit; inviolation of §18-4-401(1)(a),(2)(c), C.R.S. (F4), and against the peace and dignity of the People of theState of Colorado.

PREDICATE ACT 31

Filing a False Tax Return, §39-21-118(4), C.R.S. (F5) 40024

On or about and between January 1, 2010 and July 31, 2012 in the State of Colorado,CONLEY HOSKINS, JANE MEDICALS, LLC and ALL CARE WELLNESS CENTERS,

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 everymaterial matter; in violation of §39-21-118(4), C.R.S. (F5), and against the peace and dignity of thePeople of the State of Colorado.




24

Starting about January 1, 2010 and continuing until roughly September 30, 2012, ConleyHoskins, Yesenia Melendez, Audra Wimer, Dialyne Parker, Carlos Meza, Nathan Newman, RyanTripp, and Jane Medicals, LLC engaged in the illegal distribution of marijuana and a conspiracy toillegally distribute marijuana. These persons and entity did so by utilizing a state licensed medicalmarijuana dispensary as a front to illegally traffic marijuana in amounts above those allowable bystate law. Mr. Hoskins and other store supervisors, acting as high managerial agents for Jane

Medicals, LLC, directed their employees to sell more than two ounces of marijuana to both legallyred carded patients and illegally to individuals without red cards. After receiving these directionsYesenia Melendez, Audra Wimer, Dialyne Parker, Carlos Meza, Nathan Newman, Ryan Tripp performed the requested illegal sales.

From January 1, 2010 until July 20, 2011 as a result of repeated sales of marijuana tocustomers through Jane Medicals, LLC and All Care Wellness Centers, LLC, during tax years 2010and 2011, Mr. Conley Hoskins committed tax evasion, conspiracy to commit tax evasion, filed falsereturns and committed theft. Mr. Hoskins did so through a scheme coordinated with his employees,whereby the participants/conspirators deliberately failed to collect and remit sales taxes to theColorado Department of Revenue. Mr. Hoskins directed employees to sell and stood complicit intheir actions to sell more than two ounces of marijuana to both legally red carded patients and

illegally to individuals without red cards. Mr. Hoskins possessed knowledge of this and encouraged Jane Medicals, LLC employees to omit certain sales and understate these sales in the point of salescomputer system to evade taxes and to avoid both the recording of illegal sales and the underreportingof sales and sales taxes to the Colorado Department of Revenue. Ms. Melendez, Ms. Wimer and Mr.Parker admitted to conducting these types of sales and the three stated they witnessed Mr. Meza, Mr. Newman and Mr. Tripp performing similar illegal sales and underreporting the volume of sales aswell.

Furthermore, Jane Medicals, LLC and All Care Wellness Centers, LLC sales tax returns did not reflect the amounts of sales and sales taxes reported in Mr. Hoskins’ and Mr. Criter’s prospectusfor the same tax periods. The prospectus reported an additional approximate $65,900.00 in collected state administered sales tax than what had been reported by Mr. Hoskins and Mr. Dirkmaat to the

Department of Revenue by Jane Medicals, LLC and All Care Wellness Centers, LLC for Januarythrough December 2010. In August of 2011, a pro forma provided to Mr. Martin by Mr. Hoskinsdescribed actual sales reported by Jane Medicals, LLC and All Care Wellness Centers, LLC fromJanuary 1, 2011 and June 30, 2011. During this period, an additional $9,982.09 in state administered sales taxes was reported collected a pro forma over what was reported by Mr. Hoskins to theDepartment of Revenue for All Care Wellness, LLC. Over the same time period, the pro forma demonstrated an additional $34,438.75 in state administered sales tax collected over and above whatMr. Hoskins reported to the Department or Revenue for Jane Medicals, LLC. In total, nearly$110,000.00 in state administered sales taxes collected and reflected in a prospectus and pro forma,were stolen by Mr. Hoskins and Jane Medicals, LLC and not remitted to the Department of Revenuein 2010 and 2011.

In July of 2012, investigators from the Department of Revenue executed a search warrant and seized a computer from Mr. Hoskins’ business. In February of 2013 Mr. Conley Hoskins reported additional sales and attempted to pay the additional remitted sales taxes associated with his previouslyfiled false returns for Jane Medicals, LLC. The bank account upon which these checks for theremittance of sales tax were drawn possessed insufficient funds at the time received by theDepartment of Revenue.



25

PREDICATE ACT 32

Forgery of Checks or Commercial Instruments, §18-5-102(1)(c), C.R.S. (F5) 1001C

On or about and between February 1, 2011 and March 31, 2011, in the State of Colorado,

CONLEY HOSKINS and DALLAN DIRKMAAT, with the intent to defraud Ritchie Bros.Auctioneers America, Inc., 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 deed, will, codicil, contract, assignment, commercial instrument, promissorynote, or other instrument which document did or may have evidenced, created, transferred,terminated, or otherwise affected a legal right, interest, obligation, or status, namely: bills of sale and or an auction contract; in violation of §18-5-102(1)(c) C.R.S. (F5), and against the peace and dignityof the People of the State of Colorado.

PREDICATE ACT 33


On or about and between February 1, 2011 and March 31, 2011, in the State of Colorado,CONLEY HOSKINS and DALLAN DIRKMAAT, unlawfully, feloniously, and knowinglyobtained or exercised control over a thing of value, namely: money of Ritchie Bros. AuctioneersAmerica, Inc.,with a value of more than twenty thousand dollars, without authorization, or by threator deception, and intended to deprive Ritchie Bros. Auctioneers America, Inc., permanently of its useor benefit; in violation of §18-4-401(1)(a),(2)(d) C.R.S. (F3), and against the peace and dignity of thePeople of the State of Colorado.

PREDICATE ACT 34

Conspiracy to Commit Theft - $20,000 Or More, §18-4-401(1),(2)(d), and §18-2-201 C.R.S. (F4)

CON

On or about and between February 1, 2011 and March 31, 2011, in the State of Colorado,CONLEY HOSKINS and DALLAN DIRKMAAT with the intent to promote or facilitate thecommission of the crime of Theft - $20,000 Or More, §18-4-401(1),(2)(d), unlawfully and feloniouslyagreed with one another 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 planningor commission or attempted commission of that crime, and an overt act in pursuance of theconspiracy was committed by one or more of the conspirators; in violation of §18-4-401(1),(2)(d),C.R.S. and §18-2-201, C.R.S. (F4), and against the peace and dignity of the People of the State of Colorado.

The offenses alleged in Predicate Acts 32 through 34 incorporate the above mentioned facts,were committed in the following manner and occurred in the State of Colorado:

Between February of 2011 and March of 2011, Mr. Hoskins and Mr. Dirkmaat conspired with one another to participate in a theft scheme involving the use of forged documents designed toaffect a fraudulent sale/auction of heavy construction equipment. This scheme by these menculminated in the utterance of forged documents and the theft of money from Ritchie Bros.Auctioneers America, Inc.



26

Prior to February of 2011 Mr. Dalan Dirkmaat’s construction business, named DirkmaatStefanich, Inc., purchased a piece of heavy construction equipment manufactured by Komatsu. Thissame piece of Komatsu heavy construction equipment carried a manufacturer’s lien. In early 2011,Mr. Dirkmaat sought to sell his construction equipment at auction. However, with the approximate$27,000 lien in place any sale would be diminished by that same amount. Mr. Dirkmaat and Mr.Hoskins then set about and conspired to fraudulently convey the equipment without satisfying the

lien.To accomplish this goal, Mr. Hoskins and Mr. Dirkmaat stood complicit with one another in

generating and uttering a forged a bill of sale. The bill of sale falsely purported to be from RyanSchwartz, a manager at Effusion Construction, Inc. to Denali Custom Homes, LLC, a companyowned by Mr. Hoskins. The fraudulent bill of sale allowed the two men to hide the existence of thelien. Mr. Dirkmaat and Mr. Hoskins’ stood complicit in each other’s actions in the utterance of theforged document to Richie Bros. Auctioneers and the failure to disclose the lien on the equipment.

Unaware of the existence of the lien, Richie Bros. Auctioneers sold the equipment with theattached lien and relinquished the proceeds of the sale, in an amount over $24,500, to Mr. Hoskins.Richie Bros. Auctioneers later discovered the lien, settled with lienholder Komatsu, and pursued payment for the lien from Mr. Hoskins and Mr. Dirkmaat. Mr. Hoskins settled with Richie Bros.

Auctioneers for approximately $17,000.



27

PREDICATE ACT 35


On or about and between April 1, 2011 and May 1, 2012, CONLEY HOSKINS, DAVID

KRAUSE, ALL CARE WELLNESS CENTERS, LLC, JANE MEDICALS, LLC, 5105 E. 39th

AVE., LLC, BRENDEN JOYCE and others known and unknown to the Grand Jury unlawfully,feloniously, and knowingly cultivated, grew, or produced marijuana plants, or allowed marijuana plants to be cultivated, grown, or produced on land owned, occupied, or controlled by the defendants.Further, the number of marijuana plants was thirty or more; in violation of §18-18-406(7.5)(c), C.R.S.(F4), and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT 36

Conspiracy to Commit Cultivation of Marijuana, More than Thirty Plants §18-18-406(7.5)(c), and §18-2-201, C.R.S (F5) CON


KRAUSE, ALL CARE WELLNESS CENTERS, LLC, JANE MEDICALS, LLC, 5105 E. 39th AVE., LLC, BRENDEN JOYCE and others known and unknown to the Grand Jury with theintent to promote or facilitate the commission of the crime of Cultivation of Marijuana, More thanThirty Plants §18-18-406(7.5)(c), unlawfully and feloniously agreed with one another and personsknown to the Grand Jury 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 planningor commission or attempted commission of that crime, and an overt act in pursuance of theconspiracy was committed by one or more of the conspirators; in violation of §18-18-406(7.5)(c),C.R.S. and §18-2-201, C.R.S. (F5), and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT 37

Distribution of Marijuana, More than One Hundred Pounds, §18-18-406(6)(b)(I),(III)(C), C.R.S. (F3)88024

On or about and between April 1, 2011 and May 1, 2012,, CONLEY HOSKINS, DAVID


AVE., LLC, BRENDEN JOYCE and others known and unknown to the Grand Jury unlawfully,feloniously, and knowingly sold or distributed, or attempted to sell or distribute, marijuana. Further,the amount of marijuana was more than one hundred pounds; in violation of §18-18-406(6)(b)(I),(III)(C), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.



28

PREDICATE ACT 38

Conspiracy to Distribute, or Possess with Intent to Manufacture or Distribute, Marijuana – More thanOne Hundred Pounds, §18-18-406(6)(b)(I),(III)(C), C.R.S. (F3) 88053


KRAUSE, ALL CARE WELLNESS CENTERS, LLC, JANE MEDICALS, LLC, 5105 E. 39th AVE., LLC, BRENDEN JOYCE and others known and unknown to the Grand Jury unlawfully,feloniously, and knowingly conspired with one another and with persons known and unknown to theGrand Jury, to sell, distribute, or possess with intent to manufacture, sell or distribute marijuana.Further, the amount of marijuana was more than one hundred pounds; in violation of §18-18-406(6)(b)(I),(III)(C) C.R.S., and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT 39


On or about and between April 1, 2011 and May 1, 2012, in the State of Colorado, CONLEY

HOSKINS, BRENDEN JOYCE, DAVID KRAUSE and others known and unknown to theGrand Jury did knowingly or intentionally use a communications facility, namely, a wire, telephoneand/or other means of communication, to facilitate the commission of a felony, namely, distributionof 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 acommmunications facility being unlawful, and in violation of 21 U.S.C. §843.

PREDICATE ACT 40


On or about and between April 1, 2011 and May 1, 2012, in the State of Colorado, CONLEYHOSKINS, DAVID KRAUSE, 5105 E. 39th AVE., LLC and ALL CARE WELLNESS

CENTERS, LLC, knowingly or intentionally kept, maintained, controlled, rented, leased, or madeavailable 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; inviolation of §18-18-411(1), C.R.S. (M1), and against the peace and dignity of the People of the Stateof Colorado.



29

PREDICATE ACT 41


On or about and between April 1, 2011 and May 1, 2012, in the State of Colorado,

BRENDEN JOYCE, CONLEY HOSKINS, DAVID KRAUSE, 5105 E. 39th AVE., LLC and ALL CARE WELLNESS CENTERS, LLC, unlawfully managed or controlled a building, room, or enclosure as an owner, lessee, agent, employee, or mortgagee and knowingly or intentionally rented,leased, or made it available for use, and the defendant knew it was resorted to for the purpose of unlawfully manufacturing a controlled substance; in violation of §18-18-411(2)(b), C.R.S. and againstthe peace and dignity of the People of the State of Colorado.


During April 1, 2011 until May 1, 2012, Mr. David Krause and Ms. Janet Joyce, the mother of Brenden Joyce, obtained an ownership interest in a warehouse located in Denver, Colorado. This

warehouse was owned through a limited liability company named 5105 E. 39th Ave., LLC. Mr.Brenden Joyce, Mr. Hoskins and Mr. Krause conspired to illegally cultivate and illegally cultivated marijuana by improperly and illegally using the medical marijuana optional premise cultivationlicense for the medical marijuana dispensary Tea Alchemy, LLC. Indeed, Mr. Brenden Joyce and Mr. Krause conspired to actively manage the cultivation and distribution of the marijuana. In emails between Mr. Krause and the then owner of Tea Alchemy, LLC, Shasta Fite, the two discuss that themarijuana cultivated by 5105 E. 39th Ave., LLC was never sold through Tea Alchemy, LLC. Mr.Joyce, Mr. Krause and Mr. Hoskins knew of the illegal and unlicensed nature of the marijuanacultivated at 5105 E. 39th Ave., LLC’s warehouse and that it would be illegally distributed and sold through Mr. Hoskins’ medical marijuana dispensaries Jane Medicals, LLC and All Care WellnessCenters, LLC. Mr. Brenden Joyce and Mr. Howard Zall, the general manager of Jane Medicals, LLCand All Care Wellness Centers, LLC, admitted to distributing over one hundred pounds of the

marijuana cultivated and produced at 5105 E. 39th

Ave. to Mr. Hoskins’ medical marijuanadispensaries. During an interview given to law enforcement officers, general manager Howard Zallexplained that the marijuana illegally cultivated by Brenden Joyce and distributed to Jane Medicals,LLC and All Care Wellness Centers, LLC was sold through Hoskins’ retail stores, Jane Medicalslocated in Denver, CO and All Care Wellness Centers located in Lakewood. Each person and entitymentioned above stood complicit in one another’s actions to engage in illegal marijuana distribution,the illegal cultivation and the use of telephone calls and email to coordinate the above described illegal activity.



30

PREDICATE ACT 42


On or about and between August 1, 2011 and August 31, 2011, in the State of Colorado,

CONLEY HOSKINS, ALL CARE WELLNESS CENTERS, LLC, DALLAN DIRKMAAT,and THE PEOPLE’S LAW FIRM unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: money, of Rafael Craveiro with a value of more than twentythousand dollars, without authorization, or by threat or deception, and intended to deprive RafaelCraveiro, permanently of its use or benefit; in violation of §18-4-401(1)(a),(2)(d), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.

The offense alleged in Predicate Acts 42 incorporates the above mentioned facts, was committed inthe following manner and occurred in the State of Colorado:

During August of 2011, Conley Hoskins (individually and acting as high managerial agentand owner for All Care Wellness Centers, LLC) and Dallan Dirkmaat (individually and acting as

owner and high managerial agent of The People’s Law Firm) conspired with one another and participated in a theft scheme targeting Mr. Rafael Craveiro. Dirkmaat and Hoskins, acting as highmanagerial agents for their companies, utilized the business entities of The People’s Law Firm and All Care Wellness Centers, LLC, to effectuate their theft from Mr. Craveiro. The scheme by thesemen and their companies revolved around deceitful representations made during the formation of a business partnership between Mr. Craveiro and Mr. Hoskins. Both Hoskins and Dirkmaat presented false and deceitful information to induce Mr. Craveiro to become a partner in All Care WellnessCenters, LLC. The false and deceitful information includes but is not limited to, representations thatMr. Hoskins was a 100% owner of All Care Wellness Centers when he sold 50% of that samecompany to Mr. Craveiro. The amount of money that Hoskins, Dirkmaat and their companies stolefrom Mr. Craveiro was nearly $300,000.00.



31

PREDICATE ACT 43

Conspiracy to Commit Theft - $20,000 Or More, §18-4-401(1),(2)(d), C.R.S. (F4) CON

On or about and between December 1, 2011 and March 31, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM with the intentto promote or facilitate the commission of the crime of Theft - $20,000 Or More, §18-4-401(1),(2)(d),unlawfully and feloniously agreed with one another that one or more of them would engage inconduct 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 overtact in pursuance of the conspiracy was committed by one or more of the conspirators; in violation of §18-4-401(1),(2)(d), C.R.S. and §18-2-201, C.R.S. (F4), and against the peace and dignity of thePeople of the State of Colorado.

PREDICATE ACT 44


On or about and between December 1, 2011 and March 31, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM unlawfully,feloniously, and knowingly obtained or exercised control over a thing of value, namely: money, of Brenden Joyce and or Dana Joyce with a value of more than twenty thousand dollars, withoutauthorization, or by threat or deception, and intended to deprive Brenden Joyce and or Dana Joyce, permanently of its use or benefit; in violation of §18-4-401(1)(a),(2)(d), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT 45

Conspiracy to Commit Theft - $20,000 Or More, §18-4-401(1),(2)(d), and §18-2-201, C.R.S. (F4)CON

On or about and between February 1, 2012 and March 31, 2012, in the State of Colorado, CONLEY

HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM, with the intent to promote or facilitate the commission of the crime of Theft - $20,000 Or More, §18-4-401(1),(2)(d),unlawfully and feloniously agreed with one another and that one or more of them would engage inconduct 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 overtact in pursuance of the conspiracy was committed by one or more of the conspirators; in violation of §18-4-401(1),(2)(d), C.R.S. and §18-2-201, C.R.S. (F4), and against the peace and dignity of thePeople of the State of Colorado.

PREDICATE ACT 46


On or about and between February 1, 2012 and March 31, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT, and THE PEOPLE’S LAW FIRM unlawfully,feloniously, and knowingly obtained or exercised control over a thing of value, namely: money, of David Krause with a value of more than twenty thousand dollars, without authorization, or by threat



32

or deception, and intended to deprive David Krause, permanently of its use or benefit; in violation of §18-4-401(1)(a),(2)(d), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT47

Computer Crime – Scheme /Defraud - $20,000 or More, § 18-5.5-102(1)(b), C.R.S. (F3) 1502T

On or about and between December 1, 2011 and March 31, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM unlawfully,feloniously, and knowingly accessed a computer, computer network, or computer system, or any partthereof, for the purpose of devising or executing a scheme or artifice to defraud, and the loss, damage,value of services, or thing of value taken, or cost of restoration or repair was twenty thousand dollarsor more; in violation of §18-5.5-102(1)(b), C.R.S. (F3), and against the peace and dignity of thePeople of the State of Colorado.

PREDICATE ACT 48


On or about and between January 1, 2012 and March 31, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM with the intentto promote or facilitate the commission of the crime of Theft - $20,000 Or More, §18-4-401(1),(2)(d),unlawfully and feloniously agreed with one another that one or more of them would engage inconduct 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 overtact in pursuance of the conspiracy was committed by one or more of the conspirators; in violation of §18-4-401(1),(2)(d), C.R.S. and §18-2-201, C.R.S. (F4), and against the peace and dignity of thePeople of the State of Colorado.

PREDICATE ACT 49


On or about and between January 1, 2012 and March 31, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM unlawfully,feloniously, and knowingly obtained or exercised control over a thing of value, namely: money, of Nathan Churchill with a value of more than twenty thousand dollars, without authorization, or bythreat or deception, and intended to deprive Nathan Churchill, permanently of its use or benefit; inviolation of §18-4-401(1)(a),(2)(d), C.R.S. (F3), and against the peace and dignity of the People of theState of Colorado.



33

PREDICATE ACT 50

Conspiracy to Commit Theft - $20,000 Or More, §18-4-401(1),(2)(d), and §18-2-201, C.R.S. (F4)CON

On or about and between April 1, 2012 and June 30, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM with the intentto promote or facilitate the commission of the crime of Theft - $20,000 Or More, §18-4-401(1),(2)(d),unlawfully and feloniously agreed with one another and persons known to the Grand Jury that one or more of them would engage in conduct which constituted that crime or an attempt to commit thatcrime, 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 §18-4-401(1),(2)(d), C.R.S. and §18-2-201, C.R.S. (F4), and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT 51

Theft - $20,000 Or More, §18-4-401(1),(2)(d), C.R.S. (F3)

On or about and between April 1, 2012 and June 30, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM unlawfully,feloniously, and knowingly obtained or exercised control over a thing of value, namely: money, of Lawrence Deutsch with a value of more than twenty thousand dollars, without authorization, or bythreat or deception, and intended to deprive Lawrence Deutsch, permanently of its use or benefit; inviolation of §18-4-401(1)(a),(2)(d), C.R.S. (F3), and against the peace and dignity of the People of theState of Colorado.

PREDICATE ACT 52

Securities Fraud – Fraud or Deceit, C.R.S. §11-51-501(1)(c) (F3) 50053

On or about and between December 1, 2011 and June 30, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM in connectionwith the offer, sale, or purchase of a security, directly or indirectly, unlawfully, feloniously, and willfully engaged in any act, practice, or course of business which operated or would have operated asfraud or deceit upon any person; in violation of §11-51-501(1)(c) and §11-51-603(1), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT 53

Securities Fraud – Untrue Statement or Omission, C.R.S. §11-51-501(1)(b) (F3) 50052

On or about and between December 1, 2011 and June 30, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM in connectionwith the offer, sale, or purchase of a security, directly or indirectly, unlawfully, feloniously, and willfully made an untrue statement of a material fact or omitted to state a material fact necessary inorder to make the statements made, in the light of the circumstances under which they were made, notmisleading; in violation of §11-51-501(1)(b) and §11-51-603(1), C.R.S. (F3), and against the peaceand dignity of the People of the State of Colorado.



34

PREDICATE ACT 54


On or about and between December 1, 2011 and June 30, 2012, in the State of Colorado,

CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM, with theintent to defraud David Krause, Nathan Churchill and or Lawrence Deutsch, 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 mayhave evidenced, created, transferred, terminated, or otherwise affected a legal right, interest,obligation, or status, namely: an operating agreement; in violation of §18-5-102(1)(c), C.R.S. (F5),and against the peace and dignity of the People of the State of Colorado.


From December of 2011 until June of 2012, Mr. Hoskins and Mr. Dirkmaat (individually and as owner and high managerial agent of The People’s Law Firm) conspired with one another and participated in a theft scheme. This scheme by these men, utilizing the business entity of ThePeople’s Law Firm, culminated in the theft of moneys from Brenden Joyce and his wife Dana Joyce,David Krause, Nathan Churchill and Lawrence Deutsch. Throughout the scheme both men used anoperating agreement, containing false information, to induce potential investors and or potential partners to put money towards the purchase of Higher Health Medicals, LLC. Mr. Hoskins and Mr.Dirkmaat conspired with one another and stood complicit with one another’s acts throughout thistheft scheme.

During the above mentioned time frame, Mr. Hoskins sought to purchase a third medicalmarijuana dispensary named Higher Health Medical, LLC. He lacked the funds to do so and sought

help from his friend, Mr. Dirkmaat. Close in time to December of 2011, the two men conspired tosteal over $130,000 from Brenden and Dana Joyce. The first part of the scheme unfolded when Mr.Hoskins offered Mr. Joyce an option to be a partner in the purchase of Higher Health Medical, LLC.Mr. Dirkmaat, through his law firm, used his client trust account to falsely portray that Mr. Hoskins possessed over $100,000.00 of his own money to be put towards the purchase of Higher HealthMedical, LLC. Convinced by the false representations of Hoskins and Dirkmaat, Mr. Joyce put hisand his wife’s money into the trust account of The People’s Law Firm at UMB bank. Instead of themoney being spent on the purchase of Higher Health Medicals, LLC., the Joyce’s money wasfraudulently used by Mr. Hoskins to pay debts and personal expenses unrelated to the purchase of thedispensary. Mr. Dirkmaat stood complicit in these criminal actions of Mr. Hoskins and the fraudulentdiversion of Mr. and Mrs. Joyce’s money.

Mr. Joyce eventually became suspicious of the behavior of Mr. Dirkmaat and Mr. Hoskins.Mr. Joyce contacted Mr. Dirkmaat via email to request the return of his $130,000.00. In an emailresponse, Mr. Dirkmaat delayed the return of the money by providing Mr. Joyce a false excuse. Needing to return the money or risk exposure of their theft scheme, Mr. Dirkmat and Mr. Hoskinsconvinced another individual named David Krause to invest in the purchase of Higher HealthMedical. Mr. Krause was informed by Mr. Hoskins that his money would be used exclusively to purchase Higher Health Medical. Within days of the receipt of Mr. Krause’s investment, Mr. Hoskinsand Mr. Dirkmaat diverted Krause’s $130,000 from its intended purpose and used it to create the



35

appearance that the escrow money of Brenden and Dana Joyce had been returned (despite havingalready been spent by Hoskins and Dirkmaat).

In January of 2012, Hoskins and Dirkmaat targeted another investor named NathanChurchill. Mr. Churchill, an ex-patriot living in Brazil for the last thirty years, invested at least$150,000.00 with Mr. Dirkmaat and Mr. Hoskins for the purchase of High Health Medical and a

subsequent planned expansion of Mr. Hoskins’ medical marijuana businesses. Instead of being used as promised, Mr. Churchill’s money was fraudulently diverted to pay debts and personal expensesunrelated to the medical marijuana businesses of Mr. Hoskins.

In May of 2012, Hoskins and Dirkmaat again targeted another investor named LawrenceDeutsch. Mr. Deutsch, invested $200,000.00 with Mr. Dirkmaat and Mr. Hoskins for the purchase of High Health and a subsequent planned expansion of Mr. Hoskins’ medical marijuana businesses.Instead, Mr. Deutsch’s money was fraudulently diverted to pay debts and personal expenses unrelated to the medical marijuana businesses of Mr. Hoskins.

Ultimately in May of 2012, Mr. Hoskins did purchase Higher Health Medical, LLC for $75,000. However, Mr. Hoskins has only delivered approximately $60,000 of the original purchase

price.



36

PREDICATE ACT 55

Attempt To Influence A Public Servant, §18-8-306, C.R.S. (F4) 24051

On or about and between March 15, 2012 and April 30, 2012 in the State of ColoradoCONLEY HOSKINS, unlawfully and feloniously attempted to influence Laura Harris of the

Colorado Department of Revenue and or her subordinates, who are a public servants, by means of deceit, with the intent thereby to alter or affect those public servants’ decision, vote, opinion, or action concerning a matter which was to be considered or performed by the public servant or theagency or body of which the public servants were a member; in violation of §18-8-306, C.R.S. (F-4),and against the peace and dignity of the People of the State of Colorado.

PREDICATE ACT 56

Offering a False Instrument Instrument for Recording in the First Degree, §18-5-114(1), C.R.S. (F5)10121

On or about and between March 15, 2012 and April 30, 2012 in the State of Colorado

CONLEY HOSKINS, unlawfully, feloniously, and with intent to defraud, presented or offered awritten instrument, namely: a Medical Marijuana Enforcement Division application, relating to or affecting real or personal property or directly affecting contractual relationships, to a public office or a public employee, namely: Laura Harris of the Colorado Department of Revenue and or her subordinates in the Medical Marijuana Enforcement Division, with the knowledge or belief that thewritten instrument would be registered, filed, or recorded or become a part of the records of that public office or public employee, and knowing that the written instrument contained a material falsestatement or material false information; in violation of §18-5-114(1), C.R.S. (F5), and against the peace and dignity of the People of the State of Colorado.


Between March and April of 2012, Conley Hoskins contacted public servants with theMedical Marijuana Enforcement Division of the Colorado Department of Revenue (“MMED”) with aletter addressed “To whom it may concern”. During this period the MMED was headed by LauraHarris and staffed by approximately fifteen of her subordinates. These same public servants wererequired to render decisions, votes and or opinions on an array of matters related to the licensing and regulation of medical marijuana. This letter dated April 1, 2012 informed the MMED that Mr.Hoskins’ company, All Care Wellness Centers, LLC, had leased a warehouse located at 5105 East39th Avenue to cultivate marijuana. The letter attempted to deceive the public servants and alter or affect their decision vote or opinion concerning a matter which was to be considered of performed bythe MMED. Specifically, the letter falsely stated that no marijuana had been grown at the warehouseon behalf of All Care Wellness Centers, LLC. However, prior to this April date and contrary to the

assertions in the letter, marijuana had been grown by Brenden Joyce and Howard Zall at the directionof Conley Hoskins at the warehouse on 5105 East 39th Avenue. Further, this particular marijuanagrow had been financially supported by both Conley Hoskins and David Krause and ultimately madeavailable for sale by All Care Wellness Centers, LLC. Indeed, Mr. Joyce grew marijuana at 5105East 39th Avenue between April 1, 2011 and May 1, 2012 and during tax year 2011 he was a W-2wage earning employee managed by Conley Hoskins and employed by All Care Wellness Centers,LLC.



37

PREDICATE ACT 57

Failure to File Return or Pay Tax, C.R.S. 39-21-118(3), C.R.S. (M) 40023

On or about and between April 15, 2011 and April 15, 2013 in the State of ColoradoCONLEY HOSKINS, 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 §39-21-118(3), C.R.S., (M),and against the peace and dignity of the People of the State of Colorado.

The offense alleged in Predicate Act 57 incorporates the above mentioned facts, were committed inthe following manner and occurred in the State of Colorado:

On or about and between April 15, 2011 and April 15, 2013 Conley Hoskins unlawfully and willfully failed to file his personal tax returns as required by law.



38

PREDICATE ACT 58


On or about and between December 1, 2011 and June 30, 2012,, in the State of Colorado,

KURT CRITER, with the intent to defraud persons unknown to the Grand Jury, its successors and/or assigns unlawfully, feloniously, and falsely made, completed, altered, or uttered a written instrumentwhich 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 otherwiseaffected a legal right, interest, obligation, or status, namely: a prospectus and or business plan; inviolation of §18-5-102(1)(c), C.R.S. (F5), and against the peace and dignity of the People of the Stateof Colorado.

PREDICATE ACT 59

Securities Fraud – Untrue Statement or Omission, C.R.S. §11-51-501(1)(b) (F3) 50052

On or about and between December 1, 2011 and June 30, 2012, in the State of Colorado,CONLEY HOSKINS and KURT CRITER in connection with the offer, sale, or purchase of asecurity, directly or indirectly, unlawfully, feloniously, and willfully made an untrue statement of amaterial fact or omitted to state a material fact necessary in order to make the statements made, in thelight of the circumstances under which they were made, not misleading; in violation of §11-51-501(1)(b) and §11-51-603(1), C.R.S. (F3), and against the peace and dignity of the People of the Stateof Colorado.


From December of 2011 until June of 2012 Mr. Hoskins utilized the services of anestablished businessman named, Kurt Criter, to implement his fraudulent investment scheme. Mr.Hoskins consulted with Mr. Criter to draft a prospectus aimed at gaining investors for his medicalmarijuana businesses. The document was produced near February of 2011. In drafting the prospectus, Mr. Criter used earnings and projected earnings figures supplied by Mr. Hoskins and incorporated them into the prospectus provided to investors. The prospectus contained falseinformation and omitted numerous material facts necessary in order to make the statements made, inthe light of the circumstances under which they were made, not misleading. Furthermore, both menwere aware that Mr. Criter falsely portrayed himself in this forged document as an officer and or executive of the various medical marijuana businesses operated by Mr. Hoskins. At a later date, Mr.Criter sought investors from outside of Colorado and attempted to defraud them by providing theabove mentioned prospectus.

During December of 2012 criminal investigators interviewed Mr. Curt Criter on a variety of subjects, including but not limited to, his involvement with a securities offering, a fraudulentinvestment scheme and a business associate named Conley Hoskins. In order to hide and or minimizehis past involvement in the above described securities fraud, Mr. Criter engaged of acts of deceitdesigned to influence the official investigative decisions of Department of Revenue Special AgentSteve Bratten, Department of Revenue Special Agent Sondra Pennington and Investigator NathanPoplinger of the Colorado Attorney General’s Office. During the interview Mr. Criter, in part, stated that that he had no involvement with the above medical marijuana businesses other than, drafting the



39

prospectus and providing it to a group of potential investors. Investigators later discovered inconsistencies and deceit in Mr. Criter’s “story”, including but not limited to, Mr. Criter’sinvolvement in the expansion of the medical marijuana businesses and participation beyond his claimof only authoring the prospectus and providing it to investors.



40

PREDICATE ACT 60

Cultivation of Cannabis, F.S. 893.13(1)(a), Third Degree Felony

On or about February 1, 2012 in Collier County, Florida, DAVID KRAUSE did unlawfullymanufacture or cultivate a controlled substance, to-wit: Cannabis, contrary to Florida Statute

893.13(1)(a).

PREDICATE ACT 61

Possession of Cannabis - Over 20 Grams, F.S. 893.13(6)(a), Third Degree Felony

On or about February 1, 2012 in Collier County, Florida, DAVID KRAUSE did unlawfullyhave, in his actual or constructive possession, a controlled substance, to-wit: more than 20 grams of Cannabis, contrary to Florida Statute 893.13(6)(a).

PREDICATE ACT 62

Possession of Paraphernalia, F.S. 893.147, First Degree Misdemeanor

On or about February 1, 2012 in Collier County, Florida, DAVID KRAUSE did unlawfully possess with intent to use, drug paraphernalia as defined in §893.145, contrary to Florida Statute893.147.

Racketeering Activity, as defined in §18-17-103(5), includes any criminal act committed in any jurisidiction of the United States which, if committed in Colorado, would be a crime listed under §18-17-103(5)(b). Predicate Acts 60 through 62 are criminal acts qualifying as predicate acts for charging purposes under §18-17-103(5)(b) of the Colorado Organized Crime Control Act. Furthermore, Acts60 through 62 relate to the behavior of the above described enterprise. The offenses alleged inPredicate Acts 60 through 62 incorporate the above mentioned facts and occurred in the following

manner in the State of Florida:

After receiving a tip about a possible marijuana grow, detectives from the Collier CountySheriff’s vice narcotics unit conducted a search of David Krause’s located house in Naples, Florida.Upon approaching the residence the narcotics unit detectives, through an open garage door, observed marijuana being dried within the garage. The detectives then questioned Mr. Krause who confessed to certain facts, including but not limited to; illegally growing marijuana plants (weighingapproximately ½ pound), possessing additional marijuana weighing approximately 94.5 grams, possessing six marijuana pipes containing marijuana residue, and possessing 5.9 grams of hashish.



41

SUBSTANTIVE COUNTS

COUNT 4


On or about and between June 1, 2010 and May 15, 2011, CONLEY HOSKINS, DALLANDIRKMAAT, JANE MEDICALS, LLC, THE PEOPLE’S LAW FIRM and others known to the

Grand Jury unlawfully, feloniously, and knowingly cultivated, grew, or produced marijuana plants,or allowed marijuana plants to be cultivated, grown, or produced on land owned, occupied, or controlled by the defendants. Further, the number of marijuana plants was thirty or more; in violationof §18-18-406(7.5)(c), C.R.S. (F4), and against the peace and dignity of the People of the State of Colorado.

COUNT 5

Conspiracy to Commit Cultivation of Marijuana, More than Thirty Plants §18-18-406(7.5)(c), and §18-2-201, C.R.S. (F5) CON



Grand Jury with the intent to promote or facilitate the commission of the crime of Cultivation of Marijuana, More than Thirty Plants §18-18-406(7.5)(c), unlawfully and feloniously agreed with oneanother and persons known to the Grand Jury 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 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 §18-18-406(7.5)(c), C.R.S. and §18-2-201, C.R.S. (F5), and against the peace and dignity of the People of the State of Colorado.

COUNT 6

Distribution of Marijuana – Five to One Hundred Pounds, §18-18-406(6)(b)(I),(III)(B), C.R.S. (F4)88023

On or about and between June 1, 2010 and May 15, 2011, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT, JANE MEDICALS, LLC, THE PEOPLE’S

LAW FIRM and others known to the Grand Jury unlawfully, feloniously, and knowingly sold or distributed, or attempted to sell or distribute, marijuana or marijuana concentrate. Further, theamount of marijuana was at least five pounds but not more than one hundred pounds; in violation of §18-18-406(6)(b)(I),(III)(B), C.R.S. (F4), and against the peace and dignity of the People of the Stateof Colorado.



42

COUNT 7



CONLEY HOSKINS, DALLAN DIRKMAAT, JANE MEDICALS, LLC, THE PEOPLE’SLAW FIRM and others known to the Grand Jury unlawfully, feloniously, and knowinglyconspired with one another and with and person or persons known and unknown to the Grand Jury, tosell, distribute, or possess with intent to manufacture, sell or distribute marijuana. Further, theamount of marijuana was at least five pounds but not more than one hundred pounds; in violation of §18-18-406(6)(b)(I),(III)(B), C.R.S (F4), and against the peace and dignity of the People of the Stateof Colorado.

COUNT 8

Money Laundering – Conduct Financial Transaction with Intent to Promote Crime, §18-5-309(1)(a)(I), C.R.S. (F3) 12211

On or about and between August 15, 2010 and May 15, 2011, in the State of Colorado,CONLEY HOSKINS and JANE MEDICALS, LLC, unlawfully and feloniously, conducted or attempted to conduct a financial transaction that involved money or any other thing of value that thedefendant 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 §18-5-309(1)(a)(I), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.

COUNT 9


On or about and between March 1, 2011 and September 30, 2011, in the State of Colorado,CONLEY HOSKINS and JANE MEDICALS, LLC unlawfully, feloniously, and knowinglyaccessed a computer, computer network, or computer system, or any part thereof, for the purpose of devising or executing a scheme or artifice to defraud, and the loss, damage, value of services, or thingof value taken, or cost of restoration or repair was twenty thousand dollars or more; in violation of §18-5.5-102(1)(b), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.

COUNT 10


On or about and between March 1, 2011 and June 30, 2012, in the State of Colorado,CONLEY HOSKINS and JANE MEDICALS, LLC, unlawfully, feloniously, and knowinglyobtained or exercised control over a thing of value, namely: money of Jerrod Martin, Gary Pool and or John Lemak with a value of more than twenty thousand dollars, without authorization, or by threator deception, and intended to deprive Jerrod Martin, Gary Pool and or John Lemak permanently of itsuse or benefit; in violation of §18-4-401(1)(a),(2)(d), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.



43

COUNT 11


On or about and between February 1, 2011 and June 30, 2012, in the State of Colorado,CONLEY HOSKINS and JANE MEDICALS, LLC, in connection with the offer, sale, or purchase

of a security, directly or indirectly, unlawfully, feloniously, and willfully engaged in any act, practice,or course of business which operated or would have operated as fraud or deceit upon any person; inviolation of §11-51-501(1)(c) and §11-51-603(1), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.

COUNT 12

Securities Fraud – Untrue Statement or Omission, §11-51-501(1)(b), C.R.S. (F3) 50052

On or about and between February 1, 2011 and June 30, 2012, in the State of Colorado,CONLEY HOSKINS and JANE MEDICALS, LLC, in connection with the offer, sale, or purchaseof a security, directly or indirectly, unlawfully, feloniously, and willfully made an untrue statement of

a material fact or omitted to state a material fact necessary in order to make the statements made, inthe light of the circumstances under which they were made, not misleading; in violation of §11-51-501(1)(b) and §11-51-603(1), C.R.S. (F3), and against the peace and dignity of the People of the Stateof Colorado.

COUNT 13


On or about and between June 1, 2010 and May 15, 2011, in the State of Colorado,CONLEY HOSKINS and others known 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 defendantknew was resorted to for the purpose of keeping for distribution, transporting for distribution, or distribution of a controlled substance; in violation of §18-18-411(1), C.R.S. (M1), and against the peace and dignity of the People of the State of Colorado.

COUNT 14



CONLEY HOSKINS and others known to the Grand Jury unlawfully managed or controlled a building, room, or enclosure as an owner, lessee, agent, employee, or mortgagee and knowingly or intentionally rented, leased, or made it available for use, and the defendant knew it was resorted to for the purpose of unlawfully manufacturing a controlled substance; in violation of §18-18-411(2)(b),C.R.S. (M1), and against the peace and dignity of the People of the State of Colorado.

The offenses alleged in Counts 4 through 14 were committed in the manner described followingPredicate Acts 1 through 12.



44

COUNT 15



NATHAN NEWMAN, JANE MEDICALS, LLC and others known to the Grand Jury

unlawfully, feloniously, and knowingly cultivated, grew, or produced marijuana plants, or allowed marijuana plants to be cultivated, grown, or produced on land owned, occupied, or controlled by thedefendants. Further, the number of marijuana plants was thirty or more; in violation of §18-18-406(7.5)(c), C.R.S. (F4), and against the peace and dignity of the People of the State of Colorado.

COUNT 16

Conspiracy to Commit Cultivation of Marijuana, More than Thirty Plants §18-18-406(7.5)(c) and §18-2-201, C.R.S. (F5) CON


NATHAN NEWMAN, JANE MEDICALS, LLC and others known to the Grand Jury with the

intent to promote or facilitate the commission of the crime of Cultivation of Marijuana, More thanThirty Plants §18-18-406(7.5)(c), unlawfully and feloniously agreed with one another and personsknown to the Grand Jury 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 planningor commission or attempted commission of that crime, and an overt act in pursuance of theconspiracy was committed by one or more of the conspirators; in violation of §18-18-406(7.5)(c),C.R.S. and §18-2-201, C.R.S. (F5), and against the peace and dignity of the People of the State of Colorado.

COUNT 17


88052


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 at least five pounds but not more than one hundred pounds; in violation of §18-18-406(6)(b)(I),(III)(B), C.R.S.(F4), and against the peace and dignity of the People of the State of Colorado.



45

COUNT 18


On or about and between May 1, 2010 and December 31, 2011, in the State of Colorado,

CONLEY HOSKINS, NATHAN NEWMAN, JANE MEDICALS, LLC and others known to theGrand Jury unlawfully, feloniously, and knowingly conspired with one another and with and personor persons known and unknown to the Grand Jury, to sell, distribute, or possess with intent tomanufacture, sell or distribute marijuana. Further, the amount of marijuana was at least five pounds but not more than one hundred pounds; in violation of §18-18-406(6)(b)(I),(III)(B), C.R.S (F4), and against the peace and dignity of the People of the State of Colorado.

COUNT 19


On or about and between May 1, 2010 and December 31, 2011, in the State of Colorado, CONLEY HOSKINS and NATHAN NEWMAN, 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 wasresorted to for the purpose of keeping for distribution, transporting for distribution, or distribution of a controlled substance; in violation of §18-18-411(1), C.R.S. (M1), and against the peace and dignityof the People of the State of Colorado.

COUNT 20


On or about and between May 1, 2010 and December 31, 2011, in the State of Colorado,CONLEY HOSKINS and NATHAN NEWMAN unlawfully managed or controlled a building,room, or enclosure as an owner, lessee, agent, employee, or mortgagee and knowingly or intentionallyrented, leased, or made it available for use, and the defendant knew it was resorted to for the purposeof unlawfully manufacturing a controlled substance; in violation of §18-18-411(2)(b), C.R.S. (M1),and against the peace and dignity of the People of the State of Colorado.




46

COUNT 21

Evasion of Taxes Administered by the Colorado Department of Revenue, §39-21-118 (1), C.R.S.(F5) 40021


ALL CARE WELLNESS CENTERS, LLC, did unlawfully, feloniously and willfully attempt toevade and defeat a tax administered by the Colorado Department of Revenue, or a payment thereof namely, wage withholdings, in violation of §39-21-118(1), C.R.S. (F5), and against the peace and dignity of the People of the State of Colorado.

COUNT 22

Theft - $20,000 Or More, §18-4-401(1),(2)(d), C.R.S. (F3), 0801V


ALL CARE WELLNESS CENTERS, LLC, unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: money of the Colorado Department of Revenue, witha value of more than twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive the Colorado Department of Revenue, permanently of its use or benefit; inviolation of §18-4-401(1)(a),(2)(d), C.R.S. (F3), and against the peace and dignity of the People of theState of Colorado.




47

COUNT 23

Evasion of Taxes Administered by the Colorado Department of Revenue, §39-21-118 (1), C.R.S.(F5) 40021

On or about and between January 1, 2010 and July 20, 2011, in the State of Colorado,

CONLEY HOSKINS, JANE MEDICALS, LLC and ALL CARE WELLNESS CENTERS,LLC, did unlawfully, feloniously and willfully attempt to evade and defeat a tax administered by theColorado Department of Revenue, or a payment thereof namely, Colorado Sales Tax, in violation of §39-21-118(1), C.R.S. (F5), and against the peace and dignity of the People of the State of Colorado.

COUNT 24

Conspiracy to Commit Evasion of Taxes Administered by the Colorado Department of Revenue, §39-21-118 (1) and §18-2-201, C.R.S. (F6) CON

On or about and between January 1, 2010 and July 20, 2011, in the State of Colorado,CONLEY HOSKINS, YESENIA MELENDEZ, AUDRA WIMER, CARLOS MEZA, NATHAN

NEWMAN, RYAN TRIPP and JANE MEDICALS, LLC, with the intent to promote or facilitatethe 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 engagein 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 overtact in pursuance of the conspiracy was committed by one or more of the conspirators; in violation of sections §39-21-118 (1) and §18-2-201, C.R.S. (F6), and against the peace and dignity of the Peopleof the State of Colorado.

COUNT 25

Evasion of Taxes Administered by the Colorado Department of Revenue,

§39-21-118 (1), C.R.S. (F-5) 40021

On or about and between January 1, 2010 and July 20, 2011, in the State of Colorado,YESENIA MELENDEZ, AUDRA WIMER, CARLOS MEZA, NATHAN NEWMAN, RYAN

TRIPP and JANE MEDICALS, LLC, did unlawfully, feloniously and willfully attempt to evadeand defeat a tax administered by the Colorado Department of Revenue, or a payment thereof namely,State of Colorado Sales Tax, in violation of §39-21-118(1), C.R.S. (F5), and against the peace and dignity of the People of the State of Colorado.



48

COUNT 26


On or about and between January 1, 2010 and September 30, 2012, in the State of Colorado,

CONLEY HOSKINS, YESENIA MELENDEZ, AUDRA WIMER, DIALYNE PARKER,CARLOS MEZA, NATHAN NEWMAN, RYAN TRIPP and JANE MEDICALS, LLC,

unlawfully, feloniously, and knowingly conspired with one another and with and person or personsknown and unknown to the Grand Jury, to sell, distribute, or possess with intent to manufacture, sellor distribute marijuana. Further, the amount of marijuana was at least five pounds but not more thanone hundred pounds; in violation of §18-18-406(6)(b)(I),(III)(B), C.R.S (F4), and against the peaceand dignity of the People of the State of Colorado.

COUNT 27

Distribution of Marijuana– Five to One Hundred Pounds, §18-18-406(6)(b)(I),(III)(B), C.R.S. (F4)88023



unlawfully, feloniously, and knowingly sold or distributed, or attempted to sell or distribute,marijuana or marijuana concentrate. Further, the amount of marijuana was at least five pounds but notmore than one hundred pounds; in violation of §18-18-406(6)(b)(I),(III)(B), C.R.S. (F4), and againstthe peace and dignity of the People of the State of Colorado.

COUNT 28


On or about and between January 1, 2010 and September 30, 2012, and discovered on or aboutSeptember 5, 2012, in the State of Colorado, CONLEY HOSKINS, YESENIA MELENDEZ,

AUDRA WIMER, DIALYNE PARKER, CARLOS MEZA, NATHAN NEWMAN, RYAN

TRIPP and JANE MEDICALS, LLC, unlawfully, feloniously, and knowingly accessed acomputer, computer network, or computer system, or any part thereof, for the purpose of devising or executing a scheme or artifice to defraud, and the loss, damage, value of services, or thing of valuetaken, or cost of restoration or repair was twenty thousand dollars or more; in violation of §18-5.5-102(1)(b), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.

COUNT 29

Tax Violation - Failure to Collect/Pay Trust Tax, §39-21-118(2), C.R.S. (F5) 40022

On or about and between February 21, 2010 and July 21, 2011, in the State of Colorado,CONLEY HOSKINS, JANE MEDICALS, LLC, and ALL CARE WELLNESS CENTERS,

LLC, who were required by law to collect, account for, or pay over a tax, unlawfully, feloniously,and willfully failed to collect or truthfully account for or pay over the tax; to wit: sales tax; inviolation of §39-21-118(2), C.R.S. (F5), and against the peace and dignity of the People of the Stateof Colorado.



49

COUNT 30


On or about and between February 21, 2010 and July 21, 2011, and discovered on or aboutSeptember 5, 2012, in the State of Colorado, CONLEY HOSKINS and JANE MEDICALS, LLC,

unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely:money of the Colorado Department of Revenue, with a value of more than twenty thousand dollars,without authorization, or by threat or deception, and intended to deprive the Colorado Department of Revenue, permanently of its use or benefit; in violation of §18-4-401(1)(a),(2)(d), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.

COUNT 31

Theft - $1,000 - $20,000, §18-4-401(1),(2)(c), C.R.S. (F4) 0801U

On or about and between February 21, 2011 and July 21, 2011, and discovered on or aboutSeptember 5, 2012, in the State of Colorado, CONLEY HOSKINS and ALL CARE WELLNESS

CENTERS, LLC, unlawfully, feloniously, and knowingly obtained or exercised control over a thingof value, namely: money of The Colorado Department of Revenue, with the value of one thousand dollars or more but less than twenty thousand dollars, without authorization, or by threat or deception,and intended to deprive The Colorado Department of Revenue permanently of its use or benefit; inviolation of §18-4-401(1)(a),(2)(c), C.R.S. (F4), and against the peace and dignity of the People of theState of Colorado.

COUNT 32

Filing a False Tax Return, §39-21-118(4), C.R.S. (F5) 40024

On or about and between January 1, 2010 and July 31, 2012 in the State of Colorado,

CONLEY HOSKINS, JANE MEDICALS, LLC and ALL CARE WELLNESS CENTERS,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 everymaterial matter; in violation of §39-21-118(4), C.R.S. (F5), and against the peace and dignity of thePeople of the State of Colorado.




50

COUNT 33


On or about and between February 1, 2011 and March 31, 2011, in the State of Colorado,CONLEY HOSKINS and DALLAN DIRKMAAT, with the intent to defraud Ritchie Bros.

Auctioneers America, Inc., 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 deed, will, codicil, contract, assignment, commercial instrument, promissorynote, or other instrument which document did or may have evidenced, created, transferred,terminated, or otherwise affected a legal right, interest, obligation, or status, namely: bills of sale and or an auction contract; in violation of §18-5-102(1)(c), C.R.S. (F5), and against the peace and dignityof the People of the State of Colorado.

COUNT 34


On or about and between February 1, 2011 and March 31, 2011, in the State of Colorado,CONLEY HOSKINS and DALLAN DIRKMAAT, unlawfully, feloniously, and knowinglyobtained or exercised control over a thing of value, namely: money of Ritchie Bros. AuctioneersAmerica, Inc.,with a value of more than twenty thousand dollars, without authorization, or by threator deception, and intended to deprive Ritchie Bros. Auctioneers America, Inc., permanently of its useor benefit; in violation of §18-4-401(1)(a),(2)(d), C.R.S. (F3), and against the peace and dignity of thePeople of the State of Colorado.

COUNT 35


On or about and between February 1, 2011 and March 31, 2011, in the State of Colorado,CONLEY HOSKINS and DALLAN DIRKMAAT with the intent to promote or facilitate thecommission of the crime of Theft - $20,000 Or More, §18-4-401(1),(2)(d), unlawfully and feloniouslyagreed with one another 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 planningor commission or attempted commission of that crime, and an overt act in pursuance of theconspiracy was committed by one or more of the conspirators; in violation of §18-4-401(1),(2)(d),C.R.S. and §18-2-201, C.R.S., and against the peace and dignity of the People of the State of Colorado.

The offenses alleged in Counts 33 through 35 were committed in the manner described following Predicate Acts 32 through 34.



51

COUNT 36



KRAUSE, ALL CARE WELLNESS CENTERS, LLC, JANE MEDICALS, LLC, 5105 E. 39th AVE., LLC, BRENDEN JOYCE and others known and unknown to the Grand Jury unlawfully,feloniously, and knowingly cultivated, grew, or produced marijuana plants, or allowed marijuana plants to be cultivated, grown, or produced on land owned, occupied, or controlled by the defendants.Further, the number of marijuana plants was thirty or more; in violation of §18-18-406(7.5)(c), C.R.S.(F4), and against the peace and dignity of the People of the State of Colorado.

COUNT 37


On or about and between April 1, 2011 and May 1, 2012, CONLEY HOSKINS, DAVIDKRAUSE, ALL CARE WELLNESS CENTERS, LLC, JANE MEDICALS, LLC, 5105 E. 39th

AVE., LLC, BRENDEN JOYCE and others known and unknown to the Grand Jury with theintent to promote or facilitate the commission of the crime of Cultivation of Marijuana, More thanThirty Plants §18-18-406(7.5)(c), unlawfully and feloniously agreed with one another and personsknown to the Grand Jury 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 planningor commission or attempted commission of that crime, and an overt act in pursuance of theconspiracy was committed by one or more of the conspirators; in violation of §18-18-406(7.5)(c),C.R.S. and §18-2-201, C.R.S. (F5), and against the peace and dignity of the People of the State of Colorado.

COUNT 38

Distribution of Marijuana, More than One Hundred Pounds, §18-18-406(6)(b)(I),(III)(C), C.R.S. (F3)88024

On or about and between April 1, 2011 and May 1, 2012,, CONLEY HOSKINS, DAVID


AVE., LLC, BRENDEN JOYCE and others known and unknown to the Grand Jury unlawfully,feloniously, and knowingly sold or distributed, or attempted to sell or distribute, marijuana. Further,the amount of marijuana was more than one hundred pounds; in violation of §18-18-406(6)(b)(I),(III)(C), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.



52

COUNT 39

Conspiracy to Distribute, or Possess with Intent to Manufacture or Distribute, Marijuana – More thanOne Hundred Pounds, §18-18-406(6)(b)(I),(III)(C), C.R.S. (F3) 88053


KRAUSE, ALL CARE WELLNESS CENTERS, LLC, JANE MEDICALS, LLC, 5105 E. 39th AVE., LLC, BRENDEN JOYCE and others known and unknown to the Grand Jury unlawfully,feloniously, and knowingly conspired with one another and with persons known and unknown to theGrand Jury, to sell, distribute, or possess with intent to manufacture, sell or distribute marijuana.Further, the amount of marijuana was more than one hundred pounds; in violation of §18-18-406(6)(b)(I),(III)(C), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.

COUNT 40


On or about and between April 1, 2011 and May 1, 2012, in the State of Colorado, CONLEY

HOSKINS, DAVID KRAUSE, 5105 E. 39th

AVE., LLC and ALL CARE WELLNESS

CENTERS, LLC, knowingly or intentionally kept, maintained, controlled, rented, leased, or madeavailable 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; inviolation of §18-18-411(1), C.R.S. (M1), and against the peace and dignity of the People of the Stateof Colorado.

COUNT 41


On or about and between April 1, 2011 and May 1, 2012, in the State of Colorado,BRENDEN JOYCE, CONLEY HOSKINS, DAVID KRAUSE, 5105 E. 39th AVE., LLC and ALL CARE WELLNESS CENTERS, LLC, unlawfully managed or controlled a building, room, or enclosure as an owner, lessee, agent, employee, or mortgagee and knowingly or intentionally rented,leased, or made it available for use, and the defendant knew it was resorted to for the purpose of unlawfully manufacturing a controlled substance; in violation of §18-18-411(2)(b), C.R.S. (M1), and against the peace and dignity of the People of the State of Colorado.

The offenses alleged in Counts 36 through 41 were committed in the manner described following

Predicate Acts 35 through 41.



53

COUNT 42


On or about and between August 1, 2011 and August 31, 2011, in the State of Colorado,

CONLEY HOSKINS, ALL CARE WELLNESS CENTERS, LLC, DALLAN DIRKMAAT,and THE PEOPLE’S LAW FIRM unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: money, of Rafael Craveiro with a value of more than twentythousand dollars, without authorization, or by threat or deception, and intended to deprive RafaelCraveiro, permanently of its use or benefit; in violation of §18-4-401(1)(a),(2)(d), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.

The offense alleged in Count 42 was committed in the manner described following Predicate Acts 42.



54

COUNT 43


On or about and between December 1, 2011 and March 31, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM with the intentto promote or facilitate the commission of the crime of Theft - $20,000 Or More, §18-4-401(1),(2)(d),unlawfully and feloniously agreed with one another that one or more of them would engage inconduct 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 overtact in pursuance of the conspiracy was committed by one or more of the conspirators; in violation of §18-4-401(1),(2)(d) and §18-2-201, C.R.S. (F4), and against the peace and dignity of the People of the State of Colorado.

COUNT 44


On or about and between December 1, 2011 and March 31, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM unlawfully,feloniously, and knowingly obtained or exercised control over a thing of value, namely: money, of Brenden Joyce and or Dana Joyce with a value of more than twenty thousand dollars, withoutauthorization, or by threat or deception, and intended to deprive Brenden Joyce and or Dana Joyce, permanently of its use or benefit; in violation of §18-4-401(1)(a),(2)(d), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.

COUNT 45


On or about and between February 1, 2012 and March 31, 2012, in the State of Colorado, CONLEY

HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM, with the intent to promote or facilitate the commission of the crime of Theft - $20,000 Or More, §18-4-401(1),(2)(d),unlawfully and feloniously agreed with one another and that one or more of them would engage inconduct 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 overtact in pursuance of the conspiracy was committed by one or more of the conspirators; in violation of §18-4-401(1),(2)(d) and §18-2-201, C.R.S. (F4), and against the peace and dignity of the People of the State of Colorado.

COUNT 46


On or about and between February 1, 2012 and March 31, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT, and THE PEOPLE’S LAW FIRM unlawfully,feloniously, and knowingly obtained or exercised control over a thing of value, namely: money, of David Krause with a value of more than twenty thousand dollars, without authorization, or by threator deception, and intended to deprive David Krause, permanently of its use or benefit; in violation of



55

§18-4-401(1)(a),(2)(d), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.

COUNT 47


On or about and between December 1, 2011 and March 31, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM unlawfully,feloniously, and knowingly accessed a computer, computer network, or computer system, or any partthereof, for the purpose of devising or executing a scheme or artifice to defraud, and the loss, damage,value of services, or thing of value taken, or cost of restoration or repair was twenty thousand dollarsor more; in violation of §18-5.5-102(1)(b), C.R.S. (F3), and against the peace and dignity of thePeople of the State of Colorado.

COUNT 48


On or about and between January 1, 2012 and March 31, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM with the intentto promote or facilitate the commission of the crime of Theft - $20,000 Or More, §18-4-401(1),(2)(d),unlawfully and feloniously agreed with one another that one or more of them would engage inconduct 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 overtact in pursuance of the conspiracy was committed by one or more of the conspirators; in violation of §18-4-401(1),(2)(d) and §18-2-201, C.R.S. (F4), and against the peace and dignity of the People of the State of Colorado.

COUNT 49


On or about and between January 1, 2012 and March 31, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM unlawfully,feloniously, and knowingly obtained or exercised control over a thing of value, namely: money, of Nathan Churchill with a value of more than twenty thousand dollars, without authorization, or bythreat or deception, and intended to deprive Nathan Churchill, permanently of its use or benefit; inviolation of §18-4-401(1)(a),(2)(d), C.R.S. (F3), and against the peace and dignity of the People of theState of Colorado.



56

COUNT 50


On or about and between April 1, 2012 and June 30, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM with the intent

to promote or facilitate the commission of the crime of Theft - $20,000 Or More, §18-4-401(1),(2)(d),unlawfully and feloniously agreed with one another and persons known to the Grand Jury that one or more of them would engage in conduct which constituted that crime or an attempt to commit thatcrime, 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 §18-4-401(1),(2)(d) and §18-2-201, C.R.S. (F4), and againstthe peace and dignity of the People of the State of Colorado.

COUNT 51


On or about and between April 1, 2012 and June 30, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM unlawfully,feloniously, and knowingly obtained or exercised control over a thing of value, namely: money, of Lawrence Deutsch with a value of more than twenty thousand dollars, without authorization, or bythreat or deception, and intended to deprive Lawrence Deutsch, permanently of its use or benefit; inviolation of §18-4-401(1)(a),(2)(d), C.R.S. (F3), and against the peace and dignity of the People of theState of Colorado.

COUNT 52


On or about and between December 1, 2011 and June 30, 2012, in the State of Colorado,CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM in connectionwith the offer, sale, or purchase of a security, directly or indirectly, unlawfully, feloniously, and willfully engaged in any act, practice, or course of business which operated or would have operated asfraud or deceit upon any person; in violation of §11-51-501(1)(c) and §11-51-603(1), C.R.S. (F3), and against the peace and dignity of the People of the State of Colorado.

COUNT 53



CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM in connectionwith the offer, sale, or purchase of a security, directly or indirectly, unlawfully, feloniously, and willfully made an untrue statement of a material fact or omitted to state a material fact necessary inorder to make the statements made, in the light of the circumstances under which they were made, notmisleading; in violation of §11-51-501(1)(b) and §11-51-603(1), C.R.S. (F3), and against the peaceand dignity of the People of the State of Colorado.



57

COUNT 54



CONLEY HOSKINS, DALLAN DIRKMAAT and THE PEOPLE’S LAW FIRM, with theintent to defraud David Krause, Nathan Churchill and or Lawrence Deutsch, 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 mayhave evidenced, created, transferred, terminated, or otherwise affected a legal right, interest,obligation, or status, namely: an operating agreement; in violation of §18-5-102(1)(c), C.R.S. (F5),and against the peace and dignity of the People of the State of Colorado.




58

COUNT 55


On or about and between March 15, 2012 and April 30, 2012 in the State of ColoradoCONLEY HOSKINS, unlawfully and feloniously attempted to influence Laura Harris of the

Colorado Department of Revenue and or her subordinates, who are a public servants, by means of deceit, with the intent thereby to alter or affect those public servants’ decision, vote, opinion, or action concerning a matter which was to be considered or performed by the public servant or theagency or body of which the public servants were a member; in violation of §18-8-306, C.R.S. (F-4),and against the peace and dignity of the People of the State of Colorado.

COUNT 56

Offering a False Instrument Instrument for Recording in the First Degree, §18-5-114(1), C.R.S. (F5)10121

On or about and between March 15, 2012 and April 30, 2012 in the State of Colorado

CONLEY HOSKINS, unlawfully, feloniously, and with intent to defraud, presented or offered awritten instrument, namely: a Medical Marijuana Enforcement Division application, relating to or affecting real or personal property or directly affecting contractual relationships, to a public office or a public employee, namely: Laura Harris of the Colorado Department of Revenue and or her subordinates in the Medical Marijuana Enforcement Division, with the knowledge or belief that thewritten instrument would be registered, filed, or recorded or become a part of the records of that public office or public employee, and knowing that the written instrument contained a material falsestatement or material false information; in violation of §18-5-114(1), C.R.S. (F5) and against the peace and dignity of the People of the State of Colorado.




59

COUNT 57

Failure to File Return or Pay Tax, §39-21-118(3), C.R.S. (M) 40023

On or about and between April 15, 2010 and April 15, 2013 in the State of ColoradoCONLEY HOSKINS, 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 §39-21-118(3), C.R.S. (M),and against the peace and dignity of the People of the State of Colorado.

The offense alleged in Count 57 was committed in the manner described following Predicate Act 64.



60

COUNT 58


On or about and between December 1, 2011 and June 30, 2012,, in the State of Colorado,KURT CRITER, with the intent to defraud persons unknown to the Grand Jury, its successors and/or

assigns unlawfully, feloniously, and falsely made, completed, altered, or uttered a written instrumentwhich 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 otherwiseaffected a legal right, interest, obligation, or status, namely: a prospectus and or business plan; inviolation of §18-5-102(1)(c), C.R.S. (F5), and against the peace and dignity of the People of the Stateof Colorado.

COUNT 59


On or about and between December 1, 2011 and June 30, 2012, in the State of Colorado,CONLEY HOSKINS and KURT CRITER in connection with the offer, sale, or purchase of asecurity, directly or indirectly, unlawfully, feloniously, and willfully made an untrue statement of amaterial fact or omitted to state a material fact necessary in order to make the statements made, in thelight of the circumstances under which they were made, not misleading; in violation of §11-51-501(1)(b) and §11-51-603(1), C.R.S. (F3), and against the peace and dignity of the People of the Stateof Colorado.




61

COUNT 60

Medical Marijuana – Unlawful Acts, §12-43.3-901(6), C.R.S. (M2) 88086

On or about and between July 1, 2010 and March 31, 2012, in the State of Colorado,

CONLEY HOSKINS, owner of Jane Medicals, LLC, a licensee licensed pursuant to Article 43.7 of Title 12 C.R.S. unlawfully offered something of value to a physician, Dr. Gerald Searle, for making patient referrals to a licensed medical marijuana center; in violation of §12-43.3-901(6), C.R.S. (M2),and against the peace and dignity of the People of the State of Colorado.

COUNT 61

Medical Marijuana – Unlawful Acts, §12-43.3-901(6), C.R.S. (M2) 88086

On or about and between July 1, 2010 and March 31, 2012, in the State of Colorado,GERALD SEARLE, a physician who makes patient referrals to a licensed medical marijuana center,unlawfully received something of value from the medical marijuana center licensee or its agents,

servants, officers or owners or anyone financially interested in the licensee for making patientreferrals; in violation of §12-43.3-901(6), C.R.S. (M2), and against the peace and dignity of thePeople of the State of Colorado.

The offenses alleged in Counts 60 through 61 incorporate all above mentioned facts and werecommitted in the following manner and occurred in the State of Colorado:

From July of 2010 until March of 2012, Dr. Gerald Searle, a licensed physician, made patientreferrals to Jane Medicals, LLC, a licensed medical marijuana center, while operating his practice ator near the 1400 block of Quince St. in Denver, Colorado. Contemporaneously, Conley Hoskins asowner of Jane Medicals, LLC, located around the corner from 1400 Quince St., paid the rent of Dr.Searle while he made the above mentioned patient referrals to Jane Medicals, LLC.



62

COUNT 62


On or about and between April 20, 2012 and April 30, 2012 in the State of Colorado AUDRA

WIMER, unlawfully and feloniously attempted to influence Special Agent Steve Bratten of the

Department of Revenue, 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 beconsidered or performed by the public servant or the agency or body of which the public servant wasa member; in violation of §18-8-306, C.R.S. (F-4), and against the peace and dignity of the People of the State of Colorado.

The offense alleged in Count 62 incorporates all above mentioned facts and was committed in thefollowing manner and occurred in the State of Colorado:

At the end of April 2013, Special Agent Steve Bratten, of the Colorado Department of Revenue, during the course of an investigation, interviewed Audra Wimer, a former employee of JaneMedicals, LLC. In efforts to minimize her involvement in ongoing illegal activities at Jane Medicals,

LLC, Ms. Wimer decieved Agent Bratten claiming she did not participate in illegal sales of marijuana. In a subsequent interview, Ms. Wimer admitted to Agent Bratten that she had attempted to decieve him about her involvement in the above mentioned illegal marijuana sales at JaneMedicals, LLC.



63

COUNT 63

Special Offender - Source of Income, §18-18-407(1)(b), C.R.S. (SE) 33442

On or about and between May 1, 2010 and May 1, 2012, in the State of Colorado, CONLEY

HOSKINS, committed the felony offenses charged in counts Four, Five, Six, Seven, Thirteen,Fourteen, Fifteen, Sixteen, Seventeen, Eighteen, Nineteen, Twenty, Twenty Six, Twenty Seven,Thirty Six, Thirty Seven, Thirty Eight, Thirty Nine, Forty and Forty One (4, 5, 6, 7, 13, 14, 15, 16,17, 18, 19, 20, 26, 27, 36, 37, 38, 39, 40 and 41) as part of a pattern of manufacturing, sale, or distributing controlled substances, which constituted a substantial source of the defendant's incomeand in which the defendant manifested special skill or expertise; in violation of §18-18-407(1)(b),C.R.S. (SE), and against the peace and dignity of the People of the State of Colorado.

COUNT 64

Special Offender – Conspiracy – Pattern of Sale, §18-18-407(1)(c) C.R.S. (SE) 33443

On or about and between May 1, 2010 and May 1, 2012, in the State of Colorado, CONLEYHOSKINS, committed the felony offenses charged in counts Four, Five, Six, Seven, Thirteen,Fourteen, Fifteen, Sixteen, Seventeen, Eighteen, Nineteen, Twenty, Twenty Six, Twenty Seven,Thirty Six, Thirty Seven, Thirty Eight, Thirty Nine, Forty and Forty One (4, 5, 6, 7, 13, 14, 15, 16,17, 18, 19, 20, 26, 27, 36, 37, 38, 39, 40 and 41) which was, or was in furtherance of, a conspiracywith 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, inviolation of §18-18-407(1)(c), C.R.S. (SE), and against the peace and dignity of the People of theState of Colorado.

COUNT 65

Special Offender – 100 Pounds of Marijuana or Marijuana Concentrate, §18-18-407(1)(e), C.R.S.(SE) 3344A

On or about and between May 1, 2010 and May 1, 2012, in the State of Colorado, CONLEY

HOSKINS, committed the felony offenses charged in counts Four, Five, Six, Seven, Thirteen,Fourteen, Fifteen, Sixteen, Seventeen, Eighteen, Nineteen, Twenty, Twenty Six, Twenty Seven,Thirty Six, Thirty Seven, Thirty Eight, Thirty Nine, Forty and Forty One (4, 5, 6, 7, 13, 14, 15, 16,17, 18, 19, 20, 26, 27, 36, 37, 38, 39, 40 and 41) and possessed, dispensed, sold, distributed, or imported into the State of Colorado a quantity in excess of one hundred pounds of marijuana or marijuana concentrate; in violation of §18-18-407(1)(e), C.R.S. (SE), and against the peace and dignity of the People of the State of Colorado.



64

COUNT 66


On or about and between June 1, 2010 and May 15, 2011, in the State of Colorado,DALLAN DIRKMAAT, committed the felony offenses charged in counts Four, Five, Six and Seven

(4, 5, 6 and 7) which was, or was in furtherance of, a conspiracy with one or more persons to engagein 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 allof the conspiracy or manufacture, sale, or distributing, in violation of §18-18-407(1)(c), C.R.S. (SE),and against the peace and dignity of the People of the State of Colorado.

COUNT 67

Special Offender - Source of Income, §18-18-407(1)(b) C.R.S. (SE) 33442

On or about and between May 1, 2010 and December 31, 2011, in the State of Colorado, NATHAN NEWMAN, committed the felony offenses charged in counts Fifteen, Sixteen, Seventeen,

Eighteen, Nineteen and Twenty (15, 16, 17, 18, 19 and 20) as part of a pattern of manufacturing, sale,or distributing controlled substances, which constituted a substantial source of the defendant's incomeand in which the defendant manifested special skill or expertise; in violation of §18-18-407(1)(b),C.R.S. (SE), and against the peace and dignity of the People of the State of Colorado.

COUNT 68


On or about and between May 1, 2010 and December 31, 2011, in the State of Colorado, NATHAN NEWMAN, committed the felony offenses charged in counts Fifteen, Sixteen, Seventeen,Eighteen, Nineteen and Twenty (15, 16, 17, 18, 19 and 20) which was, or was in furtherance of, a

conspiracy with one or more persons to engage in a pattern of manufacturing, sale, or distributing acontrolled 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 §18-18-407(1)(c), C.R.S. (SE), and against the peace and dignity of the People of theState of Colorado.



COUNT 69


On or about and between April 1, 2011 and May 1, 2012, in the State of Colorado, DAVID

KRAUSE, committed the felony offenses charged in counts Thirty Six, Thirty Seven, Thirty Eight,

Thirty Nine, Forty and Forty One (36, 37, 38, 39, 40 and 41) which was, or was in furtherance of, aconspiracy with one or more persons to engage in a pattern of manufacturing, sale, or distributing acontrolled 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 §18-18-407(1)(c), C.R.S. (SE), and against the peace and dignity of the People of theState of Colorado.

COUNT 70


On or about and between April 1, 2011 and May 1, 2012, in the State of Colorado,

BRENDEN JOYCE, committed the felony offenses charged in counts Thirty Six, Thirty Seven,Thirty Eight, Thirty Nine and Forty One (36, 37, 38, 39 and 41) which was, or was in furtherance of,a conspiracy with one or more persons to engage in a pattern of manufacturing, sale, or distributing acontrolled 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 §18-18-407(1)(c), C.R.S. (SE), and against the peace and dignity of the People of theState of Colorado.

COUNT 71

Special Offender – 100 Pounds of Marijuana or Marijuana Concentrate, §18-18-407(1)(e), C.R.S.(SE) 3344A

On or about and between April 1, 2011 and May 1, 2012, in the State of Colorado, BRENDEN JOYCE, committed the felony offense[s] charged in counts Thirty Six, Thirty Seven,Thirty Eight, Thirty Nine and Forty One (36, 37, 38, 39 and 41) and possessed, dispensed, sold,distributed, or imported into the State of Colorado a quantity in excess of one hundred pounds of marijuana or marijuana concentrate; in violation of §18-18-407(1)(e), C.R.S. (SE), and against the peace and dignity of the People of the State of Colorado.

hoskins et al indictment

Documents