Hoppz' Cropz Indictment

DISTRICT COURT, CITY AND COUNTY OF DENVER, COLORADO
1437 Bannock Street

Denver, CO 80202
THE PEOPLE OF THE STATE OF COLORADO,
v.
JOSEPH HOPPER (A.K.A. JOEY HOPS)

DARA WHEATLEY (A.K.A. BOSS LADY)
ADAM DONALDSON (A.K.A. POPS, POPZ)
JOSEPH SERGIO CRIVICI (A.K.A. JOSEPH CRAVICI)
HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBERS
ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP)
DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX
UGRILLA, PHEONUAX)
NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE,
FRANKIE, NATE)
VICTORIA FERNANDEZ (A.K.A. TORI)
MARCEE SMITH (A.K.A. MARLEY)
ALEJANDRA GONZALEZ (A.K.A. ALE)
RAYLENE RUBIO (A.K.A. RAY, RAE, RAYLEEN,
RAYLEAN)
NICOLE SANDOVAL (A.K.A. NIKKI)
ASHLEY HEFNER
MELISSA COLMUS
COURT USE ONLY
Defendants.
CYNTHIA COFFMAN, Attorney General
Grand Jury Case No.:
MICHAEL W. MELITO
16CR01
Senior Assistant Attorney General
1300 Broadway, 9th Floor
Denver, CO 80203 Ctrm: 259
720 508 6702
Reg. No. 36059
JON W. IPPOLITO
Special Assistant Attorney General
105 E. Vermijo Ave.
Colorado Springs, CO 80903
(719) 520-6000
Reg. No. 45002
ANDREW S. VAUGHAN
105 E. Vermijo Ave.
Colorado Springs, CO 80903
(719) 520-6000
Reg. No. 41223
COLORADO STATE GRAND JURY INDICTMENT
Of the 2016-2017 term of the Denver District Court in the year 2017; the 2016-2017
Colorado State Grand Jurors, chosen, selected and sworn in the name and by the authority of the
People of the State of Colorado, upon their oaths, present the following:
COUNT 1 Violation of the Colorado Organized Crime Control Act Pattern of Racketeering-
Participation in Enterprise, 18-17-104(3) and 18-17-105, C.R.S. (F2) 37284
COUNT 2 Violation of the Colorado Organized Crime Control Act Conspiracy/Endeavoring,

18-17-104(4), C.R.S. (F2) 37285
COUNT 3 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 4 Distribution Of Marijuana (50 LBS) or Marijuana Concentrate (25 LBS), 18-18-
406(2)(B)(I),(III)(A), C.R.S. (DF1) 8802P
COUNT 5 Possession with Intent to Manufacture or Distribute Marijuana (50 LBS) or

Marijuana Concentrate (25 LBS), 18-18-406(2)(B)(I),(III)(A), C.R.S. (DF1) 8802U
COUNT 6 Conspiracy to Distribute, or Possess with Intent to Manufacture or Distribute,

Marijuana (50 LBS) or Marijuana Concentrate (25LBS), 18-18-
406(2)(B)(I),(III)(A), C.R.S. (DF1) 8802Z
COUNT 7 Money Laundering Conduct Financial Transaction with Intent to Promote Crime,
18-5-309(1)(A)(I), C.R.S. (F3) 12211
COUNT 8 Conspiracy to Commit Money Laundering Conduct Financial Transaction with

Intent to Promote Crime, 18-5-309(1)(A)(I) and 18-2-201, C.R.S. (F4) CON
COUNT 9 Money Laundering Transfer Monetary Instrument with Intent to

Promote Crime, 18-5-309(1)(B)(I), C.R.S. (F3) 12213
COUNT 10 Conspiracy to Commit Money Laundering Transfer Monetary Instrument with

Intent to Promote Crime, 18-5-309(1)(B)(I) and 18-2-201, C.R.S. (F4) CON
COUNT 11 Keeping Property for Unlawful Distribution of Controlled Substances,

18-18-411(1), C.R.S. (DM1) 33514
COUNT 12 Evasion of Taxes Administered by the Colorado Department of Revenue,

39-21-118(1), C.R.S. (F5) 40021
COUNT 13 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

39-21-118(1), C.R.S. (F5) 40021
COUNT 15 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
COUNT 16 Failure to File Return or Pay Tax, 39-21-118(3), C.R.S. (M) 40023
COUNT 17 Filing a False Tax Return, 39-21-118(4), C.R.S. (F5) 40024
COUNT 18 Forgery, 18-5-102(1)(C), C.R.S. (F5)
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COUNT 19 Attempt To Influence A Public Servant, 18-8-306, C.R.S. (F4) 24051
COUNT 23 Special Offender Conspiracy Pattern of Sale, 18-18-407(1)(b), C.R.S. (DF-1)

33A43
COUNT 24 Special Offender Organizer in Series of Violations with Others, 18-18-407(1)(F),

C.R.S. (DF1) 33A48
COUNT 25 Special Offender Firearm, C.R.S. 18-18-407(1)(d)(II), C.R.S. (DF1) 33A45
COUNT 26 Filing a False Tax Return, 39-21-118(4), C.R.S. (F5) 40024

39-21-118(1), C.R.S. (F5) 40021
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INDEX OF DEFENDANTS
Defendant Date of Birth Counts

DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, 03/22/1989 1,2,4-16, 25
PHOENIXX UGRILLA, PHEONUAX)
NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY 01/11/1980 1,2,4-16, 25
LEONE, FRANKIE, NATE)
MELISSA COLMUS 01/18/1984 1,2,4-16, 18
JOSEPH SERGIO CRIVICI (A.K.A. JOSEPH 11/25/1983 1-16, 20, 23, 24
CRAVICI)
ADAM DONALDSON (A.K.A. POPS, POPZ) 06/23/1967 1-16, 23, 24
VICTORIA FERNANDEZ (A.K.A. TORI) 02/07/1995 1,2,4-16, 18, 21
ALEJANDRA GONZALEZ (A.K.A. ALE) 3/18/1995 1,2,4-16, 18
ASHLEY HEFNER 04/25/1988 1,2,4-16, 18, 22
JOSEPH HOPPER (A.K.A. JOEY HOPS) 06/16/1983 1-16, 18, 23, 24
HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A N/A 1-18, 20
MEMBERS ONLY, HOPPY CROPZ, HOPPZ
CROPZ, HOPZ CROP)
RAYLENE RUBIO (A.K.A. RAY, RAE, 02/07/1995 1,2,4-16, 19
RAYLEEN, RAYLEAN)
NICOLE SANDOVAL (A.K.A. NIKKI) 10/13/1995 1,2,4-16, 18, 21
MARCEE SMITH (A.K.A. MARLEY) 03/27/1994 1,2,4-16, 18
DARA WHEATLEY (A.K.A. BOSS LADY) 12/16/1988 1-18, 23, 24, 26, 27
4
COUNT 1
Violation of the Colorado Organized Crime Control Act Pattern of Racketeering- Participation in
Enterprise, 18-17-104(3) and 18-17-105, C.R.S. (F2) 37284
On or about and between July 1, 2016 and May 25, 2017, in and triable in the State of Colorado,
JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO
CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBERS ONLY,
HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A.
UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX), NATHAN
BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE),
VICTORIA FERNANDEZ (A.K.A. TORI), MARCEE SMITH (A.K.A. MARLEY),
ALEJANDRA GONZALEZ (A.K.A. ALE), RAYLENE RUBIO, NICOLE SANDOVAL,
ASHLEY HEFNER, MELISSA COLMUS and others known and unknown to the Grand Jury,
while employed by or associated with an enterprise, namely a group of individuals associated in fact,
although not a legal entity, unlawfully, feloniously, and knowingly conducted or participated, directly
or indirectly, in the enterprise through a pattern of racketeering activity: in violation of 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
ASHLEY HEFNER, MELISSA COLMUS and others known and unknown to the Grand Jury
did unlawfully, knowingly, and feloniously conspire to conduct and participate, directly or indirectly,
in an enterprise, through a pattern of racketeering activity in violation of C.R.S. 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 Interest
in Enterprise, 18-17-104(2) C.R.S. (F2) 37283
HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP) and others known and unknown to the
Grand Jury, did unlawfully, feloniously, and knowingly acquired or maintained, directly or
indirectly, an interest in or control of an enterprise, namely: HOPPZ CROPZ through a pattern of
racketeering activity or through the collection of an unlawful debt; in violation of 18-17-104(2),
C.R.S. (F2), and against the peace and dignity of the People of the State of Colorado.
5
The offenses alleged in Counts One, Two and Three were committed in the following manner:
The Enterprise
The enterprise alleged in Counts One, Two and Three consisted of a group of individuals,
associated in fact, and at least one legal entity. The enterprise included, the following associated in
fact individuals, a group of individuals, along with a legal entity and/or other entities: JOSEPH
HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ
CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBERS ONLY, HOPPY CROPZ, HOPPZ
CROPZ, HOPZ CROP), DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX
UGRILLA, PHEONUAX), NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY
LEONE, FRANKIE, NATE), VICTORIA FERNANDEZ (A.K.A. TORI), MARCEE SMITH
(A.K.A. MARLEY), ALEJANDRA GONZALEZ (A.K.A. ALE), RAYLENE RUBIO, NICOLE
SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS and others both known and unknown to the
Grand Jury, who were associated from time to time in the racketeering activity related to the conduct
of the enterprise.
The above persons and entity that associated with the enterprise, and the enterprise itself,
engaged in a scheme whereby the members conspired to purchase medical marijuana from licensed
facilities and resell it for profit under the guise the marijuana was being offerred as a free giveaway
with the purchase of a dramatically overpriced, yet low cost, item. In essence, the enterprise
possessed and distributed marijuana -and conspired to do the same- in Colorado Springs, Colorado
while simultaneously engaging in tax evasion, money laundering, attempts to influence public
servants, filing false tax information and failing to pay over taxes.
Joseph Hopper, his fiance Dara Wheatley, Joseph Sergio Crivici and Adam Donaldson
opened or joined in the ownership of marijuana distributing franchises. Under the brand Hoppz
Cropz these individuals leased storefronts at 2402 East Boulder St., Colorado Springs, Colorado and
2549 Delta Dr., Colorado Springs, Colorado. Acting as owners and high managerial agents, the four
owners used the Hoppz Cropz storefronts and Hoppz Cropz employees1 to sell marijuana along with
paraphernalia. The owner-managers and their employees engaged in a free giveaway ruse
combining sales of drug-related tangible personal property along with marijuana itself. 2 Members of
the enterprise routinely hand out a Hoppz Cropz form deceitfully acknowledging the store is gifting
patrons -without remuneration- less than two ounces of marijuana pursuant to Amendment 64.
Despite local ordinances against retail recreational marijuana stores, the drug trafficking organization
(DTO) through the Hoppz Cropz stores, skirted civil enforcement by the City of Colorado Springs
and ultimately trafficked nearly 200 pounds of finished/refined marijuana since its July of 2016
inception.
Detectives calculated the aggregate amount of nearly 200 pounds of illegally distributed
marijuana by Hoppz Cropz owners and employees using inventory records seized during the
execution of search warrants in the two Hoppz Cropz stores. Inventories from Hoppz Delta
indicated the daily amount of marijuana sold averaged 250.4 grams. By significantly underestimating
this average amount at 200 grams and multiplying it by the number of days Hoppz Delta has been
1 The employees of Hoppz Cropz managed by Joseph Hopper, Dara Wheatley, Adam Donaldson and Joseph Sergio Crivici,
include but are not limited to: Derrick Bernard, Nathan Bernheisel, Victoria Fernandez, Marcee Smith, Alejandra Gonzalez,
Raylene Rubio, Nicole Sandoval Ashley Hefner, Melissa Colmus, Tim, Mike, Alan, Nikki, Kelsey, Ashlie,
Bree, Shay, Dejanique Trashai, Patricia, Justin, John, Laura and Felicia.
2 By way of limited example, the members of the enterprise sold cheap lighters -worth a few cents- for $15 and employed
the ruse that the business was giving away one gram of marijuana for free along with the $15 lighter. The street value of one
gram of marijuana is approximately $15.
6
open (July 15, 2016, to May 6, 2017 = 42 weeks = 294 days), the total amount of marijuana sold can
be estimated at approximately 58,800 grams, or 129.6 pounds at the Hoppz Delta store alone.
Inventories from the Hoppz Boulder indicated the monthly amount of marijuana sold averaged at
4,418.33 grams. By significantly underestimating this average amount at 4,000 grams and multiplying
it by the number of months Hoppz Boulder has been open (October, 2016, to April, 2017 = 7
months), the total amount of marijuana sold can be estimated at approximately 28,000 grams, or 61.7
pounds. This results in an approximate, conservatively estimated total of marijuana sold through both
stores at 86,800 grams, or 191.3 pounds.
With this ruse in place, Hoppz Cropz succesfully evaded paying fees regularly associated
with retail recreational marijuana dispensary licensure and evaded excise taxes that an otherwise fully
licensed retail recreational dispensary would normally be required to pay to the Department of
Revenue. In effect, Hoppz Cropz, LLC, its owners and employees contributed to the recreational
marijuana black market. Despite opening a sales tax account with the Colorado Department of
Revenue in July of 2016 and engaging in conventional retail sales of parphernalia and clothing (as
well as illicit marijuana sales), Hoppz Cropz, LLC, its owner-managers and employees failed to
report the proper figures on nearly half a million dollars in retail sales. Moreover, the managers and
lower level members of the enterprise engaged in a second form of tax evasion by promoting and
receiving under the table payments of wages, thereby evading the associated wage withholding
taxes otherwise due to the Colorado Department of Revenue. Indeed, managers instructed the
workers to engage in deceit and inform any government officials who inquired that they the
salespersons- were merely volunteers working at their respective stores without pay.
Pattern of Racketeering Activity
For purposes of Counts One, Two and Three, JOSEPH HOPPER, DARA WHEATLEY,
ADAM DONALDSON, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ
CROPZ, A.K.A MEMBERS ONLY, HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP), DERRICK
BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA, PHEONUAX),
NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE, NATE),
directly and in concert, engaged in, attempted to engage in, conspired to engage in, or solicited
another to engage in at least two predicate acts, and any lesser included offenses as permitted in 18-
17-103, related to the conduct of the enterprise, at least one of which took place in the State of
Colorado after July 1, 1981 and the last of the acts of racketeering activity occurring within ten years
after a prior act of racketeering activity and include:
Distribution of Marijuana or Marijuana Concentrate

Conspiracy to Distribute or Possess with Intent to Manufacture or Distribute Marijuana or
Marijuana Concentrate
Possession with Intent to Manufacture or Distribute Marijuana or Marijuana Concentrate
Money Laundering
Evasion of Taxes Administered by the Colorado Department of Revenue
Conspiracy to Commit Evasion of Taxes Administered by the Colorado Department of
Revenue
Failure to File a Return or Pay Tax
Filing of a False Return
7
Keeping Property for Unlawful Distribution of Controlled Substances
Attempt to Influence a Public Servant
And the Predicate Act of: Unlawful Use of a Communications Facility.
RACKETEERING ACTIVITY
The acts of racketeering activity that the above named persons and/or entities committed,
attempted to commit, conspired to commit, or solicited, coerced, or intimidated another person to
commit, consist of the following predicate acts, including any lesser included offenses permitted to be
used as predicates under this statute:
Counts Four through Twenty Two and all other identified Predicate Act(s) set forth the
essential relevant acts of racketeering and are incorporated in these Counts One, Two and Three by
this reference. The relevant acts of racketeering activity include any lesser included offenses of
Counts Four through Twenty Two and all other identified Predicate Acts.
COUNT 4
Distribution Of Marijuana (50 LBS) or Marijuana Concentrate (25 LBS), 18-18-

406(2)(B)(I),(III)(A), C.R.S. (DF1) 8802P
ASHLEY HEFNER, MELISSA COLMUS, and others known and unknown to the Grand Jury,
unlawfully, feloniously, and knowingly sold or distributed, or attempted to sell or distribute marijuana
or marijuana concentrate. Further, the amount of marijuana was more than fifty pounds or the
marijuana concentrate was more than twenty five pounds, in violation of 18-18-406(2)(b)(I),(III)(A),
C.R.S. (DF1), and against the peace and dignity of the People of the State of Colorado.
COUNT 5
Possession with Intent to Manufacture or Distribute Marijuana (50 LBS) or Marijuana Concentrate
(25 LBS), 18-18-406(2)(B)(I),(III)(A), C.R.S. (DF1) 8802U
unlawfully, feloniously, and knowingly possessed, or attempted to possess, with intent to
manufacture, sell or distribute, marijuana or marijuana concentrate. Further, the amount of marijuana
8
was more than fifty pounds or the amount of marijuana concentrate was more than twenty five
pounds; in violation of 18-18-406(2)(b)(I),(III)(A), C.R.S. (DF1), and against the peace and dignity
of the People of the State of Colorado.
COUNT 6
Conspiracy to Distribute, or Possess with Intent to Manufacture or Distribute, Marijuana (50 LBS)
or Marijuana Concentrate (25LBS), 18-18-406(2)(B)(I),(III)(A), C.R.S. (DF1) 8802Z
unlawfully, feloniously, and knowingly conspired with one another and with a person or persons
known and unknown to the Grand Jury, to sell, distribute, or possess with intent to manufacture, sell
or distribute marijuana or marijuana concentrate. Further, the amount of marijuana was more than
fifty pounds or the amount of marijuana concentrate was more than twenty five pounds, in violation
of 18-18-406(2)(b)(I),(III)(A), C.R.S. (DF1), and against the peace and dignity of the People of the
State of Colorado.
COUNT 7
Money Laundering Conduct Financial Transaction with Intent to Promote Crime,

18-5-309(1)(A)(I), C.R.S. (F3) 12211
unlawfully and feloniously, conducted or attempted to conduct a financial transaction that involved
money or any other thing of value that the defendant knew or believed to be the proceeds, in any
form, of a criminal offense, with the intent to promote the commission of a criminal offense; in
violation of 18-5-309(1)(A)(I), C.R.S. (F3), and against the peace and dignity of the People of the
State of Colorado.
9
COUNT 8
Conspiracy to Commit Money Laundering Conduct Financial Transaction with Intent to Promote
Crime, 18-5-309(1)(A)(I) and 18-2-201, C.R.S. (F4) CON
with the intent to promote or facilitate the commission of the crime of Money Laundering Conduct
Financial Transaction with Intent to Promote Crime, unlawfully and feloniously agreed with one
another that one or more of them would engage in conduct which constituted that crime or an attempt
to commit that crime, or agreed to aid the other person or persons in the planning or commission or
attempted commission of that crime, and an overt act in pursuance of the conspiracy was committed
by one or more of the conspirators; in violation of 18-5-309(1)(A)(I) and 18-2-201, C.R.S. (F4),
and against the peace and dignity of the People of the State of Colorado.
COUNT 9
Money Laundering Transfer Monetary Instrument with Intent to

Promote Crime, 18-5-309(1)(B)(I), C.R.S. (F3) 12213
unlawfully and feloniously transported, transmitted, or transferred a monetary instrument or moneys,
with the intent to promote the commission of a criminal offense, in violation of 18-5-309(1)(B)(I),
C.R.S. (F3) and against the peace and dignity of the People of the State of Colorado.
COUNT 10
Conspiracy to Commit Money Laundering Transfer Monetary Instrument with Intent to

Promote Crime, 18-5-309(1)(B)(I) and 18-2-201, C.R.S. (F4) CON
10
with the intent to promote or facilitate the commission of the crime of Money Laundering Transfer
Monetary Instrument with Intent to Promote Crime, unlawfully and feloniously agreed with one
another that one or more of them would engage in conduct which constituted that crime or an attempt
to commit that crime, or agreed to aid the other person or persons in the planning or commission or
attempted commission of that crime, and an overt act in pursuance of the conspiracy was committed
by one or more of the conspirators; in violation of 18-5-309(1)(B)(I) and 18-2-201, C.R.S. (F4),
COUNT 11
Keeping Property for Unlawful Distribution of Controlled Substances,

18-18-411(1), C.R.S. (DM1) 33514
knowingly or intentionally kept, maintained, controlled, rented, leased, or made available for use a
store, shop, warehouse, dwelling, building, vehicle, vessel, aircraft, room, enclosure, or other
structure or place, which the defendant knew was resorted to for the purpose of keeping for
distribution, transporting for distribution, or distribution of a controlled substance; in violation of
18-18-411(1), C.R.S. (DM1), and against the peace and dignity of the People of the State of
Colorado.
COUNT 12
Evasion of Taxes Administered by the Colorado Department of Revenue,

39-21-118(1), C.R.S. (F5) 40021
did unlawfully, feloniously and willfully attempt to evade and defeat a tax administered by the
Colorado Department of Revenue, or a payment thereof namely, state wage withholding tax in
violation of 39-21-118(1), C.R.S. (F-5), and against the peace and dignity of the People of the State
of Colorado.
11
COUNT 13
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
with the intent to promote or facilitate the commission of the crime of Evasion of Taxes Administered
by the Colorado Department of Revenue, unlawfully and feloniously agreed with one another that one
or more of them would engage in conduct which constituted that crime or an attempt to commit that
crime, or agreed to aid the other person or persons in the planning or commission or attempted
commission of that crime, and an overt act in pursuance of the conspiracy was committed by one or
more of the conspirators; in violation of 39-21-118(1) and 18-2-201, C.R.S. (F6), and against the
peace and dignity of the People of the State of Colorado.
COUNT 14

39-21-118(1), C.R.S. (F5) 40021
did unlawfully, feloniously and willfully attempt to evade and defeat a tax administered by the
Colorado Department of Revenue, or a payment thereof namely, state sales tax in violation of 39-21-
118(1), C.R.S. (F-5), and against the peace and dignity of the People of the State of Colorado.
COUNT 15
Conspiracy to Commit Evasion of Taxes Administered by the Colorado Department of Revenue,

39-21-118(1) and 18-2-201, C.R.S. (F6) CON
12
with the intent to promote or facilitate the commission of the crime of Evasion of Taxes Administered
by the Colorado Department of Revenue, unlawfully and feloniously agreed with one another that one
or more of them would engage in conduct which constituted that crime or an attempt to commit that
crime, or agreed to aid the other person or persons in the planning or commission or attempted
commission of that crime, and an overt act in pursuance of the conspiracy was committed by one or
more of the conspirators; in violation of 39-21-118(1) and 18-2-201, C.R.S. (F6), and against the
peace and dignity of the People of the State of Colorado.
COUNT 16
Failure to File Return or Pay Tax, 39-21-118(3), C.R.S. (M) 40023
On or about and between August 21, 2016 and May 21, 2017, in and triable in the State of Colorado,
HOPPY CROPZ, HOPPZ CROPZ, HOPZ CROP) and others known and unknown to the
Grand Jury, unlawfully and willfully failed to pay a tax or estimated tax, make a return, keep tax
records, or supply tax information as required; in violation of 39-21-118(3), C.R.S. (M), and against
the peace and dignity of the People of the State of Colorado.
COUNT 17
Filing a False Tax Return, 39-21-118(4), C.R.S. (F5) 40024
On or about April 16, 2017 in and triable in the State of Colorado, DARA WHEATLEY and
HOPPZ CROPZ, LLC, unlawfully, feloniously, and willfully made and subscribed returns,
statements, or other documents, which contained or were verified by a written declaration that they
were made under the penalties of perjury, and which the defendant did not believe to be true and
correct as to every material matter; in violation of 39-21-118(4), C.R.S. (F5), and against the peace
and dignity of the People of the State of Colorado.
COUNT 18
Forgery, 18-5-102(1)(C), C.R.S. (F5)
On or about and between July 1, 2016 and May 25, 2017, in the State of Colorado, JOSEPH
HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO CRIVICI,
HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBERS ONLY, HOPPY
CROPZ, HOPPZ CROPZ, HOPZ CROP), VICTORIA FERNANDEZ (A.K.A. TORI),
MARCEE SMITH (A.K.A. MARLEY), ALEJANDRA GONZALEZ (A.K.A. ALE),
RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS, with
the intent to defraud Hoppz Cropz customers including but not limited to Michael Adam Hughes,
Chace Passanante, Joey Harris and those individual customers identified below in Attachment A,
unlawfully, feloniously, and falsely made, completed, altered, or uttered a written instrument which
was or which purported to be, or which was calculated to become or to represent if completed, a deed,
will, codicil, contract, assignment, commercial instrument, promissory note, or other instrument
which document did or may have evidenced, created, transferred, terminated, or otherwise affected a
legal right, interest, obligation, or status, namely: a contract pertaining to Hoppz Cropz customers
13
Amendment 64 rights; in violation of 18-5-102(1)(c), C.R.S. (F-5), and against the peace and dignity
of the People of the State of Colorado.
COUNT 19
Attempt To Influence A Public Servant, 18-8-306, C.R.S. (F4) 24051
On or about November 17, 2016, in and triable in the State of Colorado, RAYLENE RUBIO
unlawfully and feloniously attempted to influence Colorado Springs Police Department Detective
Nick Bayne, who is a public servant, by means of deceit, with the intent thereby to alter or affect the
public servants decision, vote, opinion, or action concerning a matter which was to be considered or
performed by the public servant or the agency or body of which the public servant was a member; in
violation of 18-8-306, C.R.S. (F-4), and against the peace and dignity of the People of the State of
Colorado.
COUNT 20
On or about May 2, 2017, in and triable in the State of Colorado, JOSEPH SERGIO CRIVICI and
HOPPZ CROPZ, LLC unlawfully and feloniously attempted to influence Colorado Springs Police
Department Sergeant Roger Vargason and or Colorado Springs Police Department Detective Nick
Bayne, who are public servants, by means of deceit, with the intent thereby to alter or affect the
public servants decisions, votes, opinions, or actions concerning a matter or matters which were to be
considered or performed by the public servants or the agency or body of which the public servants
were members; in violation of 18-8-306, C.R.S. (F-4), and against the peace and dignity of the
People of the State of Colorado.
COUNT 21
On or about May 2, 2017, in and triable in the State of Colorado, NICOLE SANDOVAL and
VICTORIA FERNANDEZ unlawfully and feloniously attempted to influence Colorado Springs
Police Department Sergeant Roger Vargason, who is a public servant, by means of deceit, with the
intent thereby to alter or affect the public servants decision, vote, opinion, or action concerning a
matter which was to be considered or performed by the public servant or the agency or body of which
the public servant was a member; in violation of 18-8-306, C.R.S. (F-4), and against the peace and
dignity of the People of the State of Colorado.
COUNT 22
On or about May 2, 2017, in and triable in the State of Colorado, ASHLEY HEFNER unlawfully
and feloniously attempted to influence Colorado Springs Police Department Detective Nick Bayne,
who is a public servant, by means of deceit, with the intent thereby to alter or affect the public
servants decision, vote, opinion, or action concerning a matter which was to be considered or
performed by the public servant or the agency or body of which the public servant was a member; in
violation of 18-8-306, C.R.S. (F-4), and against the peace and dignity of the People of the State of
Colorado.
14
COUNT 23
Special Offender Conspiracy Pattern of Sale, 18-18-407(1)(b), C.R.S. (DF-1) 33A43
DARA WHEATLEY committed the felony offenses charged in counts 4, 5 and 6;
ADAM DONALDSON committed the felony offenses charged in counts 4, 5 and 6;
which was, or was in furtherance of, a conspiracy with one or more persons to engage in a pattern of
manufacturing, sale, or distributing a controlled substance, and the defendant did, or agreed that
defendant would initiate, organize, plan, finance, direct, manage, or supervise part or all of the
conspiracy or manufacture, sale, or distributing, in violation of 18-18-407(1)(b), C.R.S. (DF-1), and
against the peace and dignity of the People of the State of Colorado.
COUNT 24
Special Offender Organizer in Series of Violations with Others, 18-18-407(1)(F), C.R.S. (DF1)
33A48
JOSEPH HOPPER committed the felony offenses charged in counts counts 4, 5 and 6;
DARA WHEATLEY committed the felony offenses charged in counts 4, 5 and 6;
ADAM DONALDSON committed the felony offenses charged in counts counts 4, 5 and 6;
JOSEPH SERGIO CRIVICI committed the felony offenses charged in counts counts 4, 5 and 6;
engaged in a continuing criminal enterprise by violating 18-17-104(3), 18-17-104(4), 18-17-
104(2), 18-17-105, 18-18-406(2)(B)(I),(III)(A), namely: Violation of the Colorado Organized
Crime Control Act Conspiracy/Endeavoring, Violation of the Colorado Organized Crime Control
Act Pattern of Racketeering- Participation in Enterprise, Violation of the Colorado Organized
Crime Control Act Pattern of Racketeering Acquire Interest in Enterprise, Distribution Of
Marijuana (50 LBS) or Marijuana Concentrate (25 LBS), Possession with Intent to Manufacture or
Distribute Marijuana (50 LBS) or Marijuana Concentrate (25 LBS), Conspiracy to Distribute, or
Possess with Intent to Manufacture or Distribute, Marijuana (50 LBS) or Marijuana Concentrate
(25LBS), and this violation was a part of a continuing series of two or more violations of part 4 of
article 18 of title 18, C.R.S., on separate occasions, namely: Distribution Of Marijuana (50 LBS) or
Marijuana Concentrate (25 LBS) in violation of 18-18-406(2)(B)(I),(III)(A), C.R.S. and any lesser
included offenses on two or more separate occasions on or about and between July 1, 2016 and May
25, 2017, Possession with Intent to Manufacture or Distribute Marijuana (50 LBS) or Marijuana
Concentrate (25 LBS), in violation of 18-18-406(2)(B)(I),(III)(A), C.R.S and any lesser included
offenses on two or more separate occasions on or about and between July 1, 2016 and May 25, 2017,
and Conspiracy to Distribute, or Possess with Intent to Manufacture or Distribute, Marijuana (50
LBS) or Marijuana Concentrate (25LBS) in violation of 18-18-406(2)(B)(I),(III)(A), C.R.S. and any
lesser included offenses on two or more separate occasions on or about and between July 1, 2016 and
May 25, 2017, and the defendants undertook the continuing series of violations in concert with at
least five other persons with respect to whom the defendant occupied a position of organizer, or
supervisor, or other position of management, and the defendant obtained substantial income or
resources from the continuing series of violations; in violation of section 18-18-407(1)(f), C.R.S.
15
COUNT 25
Special Offender Firearm, C.R.S. 18-18-407(1)(d)(II), C.R.S. (DF1) 33A45
On or about and between November 17, 2016 and May 25, 2017 in and triable in the State of
Colorado,
DERRICK BERNARD committed the felony offenses charged in counts 4, 5 and 6;
NATHAN BERNHEISEL committed the felony offenses charged in counts 4, 5, and 6;
and the defendant or a confederate of the defendant possessed a firearm to which: the defendant or
confederate had access in a manner that posed a risk to others; or in a vehicle the defendant was
occupying, during the commission of the offense; in violation of 18-18-407(1)(d)(II), C.R.S. (DF1),
COUNT 26
Filing a False Tax Return, 39-21-118(4), C.R.S. (F5) 40024
On or about and between April 1, 2017 and May 25, 2017, in and triable in the State of Colorado,
DARA WHEATLEY unlawfully, feloniously, and willfully made and subscribed returns, statements,
or other documents, which contained or were verified by a written declaration that they were made
under the penalties of perjury, and which the defendant did not believe to be true and correct as to
every material matter; in violation of 39-21-118(4), C.R.S. (F5), and against the peace and dignity of
the People of the State of Colorado.
COUNT 27

39-21-118(1), C.R.S. (F5) 40021
On or about and between April 1, 2017 and May 25, 2017, in and triable in the State of Colorado,
DARA WHEATLEY, did unlawfully, feloniously and willfully attempt to evade and defeat a tax
administered by the Colorado Department of Revenue, or a payment thereof namely, Colorado
Income Tax in violation of 39-21-118(1), C.R.S. (F-5), and against the peace and dignity of the
People of the State of Colorado.
The offenses alleged in Counts 1 through 27 and the below Predicate Acts (connected to Counts 1, 2
& 3) incorporate any and all above asserted facts and dates. The below essential facts of the crimes
were committed in the following manner and occurred either entirely or partly in the State of
Colorado:
Starting in January of 2014, the State of Colorado enacted a marijuana excise tax. Retail marijuana
became subject to a 15% excise tax based on the average market price of retail marijuana. The tax is
calculated on the basis of the category of the retail marijuana product3 being sold or transferred.
Neither JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO
CRIVICI, HOPPZ CROPZ, LLC, DERRICK BERNARD, NATHAN BERNHEISEL, VICTORIA
FERNANDEZ, MARCEE SMITH, ALEJANDRA GONZALEZ, RAYLENE RUBIO, NICOLE
SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS, nor any of their co-conspirators paid this
excise tax or filed any returns associated with the excise tax. The members of the enterprise were able
to increase profits by purchasing medical marijuana -which is taxed at a substantially lower rate
3 i.e., Flower, Trim, or Immature Plant.

16
compared to recreational- from licensed dispensaries by illegally using the patient red cards of
fellow co-conspirators. This effectively created a lower priced, black market marijuana sold by
Hoppz Cropz and its employees. Furthermore, none of the members of the enterprise paid or
collected and remitted the proper amount of sales tax due from the numerous retail sales made in the
Hoppz Cropz stores.
On July 29, 2016, Colorado Springs law enforcement agents assigned to the Metro Vice, Narcotics,
and Intelligence Division (MVNI) received anonymous information from a Crime Stopper tip
regarding the address 2549 Delta Drive (Hoppz Delta). The complaint stated Hoppz Delta
employees were selling marijuana to people without medical marijuana cards. MVNI detectives soon
learned employees at a second related store located at 2402 East Boulder Street (Hoppz Boulder)
conducted similar illegal distributions of marijuana.
A records check of Hoppz Cropz through the Colorado Secretary of State revealed the business
entitys formation in July of 2016 and listed its registered agent as Dara Wheatley. Later, the
Secretary of States website listed Adam Donaldson as the registered agent beginning October, 2016,
ultimately followed by another change which listed Joseph Sergio Crivici as the registered agent as of
March, 2017. All parties provided their registered agent address as 750 East Cimarron Street.
Detectives soon became aware of Hoppz Cropz presence through social media and a television news
report featuring Dara Wheatleys fiance, Mr. Joseph Hopper. Eventually, the detectives learned that
Mr. Hopper self-identified as the stores owner in both social media and on a television interview
with KRDO News. After taking initial investigative steps and discovering social links between
numerous Hoppz Cropz owners and employees, MVNI detectives commenced an investigation
involving undercover operations.
Undercover Marijuana Purchases at Hoppz Delta:
On Thursday, August 18, 2016, Detective Michael Adam Hughes was assigned to act in an
undercover capacity to purchase marijuana from Hoppz Delta to help verify the validity of the Crime
Stopper tip. Detective Hughes entered the store and was asked for identification by an employee who
provided a typed form. Detective Hughes proceeded to fill out a typed form4 purporting to explain
Amendment 64 and the stores sales model of gifting marijuana during a purchase. Hughes was told
he could purchase a memo (which appeared to be a rolling paper) for $5, a sticker ($10), or various
other items, and he would be gifted either a joint (a marijuana cigarette) or a gram or more of
marijuana (depending on how much he spent). He was also told he could smoke in the store if he
purchased a $3 gift. Detective Hughes opted to spend $15 and was given a lighter (which retails for as
low as 14 cents) and 1.35 grams of Dark Horse, a green, leafy substance which later tested positive
for Tetrahydrocannabinol (THC), the chemical ingredient in marijuana responsible for the high.
On Wednesday, November 9, 2016, Detective Joey Harris was assigned to act in an undercover
capacity to enter Hoppz Delta and attempt to purchase marijuana. Detective Harris entered the store
4 This form and the others like it described throughout this document- was a contract uttered for the purpose of deceiving
the customers of Hoppz Cropz by providing false information as to the status of the marijuana the Hoppz Cropz customer
purchased in conjunction with various tangible items such as lighters, stickers, rolling papers and the like. All of the
members of the enterprise including JOSEPH HOPPER, DARA WHEATLEY, ADAM DONALDSON, JOSEPH SERGIO
CRIVICI, HOPPZ CROPZ, LLC (D.B.A. HOPPZ CROPZ, A.K.A MEMBERS ONLY, HOPPY CROPZ, HOPPZ
CROPZ, HOPZ CROP), VICTORIA FERNANDEZ (A.K.A. TORI), MARCEE SMITH, ALEJANDRA GONZALEZ
(A.K.A. ALE), RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER, MELISSA COLMUS, conspired and
or stood complicit in completing or uttering these forgeries as it advanced the enterprise as a whole and each member
eventually profited personally. A larger list of customers defrauded by the employees and owner managers is listed below at
ATTACHMENT A
17
and was greeted by Hoppz Cropz owner/employee Dara Wheatley who asked him if he had his
identification card with him. Ms. Wheatley instructed Detective Harris to complete one of forms
stating he understood Amendment 64, is over 21 years of age, and is becoming a member of Hoppz
Cropz (at both locations). Once Wheatley took possession of the form she told Detective Harris he
could be gifted marijuana in exchange for purchasing a small item, such as a rolling paper or
lighter. After being shown some marijuana products, Detective Harris purchased a (14 cent) lighter
for $15 and was gifted 1.03g of a green, leafy substance labelled Kandy Kush. This so called gift
field tested positive for THC.
On Friday, November 11, 2016, Detective Chace Passanante was assigned to act in an undercover
capacity to enter Hoppz Delta in attempts to purchase marijuana. At 1508 hours on that date,
Detective Passanante entered the store and was greeted by Hoppz Cropz employee Melissa Colmus.
The employee asked the detective to complete the form stating he understood Amendment 64, was
over 21, and he was joining Hoppz Cropz as a member. Colmus then told Detective Passanante they
do not sell marijuana, they gift it with a purchase of another item. She showed Detective Passanante
three shelves containing different marijuana products (buds, extract, etc.). Melissa Colmus told him
he could buy a paper for $10 and she would gift him a gram of marijuana, a lighter for $15 with a
gram, or a small pipe for $20 with a gram of marijuana. Colmus said, That shows you the level of
shelves we have, but we do gift up to 14 grams. Detective Passanante bought a (14 cent) lighter for
$15 and a baggie weighing 2.94 grams (including the baggie), containing a green, leafy substance
which field tested positive for THC.
Undercover Marijuana Purchases at Hoppz Boulder:
On Wednesday, November 9, 2016, Detective J. Harris entered Hoppz Boulder and attempted to
purchase marijuana. At approximately 1411 hours on that date, Hoppz Cropz employee Raylene
Rubio greeted Detective Harris as he entered the store. Rubio asked him if he had been to the store
before. Raylene Rubio next asked Detective Harris to complete one of the forms stating he
understood Amendment 64, he is over 21 years of age, and he is becoming a member of Hoppz
Cropz. When he had completed the form, the employee, Raylene Rubio, went on to say, We are
more like a gift shop rather than a dispensary, so we gift weed we do not sell it. Rubio showed
Detective Harris some marijuana and told he could purchase a lighter or a small, glass pipe and be
gifted some marijuana. She also told him the detective he could buy a $5 memo (which appeared to
be a small baggie of marijuana) or he could buy a sticker. Raylene Rubio then told him she was out of
stickers so she could give him a rolling paper, or, she stated, You are purchasing the bag and I am
gifting you a memo. Detective Harris purchased a small glass pipe for $20 and was gifted 0.97
grams of Gorilla Glue, a green, leafy substance which field tested positive for THC.
On Friday, November 11, 2016, Detective C. Passanante visited Hoppz Boulder to try to purchase
marijuana. At 1540 hours, Detective Passanante entered the store and Hoppz Cropz employee
Marcee Smith asked the undercover detective to complete the form stating he understood Amendment
64, was over 21, and that he was joining Hoppz Cropz as a member. Marcee Smith told Detective
Passanante the marijuana would be gifted with another purchase. She showed Detective Passanante
three shelves of marijuana products with different THC levels. Detective Passanante selected the
Jelly Bean variety of marijuana and Marcee Smith then asked if he wanted to do a $15 small pipe.
Detective Passanante purchased a pipe and received a baggie weighing 3.15 grams (including the
baggie), holding a green, leafy substance which tested positive for THC.
18
First Search Warrant
On November 16, 2016, Detective Kerry Linfoot completed a search warrant for both Hoppz Cropz
locations. The search warrants were reviewed and signed by Judge Walter on November 16, 2016, and
executed on November 17, 2016. During the searches of the Hoppz Cropz stores, detectives seized
approximately 2198 grams of marijuana and marijuana products, along with a handgun and $3290 in
U.S. currency. Ledgers at the store put the daily sales for the Boulder store at $700-$1500 and the daily
sales at the Delta store from $2000-$3500.
During the execution of these warrants, receipts and financial documentation obtained by law
enforcement officials indicated several sources for the marijuana sold in the Hoppz Cropz stores were
medical marijuana dispensaries. Receipts showed quantities of marijuana and marijuana concentrate
being purchased from, among other stores, Altitude Organic Medicine. Some of the receipts recovered
specifically indicated Adam Donaldson was purchasing medical marijuana from Altitude Organic
Medicine for later illegal resale at the Hoppz Cropz stores.
Close in time to the execution of the November 16, 2016 search warrants, Raylene Rubio attempted
to influence Colorado Springs Police Department Detective Nick Bayne, by means of deceit and with
the intent thereby to alter or affect the detectives decision, vote, opinion, or action concerning his
investigation into the Hoppz Cropz drug distribution conspiracy. When asked by the detective who
had identified himself as law enforcement - Ms. Rubio stated that she was a volunteer working at the
Hoppz Cropz store, when in fact she was a paid employee working under the table to help the
business avoid paying wage withholding taxes to the Colorado Department of Revenue.
Further Investigation
On December 8, 2016, undercover MVNI detectives conducted buys at both Hoppz Cropz locations.
Undercover MVNI detectives successfully purchased marijuana from both stores under what the
employees, including both Marcee Smith and Raylene Rubio, referred to as a reimbursement process.
The detectives were advised they were joining the Hoppz Cropz club and they were permitting Hoppz
Cropz to grow their six plants which are permitted under Amendment 64. They were told they were
paying to reimburse Hoppz Cropz for the time, labor, and resources used to grow their plants. The
marijuana products purchased at both stores later field tested positive for the presence of THC.
On the morning of Friday, April 7, 2017, detectives from MVNI noticed Joseph Sergio Crivicis
vehicle parked outside the home of Hopper. Crivici and Donaldson left the residence and entered a
silver Lincoln carrying backpacks. The men drove to Hoppz Boulder where they remained for just
over one hour. Both Crivici and Donaldson then left the Boulder store and drove to Hoppz Delta.
When they arrived, both men went into the store and remained while several customers came and
went.
Later that same morning, Crivici and Donaldson left the Delta store and travelled to 2354 E. Platte
Avenue, a medical marijuana dispensary called Altitude Organic Medicine. The reader should note
that receipts from this store were found during the search warrants previously executed on the Hoppz
Cropz stores. Altitude Organic Medicine appeared to be a source of supply where employees and or
supervisor level employees, such as Crivici and Donaldson, purchased marijuana for resale at the
Hoppz Cropz stores.
19
Tax Evasion
As MVNI detectives continued their investigation it became increasingly clear from the undercover
buys, information retrieved during search warrants, and data from electronics retrieved during the
search, that Hoppz Cropz, LLC, and its owner managers Joseph Hopper, Adam Donaldson, Dara
Wheatley or Joseph Sergio Crivici paid little to no state or local taxes on retail sales.5 Accordingly,
MVNI detectives reached out to and began working with special agents6 from the Colorado
Department of Revenue (CDOR).
CDOR records indicated Dara Wheatley applied for a sales tax license in July of 2016 using the
Colorado Business Express portal and received a sales tax license for Hoppz Cropz. The application
stated Hoppz Cropz would be conducting retail sales and specifically listed products being sold as
suckers, papers, memos, playing cards, bongs, pipes rigs, sports memorabilia and bottled water. At
the time of the application, Wheatley estimated monthly sales at $15/month or less, which would have
made the business an annual filer. The business should have filed a sales tax return on January 20,
2017 for sales in 2016. If no sales had occurred in 2016 the business should have filed a zero dollar
return on January 20, 2017. However, Hoppz Cropz never filed a return showing either sales or
no sales as required.
Even though Hoppz Cropz and its coconspirator owners, managers and employees conducted
significant retail sales, Dara Wheatley closed the sales tax account on February 6, 2017. Due to the
business having failed to file any returns, including a zero amount return, the CDOR sent a non-filer
notice on March 8, 2017. On March 17, 2017 a Notice of Deficiency was sent to the business
based on the CDOR generating an estimated return. Despite the warning inherent in these notices and
Wheatleys earlier registration for a sales tax license, no payments or amended returns have been filed
by either managers, owners or employees of Hoppz Cropz. As the MVNI detectives coordinated
their investigation with CDOR special agents the questioning of Hoppz Cropz employees shifted
subtly and they began inquiring into tax liabilities during undercover operations.
On Friday, April 14, 2017, undercover Detective Michael Hughes again made purchases of marijuana
at both Hoppz Cropz stores. At Hoppz Boulder, Detective Hughes again contacted Ms. Marcee
Smith, and explained that he had not been to the store before. Ms. Smith asked for Detective Hughes
ID and photocopied it. She next brought out a single sheet of paper with typed information on it
stating that he the customer was over the age of 21 and understood Amendment 64. She then said
Detective Hughes was a now a member of Hoppz Cropz and he was asked to sign the form. Hoppz
Cropz employee Marcee Smith explained a reimbursement process through which the customer
reimburses the store for the electricity, nutrients, and everything that actually goes into the growth of
the plants. When the detective handed the Hoppz employee two $20 bills to pay for a $40 purchase,
he asked her, No taxes on that? The employee laughed and responded, No taxes. The detective
purchased marijuana with an approximate weight of 1.66 grams and suspected marijuana concentrate
with an approximate weight of 1.4 grams.
5 A person or business having a permanent location where retail sales are conducted on a regular basis must obtain a
standard sales tax license. The filing frequency is determined by the amount of sales tax collected monthly. The following
are the required filing frequencies based on monthly sales for the State of Colorado as published on the Colorado
Department of Revenue website: $15 or less per month: sales tax returns may be filed annually; Under $300 per month:
sales tax returns may be filed quarterly; $300 or more per month: sales tax returns must be filed monthly; Businesses that
pay more than $75,000 per year in state sales tax must pay by Electronic Funds Transfer. Sales tax returns are to be filed
based on the reporting requirement. Annual sales tax filers must file on January 20th of the year preceding the reporting
year. Quarterly sales tax filers must file on the 20th day of the month following the reporting quarter. Monthly sales tax
filers must file on the 20th of the month following the reporting month. If the due date falls on a weekend or holiday then
the return is due the next business day. If there are no taxable sales during a filing period, a zero return must be filed.
Failure to file will result in a non-filer notice being sent, which will be filed by an estimated bill.
6 CDOR special agents possess access to a database of sales tax returns submitted by individuals and organizations to the
CDOR itself.
20
At the Delta store on this date, the undercover detective again made a purchase of marijuana. When
he gave Hoppz Cropz employee Raylene Rubio the cash to pay for this purchase, the detective
remarked that he did not like paying taxes for marijuana. The employee replied, No taxes. The
detective purchased marijuana with a total approximate weight of 3.2 grams, called Gilz Nilz.
Second Search Warrant
On May 2, 2017, Detective Kerry Linfoot once again completed a search warrant for both Hoppz
Cropz locations and the residence of Donaldson and Crivici. The search warrants were reviewed and
signed by Judge Wilson, on May 2, 2017, and executed on May 2, 2017. During the searches of the
Hoppz Cropz stores and the residence, detectives seized approximately 10,652.43 grams of
marijuana and marijuana products, along with a shotgun, 26 marijuana-infused vape cartridges, 0.6
grams of methamphetamines, and $8,132.00 in U.S. currency. Daily totals from register receipts
found at the three locations put the daily proceeds for the Boulder and Delta stores combined at
$82,549 for 2017. Additionally, a cumulative total for sales taken from a single daily receipt dated
April 30, 2017, indicated the total amount of sales at $417,265. On some daily receipts for 2017 there
is a tax category on the receipt, which reflects $4,865 in tax was collected at the retail stores but not
remitted.
The receipt books seized during the second search warrant had purchase receipts written for shake
and edibles in the amount of $2,675 and approximately $1,051 dollars in raw cones, silicone dabbers,
and similar items. Further, the receipt books showed $6,136 dollars had been paid to employees in
2017. The $6,136 does not include receipts written to employees when a date was not noted.
During the execution of these warrants, receipts and financial documentation obtained by law
enforcement officials indicated several sources for the marijuana sold in the Hoppz Cropz stores
were medical marijuana dispensaries. Receipts showed quantities of marijuana and marijuana
concentrate being purchased from, among other stores, Altitude Organic Medicine. Some of the
receipts recovered continued to indicate Adam Donaldson purchased medical marijuana from Altitude
Organic Medicine. Close in time to the execution of the May 2, 2017 search warrants, detectives
interviewed a co-owner and several employees of the Hoppz Cropz stores.
On or about May 2, 2017, Joseph Sergio Crivici, in his capacity as owner and high managerial agent
of Hoppz Cropz, attempted to influence Colorado Springs Police Department Detective Nick Bayne,
by means of deceit and with the intent thereby to alter or affect the detectives decision, vote, opinion,
or action concerning his investigation into the Hoppz Cropz drug distribution conspiracy. When
questioned by the detective who had identified himself as law enforcement - Mr. Crivici stated that
he was a new owner at the Hoppz Cropz store who had only been working at and only owned the
store for a few days, when in fact he had been working at the store and a part owner for several
months. Indeed, Mr. Crvici told another law enforcement officer that he had only been an owner of
the store for six weeks.
On or about May 2, 2017, Nicole Sandoval and Victoria Fernandez both attempted to influence
Colorado Springs Police Department Sergeant Roger Vargason, by means of deceit and with the
intent thereby to alter or affect the detectives decision, vote, opinion, or action concerning his
investigation into the Hoppz Cropz drug distribution conspiracy. When questioned by Vargason
who had identified himself as law enforcement - Both Ms. Sandoval and Ms. Fernandez explained
that they were volunteers working at the Hoppz Cropz store, when in fact they were each paid
employees working under the table to help the business avoid paying wage withholding taxes to the
Colorado Department of Revenue.
21
On or about May 2, 2017, Ashley Hefner attempted to influence Colorado Springs Police Department
Detective Nick Bayne, by means of deceit and with the intent thereby to alter or affect the detectives
decision, vote, opinion, or action concerning his investigation into the Hoppz Cropz drug distribution
conspiracy. When questioned by the Detective Bayne who had identified himself as law
enforcement - Ms. Hefner stated that she was a volunteer working at the Hoppz Cropz store, when
in fact she was a paid employee working under the table to help the business avoid paying wage
withholding taxes to the Colorado Department of Revenue.
After executing the search warrants, the detectives viewed security footage from the stores showing
many instances of unlawful distribution of marijuana by the employees of and an owner of Hoppz
Cropz. Just a handful of these illegal distributions include but are not limited to the sales by the
below listed individuals at the times, dates and locations listed in the chart immediately below:
Name Date of Sale 1 Date of Sale 2 Date of Sale 3 Date of Sale 4 Date of Sale 5
Alejandra 4/30/17 - 1630 hrs. 4/30/17 - 1648 hrs. 4/30/17 - 1650 hrs. 4/30/17 - 1653 hrs. 5/17/17 1649 hrs.
Gonzalez (Delta - Sec. Cam) (Delta - Sec. Cam) (Delta - Sec. Cam) (Delta - Sec. Cam) (Delta - UC)
5/2/17 - 1147 hrs.
Ashley 5/2/17 - 1138 hrs. (Boulder - Sec. 5/2/17 - 1155 hrs. 5/2/17 - 1203 hrs. 5/2/17 - 1208 hrs.
Hefner (Boulder - Sec. Cam) Cam) (Boulder - Sec. Cam) (Boulder - Sec. Cam) (Boulder - Sec. Cam)
Victoria 4/29/17 - 1120 hrs. 4/29/17 - 1141 hrs. 4/29/17 - 1143 hrs. 4/29/17 - 1154 hrs. 4/29/17 - 1208 hrs.
Fernandez (Delta - Sec. Cam) (Delta - Sec. Cam) (Delta - Sec. Cam) (Delta - Sec. Cam) (Delta - Sec. Cam)
Nicole 4/30/17 - 1650 hrs. 4/30/17 - 1652 hrs. 4/30/17 - 1656 hrs. 4/30/17 - 1700 hrs. 4/30/17 - 1718 hrs.
Sandoval (Delta - Sec. Cam) (Delta - Sec. Cam) (Delta - Sec. Cam) (Delta - Sec. Cam) (Delta - Sec. Cam)
Melissa 11/11/16 1510 hrs. 11/16/16 - 2115 hrs. 11/16/16 - 2118 hrs. 11/16/16 - 2121 hrs. 11/16/16 - 2122 hrs.
Colmus (Delta - UC) (Delta - Sec. Cam) (Delta - Sec. Cam) (Delta - Sec. Cam) (Delta - Sec. Cam)
11/16/16 - 1530 hrs.
Raylene 11/9/16 - 1446 hrs. (Boulder - Sec. 11/16/16 - 1533 hrs. 11/9/16 - 1537 hrs. 12/8/16 1632 hrs.
Rubio (Boulder - UC) Cam) (Boulder - Sec. Cam) (Boulder - UC) (Delta - UC)
11/16/16 1910 hrs.
Marcee 11/11/16 1540 hrs. (Boulder - Sec. 11/16/16 1920 hrs. 12/8/16 1715 hrs. 5/17/17 1629 hrs.
Smith (Boulder - UC) Cam) (Boulder - Sec. Cam) (Boulder - UC) (Boulder - UC)
Dara 11/15/16 1037 hrs. 11/15/16 1040 hrs. 11/15/16 1044 hrs. 11/15/16 1046 hrs. 11/15/16 1055 hrs.
Wheatley (Delta - Sec. Cam) (Delta - Sec. Cam) (Delta - Sec. Cam) (Delta - Sec. Cam) (Delta - Sec. Cam)
Money Laundering Activity by Members of the Enterprise
Financial investigators examined banking transactions of certain members of the Hoppz Cropz
enterprise. The investigators discovered that from July of 2016 until the present day Dara Wheatley
and Adam Donaldson engaged in various money laundering transactions with the apparent proceeds
derived from the illegal distribution of marijuana at the Hoppz Cropz stores. The other members of
the enterprise including JOSEPH HOPPER, JOSEPH SERGIO CRIVICI, HOPPZ CROPZ, LLC,
DERRICK BERNARD, NATHAN BERNHEISEL, VICTORIA FERNANDEZ, MARCEE SMITH,
ALEJANDRA GONZALEZ, RAYLENE RUBIO, NICOLE SANDOVAL, ASHLEY HEFNER,
MELISSA COLMUS, conspired and or stood complicit in this money laundering behavior as it
advanced the enterprise as a whole and each member profited personally from their co-conspirators
money laundering behavior.
22
An example of this behavior includes, but is not limited to, multiple financial transactions involving
United States currency. These are known to be transfers of money by members of the enterprise, and
Dara Wheatley and Adam Donaldson in particular, made with the intent to promote the commission
of the criminal offense including, but not limited to, the illegal distribution of marijuana and
marijuana concentrate. Specifically, Ms. Wheatley and Mr. Donaldson transferred or transmitted
moneys and proceeds of illegal distributions to pay bills and to keep utility services active for the
Hoppz Cropz business locations. Moreover, Ms. Wheatley and Mr. Donaldson transmitted or
transferred moneys, including some proceeds of illegal distributions, to purchase supplies for future
sales and pay advertising costs for the commission of future illegal activity, including the illegal
distribution of marijuana and marijuana concentrate.
Adam Donaldson Pueblo Bank and Trust, Account # XXXXX9943
Between July of 2016 and the present, as demonstrated below with specific examples, Mr. Donaldson
transferred proceeds of the illegal marijuana distribution or by:
a) Making payments to ADT, Colorado Springs Utilities and Springs Waste Systems. Bills
addressed to the store show utility payments being made for security monitoring, electrical
and waste removal. These services help the business to run by keeping the power on,
removing waste from the stores, and keeping the stores secure;
b) Making payments/purchases to CA Wholesale, Oriental Imports and East Grow Warehouse
for supplies for the store, such as marijuana paraphernalia and t-shirts. These purchases aid in
keeping the business operating and assists in advertising to obtain future revenue;
c) Making a payment to the landlord of the Hoppz Cropz location on Boulder Street, thereby
keeping the doors open to enable the DTO to do business;
d) Making purchases to Adobe Creative Cloud and Vista Print for the purpose of website and
business card advertising. This assists in advertising for the business to increase visibility and
customer base for continued and future sales;
e) Making purchases from Modern Medicine, a marijuana dispensary in Colorado Springs,
Colorado, for the gifted marijuana given as the free gift with purchase.
Cash In / Cash Out
Analysis of Mr. Donaldsons account also revealed that, between July 18, 2016, and February 18,
2017, Mr. Donaldson made forty six cash deposits totaling $62,130.00. These were all cash and not
deposited by a known employer in the form of payroll, nor could these be tied to a legitimate source.
There are several cash withdrawals from Mr. Donaldsons account between July 18, 2016, and
September 28, 2016, totaling $21,709.54. Since there appears to be no other legitimate source of
income for Mr. Donaldson, in looking at both his bank account and Federal Wage/Income Transcripts
(i.e.W-2 and 1099 information) for income, it would appear that his money is coming from the
Hoppz Cropz stores, at which he occupies a high level managerial role and/or an ownership tie to the
company.
In a period of time between July, 2016, and May, 2017, Donaldson by way of his red card- was
identified as having purchased $20,210.70 of medical marijuana at Altitude Organic Medicine,
LivWell, and Pain Management Solutions. This marijuana was resold through Hoppz Cropz.
23
Finally, statements from the landlords for 750 E. Cimarron, the address at which Mr. Donaldson
resides, indicate that rent payments were made in cash. This may account for some of the cash
withdrawals made by Mr. Donaldson.
Eleven cash withdrawals between 7/18/16 and 9/28/16 totaling $21,709.54

Monthly payments to Adobe Creative Cloud, a business software expert company, for $19.99
between 8/26/16 and 01/26/17
Two payments to ADT Security: 8/12/16 for $603.00 and 8/22/16 for $103.49
One payment to Bonicelli-Hinton LLC (Hoppz Landlord Boulder Location) for $4605.00
One payment to CA Wholesale on 9/13/16 for $165.00
One payment to Colorado Springs Utilities on 9/25/16 for $914.84
Four payments to East Grow Warehouse (2 in August 2016 and 2 in September, 2016) totaling
$300.67
Eighteen total payments to Modern Medicine (d/b/a Altitude Organic Medicine) between
8/16/16 and 11/3/16 totaling $3,627.11
One payment to Oriental Imports on 9/26/16 for $3,214.20
One payment to Purple Mountain Hydro on 9/22/16 for $45.95
One payment to Springs Waste Systems on 8/9/16 for $62.00
Nine payments to Vista Print between 7/22/16 and 12/8/16 totaling $395.93
Dara Wheatley JPMorgan Chase, Account # XXXXX0335
As demonstrated below with specific examples, between July of 2016 and the present, Ms. Wheatley
shows behaviors of transmitting or transferring proceeds and/or other money by:
a) Making payments to Colorado Springs Utilities and Springs Waste Systems for bills
addressed to and of the store. These records show utility payments being made for electrical
and waste removal, which helps enable the business to run by keeping the power on,
removing waste from the stores;
b) Making a payment to the Colorado Secretary of States Office to register Hoppz Cropz, LLC
as a Colorado business;
c) Making payments/purchases Oriental Imports and West Grow Warehouse for supplies for the
store, such as marijuana paraphernalia and t-shirts. These purchases aid in keeping the
business operating and assist in advertising to acquire future business and revenue;
d) Making purchases to Vista Print for the purpose of advertising. This assists in advertising for
the business to increase visibility and the customer base;
e) Making payments to Comcast for service at the stores.
Cash In / Cash Out
Analysis of Ms. Wheatleys account also revealed that, between January 7, 2016 and March 21, 2017,
Ms. Wheatley made ninety six cash deposits (including ATM and transfers) totaling $68,087.27.
These were all cash or transfer and not deposited by a known employer in the form of payroll nor
could these be tied to a legitimate source. $18.980.92 was in the form of electronic transfer from the
following: Joseph Hopper with fourteen transfers totaling $10,255.92; Alejandro Gonzalez
24
(believed to actually be Alejandra Gonzalez) with four transfers totaling $625.00; one transfer from
Joseph Crivici totaling $1,100.00 and seven transfers from an unidentified party totaling $7,000.00.
There are several cash withdrawals from Ms. Wheatleys account, including ATM and transfers,
between January 4, 2014 and December 10, 2016 totaling $18,140.49. $4,390.00 was in the form of
electronic transfer to the following: My Love (presumably her fiance Joseph Hopper) with six
transfers totaling $3,030.00; one transfer to Vegas Joe (presumably Joseph Crivici, as he had
previously resided in Las Vegas) for $1,050.00; and two transfers to Poppo/PDppo (presumably
Adam Donaldson (A.K.A. Popz)) for $310.00. There appears to be no other legitimate source of
income for Ms. Wheatley, other than approximately $2,367.00. In looking at both her bank account
(which showed only $262.71 deposited) and the 2016 income tax return she filed in Colorado, it
appears that the vast majority of her money came from the Hoppz Cropz stores revenue, in which she
occupies a high level managerial and/or ownership position.
The landlords for 750 E. Cimarron, Ms. Wheatleys residence, indicate that rent payments were made
in cash which may account for some of the cash withdrawals made by Ms. Wheatley.
Thirty two cash withdrawals between 1/4/16 and 12/12/16 totaling $18,140.49
One payment to the Colorado Secretary of State for $50.00
Nine payments to Comcast between 11/2/16 and 2/3//17 totaling $2,543.29
Seventeen payments to Colorado Springs Utilities between 1/8/16 and 3/2/17
totaling $6,478.63
Three payments to West Grow Warehouse on 2/22/16, 6/9/16 and 6/20/16 totaling
$128.29
One payment to Oriental Imports on 1/3/17 for $364.20
Nine payments to Century Link between 3/2/16 and 1/8/17 totaling $823.51
Seven payments to Springs Waste Systems between 2/16/16 and 1/25/17 totaling
$541.25
One payment to Vista Print on 10/26/16 for $147.99
On numerous occasions, as described in greater detail in the below Predicate Acts, specific members
of the enterprise unlawfully used their cell phones text messaging or email via social media
platforms such as Face Book- to facilitate distribution of marijuana or the conspiracy to distribute a
marijuana from the stores.
PREDICATE ACT 1
Unlawful Use of a Communication Facility, 21 U.S.C. 843
On or about March 29, 2017, at 10:38:48 a.m. (UTC-6) in and triable in the State of Colorado, Nicole
Sandoval and a person known to the Grand Jury did knowingly or intentionally use a
communications facility, namely, a wire, telephone and/or other means of communication, to
facilitate the commission of a felony, namely, distribution of a controlled substance, possession with
the intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance in
violation of 21 U.S.C. 841 and 846, such use of a commmunications facility being unlawful, and in
violation of 21 U.S.C. 843.
25
PREDICATE ACT 2
On or about April 19, 2017, at 4:04:10 p.m. (UTC-6) in and triable in the State of Colorado, Nicole
Sandoval did knowingly or intentionally use a communications facility, namely, a wire, telephone
and/or other means of communication, to facilitate the commission of a felony, namely, distribution
of a controlled substance, possession with the intent to distribute a controlled substance and/or
conspiracy to distribute a controlled substance in violation of 21 U.S.C. 841 and 846, such use of a
commmunications facility being unlawful, and in violation of 21 U.S.C. 843.
PREDICATE ACT 3
On or about April 20, 2017, at 12:16:41 p.m. (UTC-6) in and triable in the State of Colorado, Nicole
PREDICATE ACT 4
On or about April 23, 2017, at 11:12:25 a.m. (UTC-6) in and triable in the State of Colorado, Nicole
PREDICATE ACT 5
On or about May 2, 2017, at 10:09:14 a.m. (UTC-6) in and triable in the State of Colorado, Nicole
PREDICATE ACT 6
On or about October 25, 2016, at 2:34:37 p.m. (UTC-7) in and triable in the State of Colorado,
Nathan Bernheisel did knowingly or intentionally use a communications facility, namely, a wire,
telephone and/or other means of communication, to facilitate the commission of a felony, namely,
26
distribution of a controlled substance, possession with the intent to distribute a controlled substance
and/or conspiracy to distribute a controlled substance in violation of 21 U.S.C. 841 and 846, such
use of a commmunications facility being unlawful, and in violation of 21 U.S.C. 843.
PREDICATE ACT 7
On or about November 6, 2016, at 1:59:17 p.m. (UTC-7) in and triable in the State of Colorado,
Nathan Bernheisel and Adam Donaldson did knowingly or intentionally use a communications
facility, namely, a wire, telephone and/or other means of communication, to facilitate the commission
of a felony, namely, distribution of a controlled substance, possession with the intent to distribute a
controlled substance and/or conspiracy to distribute a controlled substance in violation of 21 U.S.C.
841 and 846, such use of a commmunications facility being unlawful, and in violation of 21 U.S.C.
843.
PREDICATE ACT 8
Nathan Bernheisel and Dara Wheatley did knowingly or intentionally use a communications
843.
PREDICATE ACT 9
Nathan Bernheisel did knowingly or intentionally use a communications facility, namely, a wire,
PREDICATE ACT 10
Nathan Bernheisel and Adam Donaldson did knowingly or intentionally use a communications
843.
27
PREDICATE ACT 11
On or about April 29, 2017, at 9:05 p.m in and triable in the State of Colorado, Raylene Rubio,
Victoria Fernandez, Marcee Smith, Alejandra Gonzalez and Nicole Sandoval did knowingly or
intentionally use a communications facility, namely, a wire, telephone and/or other means of
communication, to facilitate the commission of a felony, namely, distribution of a controlled
substance, possession with the intent to distribute a controlled substance and/or conspiracy to
distribute a controlled substance in violation of 21 U.S.C. 841 and 846, such use of a
PREDICATE ACT 12
On or about May 2, 2017, at 9:05 p.m in and triable in the State of Colorado, Raylene Rubio and
Victoria Fernandez did knowingly or intentionally use a communications facility, namely, a wire,
PREDICATE ACT 13
On or about July 8, 2016, at 4:22:51 p.m (UTC-6) in and triable in the State of Colorado, Victoria
Fernandez did knowingly or intentionally use a communications facility, namely, a wire, telephone
On or about March 29, 2017, at the times listed below, Nicole Sandoval and a party unknown to
the Grand Jury took part in the below text message conversation with one another in order to
facilitate the felony distribution of a controlled substance, possession with the intent to distribute a
controlled substance and/or conspiracy to distribute a controlled substance. The entire text
conversation has been included for context.
28
29
30
31
On or about April 19, 2017, at the times listed below, Nicole Sandoval and a party unknown to the
Grand Jury took part in the below text message conversation with one another in order to facilitate
the felony distribution of a controlled substance, possession with the intent to distribute a controlled
substance and/or conspiracy to distribute a controlled substance. The entire text conversation has
been included for context.
32
On or about April 20, 2017, at the time listed below, Nicole Sandoval and a party unknown to the
substance and/or conspiracy to distribute a controlled substance.
33
On or about April 23, 2017, at the time listed below, Nicole Sandoval and a party unknown to the
substance and/or conspiracy to distribute a controlled substance.
On or about May 2, 2017, at the time listed below, Nicole Sandoval and Chase Andrisko took part
in the below text message conversation with one another in order to facilitate the felony distribution
conspiracy to distribute a controlled substance.
34
Between on or about October 25, 2016, and November 4, 2016, at the times listed below, Nathan
Bernheisel and a party unknown to the Grand Jury took part in the below Facebook message
exchange in order to facilitate the felony distribution of a controlled substance, possession with the
intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance. The
entire Facebook message conversation has been included for context.
35
Between on or about November 6, 2016, and November 16, 2016, at the times listed below, Nathan
Bernheisel and a party unknown to the Grand Jury took part in the below Facebook message
exchange in order to facilitate the felony distribution of a controlled substance, possession with the
intent to distribute a controlled substance and/or conspiracy to distribute a controlled substance. The
entire Facebook message conversation has been included for context.
36
37
On or about November 16, 2016, at the times listed below, Nathan Bernheisel and Dara Wheatley
took part in the below text message conversation with one another in order to facilitate the felony
and/or conspiracy to distribute a controlled substance.
38
On or about November 17, 2016, at the time listed below, Nathan Bernheisel sent the following text
message to Adam Donaldson in order to facilitate the felony distribution of a controlled substance,
possession with the intent to distribute a controlled substance and/or conspiracy to distribute a
controlled substance. This message references an incident when Derrick Bernard and Nathan
Bernheisel were sleeping at Hoppz Boulder and Bernard confronted some people outside the store
with a firearm.
On or about November 17, 2016, at the times listed below, Nathan Bernheisel and Adam
Donaldson took part in the below text message conversation with one another (referring to another
employee, Raylene Rubio) in order to facilitate the felony distribution of a controlled substance,
controlled substance. The entire text conversation has been included for context.
39
On or about April 29, 2017, at the times listed below, Raylene Rubio, Victoria Fernandez, Marcee
Smith, Alejandra Gonzalez, Nicole Sandoval, and parties unknown to the Grand Jury took part
in the below text message conversation with one another in order to facilitate the felony distribution
conspiracy to distribute a controlled substance. The entire text conversation has been included for
context.
40
41
On or about May 2, 2017, at the times listed below, Raylene Rubio and Victoria Fernandez took
part in the below text message conversation with one another in order to facilitate the felony
and/or conspiracy to distribute a controlled substance. The entire text conversation has been included
for context.
42
Between on or about July 8, 2016, and October 3, 2016, at the times listed below, Victoria
Fernandez and a party unknown to the Grand Jury took part in the below conversation via
Twitter with one another in order to facilitate the felony distribution of a controlled substance,
controlled substance. The entire Twitter conversation has been included for context.
43
Dara Wheatleys Income Tax Evasion and Filing of a False Return
The CDOR maintains a database of income tax returns submitted by individuals and organizations.
During May of 2017, an examination was performed for records contained in the CDOR database for
Dara Wheatley who had filed Colorado individual income tax returns for 2016 on or about April 18,
2017. CDOR records indicate that Wheatley had not previously filed income tax in the State of
Colorado. Included in the CDOR data base is the Federal income tax filing, including: a schedule C,
Schedule SE, and W-2 forms. The schedule C is the profit and loss from a business and is used when
the profit or loss of said business is to flow through to the individual. Wheatleys Schedule C forms
included with her return stated the business to be Hoppz Cropz LLC. The CDOR has access to
certain federal information. During May of 2017, a request of Wheatleys Federal Income tax returns
was submitted to the Internal Revenue Service (IRS) including transcripts for tax year 2016 with a
request for the certified returns (not yet received).
Wheatleys 2016 Federal income tax return was recalculated based on the best information available,
with Wheatley as the sole member of Hoppz Cropz LLC. This resulted in re-calculating the Profit or
Loss from a Business on Schedule C and Self-Employment Tax on Schedule SE on the Federal
income tax return.
The recalculation was based on the Gross Receipts reported of $36,452 being under reported. The
assertion that the gross receipts were under reported is due to the information contained in a
ledger/journal during a search warrant executed in November of 2016 that listed daily sales totals
from July 15, 2016 through November 4, 2016. The ledger/journal entries for daily sales totaled
$410,608.
As the gross receipts were adjusted to reflect the amounts in the ledger/journal the expenses and cost
of goods were also adjusted reflecting higher amounts to offset the higher gross receipts.
44
Expense credits were re-calculated on the Schedule C. Credits for the amounts reported were
combined with additional amounts in categories of rent, wages, supplies, phone, taxes and fees.
Additional advertising credit was given and credit was given for items appearing to be business
expenses found in a receipt book during search warrants executed in November 2016 and May 2017.
Total business expenses were determined to be $90,955.67.
Category Estimate Amount

Rent $14,700
Payroll 17,387
Receipt Book 28,092
Taxes/Fees 2,149
Per Schedule C
filed 19,798
Utilities 7,019.88
Advertising 897.99
Telephone 823.51
128.29
Supplies
Total $ 90,995.67
The cost of goods was recalculated using the total combined marijuana purchases of three individuals,
none of whom were reported to be Wheatley, a single wholesale purchase attributed to Wheatley and
the amount reported on the Schedule C filed by Wheatley. The total amount of cost of goods was
calculated to be $42,694.66.
Schedule C (profit or loss from a business) was calculated using gross receipts less Cost of Goods and
expenses. The results of schedule C were a profit of $276,918.
Schedule C
Gross Receipts $410,608
Cost of Goods 42,695
Expenses 90,996
Profit/Loss $276,918
45
A Schedule SE is a federal tax form used to determine the tax due on net earnings from self-
employment. Schedule SE (self-employment tax) was re-calculated using the profit determined on
Schedule C. The results of schedule SE were a self-employment tax of $22,110 and a self-
employment tax deduction of $11055.
Schedule SE
Net Profit or (loss) Schedule C Line 2 $276,918
Total Income less approved reductions Line 3 $276,918
Self-Employment Tax - $118,500 or more Report on line

multiply by .029 plus $14,694 Line 5 $22,110 57 of 1040
Deduction for 1/2 of self-employment tax - Line Report on line

5 multiplied by .50 Line 6 $11,055 27 of 1040
Recalculation of Federal income tax 1040 for tax year 2016 resulted in a Federal tax liability of
$90,222. The calculation was based on Wheatley filing as single with one exemption. Total income
was reduced by SE deduction to compute the Adjusted Gross Income of $268,230. The Adjusted
Gross Income was reduced by subtracting the allowable standard deduction and credit for one
exemption resulting in a Federal taxable income of $257,880.
Colorado Income Tax was calculated by taking the amount of Total Taxable Income from the Federal
Return and applying the Colorado State Income Tax rate of 4.63% for a total amount due of $11,940
less withholding in the amount of $42. As Wheatley filed a return that resulted in a refund of $42
being issued that amount was added to the amount due.
According to the analysis, Wheatley filed a false Colorado Income tax return when she filed a return
stating a negative amount of Federal Taxable Income which ultimately resulted in a refund of $42
from the State of Colorado being issued on April 27, 2017. The correct amount of tax due the State
of Colorado is $11,898 ($257,880*.0463 [Colorado individual income tax rate] less amount of
withholding reported $42) of Colorado income tax in tax year 2016. However the amount due is
$11,940 as the amount paid by the State of Colorado as a refund is added back to $11,898.
Tax Year Social CO Taxable CO Tax Refund CO Tax

Security Income Withheld Received Owed
Number
2016 XXX-XX- $11,940 $42 $42 $11,940
4179
Total $11,940
46
ATTACHMENT A
08/13/16 Leo Phillips 0251
08/14/16 William Holt, Jr. 0934 719-216-8026/cemetarygate23@gmail.com
08/16/16 Lourdes Russell 0578 (TX) 956-570-4592/lourdesrussell@gmail.com
08/16/16 Kei'Andre C. 0829
08/16/16 Anthony S. Maxeiner 0036 (MO) scottanthony78@gmail.com
08/16/16 Andrea Pagan 0483 719-639-0949/andreaspagan17@gmail.com
08/17/16 Fred. W. Bake 1822 720-481-8463
08/17/16 Andrew King 4811
08/25/16 Sherman Bead 9316 719-482-4731
08/26/16 Chris Driver 7103 360-770-1660/driver7163@gmail.com
08/26/16 Peggy Schmeckpeper 0323-72-0260
08/26/16 Vernon Colbert 0463
08/26/16 Courtney Washington 2287 (TN) 321-525-1589/cnwashington1984@icloud.com
08/26/16 Daniel DeHerrera 0776 719-419-4858/deheerrerada2@gmail.com
08/26/16 Carol Richardson 0256 cjr122432cjr@gmail.com
08/26/16 Richard St.Louis 0699 (CO)
08/26/16 Ray Flores 0268
08/26/16 Pedro J. Cruz 0699
08/26/16 Kaci Rowley 0580 719-354-5996/kacirowley@gmail.com
08/30/16 Robert Osbourn 1189
08/30/16 Bruce Hughes 0261 719-355-4740/iceman2976@yahoo.com
08/30/16 Brenda Phillips 0049 719-290-0884
08/31/16 Eric Ashby 1644 719-291-7418/eashby79@gmail.com
08/31/16 Martina Quintanilla 7663 515-257-0653
08/31/16 Tina Miles 9971 515-266-7448
08/31/16 Thomas Buckner 9431 706-294-8400/thomasb@hotmail.com
08/31/16 Lucious Welly 8523 720-628-2142/jonezjugg8@gmail.com
08/31/16 Dustin Thom 4511
08/31/16 Robert Lahr 5690 719-578-5399/lahr719@gmail.com
08/31/16 Robert Lee 4642
08/31/16 K. Jones 1931 75kjones.kj@gmail.com
08/31/16 Reggie Wright 7247 400-240-6017/reginald.wright@yahoo.com
08/31/16 Holly Hurtado 4728 719-220-0813/hollisugar420@yahoo.com
08/31/16 Gregg Huphrys 1133
08/31/16 Eddie Smith 6175
08/31/16 Hunam Ducommon 6113
08/31/16 Justin Wood 6611
08/31/16 Linda Brown 8785
08/31/16 Arthur Clifford Garcia 3270
08/31/16 Hugo Preciado 0312
08/31/16 Holly Sorell 0768
47
08/31/16 Stacy Holly 0617
08/31/16 Vincent Robinson 01DK
08/31/16 Shaun McNemar, Sr. 0953
08/31/16 Joseph Lafferty 0383 719-337-8561/zeusware1986@yahoo.com
08/31/16 Jerrod Buice 0636 719-213-9274/jerrod.buice@yahoo.com
08/31/16 Jennifer A. Mason 0739 302-276-5802/italiana_bonita@yahoo.com
09/01/16 Rafael Camargo 1206 (CO) 719-722-4464/camargor91@gmail.com
09/01/16 Ronald Hearn 4719
09/01/16 Crystal Pope 0650 719-495-9563/pope_amy2008@gmail.com
09/01/16 Javier Cruz 1887 719-644-4489/dbonethugs11@gmail.com
09/01/16 Paul Dunlap 0327 719-460-4167
09/01/16 Tanesha Jones Murry 0252 (CO)
09/01/16 John Mata 1008 361-571-8943/jmmata1965@yahoo.com
09/01/16 Anthony Hoder 0453
09/01/16 Nichole Smith 9844 214-753-7050/nickismithh@gmail.com
09/01/16 Manasia Smith 0328
09/01/16 Kelly Garriott 4432 713-514-4300/banditskel@aol.com
09/01/16 Doris Moment 8919 ms.thingthing2@yahoo.com
09/01/16 Kevin Johnson 9862 303-304-7001/klj18@msn.com
09/01/16 Karen Barnett 4703 (MO)
09/01/16 James Barnett 7001 (MO)
09/01/16 Donald R. Ord 6524 719-360-4655
09/01/16 Raylene Rubio 0489
09/01/16 Patricia Goodrich 0478 720-982-3683/braceyshort@gmail.com
09/01/16 Philip Thompson 0257
09/01/16 Anita Jones 9256 719-964-6248/anitajones2000@gmail.com
09/01/16 Jancel/Janel Miller 2881
09/01/16 Devin Smith 0901
09/01/16 Nicholas Chandler 0545 817-449-8395/nicholaschandler92@gmail.com
09/01/16 Tyler Kennedy 0397 (CO) 719-648-4776/magicman33@gmail.com
09/01/16 Ronnie Corey 0492
09/01/16 Ed Fromm 422
09/01/16 Edward Rubio 1329
09/07/16 Romeo Sudaria 1319 (CO)
09/07/16 Cedric Davis 7852 719-321-4167/cedricdavid459@yahoo.com
09/07/16 Ronald C. Jones 1123
09/08/16 Robert Lozen 0112
09/08/16 Charles W. Cox 1974 719-282-5610
09/08/16 LaToia Neal 0911
09/08/16 Davonte Thompson 8002 (CA)
09/08/16 Matthew Reed 0852 (CA) 760-274-5968
09/08/16 Bryan Myers 4889
09/08/16 Ural Jackson 8221
48
09/08/16 Joseph Pineda 4352 (MI) 810-259-5342/jrpqudr@gmail.com
09/08/16 Myrion Rivera 0204
09/08/16 William V. Dorman 8356
09/08/16 Tom Sack 8231
09/08/16 Karen E. Shaffer 8433
09/08/16 Roger Mullins 0897 (VA)
09/09/16 Dennis Noeske 0433 719-459-6020/dnoeske719@gmail.com
09/09/16 Geraldine Jimenez 5622 719-644-4176
H620143771410
09/09/16 Charles Harris (FL)
09/09/16 Re'Mon C. Miller 6649 773-308-4350/remonmiller@gmail.com
09/09/16 Jeanette Hewlin 4430 719-216-7410/jmhewlin@yahoo.com
09/09/16 Amber Gutierrez 6971 719-216-7410/amberg607@gmail.com
09/09/16 Tiffany Dalton 5476 208-404-5195/justinsangel0827@gmail.com
09/09/16 Roberto C. Delgado Cruz 0973 719-644-0465/rcdcruz2123@gmail.com
09/10/16 Aaron Mans 1422/1922(?)
09/10/16 Richard Sutton 0253
09/10/16 Ara/Aria Ewing 2552
09/10/16 Sharaine Ewing 0812
09/10/16 Sharron Ewing 0572
09/10/16 David S. 1050 (FL)
09/10/16 James Grigsby 0866
09/10/16 Markilla Smith 1026 719-639-5541/markillasweet@gmail.com
09/11/16 Chris McEachin 5328
09/11/16 Gary Brutto 2020 719-419-0179/bruttogjohn@yahoo.com
09/11/16 Mark Pangelinan 0538
09/13/16 Nanolo Morin 0751
09/15/16 Sydney Barker 7626 (TN) 931-801-1843
09/15/16 Tucker Heaton 5749 (TN) 931-216-5621/tucker_heaton@outlook.com
09/15/16 May Christine 3140 (OH) krisstmae28@yahoo.com
10/03/16 Eric Harvey 5002
10/03/16 Samuel Gallegos 8189
10/03/16 Jessica Boaman 0208
10/03/16 Kit Day 2007
10/03/16 Joe Timerman 5382 (NE)
10/03/16 Kemone Scott 0662
10/03/16 Rochelle Adams 9360
10/03/16 Howard Smith 7928
10/04/16 Sharon L. Henson 0269
10/04/16 Jennifer Queen 0422
10/04/16 Chris Sanders 1265
10/04/16 Haywood Miller 0284
10/15/16 Alisha Newberry 0537
49
10/16/16 Leonard Contreras 0945
10/16/16 Calvin Baker 299-0 6135 (FL)
10/16/16 Jose Cuevas 0895
10/16/16 Jadelyn Vincent 0488
10/16/16 Cesar Contreras 0986
10/16/16 Ashley Kabel 6014
10/16/16 Billy (Jo) Wathey 3038
10/16/16 Steven Miles 8092
10/16/16 Michael Wallace 0551
10/16/16 Tina Crabtree 0382
10/16/16 Jesse Westfall 4342 (OH)
10/16/16 Nateria Williams 5756/5946/5456(?)
10/16/16 Cangeron Gibson 0663
10/16/16 Elena Rodriguez 0051
10/17/16 Elia Vera 4194
10/17/16 Raul Munoz 0478
10/17/16 Jamie Butler 0085
10/17/16 Imani Mauzon 5521 (CA)
10/17/16 Jesse Brady 0790
10/17/16 Rodney Boemer 3616 (MN)
10/17/16 David Bailey 0443
10/17/16 Ira Franklin 0311 (AR)
10/17/16 Andrews Adams 9547 (MD)
10/17/16 Jeneva Nelson 7127 (OK)
10/17/16 Xavier Cochran 2392 (OK)
10/17/16 Maverick Rhone 7362
10/17/16 Andre Williams 9843 (TX)
10/18/16 Christopher Luera 6955 (TX)
10/18/16 Paul E. Newton 9972
10/18/16 Candace Martinez 3145 (TX)
10/18/16 Angela Newton 4501
10/18/16 Jacqueline Bozeman 7058
10/18/16 Danzelle Ford 6958
10/18/16 Espinoza 1958
10/18/16 Jamika Elliott 1056
10/18/16 James Honaker, Jr. 0661
10/18/16 Demetrius Goldston, Jr. 0874
10/18/16 Michael Lafordy 9710
10/18/16 Damien Clair 0461
10/18/16 Raynie King 1325
10/19/16 Cody Claeys 4507
10/19/16 Lorenzo Duarte 1184
10/19/16 Larry Valadez 1934
50
10/19/16 Keith Adams, II 3040 (FL)
10/19/16 Marie Morales 0687
10/19/16 Jeff Dugger 5831
10/19/16 James R. Dolson 0572
10/19/16 J. Swuartz 2500
10/19/16 Zenas Nations, Jr. 0470
10/19/16 Savanah Pease 0449
10/19/16 Rob Hask 0381
10/19/16 James "Andrew" Russell 0631
10/19/16 Chance Dearth 0724
10/19/16 Dwandre Parker 3682
10/19/16 Jennifer Harris 8122 (OK)
10/19/16 Adam Harris 8115
10/20/16 Anthony S. Velasquez 3149
10/20/16 Brook Shenberg 8557
10/20/16 April Meraz 0249
10/20/16 Demetrius Somerville 0748
10/20/16 Marcy White 1096
10/20/16 Pamela Shipp 6074
10/20/16 Rylan Timmons 0825
10/20/16 Stephanie Dorman 0490 (CO)
10/20/16 Marlana Dorman 8320
10/20/16 Destiny Morran 0385
10/20/16 Kathleen Buoniconti 0127
10/20/16 Faatalale Taase 0039
10/21/16 Raymond Proveneo 0950
10/21/16 Terrel Atencio 1149
10/22/16 Robert Thomas 0109 (MO)
10/22/16 Robert Bishop 0346
10/22/16 James Hilton 4653
10/22/16 Edgar Contreras 4261
10/22/16 Tania Nathan 0097
10/22/16 Daniel Quintana 1019
10/22/16 Ricardo Fagins 4939
11/11/16 William Maestas 3119
11/11/16 Ethan Miller 0886
11/11/16 Randall M. Reese, Jr. 0769
11/11/16 Kristen Crable 0875 kristenrb1980@hotmail.com
11/11/16 Bradley Crable 0817 bradcrable2000@gmail.com
11/11/16 Evangelina Buell 0730 (CO) aniyahsmommy@gmail.com
11/11/16 Anthony Norvell 1023
11/11/16 Samantha Hyatt 0596
11/11/16 Delinski Banks 0559/7?
51
11/11/16 Mustafa 0195
11/11/16 Roy Masada 2019 roymasada@yahoo.com
11/11/16 Anthony W. Kent 0103
11/11/16 Valerie L. DeMarco 0070
11/11/16 Michael Brister 0165
11/11/16 Trey Jones 0498
11/11/16 Carlos Vergara 02672
11/11/16 Feleicia Andrews 0038
11/11/16 Mario De La Torre 0321
11/11/16 Hayward Reed 4166 (TX) hcreed316@yahoo.com
11/15/16 Devonia Smith 0761
11/15/16 Eric Dockery 0721 edockery2212@gmail.com
11/15/16 Karlos Poindexter 2452 poindexter.karlos187@yahoo.com
11/15/16 Genoveva Martinez 6345
11/15/16 Courtney Stutzman 0453 stutz719@gmail.com
11/15/16 Julie Welch FA 5041
11/15/16 Frances Velasquez 2699
11/15/16 Mario Herrera 0361
11/15/16 Aaron Peterson 0935 a.jpeterson10@yahoo.com
11/15/16 Vincent Salaz 0119
11/15/16 Crystal Sorenson 0545 crystalsorenson13@gmail.com
11/15/16 Dawn Kempers 5366
11/16/16 Brian Aniler 0173
11/16/16 Bradley Brown 5468
11/16/16 Faith Turner 0709
11/16/16 Rachael Schreiner 0892
11/16/16 James Samson 0858
11/16/16 John J. Kruck 1078
11/16/16 Roy E. Gaw 0478 roygaw83@gmail.com
11/16/16 Shirley Cucer 7507
11/16/16 Merrilee Morgan 0353
11/16/16 Andrew Moore 1057
11/16/16 Paul Williams 1212
11/16/16 Justin Peterson 0554 driver7163@gmail.com
52
AS TO COUNT ONE:
A TRUE BILL A NO TRUE BILL
_________________________ ____________________________
Foreperson Foreperson
AS TO COUNT TWO:
_________________________ ____________________________
AS TO COUNT THREE:
_________________________ ____________________________
AS TO COUNT FOUR:
_________________________ ____________________________
AS TO COUNT FIVE:
_________________________ ____________________________
AS TO COUNT SIX:
_________________________ ____________________________
53
AS TO COUNT SEVEN:
_________________________ ____________________________
AS TO COUNT EIGHT:
_________________________ ____________________________
AS TO COUNT NINE:
_________________________ ____________________________
AS TO COUNT TEN:
_________________________ ____________________________
AS TO COUNT ELEVEN:
_________________________ ____________________________
AS TO COUNT TWELVE:
_________________________ ____________________________
AS TO COUNT THIRTEEN:
_________________________ ____________________________
54
AS TO COUNT FOURTEEN:
_________________________ ____________________________
AS TO COUNT FIFTEEN:
_________________________ ____________________________
AS TO COUNT SIXTEEN:
_________________________ ____________________________
AS TO COUNT SEVENTEEN:
_________________________ ____________________________
AS TO COUNT EIGHTEEN:
_________________________ ____________________________
AS TO COUNT NINETEEN:
_________________________ ____________________________
AS TO COUNT TWENTY:
_________________________ ____________________________
55
AS TO COUNT TWENTY ONE:
_________________________ ____________________________
AS TO COUNT TWENTY TWO:

_________________________ ____________________________
AS TO COUNT TWENTY THREE:

_________________________ ____________________________
AS TO COUNT TWENTY FOUR:

_________________________ ____________________________
AS TO COUNT TWENTY FIVE:

_________________________ ____________________________
AS TO COUNT TWENTY SIX:

_________________________ ____________________________
AS TO COUNT TWENTY SEVEN:

_________________________ ____________________________
56
I, ____________________________, the Foreperson of the 2016-2017 Colorado State Grand Jury, do
hereby swear and affirm that each and every True Bill returned in this superseding indictment by the
2016-2017 Colorado State Grand Jury was arrived at after deliberation and with the assent and
agreement to the existence of probable cause by at least nine members of the Colorado State Grand
Jury. The Colorado State Grand Jury further authorizes and instructs the Colorado Attorney General
to return this superseding indictment to open court with or without the presence of the foreperson.
_____________________________
Foreperson
Subscribed to before me in the City and County of Denver, State of Colorado, this 25th day of May,
2017.
______________________________
Notary Public
My commission expires:______________________
57
CYNTHIA H. COFFMAN
ATTORNEY GENERAL
STATE OF COLORADO
__________________________
MICHAEL W. MELITO
Senior Assistant Attorney General
Criminal Justice Section
Special Prosecution Unit
__________________________
JON W. IPPOLITO
Deputy District Attorney
4th Judicial District District Attorneys Office
__________________________
ANDREW S. VAUGHAN
Deputy District Attorney
4th Judicial District District Attorneys Office
The 2016-2017 Colorado Statewide Grand Jury presents the within Superseding Indictment, and the
same is hereby ORDERED FILED this 25th day of May, 2017.
Pursuant to 13-73-107, C.R.S., the Court designates El Paso County, Colorado as the county
of venue for the purposes of trial.
Dated this 25th day of May, 2017.
____________________________
Chief Judge Michael Martinez
Presiding Judge, State Grand Jury
58
WARRANTS TO ISSUE:
BOND FOR JOSEPH HOPPER (A.K.A. JOEY HOPS) SET AT $150,000.00 C/S/P
Conditions of bond include:
No contact with any codefendants

Obey all state and federal laws
That the defendant shall refrain from harassing, molesting, intimidating, retaliating against, or
tampering with any witnesses to the acts charged.
BOND FOR DARA WHEATLEY (A.K.A. BOSS LADY) SET AT $150,000.00 C/S/P

BOND FOR ADAM DONALDSON (A.K.A. POPS, POPZ) SET AT $75,000 C/S/P

BOND FOR JOSEPH SERGIO CRIVICI (A.K.A. JOSEPH CRAVICI) SET AT $75,000 C/S/P

59
BOND FOR DERRICK BERNARD (A.K.A. UGRILLA PHOENIXX, PHOENIXX UGRILLA,
PHEONUAX) SET AT $125,000 C/S/P

BOND FOR NATHAN BERNHEISEL (A.K.A. BERNIE, SHANLEY LEONE, FRANKIE,

NATE) SET AT $125,000 C/S/P

BOND FOR VICTORIA FERNANDEZ (A.K.A. TORI) SET AT $25,000 C/S/P

BOND FOR MARCEE SMITH (A.K.A. MARLEY) SET AT $25,000 C/S/P

60
BOND FOR ALEJANDRA GONZALEZ (A.K.A. ALE) SET AT $25,000 C/S/P

BOND FOR RAYLENE RUBIO (A.K.A. RAY, RAE, RAYLEEN, RAYLEAN) SET AT
$25,000 C/S/P

BOND FOR NICOLE SANDOVAL (A.K.A. NIKKI) SET AT $25,000 C/S/P

BOND FOR ASHLEY HEFNER SET AT $25,000 C/S/P

61
BOND FOR MELISSA COLMUS SET AT $25,000 C/S/P

Dated this 25th day of May, 2017.
____________________________
Chief Judge Michael Martinez
Presiding Judge, State Grand Jury
62

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DISTRICT COURT, CITY AND COUNTY OF DENVER, COLORADO

1437 Bannock Street

JOSEPH HOPPER (A.K.A. JOEY HOPS)

COLORADO STATE GRAND JURY INDICTMENT

COUNT 2 Violation of the Colorado Organized Crime Control Act Conspiracy/Endeavoring,

COUNT 5 Possession with Intent to Manufacture or Distribute Marijuana (50 LBS) or

COUNT 6 Conspiracy to Distribute, or Possess with Intent to Manufacture or Distribute,

COUNT 8 Conspiracy to Commit Money Laundering Conduct Financial Transaction with

COUNT 9 Money Laundering Transfer Monetary Instrument with Intent to

COUNT 10 Conspiracy to Commit Money Laundering Transfer Monetary Instrument with

COUNT 11 Keeping Property for Unlawful Distribution of Controlled Substances,

COUNT 12 Evasion of Taxes Administered by the Colorado Department of Revenue,

COUNT 13 Conspiracy to Commit Evasion of Taxes Administered by the Colorado Department

COUNT 14 Evasion of Taxes Administered by the Colorado Department of Revenue,

COUNT 15 Conspiracy to Commit Evasion of Taxes Administered by the Colorado Department

COUNT 17 Filing a False Tax Return, 39-21-118(4), C.R.S. (F5) 40024

COUNT 18 Forgery, 18-5-102(1)(C), C.R.S. (F5)

COUNT 20 Attempt To Influence A Public Servant, 18-8-306, C.R.S. (F4) 24051

COUNT 21 Attempt To Influence A Public Servant, 18-8-306, C.R.S. (F4) 24051

COUNT 22 Attempt To Influence A Public Servant, 18-8-306, C.R.S. (F4) 24051

COUNT 23 Special Offender Conspiracy Pattern of Sale, 18-18-407(1)(b), C.R.S. (DF-1)

COUNT 24 Special Offender Organizer in Series of Violations with Others, 18-18-407(1)(F),

COUNT 25 Special Offender Firearm, C.R.S. 18-18-407(1)(d)(II), C.R.S. (DF1) 33A45

COUNT 26 Filing a False Tax Return, 39-21-118(4), C.R.S. (F5) 40024

COUNT 27 Evasion of Taxes Administered by the Colorado Department of Revenue,

Defendant Date of Birth Counts

Violation of the Colorado Organized Crime Control Act Conspiracy/Endeavoring,

Pattern of Racketeering Activity

Distribution of Marijuana or Marijuana Concentrate

Distribution Of Marijuana (50 LBS) or Marijuana Concentrate (25 LBS), 18-18-

Money Laundering Conduct Financial Transaction with Intent to Promote Crime,

Money Laundering Transfer Monetary Instrument with Intent to

Conspiracy to Commit Money Laundering Transfer Monetary Instrument with Intent to

Keeping Property for Unlawful Distribution of Controlled Substances,

Evasion of Taxes Administered by the Colorado Department of Revenue,

Conspiracy to Commit Evasion of Taxes Administered by the Colorado Department of Revenue,

Evasion of Taxes Administered by the Colorado Department of Revenue,

Conspiracy to Commit Evasion of Taxes Administered by the Colorado Department of Revenue,

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

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

Forgery, 18-5-102(1)(C), C.R.S. (F5)

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

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

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

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

Special Offender Conspiracy Pattern of Sale, 18-18-407(1)(b), C.R.S. (DF-1) 33A43

Special Offender Firearm, C.R.S. 18-18-407(1)(d)(II), C.R.S. (DF1) 33A45

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

Evasion of Taxes Administered by the Colorado Department of Revenue,

3 i.e., Flower, Trim, or Immature Plant.

Undercover Marijuana Purchases at Hoppz Delta:

Undercover Marijuana Purchases at Hoppz Boulder:

Second Search Warrant

Money Laundering Activity by Members of the Enterprise

Adam Donaldson Pueblo Bank and Trust, Account # XXXXX9943

Cash In / Cash Out

Eleven cash withdrawals between 7/18/16 and 9/28/16 totaling $21,709.54

Dara Wheatley JPMorgan Chase, Account # XXXXX0335

Cash In / Cash Out

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

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

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

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

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

Hoppz' Cropz Indictment

Hoppz' Cropz Indictment