Free Indictment - District Court of Colorado - Colorado

Case 1:01-cr-00350-WYD

Document 402-2

Filed 12/20/2005 DATE:

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Superseding Indictment (01-cr-00350-WYD) DEFENDANT: Jason M. Price AGE: ADDRESS: OFFENSE: 31 Denver, Colorado

December 20, 2005

Count One: Engaging in a Continuing Criminal Enterprise, in violation of Title 21, United States Code, Section 848. Count Two: Knowingly and intentionally conspiring to possess with intent to distribute and to distribute a mixture or substance containing a detectable amount of 3,4methylenedioxymethamphetamine (MDMA) (commonly known as "Ecstasy"), a controlled substance listed in Schedule I, Title 21, United States Code, Section 812, and the regulations enacted thereunder, in violation of Title 21, United States Code, Section 841(a)(1); all in violation of Title 21, United States Code, Section 846. Count Three: Knowingly and intentionally conspiring to import a mixture or substance containing a detectable amount of 3,4-methylenedioxymethamphetamine (MDMA) (commonly known as "Ecstasy"), a controlled substance listed in Schedule I, Title 21, United States Code, Section 812, and the regulations enacted thereunder, in violation of Title 21, United States Code, Section 841(a)(1), into the United States from a place outside thereof; in violation of Title 21, United States Code, Sections 963, 960 and 952. Counts Four, Five, Six, and Nine: Knowingly and intentionally using a communications facility (telephone) to facilitate a drug trafficking felony, in violation of Title 21, United States Code, Section 843 (b), and Title 18, United States Code, Section 2. Counts Seven, Ten, and Eleven: Knowingly and intentionally distributing a mixture or substance containing a detectable amount of 3,4-methylenedioxymethamphetamine (MDMA) (commonly known as "Ecstasy"), a controlled substance listed in Schedule I, Title 21, United States Code, Section 812, and the regulations enacted thereunder, in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)(C). Count Eight: Knowingly and intentionally possessing with intent to distribute a mixture or substance containing a detectable amount of 3,4-methylenedioxymethamphetamine (MDMA) (commonly known as "Ecstasy"), a controlled substance listed in Schedule I, Title 21, United States Code, Section 812, and the regulations enacted thereunder, in violation of Title 21, United States Code, Section 841(a)(1) and (b)(1)©.

LOCATION OF OFFENSE: Denver, Colorado; New York, New York; France; Belgium; Netherlands PENALTY: Count One: A term of imprisonment of not less than 20 years and up to life; a fine not to exceed $2,000,000.00; or both; a term of supervised release of at least 5 years; and a $100.00 special assessment fee.

Case 1:01-cr-00350-WYD

Document 402-2

Filed 12/20/2005

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Counts Two, Three, Seven, Eight, Eleven, Twelve: A term of imprisonment of not more than 20 years; a fine not to exceed $1,000,000; or both; a term of supervised release of 3 years; and a $100.00 special assessment fee. Counts: Four, Five, Six, Nine, Ten: A term of imprisonment of not more than 4 years; a fine not to exceed $250,000.00; or both; a term of supervised release of 3 years; and a $100.00 special assessment fee AGENT: Paul Roach, Special Agent, Drug Enforcement Administration

AUTHORIZED BY: Joseph T. Urbaniak Jr. Assistant United States Attorney ESTIMATED TIME OF TRIAL: five days or less X over five days

THE GOVERNMENT X will not seek detention in this case (because the Defendant has been on bond).

The statutory presumption of detention is applicable to this defendant.