Free Indictment - District Court of Colorado - Colorado

Case 1:01-cr-00350-WYD

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Judge Wiley Y. Daniel

Criminal Case No. 01-cr-00350-WYD UNITED STATES OF AMERICA, Plaintiff, v. 1. JASON M. PRICE, Defendant. ______________________________________________________________________________ SUPERSEDING INDICTMENT 21 U.S.C. §963 21 U.S.C. §960 21 U.S.C. §952 21 U.S.C. §848 21 U.S.C.§846 21 U.S.C. § 841(a)(1) and (b)(1)(C) 21 U.S.C. §843(b) 18 U.S.C. §2 ______________________________________________________________________________ The Grand Jury charges that: COUNT ONE From at least on or about April 18, 2001, until on or about August 31, 2001, in the State and District of Colorado, and elsewhere, the Defendant, Jason M. Price, did unlawfully and knowingly or intentionally engage in a Continuing Criminal Enterprise in that he did violate Title 21, United States Code, Sections 841(a)(1), 843(b) and 846, which violations were part of a continuing series of violations of said statutes undertaken by the Defendant, Jason M. Price, in

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concert with at least five other persons, with respect to whom the Defendant, Jason M. Price, occupied a position of organizer, supervisor or manager, and from which continuing series of violations the Defendant, Jason M. Price, obtained substantial income and resources. All in violation of Title 21, United States Code, Section 848. COUNT TWO From at least on or about April 18, 2001, until on or about August 31, 2001, in the State and District of Colorado, and elsewhere, the Defendant, Jason M. Price, did unlawfully and knowingly or intentionally conspire, combine, confederate, cooperate and agree with other persons both known and unknown to the Grand Jury 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 From at least on or about April 18, 2000, until on or about August 31, 2001, in the State and District of Colorado, and elsewhere, the Defendant, Jason M. Price, did unlawfully and knowingly or intentionally conspire, combine, confederate, cooperate and agree with other persons both known and unknown to the Grand Jury to import into the United States from a place outside thereof, 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 2

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enacted thereunder, in violation of Title 21, United States Code, Sections 952 and 960. All in violation of Title 21, United States Code, Section 963. COUNT FOUR On or about June 1, 2001, in the State and District of Colorado, the Defendant, Jason M. Price, did unlawfully and knowingly or intentionally use a communication facility, namely, a telephone, in committing or in causing or facilitating the commission of an act or acts constituting a felony under subchapter I or subchapter II of Chapter 13 (Comprehensive Drug Abuse Prevention and Control Act), that is, distribution of, possession with intent to distribute, or conspiracy to possess 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, in violation of Title 21, United States Code, Sections 841(a)(1) and 846 ; and did knowingly or intentionally aid and abet and cause the same. All in violation of Title 21, United States Code, Section 843(b), and Title 18, United States Code, Section 2. COUNT FIVE On or about June 1, 2001, in the State and District of Colorado, the Defendant, Jason M. Price, did unlawfully and knowingly or intentionally use a communication facility, namely, a telephone, in committing or in causing or facilitating the commission of an act or acts constituting a felony under subchapter I or subchapter II of Chapter 13 (Comprehensive Drug Abuse Prevention and Control Act), that is, distribution of, possession with intent to distribute, or conspiracy to possess with intent to distribute a mixture or substance containing a detectable 3

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amount of 3,4-methylenedioxymethamphetamine (MDMA) (commonly known as "Ecstasy"), a controlled substance listed in Schedule I, Title 21, United States Code, Section 812, in violation of Title 21, United States Code, Sections 841(a)(1) and 846 ; and did knowingly or intentionally aid and abet and cause the same. All in violation of Title 21, United States Code, Section 843(b), and Title 18, United States Code, Section 2. COUNT SIX On or about June 6, 2001, in the State and District of Colorado, the Defendant, Jason M. Price, did unlawfully and knowingly or intentionally use a communication facility, namely, a telephone, in committing or in causing or facilitating the commission of an act or acts constituting a felony under subchapter I or subchapter II of Chapter 13 (Comprehensive Drug Abuse Prevention and Control Act), that is, distribution of, possession with intent to distribute, or conspiracy to possess 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, in violation of Title 21, United States Code, Sections 841(a)(1) and 846 ; and did knowingly or intentionally aid and abet and cause the same. All in violation of Title 21, United States Code, Section 843(b), and Title 18, United States Code, Section 2. COUNT SEVEN On or about June 7, 2001, in the State and District of Colorado, the Defendant, Jason M. Price, did unlawfully and knowingly or intentionally distribute a mixture or substance 4

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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; and did knowingly or intentionally aid and abet and cause the same. All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C), and Title 18, United States Code, Section 2. COUNT EIGHT On or about June 8, 2001, in the State and District of Colorado, the Defendant, Jason M. Price, did unlawfully and knowingly or intentionally possess 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; and did knowingly or intentionally aid and abet and cause the same. All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C), and Title 18, United States Code, Section 2. COUNT NINE On or about July 26, 2001, in the State and District of Colorado, the Defendant, Jason M. Price, did unlawfully and knowingly or intentionally use a communication facility, namely, a telephone, in committing or in causing or facilitating the commission of an act or acts constituting a felony under subchapter I or subchapter II of Chapter 13 (Comprehensive Drug Abuse Prevention and Control Act), that is, distribution of, possession with intent to distribute, or conspiracy to possess with intent to distribute a mixture or substance containing a detectable 5

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amount of 3,4-methylenedioxymethamphetamine (MDMA) (commonly known as "Ecstasy"), a controlled substance listed in Schedule I, Title 21, United States Code, Section 812, in violation of Title 21, United States Code, Sections 841(a)(1) and 846 ; and did knowingly or intentionally aid and abet and cause the same. All in violation of Title 21, United States Code, Section 843(b), and Title 18, United States Code, Section 2. COUNT TEN On or about July 26, 2001, in the State and District of Colorado, the Defendant, Jason M. Price, did unlawfully and knowingly or intentionally 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; and did knowingly or intentionally aid and abet and cause the same. All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C), and Title 18, United States Code, Section 2. COUNT ELEVEN On or about August 4, 2001, in the State and District of Colorado, the Defendant, Jason M. Price, did unlawfully and knowingly or intentionally 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; and did knowingly or intentionally aid and abet and cause the same. 6

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All in violation of Title 21, United States Code, Sections 841(a)(1) and (b)(1)(C), and Title 18, United States Code, Section 2. A TRUE BILL:

s/Foreperson____________________ FOREPERSON

WILLIAM J. LEONE UNITED STATES ATTORNEY

BY: s/ Joseph T. Urbaniak Jr. JOSEPH T. URBANIAK JR. Assistant United States Attorney United States Attorney's Office 1225 Seventeenth Street, Suite 700 Denver, Colorado 80202 Telephone: (303) 454-0317 FAX: (303) 454-0401 E-mail: [email protected] Attorney for Government

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