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Wrenfrow Indictment

Wrenfrow Indictment

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Published by: Nick on Jun 04, 2012
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06/04/2012

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 District Court, City and County of Denver, ColoradoCity and County Building, Room 2151437 Bannock StreetDenver, CO 80202
Plaintiff:
THE PEOPLE OF THE STATE OFCOLORADO
Defendants:CHARLES WAYNE WRENFROWMICHELLE JEAN WRENFROW
COURT USE ONLYCase Number:Grand Jury No.
12CR2A
 Div.: Criminal Ctrm: 215 / ____
INDICTMENT
VIOLATION OF COLORADO ORGANIZED CRIME CONTROL ACT, C.R.S. 18-17-104(3),(F2) <37284> 1 (1 count)CONSPIRACY TO COMMIT THEFT BY RECEIVING, C.R.S. 18-4-410(1),(5);18-2-201 (F4)<0805HC> 2 (1 count)THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> 3, 4, 5, 6, 7, 8, 9, 11, 12, 13,14, 15, 16, 17, 18, 19, 20, 21 (18 counts)THEFT BY RECEIVING, C.R.S. 18-4-410(1),(5) (F3) <0805H> 10 (1 count)The Grand Jury presents the within Indictment and the same is ordered filed.Dated this _________ day of ____________________, 2012._________________________________________Christina M. HabasPresiding JudgeDenver District Court
 
 
COUNT ONE
VIOLATION OF COLORADO ORGANIZED CRIME CONTROL ACT, C.R.S. 18-17-104(3),(F2) <37284>Between and including
September 1, 2009, and May 23, 2012,
at and triable in the City andCounty of Denver, State of Colorado,
CHARLES WAYNE WRENFROW and MICHELLEJEAN WRENFROW,
while employed by or associated with an enterprise, namely:
C & MTOWING AND RECOVERY, INC,
unlawfully, feloniously, and knowingly conducted orparticipated, directly or indirectly, in the enterprise through a pattern of racketeering activity; inviolation of sections C.R.S. 18-17-104(3) and 18-17-105.
The Enterprise
The enterprise alleged in Count One included, but was not limited to, the following:
CHARLESWAYNE WRENFROW, MICHELLE JEAN WRENFROW, and C & M TOWING ANDRECOVERY, INC,
and other persons known or unknown, who were associated from time totime in racketeering activity that was related to the conduct of the enterprise.
Pattern of Racketeering Activity
For purposes of this count, the defendants engaged in acts related to the conduct of theenterprise, including:As to
CHARLES WAYNE WRENFROW,
the acts described in counts 2 through 21, includingany lesser included offenses of these counts.
 
As to
MICHELLE JEAN WRENFROW,
the acts described in counts 2 through 21, includingany lesser included offenses of these counts.
 
 
 
COUNT TWO
 CONSPIRACY TO COMMIT THEFT BY RECEIVING, C.R.S. 18-4-410(1),(5);18-2-201 (F4)<0805HC>Between and including
September 1, 2009, and May 23, 2012,
at and triable in the City andCounty of Denver, State of Colorado,
CHARLES WAYNE WRENFROW and MICHELLEJEAN WRENFROW
, with the intent to promote or facilitate the commission of the crime of 
THEFT BY RECEIVING
, unlawfully and feloniously agreed with
CHARLES WAYNEWRENFROW and MICHELLE JEAN WRENFROW
and a person or persons to the DistrictAttorney unknown that one or more of them would engage in conduct which constituted thatcrime or an attempt to commit that crime, or agreed to aid the other person or persons in theplanning or commission or attempted commission of that crime, and an overt act in pursuance of the conspiracy was committed by one or more of the conspirators; in violation of sections C.R.S.18-4-410(1),(5) and 18-2-201.The facts supporting Counts 1 and 2 are as follows:1. The facts supporting all other counts in this Indictment are incorporated herein byreference.2. From at least September 1, 2009, through May 23, 2012, Charles Wayne Wrenfrow andMichelle Jean Wrenfrow, and other, as yet unidentified persons, while employed by or associatedwith an enterprise, namely: C & M Towing and Recovery, Inc., operated with a common goal.The common goal of the members of the enterprise was to steal motor vehicles from locationswithin the State of Colorado. Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, and other, asyet unidentified persons,
then disassembled or facilitated the disassembly (“chopping”) of thosestolen vehicles. Those stolen vehicles’ parts wer 
e then sold from the C & M Towing andRecovery, Inc., impound lot located at 821 W. 56
th
Avenue, Adams County, State of Colorado,to various third party purchasers.3. At all times relevant to this Indictment, C & M Towing and Recovery, Inc., under thedirection and control of Charles Wayne Wrenfrow and Michelle Jean Wrenfrow, leased theproperty at 821 W. 56
th
Avenue, Adams County, Colorado, from James Langley.4. In March 2005, C & M Towing & Recovery Inc (sic) was incorporated with the Colorado
Secretary of State’s Office pursuant to C.R.S. 7
-90-301, et seq., and 7-102-102. CharlesWrenfrow was listed as the Registered Agent and Michelle Wrenfrow was listed as theincorporator. The Colorado Secretary of State assigned entity identification number20051131859 to C & M Towing & Recovery Inc. From time to time, Michelle Wrenfrow filed
annual reports and other documents with the Secretary of State’s Office on behalf of C & M
Towing & Recovery Inc.5. C & M Towing & Recovery Inc operated under Colorado Public Utilities Commissiontowing permit number T-03661 between and including March 31, 2005, and November 22, 2010,

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