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,

DI~)TRICT COURT, WELD COUNTY, COLORADO
90 1 9th Avenue
Greeley, Colorado 80631
(970) 356-7425
PEOPLE OF THE STATE OF COLORADO, Plaintiff
v.
Rosendo Santa Cruz aka "Kong" aka "Sir Kong" aka
"Malo," Ramon Acevedo aka "Ace" aka "Ray,"
Christopher Cox aka "Crook" aka ··VaniUa," Joseph
Perez aka "Abel," Jeremiah Guajardo aka "Reeper," A
Defendants A Court Use Only
Kenneth R. Buck, District Attorney:
Address: 915 10th Street, P.O. Box 1167 Case No. 11 CR 2
Greeley, Colorado 80632 Division _j_
Phone Number: 970-356-4010
Fax: 970-352-8023
INDICfMENT CHARGES:

COUNT ONE: VIOLATION OF COLORADO ORGANIZED CRIME CONTROL ACT, 18- 17-104(3) C.R.S. (F.l) (COCCA)

COUNT TWO: AGGRAVATED ROBBERY 18-4-301(1)(C), C.R.S. (F3)

COUNT THREE: CRIMINAL ATTEMPT TO COMMIT AGGRAVATED ROBBERY, 18-4-301(1)(C), AND 18-1-101, C.R.S. (F3)

COUNT FOUR: CONSPIRACY TO COMMIT INTIMIDATING A WITNESS OR VICTIM, 18-8-704 AND 18-1-201, C.R.S. (F5)

COUNT FIVE: INTIMIDATING A WITNESS OR VICfIM, 18-8-704 C.R.S. (F4)

COUNT SIX: CONSPIRACY TO COMMIT INTIMIDATING A WITNESS OR VICTIM, 18- 8-704 AND 18-1-101, C.R.S. (F5)

COUNT SEVEN: SECOND DEGREE BURGLARY-DWELLING, 18-4-103(1),(1)(A), C.R.S. (F3) COUNT EIGHT: INTIMIDATING A WITNESS OR VICTIM, 18-8-704, C.R.S. (F4)

The Grand Jury presents an Indictment and the same is ordered filed.

By the Court this 11 dayof,t.{ Cf'(,~ , 2011.

. "

Of the 2011-2012 term of the 19th Judicial District Court, in the year 2011, the grand jurors chosen, selected, and sworn, in and for the County of Weld. in the name and by the authority of the People of the State of Colorado, upon their oaths, present as to Rosendo Santa Cruz aka "Kong" aka "Sir Kong" aka "Malo," Ramon Acevedo aka "Ace" aka "Ray," Christopher Cox aka "Crook" aka "Vanilla," Joseph Perez aka "Abel," Jeremiah Guajardo aka "Reeper".

COUNT ONE (COCCA)

as to Rosendo Santa Cruz aka "Kong" aka "Sir Kong" aka "Malo"

A TRUE BILL NO TRUE BILL

Foreperson or Alternate Foreperson

And further find that in connection with Count One. Rosendo Santa Cruz aka "Kong" aka "Sir Kong" aka "Malo" engaged in the following predicate acts as described in the allegations under Count One of

this in . . ed here by the signature of the Foreperson or Alternate Foreperson:

Act 1

• II I I' ;

• • ,..(t • •

emate Foreperson

Foreperson or Alternate Foreperson

A TRUE BILL

COUNT ONE (COCCA)

as to Ramon Acevedo aka "Ace" aka "Ray" NO TRUE BILL

And further find that in connection with Count One, Ramon Acevedo aka "Ace" aka "Ray" engaged in the following predicate acts as described in the allegations under Count One of this indictment,

indica nature of the Foreperson or Alternate Foreperson:

Act I

. . .... '. , . ~

Act 3

Foreperson or Alternate Foreperson

A TRUE BILL

COUNT ONE (COCCA)

as to Christopher Cox aka "Crook" aka "Vanilla" NO TRUE BILL

And further find that in connection with Count One, Christopher Cox aka "Crook" aka "Vanilla" engaged in the following predicate acts as described in the allegations under Count One of this by the signature of the Foreperson or Alternate Foreperson:

A TRUE BILL

COUNT ONE (COCCA)

as to Joseph Perez aka "Abel" NO TRUE BILL

Foreperson or Alternate Foreperson

And further find that in connection with Count One, Joseph Perez aka "Abel" engaged in the following predicate acts as described in the allegations under Count One of this indictment, indicated here by the FnI· .. ""~r!U\n or Alternate Foreperson:

---~--.~-

A TRUE BILL

COUNT ONE (COCCA)

as to Jeremiah Guajardo aka "Reeper" NO TRUE BILL

~... ..... . '

Itemate Foreperson

Foreperson or Alternate Foreperson

. ." .

ternate Foreperson

Foreperson or Alternate Foreperson

And further find that in connection with Count One, Jeremiah Guajardo aka "Reeper" engaged in the following predicate acts as described in the allegations under Count One of this indictment, indicated

here . the Foreperson or Alternate Foreperson:

COUNT TWO (AGGRAVATED ROBBERy) .s to Josepb Perez aka "Abel"

A TRUE BILL NO TRUE BILL

COUNT TWO (AGGRAVATED ROBBERy) .s to Jeremlab Guajardo aka "Reeper"

A TRUE BILL NO TRUE BILL

Foreperson or Alternate Foreperson

COUNT THREE (CRIMINAL ATTEMPT TO COMMIT AGGRAVATED ROBBERy) as to Josepb Perez aka "Abel"

A TRUE BILL NO TRUE BILL

Foreperson or Alternate Foreperson

COUNT THREE (CRIMINAL ATTEMPT TO COMMIT AGGRAVATED ROBBERy) as to Jeremiah Guajardo aka "Reeper"

A TRUE BILL NO TRUE BILL

emate Foreperson

Foreperson or Alternate Foreperson

COUNT FOUR (CONSPIRACY TO COMMIT INTIMIDATING A WITNESS OR VICTIM) as to Rosendo Santa Cruz aka "Kong" aka "Sir Kong" aka "Malo"

A TRUE BILL NO TRUE BILL

Foreperson or Alternate Foreperson

COUNT FOUR (CONSPIRACY TO COMMIT INTIMIDATING A WITNESS OR VICTIM) as to Ramon Acevedo aka "Ace" aka "Ray"

A TRUE BILL NO TRUE BILL

Foreperson or Alternate Foreperson

Iternate Foreperson

COUNT FOUR (CONSPIRACY TO COMMIT INTIMIDATING A WITNESS OR VICTIM) as to Christopher Cox aka "Crook" aka "Vanilla"

A TRUE BILL NO TRUE BILL

Foreperson or Alternate Foreperson

COUNT FOUR (CONSPIRACY TO COMMIT INTIMIDATING A WITNESS OR VICTIM) as to Joseph Perez aka "Abel"

A TRUE BILL NO TRUE BILL

Alternate Foreperson

Foreperson or Alternate Foreperson

COUNT FIVE (INTIMIDATING A WITNESS OR VICTIM) as to Rosendo Santa Cruz aka "Kong" aka "Sir Kong" aka "Malo"

A TRUE BILL NO TRUE BILL

Foreperson or Alternate Foreperson

COUNT FIVE (INTIMIDATING A WITNESS OR VlCI1M) as to Ramon Acevedo aka "Ace" aka "Ray"

A TRUE BILL NO TRUE BILL

Foreperson or Alternate Foreperson

Foreperson or Alternate Foreperson

COUNT nVE (INTIMIDATING A WITNESS OR VICTIM) as to Christopher Cox aka "Crook" aka "Vanilla"

A TRUE BILL NO TRUE BILL

Alternate Foreperson

Foreperson or Alternate Foreperson

COUNT FIVE (INTIMIDATING A WITNESS OR VICTIM) as to Joseph Perez aka "Abel"

A TRUE BILL NO TRUE BILL

u-

•• •

ternate Foreperson

Foreperson or Alternate Foreperson

COUNT SIX (CONSPIRACY TO COMMIT INTIMIDATING A WITNESS OR VICTIM) as to Christopher Cox aka "Crook" aka "Vanilla"

A TRUE BILL NO TRUE BILL

Foreperson or Alternate Foreperson

COUNT SEVEN (SECOND DEGREE BURGLARY-DWELLING) as to Christopher Cox aka "Crook" aka "Vanilla"

A TRUE BILL NO TRUE BILL

temate Foreperson

COUNT EIGHT (INTIMIDATING A WITNESS OR VICTIM) as to Christopher Cox aka "Crook" aka "VaDiUa"

A TRUE BILL NO TRUE BILL

Foreperson or Alternate Foreperson

KENNETH R. BUCK

DISTRICT ATTORNEY NINETEENTH JUDICIAL DISTRICT

BT-~

Mici18e1iROUl"kC: 28812

Assistant District Attorney

------------------- _._-

PATIERN OF RACKETEERING ACTIVITY

For purposes of Count One (COCCA), the Defendants, as members of the 18th Street Gang, unlawfully and knowingly participated, directly or indirectly, in the enterprise through a pattern of racketeering activity more particularly described as follows:

COYNTQNE

VIOLATION OF COLORADO ORGANIZED CRIME CONTROL ACT, 18-17-104(3) C.R.s. (Fl) (COCCA)

Between and including September 12, 1994 and March 17, 2011, in the County of Weld, State of Colorado, Rosendo Santa Cruz aka "Kong" aka "Sir Kong" aka "Maio," Ramon Acevedo aka "Ace" aka "Ray," Christopher Cox aka "Crook" aka "Vanilla," Joseph perez aka "Abel," Jeremiah Guajardo aka "Reeper," and others known and unknown to the Grand Jury while associated with an enterprise, namely: a group of individuals associated in fact, although not a legal entity, unlawfully feloniously and knowingly 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.

THE ENTERPRISE

Between and including September 12, 1994, and March 17, 2011, the enterprise alleged in Count One was known as the 18th Street Gang based in Greeley, Colorado aka "Streeters" aka "Los Pokos Klique (LPK)" referred to hereafter as the 18th Street Gang.

The members and associates of the 18th Street Gang included but were not limited to, the following:

Rosendo Santa Cruz aka "Kong" aka "Sir Kong" aka "Malo," Ramon Acevedo aka "Ace" aka "Ray," Christopher Cox aka "Crook" aka "Vanilla," Carlos Martinez aka "Loco," Enrique Rivas aka "E-Loc," Jose Martinez aka "Moose," Pablo Pluma aka "Guero" aka "Wedo," Jose Pluma aka "Diablo" aka "Psycho" aka "Lucifer," John Gonzales aka "Sun Bun" aka "Sun," Simon Martinez aka "Dopey," Jadrian perez aka "Kain," Joseph Perez aka "Abel," David Ramirez aka "Chuco," Sergio Martinez aka "Snoop," John Sandoval aka "Switches," Juan Gonzales aka "Dreamer," Alex Henderson aka "Gadget," Steven Henderson aka "Wino" aka "Biscuit," Rogelio Mares aka "Pachaco," Felix Cruz aka "Chivo," Eduardo Madrid aka "Majic" aka "Lalo," Aurelio Madrid aka "Bashful," Jeremiah Guajardo aka "Reeper," Joshua Guajardo aka "ToTO," Marcel Preece aka "Wicked" aka "Moose," Antonio Cardenas aka "Little Boxer," Efren Sanchez aka "Shine," Richard Rebeterano aka "Sicko" aka "Quieto," Alfredo Gonzales aka "Joker," Ryan Salinas aka "Lucky" aka "Scrappy," Derek Gallegos aka "Oso," Orlando Vasquez aka "Menace," Matias Benavides aka "Silencio," Adam Ponce aka "Mr. Ocho," Eric Hernandez aka "Monster," Paul Lopez aka "P-Loc," Marco Garcia aka "Boxer," Chris Valverde aka "Pequeno" aka "Payaso," Jessica Hernandez aka "Shorty," Diedre Batten aka Diedre Madrid, Chauvanna Gesick aka "Creamy," Sarah Reinick aka "Saraquil," and other persons known and unknown to the Grand Jury, who are associated from time to time in racketeering activity that was related to the conduct of the enterprise.

The purpose of the enterprise alleged in Count One is fmancial gain through illegal activities; to establish and maintain respect, power, control and influence over the entire gang sub-culture in prison and in the community through criminal activity, intimidation, fear and violence.

, ACTl

On or about September 12, 1994, Defendants Rosendo Santa Cruz aka "Kong" aka "Sir Kong" aka "Malo," and Ramon Acevedo aka "Ace" aka "Ray," acting with others including Juan Mendez aka "Chumano" and John Gonzales aka "Sun Bun" aka "Sun," unlawfully, feloniously, knowingly, or recklessly discharged a firearm into a dwelling in Greeley, Colorado; in violation of section 18-12- 107.5, C.R.S.

ACT 1

On or about April 3, 1996, Defendant Rosendo Santa Cruz aka "Kong" aka "Sir Kong" aka "Malo" acting with others including John Gonzales aka "Sun Bun," unlawfully, feloniously, and knowingly took a thing of value, specifically a purse, from the person of Lucy Archuleta in Greeley, Colorado; in violation of section 18-4-401 (1 ),(5), C.R.S.

ACT 4

On or about December 2, 1997, Defendants Rosendo Santa Cruz aka "Kong" aka "Sir Kong" aka "Maio," Ramon Acevedo aka "Ace" aka "Ray," acting with others including John Gonzales aka "Sun Bun," unlawfully and feloniously attempted to commit the crime of Second Degree Assault against Hector Gonzales, and engaged in conduct constituting a substantial step toward the commission of said crime by assaulting Hector Gonzales with their hands and feet while he was dying from a gunshot wound in Greeley, Colorado, as defined by C.R.S. 18-3-203, in violation of sections 18-2-101(1),(4) C.R.S.

ACT 3

On or about August 21, 1997, Defendants Rosendo Santa Cruz aka "Kong" aka "Sir Kong" aka "Malo," Ramon Acevedo aka "Ace" aka "Ray," acting with others including Pablo Plurna aka "Wedo," and Francisco Corona-Altamirano aka "Chava," unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, specifically firearms of George Roosevelt in Greeley, Colorado, with the value of fifteen thousand dollars or more, without authorization and by deception, and intended to deprive him pennanently of their use or benefit; in violation of section 18- 4-401(1),(2)(d), C.R.S.

ACTS

On or about June 27, 2003, Defendant Christopher Cox aka "Crook" aka "Vanilla," unlawfully and

feloniously attempted to of a Dwelling at the home of

Michael Hubbard located and engaged in conduct

constituting a substantia1 step toward the commission as defined by C.R.S, 18-4-

203(1),(2)(a); in violation of 18-2-101(1),(4) C.R.S.

ACT6

Between and including on or about March 1,2008 and June 30, 2008 Defendant Jeremiah Guaiardo aka "Reeper," unlawfully, feloniously. and knowingly exercised control over the laptop computer and the 1985 Monte Carlo owned by Christina Maestas with the value of one thousand dollars or more, but less than twenty thousand dollars, without her authorization, and intended to deprive her permanently of its use or benefit in Greeley, Colorado; in violation of section section 18-4-401(1)(a),(2)(c), C.R.S.

ACT 7

On or about November 20, 2008 Defendant Jeremiah Guaiardo aka "D.~ __ ~_ and knowingly broke into the dwelling of Joanna Garcia located Colorado with the intent to commit therein the crime of theft; in 203(1),(2)(a), C.R.S.

ACT 8

On or about September 8, 2010, Defendants Joseph Perez aka "Abel" and Jeremiah Guajardo aka "Reeper," acting with others including Joshua Guajardo aka "Toro," Matias Benavides aka "Silencio" and David Ramirez-Nunez aka "Chuco," unlawfully, feloniously, and knowingly took a thing of value, specifically a purse from the person ofElia Kupperberg in Greeley, Colorado, by force, threats, or intimidation, and the Defendants during the robbery or immediate flight therefrom had present a confederate, aiding and abetting the robbery, anned with a deadly weapon, specifically a firearm, with the intent on the part of the Defendants Joseph Perez aka "Abel" and Jeremiah Guajardo aka "Reeper," or their confederates, by the use of force, threats, or intimidation, to put the person robbed, Ella Kupperberg, or any other person, in reasonable fear of death or bodily injury; in violation of section IS-4-302( 1)( c), C.R.S.

ACT 9

On or about September 8, 2010, by engaging in conduct constituting a substantial step toward the commission of aggravated robbery, Defendants Joseph Perez aka "Abel" and Jeremiah Guajardo aka "Reeper," acting with others including Joshua Guajardo aka "Toro," Matias Benavides aka "Silencio" and David Ramirez-Nunez aka "Chuco," unlawfully, feloniously, and knowingly attempted to take a thing of value from the person or presence of Ethan Snider, Ryan Trujillo, Jordan Fabela, and Casey Laurent in Greeley, Colorado, by force, threats, or intimidation, and the Defendants during the attempted robbery or during the immediate flight therefrom had present confederates, aiding and abetting the robbery, armed with a deadly weapon, specifically a firearm, with the intent on the part of the Defendants Joseph Perez aka "Abel" and Jeremiah Guajardo aka "Reeper," or their confederates, by the use of force, threats, or intimidation, to put the person to be robbed or any other person in reasonable fear of death or bodily injury; in violation of sections lS-4-302(I)(c) and IS-2-101, C.R.S.

ACTIO

Between and including on or about October 5, 2010 and March 17. 2011, Defendants Rosendo Santa Cruz aka "Kong" aka "Sir Kong" aka "Malo," Ramon Acevedo aka "Ace" aka "Ray," Christopher Cox aka "Crook" aka "Vanilla" and Joseph Perez aka "Abel," with the intent to promote or facilitate the commission of the crime oflntimidating a Witness or Victim, unlawfully and feloniously agreed with each other and/or others known and unknown to the Grand Jury that one or more of them would engage in conduct which constituted that crime or an attempt to commit the 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 ofthe conspiracy was committed by one or more of the conspirators in Greeley, Colorado; in violation of sections 18-8-704 and 18-2-201, C.R.S.

ACT 11

Between and including on or about October 5, 2010 and March 17, 2011, Defendants Rosendo Santa Cruz aka "Kong" aka "Sir Kong" aka "Malo," Ramon Acevedo aka "Ace" aka "Ray:' Christopher Cox aka "Crook" aka "Vanilla" and Joseph Perez aka "Abel," by use ofa threat, act of harassment, or act of harm or injury to a person or property directed to or committed upon a witness or victim of a crime, the Defendants unlawfully. feloniously, and intentionally attempted to or did influence the following witnesses or victims, Alfredo Gonzales, Bonnie Martinez aka Bonnie Gonzales and Chantee Gonzales to testify falsely or unlawfully withhold any testimony in Greeley, Colorado; in violation of section 18-8-704, C.R.S.

ACfll

On or about October 12.20]0. Defendant Christopher Cox aka "Crook" aka "Vanilla," with the intent to promote or facilitate the commission of the crime oflntimidating a Witness, unlawfully and feloniously agreed with Jessica Hernandez aka "Shorty," 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 sections 18-8-704 and 18-2-201, C.R.S.

ACTl4

Between and including on or about October 12,2010 and October 13,2010, Defendant Christopher Cox aka "Crook" aka "Vanilla," by use of a threat, act of harassment, or act of hann or injury to a person or property directed to or committed upon a witness or victim of a crime, unlawfully, feloniously, and intentionally attempted to or did influence the witness or victim, Alfredo Gonzales and Bonnie Martinez aka Bonnie Gonzales to testify falsely or unlawfully withhold any testimony in Greeley, Colorado; in violation of section 18-8-704, C.R.S.

COUNITHREE

CRIMINAL ATTEMPT TO COMMIT AGGRAVATED ROBBERY, 18-4-302(1)(C), AND

18-2-101, C,R.S. (F3)

On or about September 8, 2010, by engaging in conduct constituting a substantial step toward the commission of aggravated robbery, Defendants Joseph Perez aka "Abel" and Jeremiah Guajardo aka "Reeper," unlawfully, feloniously, and knowingly attempted to take a thing of value, namely: personal property from the person or presence of Ethan Snider, Ryan Trujillo, Jordan Fabela. and Casey Laurent by force, threats. or intimidation, and the defendants during the attempted robbery or during the immediate flight there from had present a confederate, aiding or abetting the perpetration of the robbery, armed with a deadly weapon, namely: firearm, with the intent on the part of the defendants or the confederates, by the use of force, threats, or intimidation, to put the person to be robbed or any other person in reasonable fear of death or bodily injury; in violation of sections 18-4-302(l){c) and 18-2-101, C.R.S.

COUNITWO

AGGRAVATED ROBBERY 18-4-302(I)(C), C,R.S, (F3)

On or about September 8,20 I 0, Defendants Joseph Perez aka "Abel" and Jeremiah Guajardo aka "Reeper," unlawfully, feloniously, and knowingly took a thing of value, namely: purse from the person or presence of Ella Kupperberg by force, threats, or intimidation. and the defendants during the robbery or immediate flight there from had present a confederate, aiding or abetting the perpetration of the robbery, armed with a deadly weapon, namely: firearm, with the intent on the part of the defendants or the confederates, by the use of force, threats. or intimidation, to put the person robbed or any other person in reasonable fear of death or bodily injury; in violation of sc«ion 18-4-302(1)( c), C.R.S.

COUNT FOUR

CONSPIRACY TO COMMIT INTIMIDATING A WITNESS OR VICTIM, 18-8-704 AND

18-2-201, C.R.s. (F5)

Between and including on or about October 6, 2010 and October 10, 20 I O. Rosendo Santa Cruz aka "Kong" aka "Sir Kong" aka "Maio," Ramon Acevedo aka "Ace" aka "Ray," Christopher Cox aka "Crook" aka "Vanilla" and Joseph Perez aka "Abel," with the intent to promote or facilitate the commission of the crime of Intimidating a Witness. unlawfully and feloniously agreed with each other and others known and unknown to the Grand Jury that one or more of them would engage in conduct which constituted that crime or an attempt to commit that crime. or agreed to aid the other person or persons in the planning or commission or attempted commission of that crime, and an overt act in pursuance of the conspiracy was committed by one or more of the conspirators; in violation of sections 18-8-704 and 18-2-20 I, C.R.S.

· ,.

COUNT FIVE

INTIMIDATING A WITNESS OR VICTIM, 18-8·704 C.R-S. (F4)

Between and including on or about October 6, 2010 and October 10,2010, Rosendo Santa Cruz aka ."Kong" aka "Sir Kong" aka "Malotttantbn Acevedo aka "Ace" aka "Ray," Christopher Cox aka .ltrook" aka "Vanilla" and Joseph Perez aka "Abel," by use ofa threat, act of harassment, or act of harm or injury to a person or property directed to or committed upon a witness or victim of a crime, namely:

Alfredo Gonzales, Bonnie Martinez aka Bonnie Gonzales and Chantee Gonzales, unlawfully, fel?Olously, and intentionally attempted to or did influence the witnesses or victims, Alfredo Gonzales, Bonnie Martinez aka Bonnie Gonzales and Chantee Gonzales to testify falsely or unlawfully withhold any testimony; in violation of section 18-8-704, C.R.S.

COUNT SIX

CONSPIRACY TO COMMIT INTIMIDATING A WITNESS OR VICTIM, 18-8-704 AND

18-1-101, C.R.S. (FS)

On or about October 12, 2010, Christopher Cox aka "Crook" aka "Vanilla," with the intent to promote or facilitate the commission of the crime ofIntimidating a Witness or Victim, unlawfully and feloniously agreed with Jessica Hernandez aka "Shorty," 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 sections 18-8-704 and 18-2-201, C.R.S.

COUNT SEVEN

SECOND DEGREE BURGLARY-DWELLING, 18-4-103(1),(1)(A), C.R.S. (F3)

On or about October 12, 2010, Christopher Cox aka "Crook" aka "Vanilla," unlawfully, feloniously, and knowingly broke an entrance into, entered, or remained unlawf!!!!t~!..~.!~!.~~~tlawful entry in the dwelling of Bonnie Martinez aka Bonnie Gonzales, located ~with the intent to commit therein the crime oflntimidating a Witness or Victim; in violation of section 18-4-203(1),(2)(a), C.R.S.

COUNT EIGHT

INTIMIDATING A WITNESS OR VICTIM, 18-8-704, C.R.S. (F4)

Between and including on or about October 12,2010 and October 13,2010, Christopher Cox aka "Crook" aka "Vanilla," by use of a threat, act of harassment, or act of harm or injury to a person or property directed to or committed upon a witness or victim of a crime, namely: Alfredo Gonzales, Bonnie Martinez aka Bonnie Gonzales and Chantee Gonzales, unlawfully, feloniously, and intentionally attempted to or did influence the witness or victim, Alfredo Gonzales. Bonnie Martinez aka Bonnie Gonzales and Chantee Gonzales to testify falsely or unlawfully withhold any testimony; in violation of section 18-8-704, C.R.S.