You are on page 1of 37

District Court, City and County of Denver, Colorado

City and County Building, Room 256


1437 Bannock Street
Denver, CO 80202

Plaintiff: THE PEOPLE OF THE STATE OF


COLORADO

Defendants:
AZIMDZHON MAZHIDOV
FIRUZI SHARIFI
BOBOKALON SHARIPOV ? COURT USE ONLY ?
FIRDAVSI URUNOV Case Number:
SHODMON BILOLOV
PARVIZ CHORSANBIEV Grand Jury No. 10CR2 A
KHISRAV CHUTOV
AZIM GOLUBOV Div.: Criminal Ctrm: 9 / ____
FARIDUM JABBOROV
BAKHTIYOR KADIROV
NODIR KHODZHAEV
MAKHMADRIZO KHOLOV
KARIMDZHON MANSUROV
BAKHTIYORKHUJA MIRZOKHOJAEV
DMITRIY ORLOVSKIY
OBID VAPAEV
INDICTMENT

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


(F2) <37284> 1 (1 count)

CONSPIRACY TO COMMIT THEFT, 18-4-401(1),(2)(c);18-2-201 C.R.S. (F5) <0801UC> 2


(1 count)

THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U> 3 – 10, 12, 14, 16, 17, 19, 21, 23, 24, 25, 27,
28, 30, 31, 37 - 41 (26 counts)

FORGERY, 18-5-102(1)(c) C.R.S. (F5) <1001C> 13, 33 (2 counts)

POSSESSION OF FORGED INSTRUMENT, 18-5-105 C.R.S. (F6) <10040> 35, 36 (2 counts)

CRIMINAL IMPERSONATION, 18-5-113(1)(e) C.R.S. (F6) <1011A> 15, 18, 20, 22, 26, 29,
34 (7 counts)

CRIMINAL ATTEMPT TO COMMIT THEFT, 18-4-401(1),(2)(c); 18-2-101, C.R.S (F5)


<0801UA> 32 (1 count)

THEFT, 18-4-401(1),(2)(b.5) C.R.S. (M1) <0801T> 11 (1 count)


COUNT ONE
VIOLATION OF COLORADO ORGANIZED CRIME CONTROL ACT, 18-17-104(3) C.R.S.
(F2) <37284>

Between and including August 1, 2009, and November 10, 2010, at and triable in the City and
County of Denver, State of Colorado, AZIMDZHON MAZHIDOV, FIRUZI SHARIFI,
BOBOKALON SHARIPOV, and FIRDAVSI URUNOV, 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 sections 18-17-104(3) and
18-17-105, C.R.S.

The Enterprise

The enterprise alleged in this count was a group of individuals, associated in fact, although not a
legal entity. The enterprise included, but was not limited to, the following: AZIMDZHON
MAZHIDOV; FIRUZI SHARIFI; BOBOKALON SHARIPOV; FIRDAVSI URUNOV;
SHODMON BILOLOV; PARVIZ CHORSANBIEV; KHISRAV CHUTOV; AZIM
GOLUBOV; FARIDUM JABBOROV; BAKHTIYOR KADIROV; NODIR
KHODZHAEV; MAKHMADRIZO KHOLOV; KARIMDZHON MANSUROV;
BAKHTIYORKHUJA MIRZOKHOJAEV; DMITRIY ORLOVSKIY; OBID VAPAEV;
MUKHAMMAD ABDUSALMOV; MUKHAMADI RAUPOV, and other persons known or
unknown, who were associated from time to time 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 the
enterprise, including:

As to AZIMDZHON MAZHIDOV, the acts described in counts 2, 6, 12, 13, 27 and 37,
including any lesser included offenses of these counts.

As to FIRUZI SHARIFI, the acts described in counts 2, 8, 14, 15, 17, 21, 22, 24, 25, 26, 31 and
40, including any lesser included offenses of these counts.

As to BOBOKALON SHARIPOV, the acts described in counts 2, 17, 18, 19, 20, 28 and 29,
including any lesser included offenses of these counts.

As to FIRDAVSI URUNOV, the acts described in counts 2, 7, and 9, including any lesser
included offenses of these counts, and Predicate Act 42 of this Indictment.

2
PREDICATE ACT FORTY-TWO
CRIMINAL ATTEMPT TO COMMIT THEFT, 18-4-401(1),(2)(c); 18-2-101, C.R.S (F5)
<0801UA>

Between and including March 12, 2010, and March 27, 2010, at and triable in the City and
County of Denver, State of Colorado, by engaging in conduct constituting a substantial step
toward the commission of theft, FIRDAVSI URUNOV, unlawfully, feloniously, and knowingly
attempted to obtain or exercise control over a thing of value, namely: MONEY, of WELLS
FARGO BANK and URUNOV DUSHANBE, with the value of one thousand dollars or more
but less than twenty thousand dollars, without authorization, or by threat or deception, and
intended to deprive WELLS FARGO BANK and URUNOV DUSHANBE permanently of its
use or benefit; in violation of sections 18-4-401(1)(2)(c) and 18-2-101, C.R.S.

COUNT TWO
CONSPIRACY TO COMMIT THEFT, 18-4-401(1),(2)(c) C.R.S.; 18-2-201 C.R.S. (F5)
<0801UC>

Between and including August 1, 2009, and November 10, 2010, at and triable in the City and
County of Denver, State of Colorado, AZIMDZHON MAZHIDOV; FIRUZI SHARIFI;
BOBOKALON SHARIPOV; FIRDAVSI URUNOV; SHODMON BILOLOV; PARVIZ
CHORSANBIEV; KHISRAV CHUTOV; AZIM GOLUBOV; FARIDUM JABBOROV;
BAKHTIYOR KADIROV; NODIR KHODZHAEV; MAKHMADRIZO KHOLOV;
KARIMDZHON MANSUROV; BAKHTIYORKHUJA MIRZOKHOJAEV; DMITRIY
ORLOVSKIY; and OBID VAPAEV, with the intent to promote or facilitate the commission of
the crime of theft, unlawfully and feloniously agreed with each other and with MUKHAMMAD
ABDUSALMOV, MUKHAMADI RAUPOV, and a person or persons to the Grand Jury
unknown 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 18-4-
401(1),(2)(c) and 18-2-201, C.R.S.

The facts supporting Counts 1 and 2 and Predicate Act 42 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. From at least August 1, 2009, through November 10, 2010, Azimdzhon Mazhidov, Firuzi
Sharifi, Bobokalon Sharipov, Firdavsi Urunov, Shodmon Bilolov, Parviz Chorsanbiev, Khisrav
Chutov, Azim Golubov, Faridum Jabborov, Bakhtiyor Kadirov, Nodir Khodzhaev, Makhmadrizo
Kholov, Karimdzhon Mansurov, Bakhtiyorkhuja Mirzokhojaev, Dmitriy Orlovskiy, and Obid
Vapaev, and others, including but not limited to: Mukhammad Abdusalmov and Mukhamadi
Raupov, were a group of individuals associated in fact, though not a legal entity, with a common
goal. The common goal of the members of the enterprise was to steal money from financial
institutions.

3
3. Azimdzhon Mazhidov, Firuzi Sharifi, Bobokalon Sharipov, Firdavsi Urunov, Shodmon
Bilolov, Parviz Chorsanbiev, Khisrav Chutov, Azim Golubov, Faridum Jabborov, Bakhtiyor
Kadirov, Nodir Khodzhaev, Makhmadrizo Kholov, Karimdzhon Mansurov, Bakhtiyorkhuja
Mirzokhojaev, Dmitriy Orlovskiy, Obid Vapaev, Mukhammad Abdusalmov, Mukhamadi
Raupov, and other members of the enterprise, opened accounts at various financial institutions
with the knowledge and intent that the accounts would be used to steal money from the financial
institutions through a check kiting scheme. Members of the enterprise would use their own
names and/or false names to open an account. Members of the enterprise would deposit a
substantial amount of cash, then knowingly deposit or cash insufficient funds or closed account
checks with the intent to steal money from the financial institution. Members of the enterprise
would withdraw cash from their account before the insufficient funds or closed account checks
were returned, unpaid, to the financial institution.

4. To accomplish the goals of the enterprise, members shared money, checks and financial
transaction devices from the accounts they opened, as well as financial information, money,
property, automobiles, transportation and living quarters.

5. At all times relevant to this Indictment, Azimdzhon Mazhidov, Firuzi Sharifi, Bobokalon
Sharipov, and Firdavsi Urunov were the primary members of the enterprise who, knowingly and
with the intent to defraud, recruited, transported, and instructed other members of the enterprise
in the scheme.

6. Azimdzhon Mazhidov, Firuzi Sharifi, Bobokalon Sharipov, and Firdavsi Urunov,


working independently or in concert with each other and/or with persons unknown to the Grand
Jury, recruited new members into the enterprise and instructed those members how to open
accounts, and how to deposit or cash bad checks and withdraw cash before the bad checks were
returned, unpaid, to the financial institution.

7. Accounts used for fraudulent transactions were opened by members of the enterprise at
various locations in the State of Colorado, including locations within the City and County of
Denver. Accounts were opened at the First Bank of Cherry Creek, 100 Saint Paul Street, City
and County of Denver, State of Colorado under the following names: Somon Corporation;
Murado Dental; Nushervon Kalandarov; Timuri Khuseyn; Payravi Fraydin; and Ravshan
Muradov.

8. Accounts used for fraudulent transactions listed addresses in the City and County of
Denver, State of Colorado, including but not limited to: 840 S. Oneida #A312 (Somon
Corporation, Ravshon Muradov and Murado Dental); 7135 Leetsdale Drive #H-15 (Payravi
Fraydin); and 7005 Leetsdale Drive #A26 (Obid Vapaev, Firdavsi Urunov, and Bakhtiyor
Kadirov).

9. At all times relevant to this Indictment, Azimdzhon Mazhidov, Firuzi Sharifi, Bobokalon
Sharipov, and Firdavsi Urunov, directly or indirectly, expected to receive and did receive
compensation in the form of money, transportation, food and lodging from other members of the
enterprise in payment for directing the scheme.

10. As a result of the activities of the enterprise members, Wells Fargo Bank, with Colorado
headquarters located in the City and County of Denver, State of Colorado, suffered an aggregate

4
monetary loss in excess of $130,000.00.

11. As a result of the activities of the enterprise members, JP Morgan Chase Bank suffered an
aggregate monetary loss in excess of $56,000.00 through branches located in the State of
Colorado, including branches within the City and County of Denver.

12. As a result of the activities of the enterprise members, US Bank, with Colorado
headquarters located in the City and County of Denver, State of Colorado, suffered an aggregate
monetary loss in excess of $15,000.00.

13. As a result of the activities of the enterprise members, Key Bank, with Colorado
headquarters located in the City and County of Denver, State of Colorado, suffered an aggregate
monetary loss in excess of $900.00.

14. As to Predicate Act 42: Between and including March 12, 2010, and March 27, 2010,
Firdavsi Urunov, using the name Urunov Dushanbe, cashed and/or deposited fraudulent checks
on the account names of Nushervon Kalandarov and Farruh Odilov at Wells Fargo Bank.
Firdavsi Urunov obtained more than $9,000.00 in cash from Wells Fargo Bank. Firdavsi Urunov
was charged for that offense and entered a guilty plea to one count of Criminal Attempt To
Commit Theft, 18-4-401(1),(2)(c); 18-2-101, C.R.S, a class five felony, in Denver County
District Court case number 2010CR4151.

5
COUNT THREE
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including August 15, 2009 and September 4, 2009, at and triable in the City and
County of Denver, State of Colorado, OBID VAPAEV unlawfully, feloniously, and knowingly
obtained or exercised control over a thing of value, namely: MONEY of WELLS FARGO
BANK, with the value of one thousand dollars or more but less than twenty thousand dollars,
without authorization, or by threat or deception, and intended to deprive WELLS FARGO
BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the
thing of value in such manner as to permanently deprive WELLS FARGO BANK, of its use or
benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 3 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about August 15, 2009, in association with the enterprise, Obid Vapaev opened
Wells Fargo Bank checking account #7885981220 at the Buckingham Square Convenience
Center in Aurora, Arapahoe County, Colorado. Obid Vapaev used a Russian passport, #0663114
and an alien registration card, #96328369, as identification documents when he opened the
account. Obid Vapaev listed his address as 11275 E. Alameda Avenue, #4, Aurora, Colorado,
80012-1007.

3. Between August 15, 2009 and September 4, 2009, Obid Vapaev, in association with the
enterprise, cashed Murado Dental checks through his Wells Fargo Bank account, withdrew cash,
and made purchases with the account’s check card. Many of the transactions occurred within the
City and County of Denver, State of Colorado. Among those transactions, Obid Vapaev cashed
Murado Dental check #1128 for $1,010.00 at the Wells Fargo Bank branch located at 1001 S.
Monaco Parkway on August 26, 2009.

4. The Murado Dental checks were returned, unpaid, to Wells Fargo Bank.

5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters
located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of
approximately $3,700.00.

6
COUNT FOUR
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including August 27, 2009 and October 15, 2009, at and triable in the City and
County of Denver, State of Colorado, BAKHTIYOR KADIROV and OBID VAPAEV,
unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value,
namely: MONEY of US BANK, with the value of one thousand dollars or more but less than
twenty thousand dollars, without authorization, or by threat or deception, and intended to deprive
US BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the
thing of value in such manner as to permanently deprive US BANK, of its use or benefit; in
violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 4 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about August 27, 2009, in association with the enterprise, Obid Vapaev opened US
Bank account #103679258162. Obid Vapaev used a Russian passport, #0663114 as an
identification document when he opened the account. Obid Vapaev listed his address as 11275 E.
Alameda Avenue, #4, Aurora, Colorado, 80012-1007.

3. On or about September 10, 2009, in association with the enterprise, Bakhtiyor Kadirov
opened Wells Fargo Bank checking account #9942909962 at the Monaco branch, located at 1001
S. Monaco Parkway, City and County of Denver, Colorado. Bakhtiyor Kadirov used a Colorado
Driver’s License, #09-059-0715, and a Tajik passport, #T223309, as identification documents
when he opened the account. Bakhtiyor Kadirov listed 7005 Leetsdale Drive #A26, Denver,
Colorado 80224, as his home address.

4. Bakhtiyor Kadirov, in association with the enterprise, gave checks from that account to
other enterprise members to use for fraudulent transactions.

5. Between August 27, 2009 and October 15, 2009, Obid Vapaev, in association with the
enterprise, transacted Bakhtiyor Kadirov checks through his US Bank account, withdrew cash,
and made purchases with the account’s check card. Many of the transactions occurred within the
City and County of Denver, State of Colorado. Among those transactions, Obid Vapaev
deposited Bakhtiyor Kadirov’s Wells Fargo Bank check #1026 for $1,700.00 at the US Bank
branch located at 444 17th Street on October 1, 2009.

4. The Bakhtiyor Kadirov checks were returned, unpaid, to US Bank.

7. As a result of the fraudulent activity, US Bank, with Colorado headquarters located at


th
950 17 Street, City and County of Denver, State of Colorado, suffered a loss of approximately
$6,400.00.

7
COUNT FIVE
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including August 27, 2009 and September 28, 2009, at and triable in the City and
County of Denver, State of Colorado, DMITRIY ORLOVSKIY, and OBID VAPAEV,
unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value,
namely: MONEY of JP MORGAN CHASE BANK, with the value of one thousand dollars or
more but less than twenty thousand dollars, without authorization, or by threat or deception, and
intended to deprive JP MORGAN CHASE BANK, permanently of its use or benefit, and
knowingly used, concealed, or abandoned the thing of value in such manner as to permanently
deprive JP MORGAN CHASE BANK, of its use or benefit; in violation of section 18-4-
401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 5 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about August 27, 2009, in association with the enterprise, Obid Vapaev opened JP
Morgan Chase Bank account #638743466. Obid Vapaev used a Russian passport, #0663114 as
an identification document when he opened the account. Obid Vapaev listed his address as
11275 E. Alameda Avenue, #4, Aurora, Colorado, 80012-1007.

3. Between August 27, 2009 and September 28, 2009, Obid Vapaev, in association with
Dmitriy Orlovskiy and the enterprise, transacted Murado Dental and Ravshon Muradov checks
through his JP Morgan Chase Bank account, withdrew cash, and made purchases with the
account’s check card. Many of the transactions occurred within the City and County of Denver,
State of Colorado. Among those transactions, Obid Vapaev deposited Murado Dental check
#1144 for $1,950.00 at the branch located at 2696 S. Colorado Blvd. on September 4, 2009.

4. The Murado Dental and Ravshon Muradov checks were returned, unpaid, to JP Morgan
Chase Bank.

5. As a result of the fraudulent activity, JP Morgan Chase Bank suffered a loss of


approximately $4,700.00.

8
COUNT SIX
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including September 10, 2009 and October 8, 2009, at and triable in the City and
County of Denver, State of Colorado, AZIMDZHON MAZHIDOV, BAKHTIYOR
KADIROV and OBID VAPAEV, unlawfully, feloniously, and knowingly obtained or
exercised control over a thing of value, namely: MONEY of WELLS FARGO BANK, with the
value of one thousand dollars or more but less than twenty thousand dollars, without
authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK,
permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of
value in such manner as to permanently deprive WELLS FARGO BANK, of its use or benefit;
in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 6 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about September 10, 2009, in association with the enterprise, Bakhtiyor Kadirov
opened Wells Fargo Bank checking account #9942909962 at the Monaco branch, located at 1001
S. Monaco Parkway, City and County of Denver, Colorado. Bakhtiyor Kadirov used a Colorado
Driver’s License, #09-059-0715, and a Tajik passport, #T223309, as identification documents
when he opened the account. Bakhtiyor Kadirov listed 7005 Leetsdale Drive #A26, Denver,
Colorado 80224, as his home address.

3. On or about September 2, 2009, in association with the enterprise, Obid Vapaev opened
TCF Bank checking account #9877283603. Obid Vapaev used a Russian passport, #0663114 as
an identification document when he opened the account. Obid Vapaev listed his address as 7005
Leetsdale Drive #A26, Denver, Colorado 80224.

4. Between September 10, 2009 and October 8, 2009, Bakhtiyor Kadirov, in association
with Azimdzhon Mazhidov and Obid Vapaev, transacted Obid Vapaev, Murado Dental and
Ravshan Muradov checks through his Wells Fargo Bank account, withdrew cash, and made
purchases with the account’s check card. Many of the transactions occurred within the City and
County of Denver, State of Colorado. Among those transactions, Bakhtiyor Kadirov cashed
Murado Dental check #1129 for $1,100.00 at the branch located at 7150 Leetsdale Drive on
September 18, 2009.

5. All of the checks were returned, unpaid, to Wells Fargo Bank.

6. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters
located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of
approximately $9,100.00.

9
COUNT SEVEN
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including October 8, 2009 and December 8, 2009, at and triable in the City and
County of Denver, State of Colorado, FIRDAVSI URUNOV, BAKHTIYOR KADIROV, and
BAKHTIYORKHUJA MIRZOKHOJAEV, unlawfully, feloniously, and knowingly obtained
or exercised control over a thing of value, namely: MONEY of US BANK, with the value of one
thousand dollars or more but less than twenty thousand dollars, without authorization, or by
threat or deception, and intended to deprive US BANK, permanently of its use or benefit, and
knowingly used, concealed, or abandoned the thing of value in such manner as to permanently
deprive US BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 7 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about October 8, 2009, Bakhtiyorkhuja Mirzokhojaev, in association with the


enterprise and under the direction of Firdavsi Urunov, opened US Bank checking account
#103679464364 at the Thornton Parkway branch, 771 Thornton Parkway, Adams County,
Colorado. Bakhtiyorkhuja Mirzokhojaev used a Tajik passport, #T490783, as an identification
document when he opened the account. Bakhtiyorkhuja Mirzokhojaev listed 2880 S. Federal
Blvd. #305, Denver, Colorado 80236, as his home address.

3. Bakhtiyorkhuja Mirzokhojaev, in association with the enterprise, also opened Wells


Fargo Bank checking account #9372998105. Bakhtiyorkhuja Mirzokhojaev listed 2880 S.
Federal Blvd. #305, Denver, Colorado 80236, as his home address.

4. Bakhtiyor Kadirov, in association with the enterprise, opened Key Bank checking
account #760102039855, and gave checks from that account to other enterprise members to use
for fraudulent transactions. Bakhtiyor Kadirov listed 7005 Leetsdale Drive #A26, Denver,
Colorado, 80224 as his home address for that account.

5. Firdavsi Uronov, in association with the enterprise, opened Wachovia (later subsumed by
Wells Fargo Bank) checking account, #1010247887907, and gave checks from that account to
other enterprise members to use for fraudulent transactions. Firdavsi Uronov listed 7005
Leetsdale Drive #A26, Denver, Colorado 80224 as his home address for that account.

6. Between October 8, 2009 and December 8, 2009, Bakhtiyorkhuja Mirzokhojaev, in


association with the enterprise, transacted checks drawn on his own Wells Fargo Bank account,
and checks from Bakhtiyor Kadirov and Firdavsi Urunov, through his US Bank account,
withdrew cash, and made purchases with the account’s check card. Many of the transactions
occurred within the City and County of Denver, State of Colorado. Among those transactions,
Bakhtiyorkhuja Mirzokhojaev deposited Firdavsi Urunov check #1092 for $3,000.00 at the ATM
located at 999 S. Monaco Parkway on November 12, 2009.

7. All of the checks were returned, unpaid, to US Bank.

10
8. As a result of the fraudulent activity, US Bank, with Colorado headquarters located at
th
950 17 Street, City and County of Denver, State of Colorado, suffered a loss of approximately
$8,600.00.

11
COUNT EIGHT
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including September 22, 2009 and December 14, 2009, at and triable in the City
and County of Denver, State of Colorado, FIRUZI SHARIFI, unlawfully, feloniously, and
knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS
FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand
dollars, without authorization, or by threat or deception, and intended to deprive WELLS
FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or
abandoned the thing of value in such manner as to permanently deprive WELLS FARGO
BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 8 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about September 22, 2009, in association with the enterprise, Firuzi Sharifi opened
Wachovia Bank checking account #1010231864800. Firuzi Sharifi used a Tajik passport,
#T486854, as identification documents when he opened the account. Firuzi Sharifi listed 4600 E.
Kentucky Avenue, #508, Denver, Colorado 80246, as his home address. Wachovia was later
subsumed by Wells Fargo Bank, and the account became a Wells Fargo Bank account with the
same number.

3. Between September 22, 2009 and December 14, 2009, Firuzi Sharifi, in association with
the enterprise, transacted Somon Corporation checks through his Wells Fargo Bank account,
withdrew cash, and made purchases with the account’s check card. Many of the transactions
occurred within the City and County of Denver, State of Colorado. Among those transactions,
Firuzi Sharifi deposited $6,700.00 cash at the branch located at 7150 Leetsdale Drive on
December 9, 2009. This cash deposit inflated the apparent balance of the account. Within a few
hours of making that deposit, Firuzi Sharifi cashed two fraudulent Somon Corporation checks for
more than $9,000.00, and withdrew $6,200.00 cash .

4. All of the checks were returned, unpaid, to Wells Fargo Bank.

5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters
located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of
approximately $8,500.00.

12
COUNT NINE
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including October 7, 2009 and November 17, 2009, at and triable in the City and
County of Denver, State of Colorado, FIRDAVSI URUNOV, BAKHTIYOR KADIROV, and
BAKHTIYORKHUJA MIRZOKHOJAEV unlawfully, feloniously, and knowingly obtained
or exercised control over a thing of value, namely: MONEY of WELLS FARGO BANK, with
the value of one thousand dollars or more but less than twenty thousand dollars, without
authorization, or by threat or deception, and intended to deprive WELLS FARGO BANK,
permanently of its use or benefit, and knowingly used, concealed, or abandoned the thing of
value in such manner as to permanently deprive WELLS FARGO BANK, of its use or benefit;
in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 9 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about October 7, 2009, Bakhtiyorkhuja Mirzokhojaev, in association with the


enterprise and under the direction of Firdavsi Urunov, opened Wells Fargo Bank checking
account #9372998105 at the Northglenn branch, 10701 Melody Drive, Northglenn, Adams
County, Colorado. Bakhtiyorkhuja Mirzokhojaev used a Tajik passport, #T490783, as an
identification document when he opened the account. Bakhtiyorkhuja Mirzokhojaev listed 2880
S. Federal Blvd. #305, Denver, Colorado 80236, as his home address.

3. Bakhtiyor Kadirov, in association with the enterprise, opened Key Bank checking
account, #760102039855, and gave checks from that account to other enterprise members to use
for fraudulent transactions. Bakhtiyor Kadirov listed 7005 Leetsdale Drive #A26, Denver,
Colorado, 80224 as his home address for that account.

4. Between October 7, 2009 and November 17, 2009, Bakhtiyorkhuja Mirzokhojaev, in


association with the enterprise, transacted checks from Bakhtiyor Kadirov through his Wells
Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Many of
the transactions occurred within the City and County of Denver, State of Colorado. Among those
transactions, Bakhtiyorkhuja Mirzokhojaev withdrew $2,500.00 at the Wells Fargo Bank branch
located at 1001 S. Monaco Parkway on November 13, 2009.

5. All of the checks were returned, unpaid, to Wells Fargo Bank.

6. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters
located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of
approximately $5,000.00.

13
COUNT TEN
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including November 10, 2009 and December 15, 2009, at and triable in the City
and County of Denver, State of Colorado, DMITRIY ORLOVSKIY, and OBID VAPAEV,
unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value,
namely: MONEY of JP MORGAN CHASE BANK, with the value of one thousand dollars or
more but less than twenty thousand dollars, without authorization, or by threat or deception, and
intended to deprive JP MORGAN CHASE BANK, permanently of its use or benefit, and
knowingly used, concealed, or abandoned the thing of value in such manner as to permanently
deprive JP MORGAN CHASE BANK, of its use or benefit; in violation of section 18-4-
401(1)(a)(b),(2)(c),C.R.S

The facts supporting Count 10 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about November 10, 2009, in association with the enterprise, Dmitriy Orlovskiy
opened JP Morgan Chase Bank account #638948503. Dmitriy Orlovskiy used a Permanent
Resident Card (“Green card”), #A071160539, and Colorado Driver’s License #09-187-0233 as
identification documents when he opened the account. Dmitriy Orlovskiy listed his home address
for the account as 11275 E. Alameda Avenue, #4, Aurora, Colorado, 80012-1007.

3. Obid Vapaev, in association with the enterprise, opened Wachovia checking account,
#1010232795127, and gave checks from that account to other enterprise members to use for
fraudulent transactions. Obid Vapaev listed 7005 Leetsdale Drive #A26, Denver, Colorado,
80224 as his home address for that account.

4. On or about September 2, 2009, in association with the enterprise, Obid Vapaev opened
TCF Bank checking account #9877283603. Obid Vapaev used a Russian passport, #0663114 as
an identification document when he opened the account. Obid Vapaev listed his address as 7005
Leetsdale Drive #A26, Denver, Colorado, 80224.

5. Between November 10, 2009 and December 15, 2009, Dmitriy Orlovskiy, in association
with Obid Vapaev and the enterprise, transacted Obid Vapaev TCF Bank and Wachovia checks
through his JP Morgan Chase Bank account, withdrew cash, and made purchases with the
account’s check card. Many of the transactions occurred within the City and County of Denver,
State of Colorado. Among those transactions, withdrawals were made from the account at 2757
North Speer Boulevard on November 23, 2009.

6. The Obid Vapaev TCF and Wachovia checks were returned, unpaid, to JP Morgan Chase
Bank.

7. As a result of the fraudulent activity, JP Morgan Chase Bank suffered a loss of


approximately $3,900.00.

14
COUNT ELEVEN

THEFT, 18-4-401(1),(2)(b.5) C.R.S. (M1) <0801T>

Between and including November 10, 2009 and December 28, 2009, at and triable in the City
and County of Denver, State of Colorado, DMITRIY ORLOVSKIY and OBID VAPAEV,
unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value,
namely: MONEY of KEY BANK, with the value of five hundred dollars or more but less than
one thousand dollars, without authorization, or by threat or deception, and intended to deprive
KEY BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned
the thing of value in such manner as to permanently deprive KEY BANK, of its use or benefit;
in violation of section 18-4-401(1),(2)(b.5) C.R.S.

The facts supporting Count 11 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about November 10, 2009, Dmitriy Orlovskiy, in association with the enterprise,
opened Key Bank account #766492006131 at the Key Bank located at 829 16th Street, City and
County of Denver, State of Colorado. Dmitriy Orlovskiy used a Permanent Resident Card
(“green card”), #A071160539, and Colorado Driver’s License #09-187-0233 as identification
documents when he opened the account. Dmitriy Orlovskiy listed his home address for the
account as 1001 16th Street #301, Denver, CO 80265.

3. Obid Vapaev, in association with the enterprise, opened Wells Fargo Bank checking
account, #7885981220, and gave checks from that account to other enterprise members to use for
fraudulent transactions. Obid Vapaev listed his home address for that account as 11275 E.
Alameda Avenue, #4, Aurora, Colorado, 80012-1007.

4. Between November 10, 2009 and December 28, 2009, Dmitriy Orlovskiy, in association
with Obid Vapaev and the enterprise, transacted Obid Vapaev Wells Fargo Bank checks through
his Key Bank account, withdrew cash, and made purchases with the account’s check card. Many
of the transactions occurred within the City and County of Denver, State of Colorado. Among
those transactions, Dmitriy Orlovskiy cashed Obid Vapaev check #152 for $450.00 at the Key
Bank located at 1675 Broadway on December 12, 2009.

5. The Obid Vapaev checks were returned, unpaid, to Key Bank.

6. As a result of the fraudulent activity, Key Bank suffered a loss of $944.45.

15
COUNT TWELVE
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including November 30, 2009 and March 4, 2010, at and triable in the City and
County of Denver, State of Colorado, AZIMDZHON MAZHIDOV and SHODMON
BILOLOV unlawfully, feloniously, and knowingly obtained or exercised control over a thing of
value, namely: MONEY of WELLS FARGO BANK, with the value of one thousand dollars or
more but less than twenty thousand dollars, without authorization, or by threat or deception, and
intended to deprive WELLS FARGO BANK, permanently of its use or benefit, and knowingly
used, concealed, or abandoned the thing of value in such manner as to permanently deprive
WELLS FARGO BANK, of its use or benefit; in violation of section 18-4-
401(1)(a)(b),(2)(c),C.R.S.

COUNT THIRTEEN
FORGERY, 18-5-102(1)(c) C.R.S. (F5) <1001C>

On or about February 3, 2010, at and triable in the City and County of Denver, State of
Colorado, AZIMDZHON MAZHIDOV, with the intent to defraud WALKER STAPLETON
and WELLS FARGO BANK, 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, CHECK #371 of WALKER STAPLETON in violation of
section 18-5-102(1)(c), C.R.S.

The facts supporting Counts 12 and 13 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about November 30, 2009, Shodmon Bilolov, in association with the enterprise,
opened Wells Fargo Bank checking account #8736111520 at the Englewood branch, 3333 S.
Bannock Street, Englewood, Arapahoe County, Colorado. Shodmon Bilolov used a Colorado
Driver’s License, #08-107-0943, as an identification document when he opened the account.
Shodmon Bilolov listed his home address for the account as 1306 S. Parker Road, Denver, CO
80231-2150.

3. Between November 30, 2009 and March 4, 2010, Shodmon Bilolov and Azimdzhon
Mazhidov, in association with the enterprise, transacted Somon Corporation checks through
Shodmon Bilolov’s Wells Fargo Bank account, withdrew cash, and made purchases with the
account’s check card. Many of the transactions occurred within the City and County of Denver,
State of Colorado. Among those transactions, Shodmon Bilolov and Azimdzhon Mazhidov
deposited Somon Corporation check #1028 for $3,200.00 and withdrew $3,200.00 in cash at the
branch located at 2043 S. Colorado Boulevard on February 6, 2010.

4. On February 3, 2010, Azimdzhon Mazhidov, in association with the enterprise, identified


himself as Shodmon Bilolov and cashed a stolen check from the account of Walker Stapleton
(check #371) for $4,500.00 at the branch located at 2043 S. Colorado Boulevard, located within
the City and County of Denver, State of Colorado.

16
5. All of the checks were returned, unpaid, to Wells Fargo Bank.

6. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters
located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of
approximately $4,500.00.

17
COUNT FOURTEEN
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including December 31, 2009 and April 6, 2010, at and triable in the City and
County of Denver, State of Colorado, FIRUZI SHARIFI, unlawfully, feloniously, and
knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS
FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand
dollars, without authorization, or by threat or deception, and intended to deprive WELLS
FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or
abandoned the thing of value in such manner as to permanently deprive WELLS FARGO
BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

COUNT FIFTEEN
CRIMINAL IMPERSONATION, 18-5-113(1)(e) C.R.S. (F6) <1011A>

Between and including December 31, 2009 and April 6, 2010, at and triable in the City and
County of Denver, State of Colorado, FIRUZI SHARIFI, unlawfully, feloniously, and
knowingly assumed a false or fictitious identity or capacity, namely: SHOKHIN T.
KHAKIMOV, and in such identity or capacity did an act with intent to unlawfully gain a benefit
for himself or another or to injure or defraud another; in violation of section 18-5-113(1)(e),
C.R.S.

The facts supporting Counts 14 and 15 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about December 31, 2009, a person using the name “Shokhin T. Khakimov,” in
association with the enterprise, opened Wells Fargo Bank checking account #9200909720 at the
Monaco branch, 1001 S. Monaco Parkway, City and County of Denver, State of Colorado. A
counterfeit Tajik passport, #T455249 in that name was used as an identification document when
the account was opened. “Shokhin T. Khakimov” listed his home address for the account as 7474
E. Arkansas Avenue #1005, Denver, CO 80231-2540. The address was later changed by the
account holder to 875 S. Dexter Street #309, Denver, CO 80246-2126.

3. Between December 31, 2009 and April 6, 2010, Firuzi Sharifi, using the name “Shokhin
T. Khakimov,” transacted Payravi Fraydin checks through his Wells Fargo Bank account,
withdrew cash, and made purchases with the account’s check card. Among those transactions,
Firuzi Sharifi deposited Payravi Fraydin check #175 for $2,700.00 at the ATM located at 1001
S. Monaco Parkway, City and County of Denver, State of Colorado, on March 4, 2010.

4. All of the checks were returned, unpaid, to Wells Fargo Bank.

5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters
located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of
approximately $9,000.00.

18
COUNT SIXTEEN
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including January 12, 2010 and February 11, 2010, at and triable in the City and
County of Denver, State of Colorado, KHISRAV CHUTOV, unlawfully, feloniously, and
knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS
FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand
dollars, without authorization, or by threat or deception, and intended to deprive WELLS
FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or
abandoned the thing of value in such manner as to permanently deprive WELLS FARGO
BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 16 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about January 12, 2010, Khisrav Chutov, in association with the enterprise, opened
Wells Fargo Bank checking account #3013338714 at the Leetsdale branch, 7150 Leetsdale
Drive, City and County of Denver, State of Colorado. Khisrav Chutov used a Colorado Driver’s
License, #08-017-0799, as an identification document when he opened the account. Khisrav
Chutov listed his home address for the account as 860 S. Oneida Street #C107, Denver, CO
80224-1725.

3. Between January 12, 2010 and February 11, 2010, Khisrav Chutov, in association with
the enterprise, transacted Somon Corporation checks through his Wells Fargo Bank account,
withdrew cash, and made purchases with the account’s check card. Many of the transactions
occurred within the City and County of Denver, State of Colorado. Among those transactions,
Khisrav Chutov withdrew $1,900.00 in cash at the branch located at 8980 E. Hampden Avenue
on January 22, 2010.

4. All of the checks were returned, unpaid, to Wells Fargo Bank.

5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters
located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of
approximately $7,500.00.

19
COUNT SEVENTEEN
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including January 16, 2010 and February 8, 2010, at and triable in the City and
County of Denver, State of Colorado, FIRUZI SHARIFI and BOBOKALON SHARIPOV,
unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value,
namely: MONEY of WELLS FARGO BANK, with the value of one thousand dollars or more
but less than twenty thousand dollars, without authorization, or by threat or deception, and
intended to deprive WELLS FARGO BANK, permanently of its use or benefit, and knowingly
used, concealed, or abandoned the thing of value in such manner as to permanently deprive
WELLS FARGO BANK, of its use or benefit; in violation of section 18-4-
401(1)(a)(b),(2)(c),C.R.S.

COUNT EIGHTEEN
CRIMINAL IMPERSONATION, 18-5-113(1)(e) C.R.S. (F6) <1011A>

Between and including January 16, 2010 and February 8, 2010, at and triable in the City and
County of Denver, State of Colorado, BOBOKALON SHARIPOV, unlawfully, feloniously,
and knowingly assumed a false or fictitious identity or capacity, namely: BUNYOD RUZIEV,
and in such identity or capacity did an act with intent to unlawfully gain a benefit for himself or
another or to injure or defraud another; in violation of section 18-5-113(1)(e), C.R.S.

The facts supporting Counts 17 and 18 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about January 16, 2010, a person using the name “Bunyod Ruziev,” in association
with the enterprise, opened Wells Fargo Bank checking account #1278481302 at the Aurora
South branch, 2550 S. Parker Road, Aurora, Arapahoe County, Colorado. A Tajik passport,
#T298015 in that name was used as an identification document when the account was opened.
“Bunyod Ruziev” listed his home address for the account as 1045 S. Dahlia Street #B6, Denver,
CO 80246-2815.

3. Firuzi Sharifi, in association with the enterprise, opened US Bank checking account
#103679448797 and gave checks from that account to other enterprise members to use for
fraudulent transactions.

4. Between January 16, 2009 and February 8, 2010, Bobokalon Sharipov, using the name
“Bunyod Ruziev,” transacted Murado Dental and Firuzi Sharifi checks through the Wells Fargo
Bank account, withdrew cash, and made purchases with the account’s check card. Among those
transactions, Bobokalon Sharipov withdrew $200.00 from the ATM located at 1001 S. Monaco
Parkway, City and County of Denver, State of Colorado, on February 5, 2010.

5. All of the checks were returned, unpaid, to Wells Fargo Bank.

20
6. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters
located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of
approximately $8,800.00.

21
COUNT NINETEEN
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including February 15, 2010 and April 6, 2010, at and triable in the City and
County of Denver, State of Colorado, BOBOKALON SHARIPOV, unlawfully, feloniously,
and knowingly obtained or exercised control over a thing of value, namely: MONEY of
WELLS FARGO BANK, with the value of one thousand dollars or more but less than twenty
thousand dollars, without authorization, or by threat or deception, and intended to deprive
WELLS FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or
abandoned the thing of value in such manner as to permanently deprive WELLS FARGO
BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

COUNT TWENTY
CRIMINAL IMPERSONATION, 18-5-113(1)(e) C.R.S. (F6) <1011A>

Between and including February 15, 2010 and April 6, 2010, at and triable in the City and
County of Denver, State of Colorado, BOBOKALON SHARIPOV, unlawfully, feloniously,
and knowingly assumed a false or fictitious identity or capacity, namely: NUSHERVON
KALANDAROV, and in such identity or capacity did an act with intent to unlawfully gain a
benefit for himself or another or to injure or defraud another; in violation of section 18-5-
113(1)(e), C.R.S.

The facts supporting Counts 19 and 20 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about February 15, 2010, a person using the name “Nushervon Kalandarov,” in
association with the enterprise, opened Wells Fargo Bank checking account #7913708751 at the
Aurora South branch, 2550 S. Parker Road, Aurora, Arapahoe County, Colorado. A Tajik
passport, #T581630, in that name was used as an identification document when the account was
opened. “Nushervon Kalandarov” listed his home address for the account as 1039 S. Parker Road
#U7, Denver, CO 80231-7801.

3. Between February 15, 2010 and April 6, 2010, Bobokalon Sharipov, using the name
“Nushervon Kalandarov,” transacted Payravi Fraydin checks through the Wells Fargo Bank
account, withdrew cash, and made purchases with the account’s check card. Among those
transactions, Bobokalon Sharipov withdrew $6,000.00 cash from the branch located at 8980 E.
Hampden Avenue, City and County of Denver, State of Colorado, on March 16, 2010.

4. All of the checks were returned, unpaid, to Wells Fargo Bank.

5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters
located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of
approximately $4,900.00.

COUNT TWENTY-ONE

22
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including February 17, 2010 and March 22, 2010, at and triable in the City and
County of Denver, State of Colorado, FIRUZI SHARIFI, unlawfully, feloniously, and
knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS
FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand
dollars, without authorization, or by threat or deception, and intended to deprive WELLS
FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or
abandoned the thing of value in such manner as to permanently deprive WELLS FARGO
BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

COUNT TWENTY-TWO
CRIMINAL IMPERSONATION, 18-5-113(1)(e) C.R.S. (F6) <1011A>

Between and including February 17, 2010 and March 22, 2010, at and triable in the City and
County of Denver, State of Colorado, FIRUZI SHARIFI, unlawfully, feloniously, and
knowingly assumed a false or fictitious identity or capacity, namely: FARIZ BURIEV, and in
such identity or capacity did an act with intent to unlawfully gain a benefit for himself or another
or to injure or defraud another; in violation of section 18-5-113(1)(e), C.R.S.

The facts supporting Counts 21 and 22 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about February 17, 2010, a person using the name “Fariz Buriev,” in association
with the enterprise, opened Wells Fargo Bank checking account #3547799787 at the Englewood
branch, 3333 S. Bannock Street, Englewood, Arapahoe County, Colorado. A Tajik passport,
#T441101 in that name was used as an identification document when the account was opened.
“Fariz Buriev” listed his home address for the account as 1039 S. Parker Road #U7, Denver, CO
80231-7801.

3. Between February 17, 2010 and March 22, 2010, Firuzi Sharifi, using the name “Fariz
Buriev,” transacted Nushervon Kalandarov checks through the Wells Fargo Bank account,
withdrew cash, and made purchases with the account’s check card. Among those transactions,
Firuzi Sharifi withdrew $1,000.00 cash from the branch located at 2500 E. 2nd Avenue, City and
County of Denver, State of Colorado, on March 9, 2010.

4. All of the checks were returned, unpaid, to Wells Fargo Bank.

5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters
located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of
approximately $2,900.00.

23
COUNT TWENTY-THREE
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including February 17, 2010 and April 8, 2010, at and triable in the City and
County of Denver, State of Colorado, MAKHMADRIZO KHOLOV, unlawfully, feloniously,
and knowingly obtained or exercised control over a thing of value, namely: MONEY of JP
MORGAN CHASE BANK, with the value of one thousand dollars or more but less than twenty
thousand dollars, without authorization, or by threat or deception, and intended to deprive JP
MORGAN CHASE BANK, permanently of its use or benefit, and knowingly used, concealed,
or abandoned the thing of value in such manner as to permanently deprive JP MORGAN
CHASE BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 23 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about February 17, 2010, Makhmadrizo Kholov, in association with the enterprise,
opened JP Morgan Chase Bank checking account #878533389 at the Brighton Beach, New York,
branch, located at 722 Brighton Beach Avenue, Brooklyn, Kings County, State of New York.
Makhmadrizo Kholov used a Tajik passport, #T167698, and a Maryland Driver’s License,
#K410578008919, as identification documents when he opened the account. Makhmadrizo
Kholov listed his home address for the account as 3009 Fallstaff Road #K, Baltimore, MD,
21209-2955.

3. Between February 17, 2010 and April 8, 2010, Makhmadrizo Kholov, in association with
the enterprise, transacted Ravshon Muradov checks through his JP Morgan Chase Bank account,
withdrew cash, and made purchases with the account’s check card. Many of the transactions
occurred within the City and County of Denver, State of Colorado. Among those transactions,
Makhmadrizo Kholov cashed Ravshon Muradov check #1136 for $7,200.00 at the branch
located at 1125 17th Street on April 6, 2010.

4. All of the checks were returned, unpaid, to JP Morgan Chase Bank.

5. As a result of the fraudulent activity, JP Morgan Chase Bank, suffered a loss of


approximately $7,300.00.

24
COUNT TWENTY-FOUR
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including February 18, 2010 and April 8, 2010, at and triable in the City and
County of Denver, State of Colorado, FIRUZI SHARIFI and AZIM GOLUBOV, unlawfully,
feloniously, and knowingly obtained or exercised control over a thing of value, namely:
MONEY of JP MORGAN CHASE BANK, with the value of one thousand dollars or more but
less than twenty thousand dollars, without authorization, or by threat or deception, and intended
to deprive JP MORGAN CHASE BANK, permanently of its use or benefit, and knowingly
used, concealed, or abandoned the thing of value in such manner as to permanently deprive JP
MORGAN CHASE BANK, of its use or benefit; in violation of section 18-4-
401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 24 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about February 18, 2010, Azim Golubov, in association with the enterprise, opened
JP Morgan Chase Bank checking account #881903835 at the Rego Park, New York, branch,
located at 9538 Queens Boulevard, Rego Park, Queens County, State of New York. Azim
Golubov used a Tajik passport, #N817088, and a Georgia Driver’s License, #056572824, as
identification documents when he opened the account. Azim Golubov listed his home address for
the account as 4112 Crowder Drive NW, Kennesaw, GA 30152-6446.

3. Firuzi Sharifi, in association with the enterprise, opened US Bank checking account
#103679448797 and gave checks from that account to other enterprise members to use for
fraudulent transactions.

4. Azim Golubov, in association with the enterprise, cashed a Nushervon Kalandarov check
for $4,700.00 on March 22, 2010, at the JP Morgan Chase Bank branch located at 4704 Harlan
Street, Lakeside, Jefferson County, Colorado.

5. Between February 18, 2010 and April 8, 2010, Azim Golubov and Firuzi Sharifi
transacted Nushervon Kalandarovl and Firuzi Sharifi checks through Azim Golubov’s JP
Morgan Chase Bank account, withdrew cash, and made purchases with the account’s check card.
Many of the transactions took place within the City and County of Denver, State of Colorado.
Among those transactions, Firuzi Sharifi deposited Nushervon Kalandarov check #1080 for
$4,100.00 at the ATM located at 100 Detroit Street, on March 23, 2010.

6. All of the checks were returned, unpaid, to JP Morgan Chase Bank.

7. As a result of the fraudulent activity, JP Morgan Chase Bank suffered a loss of


approximately $4,800.00.

25
COUNT TWENTY-FIVE
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including February 20, 2010 and March 25, 2010, at and triable in the City and
County of Denver, State of Colorado, FIRUZI SHARIFI, unlawfully, feloniously, and
knowingly obtained or exercised control over a thing of value, namely: MONEY of WELLS
FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand
dollars, without authorization, or by threat or deception, and intended to deprive WELLS
FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or
abandoned the thing of value in such manner as to permanently deprive WELLS FARGO
BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

COUNT TWENTY-SIX
CRIMINAL IMPERSONATION, 18-5-113(1)(e) C.R.S. (F6) <1011A>

Between and including February 20, 2010 and March 25, 2010, at and triable in the City and
County of Denver, State of Colorado, FIRUZI SHARIFI, unlawfully, feloniously, and
knowingly assumed a false or fictitious identity or capacity, namely: FARRUH ODILOV, and
in such identity or capacity did an act with intent to unlawfully gain a benefit for himself or
another or to injure or defraud another; in violation of section 18-5-113(1)(e), C.R.S.

The facts supporting Counts 25 and 26 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about February 20, 2010, a person using the name “Farruh Odilov,” in association
with the enterprise, opened Wells Fargo Bank checking account #3547799787 at the Downing
Street branch, 2150 S. Downing Street, City and County of Denver, State of Colorado. An Uzbek
passport, #CB1951500 in that name was used as an identification document when the account
was opened. “Farruh Odilov” listed his home address for the account as 878 S. Oneida Street
#J114, Denver, CO 80224-1783.

3. Between February 20, 2010 and March 25, 2010, Firuzi Sharifi, using the name “Farruh
Odilov,” transacted Payravi Fraydin checks through the Wells Fargo Bank account, withdrew
cash, and made purchases with the account’s check card. Among those transactions, Firuzi
Sharifi withdrew $1,800.00 cash from the branch located at 2043 S. Colorado Boulevard, City
and County of Denver, State of Colorado, on March 6, 2010.

4. All of the checks were returned, unpaid, to Wells Fargo Bank.

5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters
located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of
approximately $11,200.00.

26
COUNT TWENTY-SEVEN
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including February 22, 2010 and April 20, 2010, at and triable in the City and
County of Denver, State of Colorado, AZIMDZHON MAZHIDOV and FARIDUM
JABBOROV, unlawfully, feloniously, and knowingly obtained or exercised control over a thing
of value, namely: MONEY of JP MORGAN CHASE BANK, with the value of one thousand
dollars or more but less than twenty thousand dollars, without authorization, or by threat or
deception, and intended to deprive JP MORGAN CHASE BANK, permanently of its use or
benefit, and knowingly used, concealed, or abandoned the thing of value in such manner as to
permanently deprive JP MORGAN CHASE BANK, of its use or benefit; in violation of section
18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 27 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about February 22, 2010, a person using the name “Azim Golubov,” in association
with the enterprise, opened Wells Fargo Bank checking account #3215826068 at the Cherry
Creek branch, 1st Avenue and Steele Street, City and County of Denver, State of Colorado.
“Azim Golubov” used a Tajik passport, #58729086, and a Georgia Driver’s License,
#056572824, as identification documents when he opened the account. “Azim Golubov” listed
his home address for the account as 1039 S. Parker Road #4-07, Denver, CO 80231-2532.

3. Between February 22, 2010 and April 20, 2010, Azimdzhon Mazhidov and Faridum
Jabborov, in association with the enterprise, transacted Rob & Max Corporation and Nushervon
Kalandarov checks through “Azim Golubov’s” Wells Fargo Bank account, withdrew cash, and
made purchases with the account’s check card. Many of the transactions occurred within the City
and County of Denver, State of Colorado. Among those transactions, Azimdzhon Mazhidov and
Faridum Jabborov deposited Nushervon Kalandarov check #1061 for $4,200.00 at the branch
located at 8980 E. Hampden Avenue on March 8, 2010. On March 9, 2010, Faridum Jabborov
cashed Nushervon Kalandarov check #1063 for $1,100.00 at the branch located at 2500 E. 2nd
Avenue.

4. All of the checks were returned, unpaid, to Wells Fargo Bank.

5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters
located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of
approximately $7,800.00.

27
COUNT TWENTY-EIGHT
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including March 10, 2010 and April 26, 2010, at and triable in the City and
County of Denver, State of Colorado, BOBOKALON SHARIPOV, unlawfully, feloniously,
and knowingly obtained or exercised control over a thing of value, namely: MONEY of
WELLS FARGO BANK, with the value of one thousand dollars or more but less than twenty
thousand dollars, without authorization, or by threat or deception, and intended to deprive
WELLS FARGO BANK, permanently of its use or benefit, and knowingly used, concealed, or
abandoned the thing of value in such manner as to permanently deprive WELLS FARGO
BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

COUNT TWENTY-NINE
CRIMINAL IMPERSONATION, 18-5-113(1)(e) C.R.S. (F6) <1011A>

Between and including March 10, 2010 and April 26, 2010, at and triable in the City and
County of Denver, State of Colorado, BOBOKALON SHARIPOV, unlawfully, feloniously,
and knowingly assumed a false or fictitious identity or capacity, namely: PARVIZ Y.
ESHONZHONOV, and in such identity or capacity did an act with intent to unlawfully gain a
benefit for himself or another or to injure or defraud another; in violation of section 18-5-
113(1)(e), C.R.S.

The facts supporting Counts 28 and 29 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about March 10, 2010, a person using the name “Parviz Y. Eshonzhonov,” in
association with the enterprise, opened Wells Fargo Bank checking account #873626078 at the
branch located at 2043 S. Colorado Boulevard, City and County of Denver, State of Colorado. A
Tajik passport, #T959518, in that name was used as an identification document when the account
was opened. “Parviz Y. Eshonzhonov” listed his home address for the account as 7535 E.
Harvard Avenue #201, Denver, CO 80231-6732.

3. Between March 10, 2010 and April 26, 2010, Bobokalon Sharipov, using the name
“Parviz Y. Eshonzhonov,” transacted Nushervon Kalandarov checks through the Wells Fargo
Bank account, withdrew cash, and made purchases with the account’s check card. Among those
transactions, Bobokalon Sharipov cashed Nushervon Kalandarov check #1082 for $4,600.00 at
the branch located at 2164 35th Avenue, Greeley, Weld County, Colorado, on March 25, 2010.

4. All of the checks were returned, unpaid, to Wells Fargo Bank.

5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters
located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of
approximately $8,800.00.

28
COUNT THIRTY

THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including March 11, 2010 and April 13, 2010, at and triable in the City and
County of Denver, State of Colorado, PARVIZ CHORSANBIEV, unlawfully, feloniously, and
knowingly obtained or exercised control over a thing of value, namely: MONEY of JP
MORGAN CHASE BANK, with the value of one thousand dollars or more but less than twenty
thousand dollars, without authorization, or by threat or deception, and intended to deprive JP
MORGAN CHASE BANK, permanently of its use or benefit, and knowingly used, concealed,
or abandoned the thing of value in such manner as to permanently deprive JP MORGAN
CHASE BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 30 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about March 11, 2010, Parviz Chorsanbiev, in association with the enterprise,
opened JP Morgan Chase Bank checking account #895141174 at the Villa Monaco branch, 2223
S. Monaco Parkway, City and County of Denver, State of Colorado. Parviz Chorsanbiev used a
Tajik passport, #T492199, as identification document when he opened the account. Parviz
Chorsanbiev listed his home address for the account as 878 Oneida Street #J114, Denver, CO
80224-1783.

3. Between March 11, 2010 and April 13, 2010, Parviz Chorsanbiev, in association with the
enterprise, transacted Nushervon Kalandarov checks through his JP Morgan Chase Bank
account, withdrew cash, and made purchases with the account’s check card. Many of the
transactions occurred within the City and County of Denver, State of Colorado. Among those
transactions, Nushervon Kalandarov check #1089 for $3,700.00 was deposited at the ATM
located at 2980 W. Evans Avenue on March 31, 2010. On that same day, Parviz Chorsanbiev
withdrew $6,500.00 in cash from the branch located at 1301 Canyon Boulevard in Boulder,
Colorado.

4. All of the checks were returned, unpaid, to JP Morgan Chase Bank.

5. As a result of the fraudulent activity, JP Morgan Chase Bank, suffered a loss of


approximately $6,200.00.

29
COUNT THIRTY-ONE
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including March 12, 2010 and April 8, 2010, at and triable in the City and County
of Denver, State of Colorado, FIRUZI SHARIFI and PARVIZ CHORSANBIEV, unlawfully,
feloniously, and knowingly obtained or exercised control over a thing of value, namely:
MONEY of WELLS FARGO BANK, with the value of one thousand dollars or more but less
than twenty thousand dollars, without authorization, or by threat or deception, and intended to
deprive WELLS FARGO BANK, permanently of its use or benefit, and knowingly used,
concealed, or abandoned the thing of value in such manner as to permanently deprive WELLS
FARGO BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 31 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about March 12, 2010, Parviz Chorsanbiev, in association with the enterprise,
opened Wells Fargo Bank checking account #8073106752 at the branch located at 1601 Blake
Street Suite 105, City and County of Denver, State of Colorado. A Tajik passport, #T959518 in
that name was used as an identification document when the account was opened. Parviz
Chorsanbiev listed his home address for the account as 1090 S. Parker Road #318, Denver, CO
80231-2010.

3. Between March 12, 2010 and April 8, 2010, Firuzi Sharifi and Parviz Chorsanbiev, in
association with the enterprise, transacted Nushervon Kalandarov checks through the Wells
Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Among
those transactions, Parviz Chorsanbiev cashed Nushervon Kalandarov check #1085 for
$5,100.00 at the branch located at 410 S. Cascade Avenue, Colorado Springs, El Paso County,
Colorado, on March 30, 2010.

4. On March 30, 2010, Firuzi Sharifi withdrew $300.00 cash from the ATM located at 3155
E. 1st Avenue in the City and County of Denver, State of Colorado.

5. All of the checks were returned, unpaid, to Wells Fargo Bank.

6. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters
located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of
approximately $9,600.00.

30
COUNT THIRTY-TWO
CRIMINAL ATTEMPT TO COMMIT THEFT, 18-4-401(1),(2)(c); 18-2-101, C.R.S (F5)
<0801UA>

Between and including April 7, 2010, and May 27, 2010, at and triable in the City and County
of Denver, State of Colorado, by engaging in conduct constituting a substantial step toward the
commission of theft, KARIMDZHON MANSUROV, unlawfully, feloniously, and knowingly
attempted to obtain or exercise control over a thing of value, namely: MONEY, of WELLS
FARGO BANK, with the value of one thousand dollars or more but less than twenty thousand
dollars, without authorization, or by threat or deception, and intended to deprive WELLS
FARGO BANK permanently of its use or benefit; in violation of sections 18-4-401(1)(2)(c) and
18-2-101, C.R.S.

COUNT THIRTY-THREE
FORGERY, 18-5-102(1)(c) C.R.S. (F5) <1001C>

On or about May 7, 2010, at and triable in the City and County of Denver, State of Colorado,
KARIMDZHON MANSUROV, with the intent to defraud WELLS FARGO BANK,
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, CHECK #1009 of MURADO DENTAL; in violation of section 18-5-102(1)(c),
C.R.S.

COUNT THIRTY-FOUR
CRIMINAL IMPERSONATION, 18-5-113(1)(e) C.R.S. (F6) <1011A>

Between and including April 7, 2010, and May 27, 2010, at and triable in the City and County
of Denver, State of Colorado, KARIMDZHON MANSUROV, unlawfully, feloniously, and
knowingly assumed a false or fictitious identity or capacity, namely: KARIMI MANSURRY,
and in such identity or capacity did an act with intent to unlawfully gain a benefit for himself or
another or to injure or defraud another; in violation of section 18-5-113(1)(e), C.R.S.

COUNT THIRTY-FIVE
POSSESSION OF FORGED INSTRUMENT, 18-5-105 C.R.S. (F6) <10040>

On or about May 19, 2010, at and triable in the City and County of Denver, State of Colorado,
KARIMDZHON MANSUROV, unlawfully and feloniously possessed a forged instrument,
namely: PENNSYLVANIA DRIVER’S LICENSE #76350390 IN THE NAME OF KOMIL
DZOGBESSI, with knowledge that it was forged and with intent to use the instrument to
defraud; in violation of section 18-5-105, C.R.S.

31
COUNT THIRTY-SIX
POSSESSION OF FORGED INSTRUMENT, 18-5-105 C.R.S. (F6) <10040>

On or about May 19, 2010, at and triable in the City and County of Denver, State of Colorado,
KARIMDZHON MANSUROV, unlawfully and feloniously possessed a forged instrument,
namely: PENNSYLVANIA DRIVER’S LICENSE #44356389 IN THE NAME OF ELPID
BERGANIO, with knowledge that it was forged and with intent to use the instrument to
defraud; in violation of section 18-5-105, C.R.S.

The facts supporting Counts 32 through 36 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about April 7, 2010, a person using the name “Karimi Mansurry,” in association
with the enterprise, opened Wells Fargo Bank checking account #8430287378 at the Glendale
branch located at 400 S. Colorado Boulevard, Glendale, Arapahoe County, State of Colorado. A
Turkish passport, #A3767406, and a New Jersey Driver’s License, #M87831171086227, in that
name was used as an identification document when the account was opened. “Karimi Mansurry”
listed his home address for the account as 1039 S. Parker Road #Y03, Denver, CO 80231-2599.

3. Between April 7, 2010 and May 27, 2010, Karimdzhon Mansurov, using the name
“Karimi Mansurry,” transacted Friendly Auto and Murado Dental checks through the Wells
Fargo Bank account, withdrew cash, and made purchases with the account’s check card. Many of
those transactions took place at branches located within the City and County of Denver, State of
Colorado.

4. On or about May 7, 2010 Karimdzhon Mansurov, using the name “Karim Mansurry,”
attempted to cash Murado Dental check #1009 for $6,900.00 at the branch located at 635
Coffman Street, Longmont, Larimer County, Colorado. Karimdzhon Mansurov presented a
counterfeit New Jersey driver’s license #M87831171086227 with his photo on it as identification
when he tried to cash that check. Wells Fargo Bank personnel refused to cash the check and
Karimdzhon Mansurov left the branch.

5. On or about May 19, 2010, Denver Police Officers contacted Karimdzhon Mansurov at
900 S. Quince Street, #B4-423 in the City and County of Denver, State of Colorado. Karimdzhon
Mansurov had two counterfeit Pennsylvania driver’s licenses in his possession, #76350390 in the
name of Komil Dzogbessi and #44356389 in the name of Elpid Berganio. Both counterfeit
licenses bore Karimdzhon Mansurov’s photo.

6. On or about May 21, 2010, Wells Fargo Bank closed the “Karimi Mansurry” account and
issued “Karimi Mansurry” a cashier’s check for the remaining balance of $7,417.56.
Karimdzhon Mansurov, using the name “Karimi Mansurry”, cashed that check at 2043 S.
Colorado Boulevard, in the City and County of Denver, State of Colorado, on May 27, 2010.

32
COUNT THIRTY-SEVEN

THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including May 10, 2010 and June 10, 2010, at and triable in the City and County
of Denver, State of Colorado, AZIMDZHON MAZHIDOV, unlawfully, feloniously, and
knowingly obtained or exercised control over a thing of value, namely: MONEY of JP
MORGAN CHASE BANK, with the value of one thousand dollars or more but less than twenty
thousand dollars, without authorization, or by threat or deception, and intended to deprive JP
MORGAN CHASE BANK, permanently of its use or benefit, and knowingly used, concealed,
or abandoned the thing of value in such manner as to permanently deprive JP MORGAN
CHASE BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 37 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about May 10, 2010, Azimdzhon Mazhidov, in association with the enterprise,
opened JP Morgan Chase Bank checking account #869651349 at a branch in the State of
Colorado. Azimdzhon Mazhidov used a Tajik passport, #T167919, as identification document
when he opened the account. Azimdzhon Mazhidov listed his home address for the account as
3001 S. Federal Boulevard, Denver, CO 80236-2711.

3. Between May 10, 2010 and June 10, 2010, Azimdzhon Mazhidov, in association with the
enterprise, transacted Timuri Khuseyn checks through his JP Morgan Chase Bank account,
withdrew cash, and made purchases with the account’s check card. Many of the transactions
occurred within the City and County of Denver, State of Colorado. Among those transactions,
Azimdzhon Mazhidov withdrew $7,150.00 in cash from the branch located at 2696 S. Colorado
Boulevard on May 15, 2010.

4. All of the checks were returned, unpaid, to JP Morgan Chase Bank.

5. As a result of the fraudulent activity, JP Morgan Chase Bank, suffered a loss of


approximately $6,500.00.

33
COUNT THIRTY-EIGHT

THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including May 15, 2010 and June 8, 2010, at and triable in the City and County of
Denver, State of Colorado, NODIR KHODZHAEV, unlawfully, feloniously, and knowingly
obtained or exercised control over a thing of value, namely: MONEY of WELLS FARGO
BANK, with the value of one thousand dollars or more but less than twenty thousand dollars,
without authorization, or by threat or deception, and intended to deprive WELLS FARGO
BANK, permanently of its use or benefit, and knowingly used, concealed, or abandoned the
thing of value in such manner as to permanently deprive WELLS FARGO BANK, of its use or
benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 38 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about May 15, 2010, Nodir Khodzhaev, in association with the enterprise, opened
Wells Fargo Bank checking account #2909452621 at the branch located at 7150 Leetsdale Drive,
City and County of Denver, State of Colorado. A Colorado Driver’s License, #07-134-0874, in
that name was used as an identification document when the account was opened. Nodir
Khodzhaev listed his home address for the account as 1150 Syracuse Street #2-8, Denver, CO
80220-3236.

3. Between May 15, 2010 and June 8, 2010, Nodir Khodzhaev, in association with the
enterprise, transacted Timuri Khuseyn checks through the Wells Fargo Bank account, withdrew
cash, and made purchases with the account’s check card. Among those transactions, Nodir
Khodzhaev cashed Timuri Khuseyn check #1039 for $5,300.00 at the branch located at 1050
Ken Pratt Boulevard, Longmont, Larimer County, Colorado, on May 14, 2010.

4. All of the checks were returned, unpaid, to Wells Fargo Bank.

5. As a result of the fraudulent activity, Wells Fargo Bank, with Colorado headquarters
located at 1700 Lincoln, City and County of Denver, State of Colorado, suffered a loss of
approximately $17,100.00.

34
COUNT THIRTY-NINE
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including May 10, 2010 and June 8, 2010, at and triable in the City and County of
Denver, State of Colorado, NODIR KHODZHAEV, unlawfully, feloniously, and knowingly
obtained or exercised control over a thing of value, namely: MONEY of JP MORGAN
CHASE BANK, with the value of one thousand dollars or more but less than twenty thousand
dollars, without authorization, or by threat or deception, and intended to deprive JP MORGAN
CHASE BANK, permanently of its use or benefit, and knowingly used, concealed, or
abandoned the thing of value in such manner as to permanently deprive JP MORGAN CHASE
BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 39 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about April 10, 2010, Nodir Khodzhaev, in association with the enterprise, opened
JP Morgan Chase Bank checking account #877362459 at the branch located at 1627 S. Havana
Street, Aurora, Arapahoe County, of Colorado. A Colorado Driver’s License, #07-134-0874, in
that name was used as an identification document when the account was opened. Nodir
Khodzhaev listed his home address for the account as 3001 S. Federal Boulevard #325, Denver,
CO 80236-2711.

3. Between May 10, 2010 and June 8, 2010, Nodir Khodzhaev, in association with the
enterprise, transacted Timuri Khuseyn checks through his JP Morgan Chase Bank account,
withdrew cash, and made purchases with the account’s check card. Many of the transactions
occurred within the City and County of Denver, State of Colorado. Among those transactions,
Nodir Khodzhaev cashed Timuri Khuseyn check #1048 for $6,600.00 at the branch located at
100 Detroit Street on May 17, 2010.

4. All of the other checks were returned, unpaid, to JP Morgan Chase Bank.

5. As a result of the fraudulent activity, JP Morgan Chase Bank, suffered a loss of


approximately $6,600.00.

35
COUNT FORTY
THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including April 10, 2010 and June 8, 2010, at and triable in the City and County
of Denver, State of Colorado, FIRUZI SHARIFI and MAKHMADRIZO KHOLOV,
unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value,
namely: MONEY of JP MORGAN CHASE BANK, with the value of one thousand dollars or
more but less than twenty thousand dollars, without authorization, or by threat or deception, and
intended to deprive JP MORGAN CHASE BANK, permanently of its use or benefit, and
knowingly used, concealed, or abandoned the thing of value in such manner as to permanently
deprive JP MORGAN CHASE BANK, of its use or benefit; in violation of section 18-4-
401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 40 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about April 10, 2010, a person using the name “Algirdas Zakarauskas” opened JP
Morgan Chase Bank checking account #881903835 at the Rego Park, New York, branch, located
at 9538 Queens Boulevard, Rego Park, Queens County, State of New York. “Algirdas
Zakarauskas” used a Latvian passport, #705958, as an identification document to open the
account. “Algirdas Zakarauskas” listed his home address for the account as 10106 Martense
Avenue #4, Corona, NY 11368-7800.

3. Between April 10, 2010 and June 8, 2010, Firuzi Sharifi and Makhmadrizo Kholov, in
association with the enterprise, transacted Timuri Khuseyn, Payravi Fraydin and Ravshon
Muradov checks through the “Algirdas Zakarauskas” JP Morgan Chase Bank account and
withdrew cash. Some of the fraudulent transactions took place within the City and County of
Denver, State of Colorado. Among those transactions, Firuzi Sharifi cashed Timuri Khuseyn
check #1036 for $7,500.00 at the branch located at 747 S. Colorado Boulevard on May 14, 2010.
On May 15, 2010, Firuzi Sharifi and Makhmadrizo Kholov deposited Ravshon Muradov check
#1140 for $3,900.00 at the ATM located at 100 Detroit Street.

4. All of the checks were returned, unpaid, to JP Morgan Chase Bank.

5. As a result of the fraudulent activity, JP Morgan Chase Bank suffered a loss of


approximately $8,200.00.

36
COUNT FORTY-ONE

THEFT, 18-4-401(1),(2)(c) C.R.S. (F4) <0801U>

Between and including April 27, 2010 and July 15, 2010, at and triable in the City and County
of Denver, State of Colorado, MAKHMADRIZO KHOLOV, unlawfully, feloniously, and
knowingly obtained or exercised control over a thing of value, namely: MONEY of JP
MORGAN CHASE BANK, with the value of one thousand dollars or more but less than twenty
thousand dollars, without authorization, or by threat or deception, and intended to deprive JP
MORGAN CHASE BANK, permanently of its use or benefit, and knowingly used, concealed,
or abandoned the thing of value in such manner as to permanently deprive JP MORGAN
CHASE BANK, of its use or benefit; in violation of section 18-4-401(1)(a)(b),(2)(c),C.R.S.

The facts supporting Count 41 are as follows:

1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.

2. On or about April 27, 2010, a person using the name “Biloliddin Lashkarov” opened JP
Morgan Chase Bank checking account #889196747 at the Bensonhurst Bay, New York, branch,
located at 8418 Bay Parkway, Brooklyn, State of New York. “Biloliddin Lashkarov” used a
Tajik passport, #T075400, as an identification document to open the account. “Biloliddin
Lashkarov” listed his home address for the account as 10106 Martense Avenue #4, Corona, NY
11368-7800.

3. Between April 27, 2010 and July 15, 2010, Makhmadrizo Kholov, in association with the
enterprise, transacted Elena Loganova and Timuri Khuseyn checks through the “Biloliddin
Lashkarov” JP Morgan Chase Bank account, and withdrew cash. Some of the fraudulent
transactions took place within the City and County of Denver, State of Colorado. Among those
transactions, Makhmadrizo Kholov deposited Elena Logvanova check #130 for $4,600.00 at the
ATM located at 2696 S. Colorado Boulevard on June 25, 2010.

4. On or about June 25, 2010, Makhmadrizo Kholov cashed Elena Logvanova check #129
for $6,900.00 at the JP Morgan Chase Bank branch located at 10414 Town Center Drive,
Westminster, Colorado.

5. All of the checks were returned, unpaid, to JP Morgan Chase Bank.

6. As a result of the fraudulent activity, JP Morgan Chase Bank suffered a loss of


approximately $7,200.00.

37