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District Court, City and County of Denver, Colorado City and County Building, Room 215 1437 Bannock

Street Denver, CO 80202 Plaintiff: THE PEOPLE OF THE STATE OF COLORADO Defendants: CHARLES WAYNE WRENFROW MICHELLE JEAN WRENFROW COURT USE ONLY Case Number: Grand Jury No. 12CR2A Div.: Criminal Ctrm: 215 / ____ INDICTMENT VIOLATION OF COLORADO ORGANIZED CRIME CONTROL ACT, C.R.S. 18-17-104(3), (F2) <37284> 1 (1 count) CONSPIRACY TO COMMIT THEFT BY RECEIVING, C.R.S. 18-4-410(1),(5);18-2-201 (F4) <0805HC> 2 (1 count) THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> 3, 4, 5, 6, 7, 8, 9, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21 (18 counts) THEFT BY RECEIVING, C.R.S. 18-4-410(1),(5) (F3) <0805H> 10 (1 count)

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

Dated this _________ day of ____________________, 2012.

_________________________________________ Christina M. Habas Presiding Judge Denver District Court

COUNT ONE VIOLATION OF COLORADO ORGANIZED CRIME CONTROL ACT, C.R.S. 18-17-104(3), (F2) <37284> Between and including September 1, 2009, and May 23, 2012, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW, while employed by or associated with an enterprise, namely: C & M TOWING AND RECOVERY, INC, unlawfully, feloniously, and knowingly conducted or participated, directly or indirectly, in the enterprise through a pattern of racketeering activity; in violation of sections C.R.S. 18-17-104(3) and 18-17-105. The Enterprise The enterprise alleged in Count One included, but was not limited to, the following: CHARLES WAYNE WRENFROW, MICHELLE JEAN WRENFROW, and C & M TOWING AND RECOVERY, INC, 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 CHARLES WAYNE WRENFROW, the acts described in counts 2 through 21, including any lesser included offenses of these counts. As to MICHELLE JEAN WRENFROW, the acts described in counts 2 through 21, including any lesser included offenses of these counts.

COUNT TWO CONSPIRACY TO COMMIT THEFT BY RECEIVING, C.R.S. 18-4-410(1),(5);18-2-201 (F4) <0805HC> Between and including September 1, 2009, and May 23, 2012, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW, with the intent to promote or facilitate the commission of the crime of THEFT BY RECEIVING, unlawfully and feloniously agreed with CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW and a person or persons to the District Attorney 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 C.R.S. 18-4-410(1),(5) and 18-2-201. The facts supporting Counts 1 and 2 are as follows: 1. The facts supporting all other counts in this Indictment are incorporated herein by reference. 2. From at least September 1, 2009, through May 23, 2012, Charles Wayne Wrenfrow and Michelle Jean Wrenfrow, and other, as yet unidentified persons, while employed by or associated with an enterprise, namely: C & M Towing and Recovery, Inc., operated with a common goal. The common goal of the members of the enterprise was to steal motor vehicles from locations within the State of Colorado. Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, and other, as yet unidentified persons, then disassembled or facilitated the disassembly (chopping) of those stolen vehicles. Those stolen vehicles parts were then sold from the C & M Towing and Recovery, Inc., impound lot located at 821 W. 56th Avenue, Adams County, State of Colorado, to various third party purchasers. 3. At all times relevant to this Indictment, C & M Towing and Recovery, Inc., under the direction and control of Charles Wayne Wrenfrow and Michelle Jean Wrenfrow, leased the property at 821 W. 56th Avenue, Adams County, Colorado, from James Langley. 4. In March 2005, C & M Towing & Recovery Inc (sic) was incorporated with the Colorado Secretary of States Office pursuant to C.R.S. 7-90-301, et seq., and 7-102-102. Charles Wrenfrow was listed as the Registered Agent and Michelle Wrenfrow was listed as the incorporator. The Colorado Secretary of State assigned entity identification number 20051131859 to C & M Towing & Recovery Inc. From time to time, Michelle Wrenfrow filed annual reports and other documents with the Secretary of States Office on behalf of C & M Towing & Recovery Inc. 5. C & M Towing & Recovery Inc operated under Colorado Public Utilities Commission towing permit number T-03661 between and including March 31, 2005, and November 22, 2010,

when that permit was revoked. C & M Towing & Recovery Inc listed 821 W. 56 th Avenue, Denver, CO, 80216, as their business location on the permit forms in 2010. 6. Between 2006 and March 28, 2012, Charles Wayne Wrenfrow, d.b.a. C & M Towing, operated under US DOT permit number 926145. 7. At all times relevant to this Indictment, C & M Towing & Recovery Inc. did not record any employees to the Colorado Department of Labor. 8. At all times relevant to this Indictment, Charles Wayne Wrenfrow and Michelle Jean Wrenfrow were the only persons identified in any documentation or actual association with the ownership and operation of C & M Towing & Recovery Inc., hereinafter C & M Towing.

COUNT THREE THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including September 9, 2009, and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 2003 JOHN DEERE SKIDLOADER #T00260A917842 OF ENVIRONMENTAL DESIGNS, INC. and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4410(1),(4). The facts supporting Count 3 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about September 9, 2009, as yet unidentified members of the enterprise unlawfully obtained control of a 2003 John Deere Skidloader, Vehicle Identification Number T00260A917842, belonging to Environmental Designs, Inc., from 975 Lincoln, City and County of Denver, State of Colorado. 3. On or about December 15, 2010, that skidloader was recovered, with identifying signs removed from it, at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. That skidloader was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That skidloader, when stolen, was valued at $17,000.00.

COUNT FOUR THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including April 23, 2010, and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 1997 HONDA ACCORD #1HGCE6679VA004475 OF MONICA SIFUENTES, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4-410(1),(4). The facts supporting Count 4 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about April 23, 2010, as yet unidentified members of the enterprise unlawfully obtained control of a 1997 Honda Accord, Vehicle Identification Number 1HGCE6679VA004475, belonging to Monica Sifuentes, from 4408 N. Cherokee Street, City and County of Denver, State of Colorado. 3. On or about December 15, 2010, parts of that vehicle were recovered, at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That vehicle, when stolen, was valued at $2,300.00.

COUNT FIVE THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including July 9, 2010 and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW, unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 1999 FORD TRUCK #1FDNF20L2XEA36615 OF ROBERT TOWNSEND, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4-410(1),(4). The facts supporting Count 5 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about July 9, 2010, as yet unidentified members of the enterprise unlawfully obtained control of a 1999 Ford Truck, Vehicle Identification Number 1FDNF20L2XEA36615, belonging to Robert Townsend, from 175 W. Maple Avenue, City and County of Denver, State of Colorado. 3. On or about December 15, 2010, parts of that vehicle were recovered, at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That vehicle, when stolen, was valued at $3,662.00.

COUNT SIX THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including July 16, 2010 and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 2001 MERCEDES BENZ C320 #WDBRF64J51F016848 OF ALISON TODHUNTER, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4-410(1),(4). The facts supporting Count 6 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about July 16, 2010, as yet unidentified members of the enterprise unlawfully obtained control of a 2001 Mercedes Benz C320, Vehicle Identification Number WDBRF64J51F016848, belonging to Alison Todhunter, from 17199 State Highway 74, Morrison, Jefferson County, State of Colorado. 3. On or about December 15, 2010, parts of that vehicle were recovered, at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That vehicle, when stolen, was valued at $15,539.00.

COUNT SEVEN THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including August 14, 2010 and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 1999 GMC JIMMY #1GKDT13W2X2523053 OF DON TITUS, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4-410(1),(4). The facts supporting Count 7 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about August 14, 2010, as yet unidentified members of the enterprise unlawfully obtained control of a 1999 GMC JIMMY, Vehicle Identification Number 1GKDT13W2X2523053, belonging to Don Titus, from 9595 Pecos Street, Thornton, Adams County, State of Colorado. 3. On or about December 15, 2010, parts of that vehicle were recovered, at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That vehicle, when stolen, was valued at $2,975.00.

COUNT EIGHT THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including August 18, 2010 and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 2000 FORD EXPLORER #1FMZU74E9YZA885 OF DEBBI EBAUGH, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4-410(1),(4). The facts supporting Count 8 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about August 18, 2010, as yet unidentified members of the enterprise unlawfully obtained control of a 2000 Ford Explorer, Vehicle Identification Number 1FMZU74E9YZA885, belonging to Debbi Ebaugh, from 11801 N. Washington Street, Northglenn, Adams County, State of Colorado. 3. On or about December 15, 2010, parts of that vehicle were recovered, at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That vehicle, when stolen, was valued at $3,325.00.

COUNT NINE THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including September 6, 2010 and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 1997 FORD F250 #1FTHF25H0VEB34707 OF RONALD MOORE, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4-410(1),(4). The facts supporting Count 9 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about September 6, 2010, as yet unidentified members of the enterprise unlawfully obtained control of a 1997 Ford F250, Vehicle Identification Number 1FTHF25H0VEB34707, belonging to Ronald Moore, from 10101 W. I-70 Frontage Road, Wheat Ridge, Jefferson County, State of Colorado. 3. On or about December 15, 2010, parts of that vehicle were recovered, at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That vehicle, when stolen, was valued at $3,512.00.

COUNT TEN THEFT BY RECEIVING, C.R.S. 18-4-410(1),(5) (F3) <0805H> Between and including September 20, 2010 and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 2007 CADILLAC ESCALADE #1GYFK63807R131485 OF ALPINE BUICK, PONTIAC and GMC, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was twenty thousand dollars or more; in violation of section C.R.S. 18-4-410(1),(5). The facts supporting Count 10 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about September 20, 2010, as yet unidentified members of the enterprise unlawfully obtained control of a 2007 Cadillac Escalade, Vehicle Identification Number 1GYFK63807R131485, belonging to Alpine Buick, Pontiac, and GMC, from 8120 W. Tufts Avenue, City and County of Denver, State of Colorado. 3. On or about December 15, 2010, parts of that vehicle were recovered; at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That vehicle, when stolen, was valued at $29,000.00.

COUNT ELEVEN THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including October 15, 2010 and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 1997 NISSAN MAXIMA #JN1CA21D8VT219417 OF MARTIN RANGEL-FONSECA, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4-410(1),(4). The facts supporting Count 11 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about October 15, 2010, as yet unidentified members of the enterprise unlawfully obtained control of a 1997 Nissan Maxima, Vehicle Identification Number JN1CA21D8VT219417, belonging to Martin Rangel-Fonseca, from 3550 S. Kendall Street, City and County of Denver, State of Colorado. 3. On or about December 15, 2010, parts of that vehicle were recovered; at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That vehicle, when stolen, was valued at $1,975.00.

COUNT TWELVE THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including October 23, 2010 and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 1997 PONTIAC GRAND PRIX #1G2WP12K5VF324340 OF PATRICIA SCHERZER, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4-410(1),(4). The facts supporting Count 12 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about October 23, 2010, as yet unidentified members of the enterprise unlawfully obtained control of a 1997 Pontiac Grand Prix, Vehicle Identification Number 1G2WP12K5VF324340, belonging to Patricia Scherzer, from 32 N. Zenobia Street, City and County of Denver, State of Colorado. 3. On or about December 15, 2010, that vehicle, largely intact, was recovered; at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That vehicle, when stolen, was valued at $2,425.00.

COUNT THIRTEEN THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including November 2, 2010 and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 1996 HONDA PRELUDE #JHMBB2250TC005627 OF KAYLA CUBA-BLINDERMAN, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4-410(1),(4). The facts supporting Count 13 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about November, 2, 2010, as yet unidentified members of the enterprise unlawfully obtained control of a 1996 Honda Prelude, Vehicle Identification Number JHMBB2250TC005627, belonging to Kayla Cuba-Blinderman, from 3481 S. Fenton Street, City and County of Denver, State of Colorado. 3. On or about December 15, 2010, parts of that vehicle were recovered; at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That vehicle, when stolen, was valued at $2,350.00.

COUNT FOURTEEN THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including November 20, 2010 and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 1995 ACURA INTEGRA #JH4DC4453SS012588 OF ANA MEJIA-GODOY, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4-410(1),(4). The facts supporting Count 14 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about November 20, 2010, as yet unidentified members of the enterprise unlawfully obtained control of a 1995 Acura Integra, Vehicle Identification Number JH4DC4453SS012588, belonging to Ana Mejia-Godoy, from 2172 S. Eaton Street, City and County of Denver, State of Colorado. 3. On or about December 15, 2010, parts of that vehicle were recovered; at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That vehicle, when stolen, was valued at $2,275.00.

COUNT FIFTEEN THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including November 23, 2010 and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 2006 SUBARU OUTBACK #4S4BP61C967329629 OF THOMAS KOSTY, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4-410(1),(4). The facts supporting Count 15 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about November 23, 2010, as yet unidentified members of the enterprise unlawfully obtained control of a 2006 Subaru Outback, Vehicle Identification Number 4S4BP61C967329629, belonging to Thomas Kosty, from 6814 Balsam Street, Arvada, Jefferson County, State of Colorado. 3. On or about December 15, 2010, parts of that vehicle were recovered; at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That vehicle, when stolen, was valued at $11,550.00.

COUNT SIXTEEN THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including November 27, 2010 and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 2000 JEEP WRANGLER #1J4FA49S7YP792471 OF JAMES KNIFLEY, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4-410(1),(4). The facts supporting Count 16 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about November 27, 2010, as yet unidentified members of the enterprise unlawfully obtained control of a 2000 JEEP WRANGLER, Vehicle Identification Number 1J4FA49S7YP792471, belonging to JAMES KNIFLEY, from Bartley City Park, Bartely, Red Willow County, Nebraska. 3. On or about December 15, 2010, that vehicle was recovered; at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That vehicle, when stolen, was valued at $6,375.00.

COUNT SEVENTEEN THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including December 3, 2010 and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 1999 CHEVROLET TRUCK #2GCEC19T9X1246995 OF MARTIN RIOS ESCOBAR, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4-410(1),(4). The facts supporting Count 17 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about December 3, 2010, as yet unidentified members of the enterprise unlawfully obtained control of a 1999 Chevrolet Truck, Vehicle Identification Number 2GCEC19T9X1246995, belonging to Martin Rios Escobar, from 6913 W. 13th Avenue, Lakewood, Jefferson County, State of Colorado. 3. On or about December 15, 2010, that vehicle was recovered; at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That vehicle, when stolen, was valued at $4,300.00.

COUNT EIGHTEEN THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including December 6, 2010 and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 1998 RANGE ROVER #SALPV1443WA386900 OF DEBBIE HARDY, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4-410(1),(4). The facts supporting Count 18 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about December 6, 2010, as yet unidentified members of the enterprise, using a C & M Towing and Recovery flatbed tow truck, unlawfully obtained control of a 1998 Range Rover, Vehicle Identification Number SALPV1443WA386900, belonging to Debbie Hardy, from 4765 Federal Boulevard, City and County of Denver, State of Colorado. 3. On or about December 15, 2010, parts of that vehicle were recovered at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That vehicle, when stolen, was valued at $4,100.00.

COUNT NINETEEN THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including December 6, 2010 and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 2004 FORD TRUCK #1FTRX12W14NB30937 OF HARLAN RIEFSCHEIDER, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4-410(1),(4). The facts supporting Count 19 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about December 6, 2010, as yet unidentified members of the enterprise unlawfully obtained control of a 2004 Ford Truck, Vehicle Identification Number 1FTRX12W14NB30937, belonging to Harlan Riefscheider, from 5250 E. Evans Avenue, City and County of Denver, State of Colorado. 3. On or about December 15, 2010, parts of that vehicle were recovered at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. That vehicle was recovered inside a Quonset-style building on that property that was equipped as an automotive workshop, including drills, saws, impact wrenches, and other tools. That vehicle was in the process of being disassembled (chopped) when it was recovered. 4. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That vehicle, when stolen, was valued at $6,875.00.

COUNT TWENTY THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including December 7, 2010 and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 2003 SUBARU IMPREZA #JF1GG29693G803713 OF ELISE DENBOW, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4-410(1),(4). The facts supporting Count 20 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about December 7, 2010, as yet unidentified members of the enterprise unlawfully obtained control of a 2003 Subaru Impreza, Vehicle Identification Number JF1GG29693G803713, belonging to Elise Denbow, from 10115 W. 25th Avenue, Lakewood, Jefferson County, State of Colorado. 3. On or about December 15, 2010, that vehicle was recovered; at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 5. That vehicle, when stolen, was valued at $5,900.00.

COUNT TWENTY-ONE THEFT BY RECEIVING, C.R.S. 18-4-410(1),(4) (F4) <0805K> Between and including December 9, 2010 and December 15, 2010, at and triable in the City and County of Denver, State of Colorado, CHARLES WAYNE WRENFROW and MICHELLE JEAN WRENFROW unlawfully and feloniously received, retained, loaned money by pawn or pledge, or disposed of a thing of value, namely: 2005 SUBARU IMPREZA #JF1GD70685L520975 OF JASON BRANDT, and the defendants knew or believed the thing of value had been stolen and intended to deprive the lawful owner, permanently of its use or benefit, and the value of the property was one thousand dollars or more but less than twenty thousand dollars; in violation of section C.R.S. 18-4-410(1),(4). The facts supporting Count 21 are as follows: 1. All facts in support of all other counts are incorporated herein by reference.

2. On or about December 9, 2010, as yet unidentified members of the enterprise unlawfully obtained control of a 2005 Subaru Impreza, Vehicle Identification Number JF1GD70685L520975, belonging to Jason Brandt, from 21st Street and Welton, City and County of Denver, State of Colorado. 3. On or about December 14, 2010, Charles Wayne Wrenfrow advertised parts from that stolen Subaru for sale on an internet auction site. Mr. Brandt and a Denver Police Detective, acting in an undercover capacity, arranged to buy those advertised parts at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 4. On or about December 15, 2010, parts of that vehicle were recovered at the C & M Towing impound lot at 821 W. 56th Avenue, Adams County, State of Colorado. 5. That vehicle was never registered to Charles Wayne Wrenfrow, Michelle Jean Wrenfrow, or C & M Towing and Recovery, Inc. 6. That vehicle, when stolen, was valued at $18,573.17.

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