MOTION TO ADD COUNTS 8-37

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1 COUNTY COURT, BOULDER COUNTY, COLORADO Court Address: Boulder County Justice Center 1777 Sixth St Boulder, Colorado Court Phone: (303) PEOPLE OF THE STATE OF COLORADO vs. EMILY ELIZABETH COHEN, Defendant Attorney Name: Jane Walsh, Reg. # Deputy Boulder County Justice Center 1777 Sixth Street Boulder, CO Attorney Phone: (303) Attorney Fax: (303) Attorney COURT USE ONLY Case No: 14CR437 Division: 7 MOTION TO ADD COUNTS 8-37 The People, through, respectfully move this Honorable Court to add Counts 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37 and 38 as shown in the attached amendment. WHEREFORE, your Petitioner prays the Court for an Order to add Counts 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37 and 38. Respectfully submitted, By: STANLEY L. GARNETT Jane Walsh, Reg. # DISTRICT ATTORNEY Deputy March 31, 2014 IT IS SO ORDERED. Done this day of,. Judge

2 , for the Twentieth Judicial District, of the State of Colorado, in the name and by the authority of the People of the State of Colorado, informs the court of the following offenses committed, or triable, in the County of Boulder. COUNT 8- THEFT - $5,000 - $20,000 (F5) That on or about May 01, 2012 to January 31, 2014 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, feloniously, and knowingly, without value, namely: U.S. Currency, of Mayra Jauregai and Juan Ramirez Cordova, with the value of five thousand dollars or more but less than twenty thousand dollars, and intended to deprive Mayra Jauregai and Juan Ramirez Cordova permanently of its use or benefit; in violation of section (1)(a),(2)(g), C.R.S. COUNT 9- THEFT - $5,000 - $20,000 (F5) That on or about March 01, 2012 to November 01, 2013 in, or triable in, the County of Boulder, value, namely: U.S. Currency, of Tayde Jimenez and Oscar Gordillo, with the value of five thousand dollars or more but less than twenty thousand dollars, and intended to deprive Tayde Jimenez and Oscar Gordillo permanently of its use or benefit; in violation of section (1)(a),(2)(g), C.R.S. COUNT 10- THEFT - $750 - $2,000 (M1) That on or about March 01, 2013 to December 31, 2013 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, and knowingly, without authorization or by threat or deception, obtained, retained, or exercised control over a thing of value, namely: U.S. Currency, of Victor Alejandro Reyes-Nunez and Brenda Ramos, with the value of seven hundred fifty dollars or more but less than two thousand dollars, and intended to deprive Victor Alejandro Reyes-Nunez and Brenda Ramos permanently of its use or benefit; in violation of section (1)(a),(2)(e), C.R.S. COUNT 11- THEFT (F4) That on or about August 01, 2012 to November 30, 2012 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, feloniously, and knowingly obtained, retained, or exercised control over a thing of value, namely: U.S. Currency, of Jose Madrid Martinez, 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 Jose Madrid Martinez permanently of its use or benefit; in violation of section (1)(a),(2)(c), C.R.S.

3 COUNT 12- THEFT (F4) That on or about August 01, 2012 to December 31, 2012 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, feloniously, and knowingly obtained, retained, or exercised control over a thing of value, namely: U.S. Currency, of Pedro Soto Soria, 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 Pedro Soto Soria permanently of its use or benefit; in violation of section (1)(a),(2)(c), C.R.S. COUNT 13- THEFT (F4) That on or about March 01, 2012 to July 31, 2012 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, feloniously, and knowingly obtained, retained or exercised control over a thing of value, namely: U.S. Currency, of Jorge Alejandro Rivera Lopez, 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 Jorge Alejandro Rivera Lopez permanently of its use or benefit; in violation of section (1)(a),(2)(c), C.R.S. COUNT 14- THEFT (F4) That on or about September 01, 2012 to February 01, 2013 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, feloniously, and knowingly obtained, retained or exercised control over a thing of value, namely: U.S. Currency, of Lizbeth Chavarria, 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 Lizbeth Chavarria permanently of its use or benefit; in violation of section (1)(a),(2)(c), C.R.S. COUNT 15- THEFT (F4) That on or about October 01, 2011 to October 01, 2012 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: U.S. Currency, of Javier Hernandez-Portillo, 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 Javier Hernandez-Portillo permanently of its use or benefit; in violation of section (1)(a),(2)(c), C.R.S.

4 COUNT 16- THEFT (F4) That on or about February 01, 2011 to February 25, 2013 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, feloniously, and knowingly obtained, retained, or exercised control over a thing of value, namely: U.S. Currency, of Lissa and Javier Almaguer, 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 Lissa and Javier Almaguer permanently of its use or benefit; in violation of section (1)(a),(2)(c), C.R.S. COUNT 17- THEFT - $2,000 - $5,000 (F6) That on or about October 01, 2013 to February 25, 2014 in, or triable in, the County of Boulder, value, namely: U.S. Currency, of Lynette Slew, with the value of two thousand dollars or more but less than five thousand dollars, and intended to deprive Lynette Slew permanently of its use or benefit; in violation of section (1)(a),(2)(f), C.R.S. COUNT 18- THEFT - $5,000 - $20,000 (F5) That on or about November 01, 2013 to March 14, 2014 in, or triable in, the County of Boulder, value, namely: U.S. Currency, of Aurelia Santistevan and Pedro Sanchez, with the value of five thousand dollars or more but less than twenty thousand dollars, and intended to deprive Aurelia Santistevan and Pedro Sanchez permanently of its use or benefit; in violation of section (1)(a),(2)(g), C.R.S. COUNT 19- THEFT - $2,000 - $5,000 (F6) That on or about November 01, 2013 to March 14, 2014 in, or triable in, the County of Boulder, value, namely: U.S. Currency, of Natasha Santistevan and Yonjer Matute, with the value of two thousand dollars or more but less than five thousand dollars, and intended to deprive Natasha Santistevan and Yonjer Matute permanently of its use or benefit; in violation of section (1)(a),(2)(f), C.R.S.

5 COUNT 20- THEFT (F4) That on or about December 01, 2011 to February 28, 2012 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, feloniously, and knowingly obtained, retained or exercised control over a thing of value, namely: U.S. Currency, of Isela Ortiz and Alonso Quesada, 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 Isela Ortiz and Alonso Quesada permanently of its use or benefit; in violation of section (1)(a),(2)(c), C.R.S. COUNT 21- THEFT - $300 - $750 (M2) That on or about January 01, 2014 to February 28, 2014 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, and knowingly, without authorization or by threat or deception, obtained, retained, or exercised control over a thing of value, namely: U.S. Currency, of Isela Ortiz and Alonso Quesada, with the value of three hundred dollars or more but less than seven hundred fifty dollars, and intended to deprive Isela Ortiz and Alonso Quesada permanently of its use or benefit; in violation of section (1)(a),(2)(d), C.R.S. COUNT 22- THEFT - $5,000 - $20,000 (F5) That on or about October 01, 2013 to February 28, 2014 in, or triable in, the County of Boulder, value, namely: U.S. Currency, of Jose Nogueda, with the value of five thousand dollars or more but less than twenty thousand dollars, and intended to deprive Jose Nogueda permanently of its use or benefit; in violation of section (1)(a),(2)(g), C.R.S. COUNT 23- THEFT - $5,000 - $20,000 (F5) That on or about August 01, 2013 to December 31, 2013 in, or triable in, the County of Boulder, value, namely: U.S. Currency, of Gilberto Burciaga, with the value of five thousand dollars or more but less than twenty thousand dollars, and intended to deprive Gilberto Burciaga permanently of its use or benefit; in violation of section (1)(a),(2)(g), C.R.S.

6 COUNT 24- THEFT (F4) That on or about December 01, 2011 to June 30, 2012 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, feloniously, and knowingly obtained, retained or exercised control over a thing of value, namely: U.S. Currency, of New Hope Baptist Church, 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 New Hope Baptist Church permanently of its use or benefit; in violation of section (1)(a),(2)(c), C.R.S. COUNT 25- THEFT (F4) That on or about February 01, 2012 to February 01, 2013 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, feloniously, and knowingly obtained, retained or exercised control over a thing of value, namely: U.S. Currency, of Vanessa Garcia and Manuel Vazquez, 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 Vanessa Garcia and Manuel Vazquez permanently of its use or benefit; in violation of section (1)(a),(2)(c), C.R.S. COUNT 26- THEFT - $750 - $2,000 (M1) That on or about October 01, 2013 to March 14, 2014 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, and knowingly, without authorization or by threat or deception, obtained, retained, or exercised control over a thing of value, namely: U.S. Currency, of Ilya Raykhel, with the value of seven hundred fifty dollars or more but less than two thousand dollars, and intended to deprive Ilya Raykhel permanently of its use or benefit; in violation of section (1)(a),(2)(e), C.R.S. COUNT 27- THEFT - $750 - $2,000 (M1) That on or about October 01, 2013 to December 01, 2013 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, and knowingly, without authorization or by threat or deception, obtained, retained, or exercised control over a thing of value, namely: U.S. Currency, of Brenda Castillo, with the value of seven hundred fifty dollars or more but less than two thousand dollars, and intended to deprive Brenda Castillo permanently of its use or benefit; in violation of section (1)(a),(2)(e), C.R.S.

7 COUNT 28- THEFT - $750 - $2,000 (M1) That on or about October 01, 2012 to October 01, 2013 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, and knowingly, without authorization or by threat or deception, obtained, retained, or exercised control over a thing of value, namely: U.S. Currency, of Justin Faye, with the value of seven hundred fifty dollars or more but less than two thousand dollars, and intended to deprive Justin Faye permanently of its use or benefit; in violation of section (1)(a),(2)(e), C.R.S. COUNT 29- THEFT - $2,000 - $5,000 (F6) That on or about May 01, 2013 to June 30, 2013 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, feloniously, and knowingly, without authorization or by threat or deception, obtained, retained, or exercised control over a thing of value, namely: U.S. Currency, of Patrick McConnell and Caroline Commins, with the value of two thousand dollars or more but less than five thousand dollars, and intended to deprive Patrick McConnell and Caroline Commins permanently of its use or benefit; in violation of section (1)(a),(2)(f), C.R.S. COUNT 30- THEFT - $5,000 - $20,000 (F5) That on or about January 01, 2012 to January 01, 2014 in, or triable in, the County of Boulder, value, namely: U.S. Currency, of Jose Sifuentes, with the value of five thousand dollars or more but less than twenty thousand dollars, and intended to deprive Jose Sifuentes permanently of its use or benefit; in violation of section (1)(a),(2)(g), C.R.S. COUNT 31- THEFT (F4) That on or about July 01, 2012 to February 28, 2013 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, feloniously, and knowingly obtained or exercised control over a thing of value, namely: U.S. Currency, of Sergio Delgado Hernandez, 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 Sergio Delgado Hernandez permanently of its use or benefit; in violation of section (1)(a),(2)(c), C.R.S.

8 COUNT 32- THEFT (F4) That on or about January 01, 2011 to May 13, 2013 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, feloniously, and knowingly obtained, retained or exercised control over a thing of value, namely: U.S. Currency, of Amanda and Edgar Diaz, 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 Amanda and Edgar Diaz permanently of its use or benefit; in violation of section (1)(a),(2)(c), C.R.S. COUNT 33- THEFT - $5,000 - $20,000 (F5) That on or about February 01, 2012 to November 01, 2013 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, feloniously, and knowingly, without authorization or by threat or deception, obtained, retained, or exercised control over a thing of value, namely: U.S. Currency, of Osman and Caritina Avitia, with the value of five thousand dollars or more but less than twenty thousand dollars, and intended to deprive Osman and Caritina Avitia permanently of its use or benefit; in violation of section (1)(a),(2)(g), C.R.S. COUNT 34- THEFT - $5,000 - $20,000 (F5) That on or about March 01, 2013 to August 31, 2013 in, or triable in, the County of Boulder, value, namely: U.S. Currency, of Nicholas Berzins, with the value of five thousand dollars or more but less than twenty thousand dollars, and intended to deprive Nicholas Berzins permanently of its use or benefit; in violation of section (1)(a),(2)(g), C.R.S. COUNT 35- THEFT - $2,000 - $5,000 (F6) That on or about June 01, 2013 to October 31, 2013 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, feloniously, and knowingly, without value, namely: U.S. Currency, of Manas Kanungo and Miriam Mascaretti, with the value of two thousand dollars or more but less than five thousand dollars, and intended to deprive Manas Kanungo and Miriam Mascaretti permanently of its use or benefit; in violation of section (1)(a),(2)(f), C.R.S.

9 COUNT 36- THEFT - $5,000 - $20,000 (F5) That on or about March 01, 2012 to March 03, 2014 in, or triable in, the County of Boulder, authorization or by threat or deception, obtained, retained, or exercised control over; or knowing or believing it to have been stolen, received, loaned money by pawn or pledge on, or disposed of, a thing of value, namely: U.S. Currency, of Maria Jimenez-Esparza, Ricardo Valdez-Martinez and Jerry Capone, with the value of five thousand dollars or more but less than twenty thousand dollars, and intended to deprive Maria Jimenez-Esparza, Ricardo Valdez-Martinez and Jerry Capone permanently of its use or benefit; in violation of section (1)(a),(2)(g), C.R.S. COUNT 37- CRIMINAL EXTORTION (F4) That on or about September 01, 2013 to December 31, 2013 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, feloniously, and with the intent to induce Rosa Reyes Diaz, against her will to perform an act or to refrain from performing a lawful act, made a substantial threat to confine or restrain cause economic hardship to Brenda Ramos,, and the defendant threatened to cause these results by invoking action by a third party, namely: Immigration and Customs Enforcement, whose interests were not substantially related to the interests pursued by the defendant; in violation of section (1)(a),(b)(II), C.R.S. COUNT 38- CRIMINAL EXTORTION (F4) That on or about January 10, 2011 to July 01, 2013 in, or triable in, the County of Boulder, State of Colorado Emily Elizabeth Cohen unlawfully, feloniously, and with the intent to induce Javier Hernandez Portillo, against his will to perform an act or to refrain from performing a lawful act, made a substantial threat to confine or restrain cause economic hardship to Javier Hernandez Portillo, and the defendant threatened to cause these results by invoking action by a third party, namely: Immigration and Customs Enforcement, whose interests were not substantially related to the interests pursued by the defendant; in violation of section (1)(a),(b)(II), C.R.S. All offenses against the peace and dignity of the People of the State of Colorado.

10 CERTIFICATE OF SERVICE I hereby certify that I mailed a true and correct copy of this motion to: Emily Elizabeth Cohen 1938 High Street Denver, CO /s/ Dated:

CRIMINAL COMPLAINT. DISTRICT ATTORNEY before me March 14, 2014

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