The People of the State of Colorado vs. Judy Faith Abdo — District Court, Prowers County, Colorado (2022CR13)

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A Complaint and Information in The People of the State of Colorado vs. Judy Faith Abdo, Case No. D0502022CR000013, in the District Court, Prowers County, Colorado, signed /s/ by District Attorney Joshua Lee Vogel with the date 2/25/2022. It lists Counts 1 through 8: theft, cybercrime, theft, attempt to influence a public servant, forgery, filing a false tax return, criminal impersonation and unemployment false statement. The information alleges that the defendant obtained money of the Colorado Department of Labor and Employment and made a false statement to obtain unemployment benefits. The caption lists Brian L Lucero and Mikayla Trinity Gordon as co-defendants under separate case numbers.

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District Court, Prowers County, Colorado ID: AIA7BAAD2ACSS
301 South Main, Suite 300 CASE NUMBER: 2022CR13

THE PEOPLE OF THE STATE OF
COLORADO

VS.

JUDY FAITH ABDO,

Defendant C1 COURT USE ONLY O

Joshua Lee Vogel
Fifteenth Judicial District
District Attorney, # 43696 Case No: D0502022CR000013
110 E. Oak Street
Phone Number: 719-336-7446 Div: D Courtroom:
Fax: 719-336-2759

COMPLAINT AND INFORMATION

CHARGES: 8
COUNT 1: THEFT, C.R.S. 18-4-401(1),(2)(h) (F4){08A15}
COUNT 2: CYBERCRIME, C.R.S. 18-5.5-102(1)(d),(3)(a)(VID) (F4){1503R}
COUNT 3: THEFT, C.R.S. 18-4-401(1),(2)(g) (F5){08A14}

COUNT 4: ATTEMPT TO INFLUENCE A PUBLIC SERVANT, C.R.S. 18-8-306
(F4){24051}

COUNT 5: FORGERY, C.R.S. 18-5-102(1)(c) (F5){1001C}
COUNT 6: FILING A FALSE TAX RETURN, C.R.S. 39-21-118(4) (F5){40024}

COUNT 7: CRIMINAL IMPERSONATION, C.R.S. 18-5-113(1)(b)(I]) (F6){1011F}

CO-DEFENDANT: D0502022CR000014 - Brian L Lucero, D0502022CR000012 -
Mikayla Trinity Gordon

Permission to file information in district court granted:
Judge:

Signature Date
People v. Judy Faith Abdo Case No.: D0502022CR000013

COUNT 8: UNEMPLOYMENT-FALSE STATEMENT, C.R.S. 8-81-101(1)(a)

Page 2 of 12
People v. Judy Faith Abdo Case No.: D0502022CR000013

Joshua Lee Vogel, District Attorney for the Fifteenth 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 Prowers:

COUNT 1-THEFT (F4)

Between and including November 1, 2020 and March 30, 2021, within the State of
Colorado, Judy Faith Abdo unlawfully, feloniously, and knowingly obtained or exercised
control over a thing of value, namely: money, of the Colorado Department of Labor and
Employment (CDLE) twice or more within a period of six months, with an aggregate
value of twenty thousand dollars or more but less than one hundred thousand dollars,
without authorization, or by threat or deception, and intended to deprive the victim
permanently of its use or benefit; in violation of section 18-4-401(1)(a),(2)(h), C.R.S.

COUNT 2-CYBERCRIME (F4)

Between and including April 26, 2020 and May 14, 2021, within the State of Colorado,
Judy Faith Abdo unlawfully, feloniously, and knowingly accessed a computer, computer
network, or computer system, or any part thereof to commit theft, and the loss, damage,
value of services, or thing of value taken, or cost of restoration or repair was twenty
thousand dollars or more but less than one hundred thousand dollars; in violation of
section 18-5.5-102(1)(d),(3)(a)(VID, C.R.S.

COUNT 3-THEFT (F5)

Between and including May 1, 2020 and November 1, 2020, within the State of
Colorado, Judy Faith Abdo unlawfully, feloniously, and knowingly obtained or exercised
control over a thing of value, namely: money, of the Colorado Department of Labor and
Employment (CDLE) twice or more within a period of six months, with an aggregate
value of five thousand dollars or more but less than twenty thousand dollars, without

authorization, or by threat or deception, and intended to deprive the victim permanently
of its use or benefit; in violation of section 18-4-401(1)(a),(2)(g), C.R.S.

COUNT 4-ATTEMPT TO INFLUENCE A PUBLIC SERVANT (F4)

Between and including April 26, 2020 and May 14, 2021, within the State of Colorado,
Judy Faith Abdo unlawfully and feloniously attempted to influence CDLE Executive
Director Joseph Barela and/or his employees and designees, a public servant, by means of
deceit, with the intent thereby to alter or affect the public servant's decision, vote,
opinion, or action concerning a matter which was to be considered or performed by the

public servant or the agency or body of which the public servant was a member; in
violation of section 18-8-306, C.R.S.

Page 3 of 12
People v. Judy Faith Abdo Case No.: D0502022CR000013

COUNT 5-FORGERY (F5)

On or about April 26, 2020, within the State of Colorado, Judy Faith Abdo with the intent
to defraud the Colorado Department of Labor and Employment (CDLE), 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, a deed, will, codicil, contract, assignment, commercial instrument,
promissory note, or other instrument which document did or may have evidenced,
created, transferred, terminated, or otherwise affected a legal right, interest, obligation, or
status, namely: an altered tax document related to Judy Faith Abdo; in violation of
section 18-5-102(1)(c), C.R.S.

COUNT 6-FILING A FALSE TAX RETURN (F5)

On or about March 14, 2021, within the State of Colorado, Judy Faith Abdo unlawfully,
feloniously, and willfully made and subscribed a return, statement, or other document,
which contained or was verified by a written declaration that it was made under the
penalties of perjury, and which the defendant did not believe to be true and correct as to
every material matter; in violation of section 39-21-118(4), C.R.S.

COUNT 7-CRIMINAL IMPERSONATION (F6)

Between and including November 1, 2020 and March 30, 2021, within the State of
Colorado, Judy Faith Abdo unlawfully, feloniously, and knowingly assumed a false or
fictitious identity or capacity, legal or other, namely: Mikayla Gordon, and in such
identity or capacity performed an act with intent to unlawfully gain a benefit for herself

or another or to injure or defraud another; in violation of section 18-5-113(1)(b)I),
C.RS.

COUNT 8-UNEMPLOYMENT-FALSE STATEMENT (M)

Between and including April 26, 2020 and May 14, 2021, within the State of Colorado,
Judy Faith Abdo unlawfully made a false statement or representation of a material fact
knowing it to be false, or knowingly failed to disclose a material fact, with the intent to
defraud, by obtaining or increasing any benefit either for himself or for any other person,
under articles 70 to 82 of title 8 of the Colorado Revised Statutes or under an
employment security law of any other state, of the federal government, or of a foreign
government; in violation of section 8-81-101(1)(a), C.R.S.

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People v. Judy Faith Abdo Case No.: D0502022CR000013

All offenses against the peace and dignity of the people of the State of Colorado.

Joshua Lee Vogel
District Attorney, #: 43696

By: _/s/ Joshua Lee Vogel Date: 2/25/2022
Joshua Lee Vogel #: 43696
District Attorney

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