Complaint and Information — People v. Brian Lee Lucero, No. D0502022CR000014 (Prowers County, Colorado)

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A Complaint and Information in People of the State of Colorado v. Brian Lee Lucero, Case Number 2022CR14 (Case No. D0502022CR000014), in the District Court, Prowers County, Colorado. Joshua Lee Vogel, District Attorney for the Fifteenth Judicial District, signs it, with a date of 2/25/2022. It charges theft, identity theft, cybercrime, attempt to influence a public servant, forgery, filing a false tax return, criminal impersonation and unemployment false statement. The theft counts allege that the defendant obtained money of the Colorado Department of Labor and Employment (CDLE) with an aggregate value of twenty thousand dollars or more but less than one hundred thousand dollars. The caption lists co-defendants Judy Faith Abdo and Mikayla Trinity Gordon.

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District Court, Prowers County, Colorado FILING ID: 167CF64E6C84E
301 South Main, Suite 300 CASE NUMBER: 2022CR14
Lamar, CO 81052

THE PEOPLE OF THE STATE OF
COLORADO

VS.

BRIAN LEE LUCERO,
Defendant C1) COURT USE ONLY 0

Joshua Lee Vogel
Fifteenth Judicial District
District Attorney, # 43696 Case No: D0502022CR000014
110 E. Oak Street
Lamar, CO 81052
Phone Number: 719-336-7446 Div: D Courtroom:
Fax: 719-336-2759

COMPLAINT AND INFORMATION

CHARGES: 10
COUNT 1: THEFT, C.R.S. 18-4-401(1),(2)(h) (F4){08A 15}
COUNT 2: IDENTITY THEFT, C.R.S. 18-5-902(1)(a) (F4){1307G}
COUNT 3: THEFT, C.R.S. 18-4-401(1),(2)(h) (F4){08A 15}
COUNT 4: CYBERCRIME, C.R.S. 18-5.5-102(1)(d),(3)(a)(VID) (F4){1503R}

COUNT 5: ATTEMPT TO INFLUENCE A PUBLIC SERVANT, C.R.S. 18-8-306
(F4){24051}

COUNT 6: FORGERY, C.R.S. 18-5-102(1)(c) (F5){1001C}
COUNT 7: FORGERY, C.R.S. 18-5-102(1)(c) (F5){1001C}

COUNT 8: FILING A FALSE TAX RETURN, C.R.S. 39-21-118(4) (F5){40024}

CO-DEFENDANT: D0502022CR000013 - Judy Faith Abdo, D0502022CR000012 -
Mikayla Trinity Gordon

Permission to file information in district court granted:
Judge:

Signature Date
People v. Brian Lee Lucero Case No.: D0502022CR000014

COUNT 9: CRIMINAL IMPERSONATION, C.R.S. 18-5-113(1)(b)(ID (F6){1011F}

COUNT 10: UNEMPLOYMENT-FALSE STATEMENT, C.R.S. 8-81-101(1)(a)

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People v. Brian Lee Lucero Case No.: D0502022CR000014

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 April 29, 2020 and October 29, 2020, within the State of
Colorado, Brian Lee Lucero 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-IDENTITY THEFT (F4)

Between and including April 20, 2020 and November 10, 2020, within the State of
Colorado, Brian Lee Lucero unlawfully, feloniously, and knowingly used the personal
identifying information, financial identifying information, or financial device of Kenneth
Tutsch without permission or lawful authority with the intent to obtain cash, credit,

property, services, or any other thing of value or to make a financial payment; in
violation of section 18-5-902(1)(a), C.R.S.

COUNT 3-THEFT (F4)

Between and including November 1, 2020 and March 30, 2021, within the State of
Colorado, Brian Lee Lucero 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),

COUNT 4-CYBERCRIME (F4)

Between and including April 20, 2020 and March 30, 2021, within the State of Colorado,
Brian Lee Lucero 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.

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People v. Brian Lee Lucero Case No.: D0502022CR000014

COUNT 5-ATTEMPT TO INFLUENCE A PUBLIC SERVANT (F4)

Between and including April 20, 2020 and April 20, 2021, within the State of Colorado,
Brian Lee Lucero 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.

COUNT 6-FORGERY (F5)

On or about April 21, 2020, within the State of Colorado, Brian Lee Lucero 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 ri ght, interest,
obligation, or status, namely: an altered tax document related to Kenneth Tutsch; in
violation of section 18-5-102(1)(c), C.R.S.

COUNT 7-FORGERY (F5)

On or about April 22, 2020, within the State of Colorado, Brian Lee Lucero 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 Brian Lee Lucero; in
violation of section 18-5-102(1)(c), C.R.S.

COUNT 8-FILING A FALSE TAX RETURN (F5)

On or about February 15, 2021, within the State of Colorado, Brian Lee Lucero
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.

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People v. Brian Lee Lucero Case No.: D0502022CR000014

COUNT 9-CRIMINAL IMPERSONATION (F6)

Between and including April 20, 2020 and November 10, 2020, within the State of
Colorado, Brian Lee Lucero unlawfully, feloniously, and knowingly assumed a false or
fictitious identity or capacity, legal or other, namely: Kenneth Tutsch, and in such
identity or capacity performed 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)(b)UD,
C.R.S.

COUNT 10-UNEMPLOYMENT-FALSE STATEMENT (M)

Between and including April 20, 2020 and April 20, 2021, within the State of Colorado,
Brian Lee Lucero 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.

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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