Executive Summary with links to the Verified Complaint

Did four Colorado Springs Police Department homicide detectives (Exley, Aulino, Aragon, and Lehukuhl) conspire to frame Jean-Joseph LeChiffre, and to violate his rights to Equal Protection of the laws? Did those detectives do so because of LeChiffre’s support of the “Black Lives Matter” movement, and of his support of the call to defund the Police? Was the conspiracy driven by LeChiffre’s former legal representation of the so-called “Bad Boys”[LeChiffre v. Exley #52], including Rosario Gambino (alleged Sicilian Mafioso); Aleksandr Litvinenko (FSB Russian Agent); Pavel Lazarenko (Former Prime Minister of Ukraine); and alleged members of various international criminal organizations? [LeChiffre v. Exley #36]

Did those same homicide detectives, and other cspD officers violate LeChiffre’s right to equal protection for the financial benefit of Mark Anthony Sandoval, [LeChiffre v. Exley #620], retired CSPD officer to whom they had a binding duty of “loyalty” and “unity”, based upon the “Thin Blue Line”? [LeChiffre v. Exley #176].

Did Mark Sandoval’s friend and employee, Jennifer Martinez [LeChiffre v. Exley #567] conspire to frame Jean- Joseph LeChiffre in return for the “sale” of a house in Colorado Springs by Mark Sandoval and Marcella Sandoval to Jennifer Martinez’s son, Rudy for a below market price? Was the deal sweetened by the “sale” of a house in New Mexico by Mark Sandoval and Marcela Sandoval to Jennifer Martinez and her Husband, Xavier, For an undisclosed “consideration”? [LeChiffre v. Exley #543] and [link g].

Did Mark A. Sandoval rely upon the “Thin Blue Line” in order to: (1) protect himself from the stigma of being identified as a “suspect” or “person of interest” [LeChiffre v. Exley #453] in the homicide of his father, Gilbert Sandoval; (2) gain absolute control over Marcella Sandoval’s 10 million dollar estate [LeChiffre v. Exley #338]; (3) protect his mother, Marcella Sandoval from arrest and prosecution [LeChiffre v. Exley #108]; and (4) satisfy his need for vengeance against his favored younger brother… LeChiffre?


Marcella Sandoval (hereinafter  “Marcella”) was a battered spouse who suffered 55(+) years of domestic violence, financial fraud, medical neglect, verbal abuse, emotional neglect adultery, and marital rape. After the violence escalated in 2018, and 2019, Marcella applied for, and was granted a Permanent Protection order (“PPO”).  [LeChiffre v. Exley #93] The tipping point was when Marcella’s husband, Gilbert Sandoval, stole $171,000.00, from her personal savings account [LeChiffre v. Exley #74]. That theft led to a confrontation where Gilbert Sandoval pointed a loaded Walther 38 semi-automatic handgun at her face when she demanded return of the funds. [LeChiffre v. Exley #75]

At the PPO hearing, Marcella testified to decades of abuse, and claimed a “fear” for her life [LeChiffre v. Exley #93]. LeChiffre corroborated the escalating domestic violence, neglect, and stalking. Mark A. Sandoval, however, refused to testify in support of Marcella, out of fear of Gilbert Sandoval, and in his own self-interest. Mark Sandoval’s own thoughts on the matter were expressed to detective Exley in a recorded police interview: “the cool thing was that I didn’t take a side, what good would that have done for me?” [LeChiffre v. Exley #81]

With respect to the PPO, the Judge found: “It’s really over the past year [2018-19] that Mr. [Gilbert] Sandoval has gotten increasingly – increasingly – increasingly aggressive. I do find that Mr. [Gilbert] Sandoval is a danger to Mrs. [Marcella] Sandoval, he [Gilbert Sandoval] shall be prohibited from possessing or owning any firearms or ammunition.” [LeChiffre v. Exley #89]. Notably, the very same Judge Found Jennifer Martinez’s testimony in support of Gilbert Sandoval to be “incredible.” [LeChiffre v. Exley #517].

THE FIRST 48 (+):

On July 22, 2020, in violation of the PPO, Gilbert Sandoval met Marcella at her home. [LeChiffre v. Exley #101] Unknown to Marcella at the time, Gilbert Sandoval’s young mistress, Julie Trimble (age 52), had allegedly been searching for a “hit man” to murder Marcella [LeChiffre v. Exley #312]. The murder would have cleared the way for Ms. Trimble to marry Gilbert Sandoval (age 82). Also at that time, Ms. Trimble had been prodding Gilbert Sandoval to obtain life insurance policies covering wrongful death, with Julie Trimble as the beneficiary. [LeChiffre v. Exley #308].

On July 22, 2020, at or around 12:30 pm, Gilbert Sandoval was found dead by Gilbert’s friend, Mr. Steve Long, who then called 911, and assisted Marcella with her injuries. Marcella later advised her lawyer that Gilbert Sandoval was armed with a knife, and that Gilbert pushed her down a staircase at which time she defended herself. In fact, the Official Coroner’s Report stated:

“CSPD reported that, according to Marcella’s statement through her lawyer that earlier that day, she and decedant [Gilbert Sandoval] were walking down to the basement so Marcella could show decedant a bathroom renovation. Marcella stated that as she was walking down the stairs, the decedant allegedly pushed her from behind. Marcella stated she noticed the decedant had a knife, and grabbed a [weapon] that she kept in the basement to protect herself. Marcella stated that she “whacked” the decedant twice and then returned upstairs.” [LeChiffre v. Exley #108].

Mark Sandoval, who was then a “person of interest” due to his prior knowledge of the meeting, as well as his “access” to the scene and to the parties [LeChiffre v. Exley #102], arrived at the scene, and created a false narrative that LeChiffre had “recently been taken out of the Will.” [LeChiffre v. Exley #119]. As the Executor of Gilbert Sandoval’s Last Will, Mark Sandoval knew that such a ciaim was demonstrably false. [LeChiffre v. Exley #120] Sadly, that false narrative was not the first time that Mark Sandoval was less than honest in a major crime investigation, according to CSPD Internal Affairs. [LeChiffre v. Exley #82].

Detectives Exley, Aulino, Aragon, and Lehmkuhl, and others, rallied around Mark A. Sandoval, a fellow member of the “Thin Blue Line”. The first step was for Exley and Lehmkuhl to isolate Marcella, by placing her in Mark Sandoval’s exclusive protective custody. [LeChiffre v. Exley #269] This was crucial, as it prevented Marcella from making any further statements against her interest i.e., that she killed Gilbert Sandoval in self-defense. At Mark Sandoval’s home, Marcella was prevented from speaking to any friends, or family, while her story was fabricated, nuanced, and practiced … for 36 days! [LeChiffre v. Exley #278]

During those first 48 hours, other events were occurring. (1) Julie Trimble’s daughter called detective Aulino to advise him of her concerns that Ms . Trimble was involved in Gilbert Sandoval’s death, and of the alleged solicitation to commit murder [LeChiffre v. Exley #315]. (2) detective Aulino interviewed Julie Trimble, but did not ask about the solicitation to commit murder, or request to make a copy of her phone, after she told Aulino that she purposefully left it her car because she did not feel “comfortable” talking the phone inside of the police station… in response, Aulino replied “I appreciate that .” [LeChiffre v. Exley #235] (3) Jennifer Martinez secretly records two or more phone calls with LeChiffre, where she tries to obtain a recorded confession, and information about Gilbert Sandoval’s death; (4) Detective Aulino leaves a message or messages on Jennifer Martinez’s phone, seeking assistance with the investigation [LeChiffre v. Exley #525]; (5) Jennifer Martinez ignores Aulino’s phone call or calls; (6) Mark Sandoval offers his “humble opinion” that Gilbert Sandoval’s death was “about the money” [LeChiffre v. Exley #451]; and (7) Mar’k Sandoval hires a lawyer to file a Petition for Guardianship and Conservatorship in order to wrest away complete control of Marcella’s money, without an appreciation of the irony involved. [LeChiffre v. Exley #389].


Regarding Marcella – (1) Gilbert Sandoval’s blood spatter was found on her shoes, skirt, blouse, legs, arms, and face; (2) her own blood drops were found on and around Gilbert Sandoval’s body; (3) her own blood drops were found on her shoes and leading from Gilbert’s body- up the basement stairs and to her room; (4) her own blood drops were found mixed with Gilbert Sandoval’s blood on the basement floor; (5) her footprints were found stepping through the blood spatter; (6) her blood and DNA were found on the blade of a knife in Gilbert Sandoval’s control; (7) injuries to her hands and arms were consistent with knife wounds; (8) and audio recording found at the scene captured two voices – hers and Gilbert Sandoval’s ; (9) she admitted that after she “whacked” Gilbert Sandoval twice, she retreated upstairs; (10) Marcella Sadoval’s motive, and her claim of self defense is consistent with a victim of domestic violence, who suffered decades of abuse, neglect, fraud, physical, violence, stalking, menacing, and the humiliation of Gilbert Sandoval’s affair with Julie Trimble which lasted more than 15 years, and which was openly and notoriously conducted in front of Marcella’s friends and neighbors. [LeChiffre v. Exley #108], [LeChiffre v. Exley #218], [LeChiffre v. Exley #388]

Tying up this mountain of evidence against Marcella, the colorado Bureau of Investigations tested the weapon used to kill Gilbert Sandoval, finding 3 DNA profiles: (1) Marcella Sandoval’s profile; (2) Gilbert Sandoval’s profile; and (3) Mark Anthony Sandoval’s profile! Notably, the Colorado Bureau of Investigations specifically excluded LeChiffre’s DNA from the weapon that killed Gilbert Sandoval! [LeChiffre v. Exley #134].

Regarding LeChiffre: There was zero blood spatter on Lechiffre’s shoes, socks, shorts, or shirt; (2) there was zero blood spatter on LeChiffre’s watch, glasses, face, or body; (3) there were zero blood drops or stains found at LeChiffre’s residence; (4) there were zero eyewitnesses (placing LeChiffre at the scene); (5) Marcelia Sandoval’s statements, and testimony made clear that she did not see, or hear LeChiffre during the afternoon of July 22, 2020 – until after the paramedics and police arrived; (6) there were zero video recordings of LeChiffre going to, or coming from the scene on July 22, 2020; (7) there were zero fingerprints attributed to LeChiffre at the scene; (8) there were zero bloody footprints or shoeprints attributed to LeChiffre at the scene; (9) there was zero DNA evidence placing Lechiffre at the scene; and (10) contrary to the alleged motive manufactured by Mark A. Sandoval, LeChiffre had not been excluded from the Last Will, but rather, the Last Will of 2013, Which Mark A. Sandoval was the Executor, provided for 50% of the estate to be placed in Trust for LeChiffre and his children. [LeChiffre v. Exley #195], [LeChiffre v. Exley #135], [LeChiffre v. Exley #500]

The physical evidence pointed in one direction… Marcella. Further, there was zero probable cause to arrest LeChiffre. There was, however, one way around the lack of physical evidence and motive… coerce Marcella to point the finger at her son, or risk torture in the El Paso County Jail, medical neglect, malnutrition, and diabetic coma. [BreakingDanger.com Website].


As mentioned above, detective Lehmkuhl placed Marcella into Mark Sandoval’s protective custody, even though he was, or should have been considered a suspect or person of interest. [LeChiffre v. Exley #453]. It was a favor granted to a fellow member of the “Thin Blue Line” that would overcome the lack of evidence against LeChiffre. For 36 days, with the assistance of the CSPD, Mark Sandoval kept Marcella isolated, and without the support of her loved ones, as she recuperated from her physical injuries, and mourned the loss of her husband, Gilbert Sandoval. This isolation was by design, and acknowledged by Mark Sandoval during an official interview. [LeChiffre v. Exley #419] Furthermore, it was done not for Marcella’s benefit, but for the benefit of the CSPD, and for Mark Sandoval.  [LeChiffre v. Exley #416]

During this 36 day period, Mark Sandoval continued to conduct a private investigation of the homicide, with the assistance of detective Exley and the CSFD. [LeChiffre v. Exley #423] Not only was detective Exley running interference for Mark Sandoval, under the color of law; when Mark Sandoval had information that he wanted to give to Exley, but that he wanted to shield from discovery, detective. Exley obliged. In Mark Sandoval’s own words: “The reason that I don’t like being in here [police station interview room] is because I want – I want to say something that can’t be recorded.” [LeChiffre v. Exley #421] Notably, whatever Mark Sandoval had to say was NOT recorded.

At least two other CSPD officers assisted in the conspiracy, when Marcella’s nephew, Raymond Valdez, requested a welfare check of an at-risk adult in order to verify Marcella’s safety. [LeChiffre v. Exley #361]. As Mr. Valdez waited at Mark Sandoval’s front step, two CSPD officers spoke privately with Mark Sandoval (after turning off their body cameras ), then advised Mr. Valdez that he would have to leave the neighborhood, and that he could not speak with Marcella, or see Marcella. [LeChiffre v. Exley #367] On information and belief, those CSPD officers then spoke with Marcella privately, and attempted to persuade her to cooperate with the CSPD, and Mark Sandoval. [LeChiffre v. Exley #493].

Those two CSPD officers, and others, then deleted the “call for service” associated with Mark Sandoval’s address, and agreed to destroy evidence, and refrain from filing a police report that would otherwise memorialize their interaction with Marcella and Mark Sandoval. [LeChiffre v. Exley #369], [LeChiffre v. Exley #376].

On day 36, Mark Sandoval drove Marcella to the CSPD Operations Center in order to give a “voluntary” statement. This was two weeks after Jennifer Martinez refused to give her own “voluntary statement”, at Mark A. Sandoval’s urging. [LeChiffre v. Exley #527]

During her “voluntary” statement, Marcella was recorded stating as follows: (1) LeChiffre was NOT in the house when Gilbert Sandoval died; (2) she did NOT see LeChiffre in her house until after the paramedics and the police arrived; (3) although she was within inches of Gilbert Sandoval, and spattered with his blood, she did NOT see or hear LeChiffre when Gilbert Sandoval died; and (4) she “did want Gilbert to die” because of the frustration and abuse she suffered over the years. [LeChiffre v. Exley #500].

Although detective Lehmkuhl kept trying to have Marcella stick to the “plan”, she continued to forget the story, and frustrate the conspiracy. It would get worse for detective Lehnkuhl, when Marcella let slip that she had been coached prior to the official police interview. Marcella’s statement regarding prior coaching was recorded, and inadvertently included in the transcript. Marcella stated: “A few of the policemen told me that [LeChiffre] told Steve [Long] that he [Steve Long] could live there [her 10,000 square foot mansion]… if Steve Long assisted with murdering Gilbert Sandoval.[LeChiffre v. Exley #495] Not surprisingly, no-where in the discovery is there any record of the “policemen” who spoke with Marcella in preparation of her first official interview.

SNITCH #1 – Jennifer Martinez:

LeChiffre was arrested based solely on Marcella’s August 26, 2020 police Interview. Two weeks later, Jennifer Martinez finally “volunteered” to meet with the CSPD, and to provide a statement regarding her knowledge of Gilbert Sandoval’s death, or lack thereof. That “voluntary” statement was largely unhelpful to detective Lehmkuhl, and the CSPD. In fact, Martinez claimed that she did not have any specific knowledge of any “plan” to harm Gilbert Sandoval. Furthermore, Martinez did not have any information regarding any admissions or confessions from Marcella, Lechittre, Julie Trimble, or Mark Sandoval of any conspiracy to harm Gilbert Sandoval. Finally, Martinez did not advise the CSPD that she had any documents, video recordings, or audio recordings of LeChiffre or others that could shed light on the events surrounding July 22, 2020. [LeChiffre v. Exley #535]. The long-awaited statement of Jennifer Martinez was a failure.

On or about November 23, 2020 – four months and a day after Gilbert Sandoval died, and 54 days after her first “voluntary” statement to the CSPD, Jennifer Martinez came forward with a few details she had overlooked. It’s not an exaggeration to stay that Martinez made a 180 degree reversal.

Martinez volunteered that several months before Gilbert Sandoval died, Marcella asked her to assist in the murder of Gilbert Sandoval, or in the alternative, help her find a person to murder Gilbert Sandoval. Further, Martinez recalled that Marcella made references to the use of a deadly weapon, and that the threat was real. Finally, Martinez recalled that Marcella was prepared to sell a rental property from her portfolio for little or no money, in exchange for the murder of Gilbert Sandoval. [LeChiffre v. Exley #550]

In the same police interview, Martinez recalled that after Marcella solicited her to commit murder, Martinez spoke with LeChiffre, who allegedly confirmed the murder plot, and confessed to his knowledge, and complicity!

CSPD detective Lehmkuhl did not ask why the 180 degree reversal . Nor did Lehmkuhl ask why she did not “volunteer” this information on July 22, 2020- when CSPD detective Aulino called for her assistance. Furthermore, Lehmkuhl did not ask why she waited over four months to give the CSPD the audio recordings that she secretly made of LeChiffre on July 22, 2020. Lehniunl did not ask why Martinez failed to tell the police about the solicitation to commit murder when it allegedly occurred, rather than four months after Gilbert Sandoval died. Furthermore, Lehmkuhl was not interested in why Martinez did not, at the very least, tell Mark Sandoval (who was a CSPD patrol officer at the time) of the alleged solicitation; of the danger that Mark Sandoval’s father faced . Finally, Lehmkuhl did not ask why Martinez did not warn Gilbert Sandoval, or anyone for that matter, that a private meeting with Marcella could be deadly given Marcella’s alleged solicitation to commit murder. [LeChiffre v. Exley #558]. Clearly, detective Lehmkuhl was either grossly incompetent, or he knew that those questions would only undermine the conspiracy.

What is known, but was not presented to the jury due to Eric Anaya’s gross malpractice [link eee ] is that Jennifer Martinez’s housing situation was dramatically changed for the better after she changed her story. First, Mark Sandoval and Marcella Sandovai sold Jennifer Martinez’s 18 year-old son (a part-time grocery bagger) a house from Marcella’s real estate portfolio… .for under market value. [LeChiffre v. Exley #628] No record of a cash payment or mortgage has been found. Second, Mark Sandoval and Marcella “sold” Jennifer Martinez and her husband, Xavier, a single family residence in Las Vaegas, New Mexico for an “undisclosed consideration”. Finally, Mark Sandoval and Marcella allowed Jennifer Martinez and her family tolLive, rent-free in Marcella’s 10,000 square foot mansion, which is located on 115 acres of land in Colorado Springs. [link ggg] Were the changes in her initial story, and the changes in her luck a coincidence?

SNITCH # 2 – Bradford Eblen:

While Jennifer Martinez was seemingly securing real estate for herself and her children, Bradford Eblen, a habitual criminal, securing his freedom and liberty. Bradford Eblen, also known as Brad Michaels, as well as the drummer for “Good Charolette”, and “’Bowling for Soup” [link hhh ], was in actuality a well-known “jail-house Snitch” who trades information (true or fabricated) for the dismissal of criminal charges, or early release from prison. [link iii].

While detained in the El Paso County Jail with LeChiffre, Eblen offered to provide information regarding a drug trafficking ring to the CSPD, in exchange for his release. Detective Lehmkuhl was tasked to speak with Eblen. On information and belief, Lehmkuhl advised Eblen that the CSPD and the District Attorney’s Office were not interested in making a “deal” for the drug trafficking information. However, on information and belief, Lehmkuhl promised Eblen that if Eblen were able to obtain a confession from LeChiffre, the District Attorney could act favorably on Eblen’s behalf.

Based upon information provided to Eblen by the CSPD; information available on the internet; information provided to news media from the Affidavit of Arrest; and confidential information leaked to Eblen by Sheriff’s deputies, Eblen was able to construct a fabricated, yet plausible “Confession” story, which he used to eventually secure Eblen’s early release from prison.

In return for Eblen’s perjured testimony, Deputy District Attorney Dave Young wrote a heart-felt, and compelling letter of support to the Colorado Parole Board in support of Eblen’s early release into the community . The Fact that Eblen is a dangerous habitual criminal, and at risk to re-offend apparently did not concern Dave Young.

To no one’s  surprise, a few months after his release from Prison, with Deputy District Attorney Dave Youn’’s stamp of approval, Eblen allegedly committed a horrible crime. One that shocks all measures of decency. Eblen has been charged with aggravated motor vehicle theft (with two priors); Kidnapping of a 13 year old girl, in the second degree; and sexual assault of that same 13 year-old girl. [link jji]


After Mark Sandoval was given protective custody of Marcella, he filed a Petition for Guardianship and Conservatorship with the Court, which would allow him to fully control all of Marcella’s assets, bank accounts, and real property. The Conservatorship comes with court oversight, however, so Mark Sandoval obtained “power of attorney” over Marcella, which did not require court oversight. Then the fire sale began. Quickly, Mark Sandoval sold over 6,000,000.00 (six million dollars) of Marcella’s real estate portfolio, and placed those funds in an account which he controlled. In addition, Mark Sandoval, using his “power of attorney” placed beneficiary deeds in his name on every real estate property owned by Marcella, including her 10,000 square foot mansion. Mark Sandoval also, through power of attorney, made all day-to-day financial decisions for Marcella, becoming an overnight millionaire in the process. [LeChiffre v. Exley #619], [LeChiffre v. Exley #623], [LeChiffre v. Exley #626]

During an early police interview with detective Exley, Mark Sandoval opined: “In my humble opinion, it’s all about the money”  [LeChiffre v. Exley #451] In fact, the only people to benefit from that money were Jennifer Martinez, and Mark Sandoval.


People v. LeChiffre, LeChiffre v. Exley, and related cases (LeChiffre v. Eblen, and LeChiffre v. Martinez) shows that in Colorado Springs, the Rule of LAW, had been replaced by the RULE of PoliceMAN.

“what will you do when they come for YOU!”

You can also download a simple printable executive summary without links>>