Table of Content with links to the Verified Complaint

I. Introduction

• Jurisdiction
• Venue
• Parties

II. Statement of Facts

• LeChittre
• Relevant History/Background
• The First 48 hours After the Homicide- July 22, 2020 through July 24, 2020
  1. July 22, 2020 – Gilbert Sandoval – Deceased
  2. July 22, 2020 – Marcella Sandoval – Initial Statement
  3. July 22, 2020 – Mark Anthony Sandoval – At the Scene
  4. July 22, 2020 – Defendant Derek Exley’s interview with Mark Sandoval
  5. July 22, 2020 – Defendant Stephen Aulino’s interview with Gilbert Sandoval’s Mistress/Fiancee
  6. July 22, 2020 – Defendant Stephen Aulino’s interview with Kristina Haney
  7. July 22, 2020 – LeChiffre’s voluntary Interview at the CSPD Operations Center
  8. July 22, 2020 – Defendant Marcus Lehmkuhl and Defendant Exley arrange for Marcella Sandoval to be transferred into Mark Sandoval’s exclusive custody and control
  9. July 22, 2020 – Defendant Stephen Francis Aulino Searches LeChiffre’s Residence
  10. July 23, 2020 – Defendant Stephen Francis Aulino and Defendant Marcus Lehmkuhl’s. contact with retired CSPD Police Officer Denny Sevene
  11. July 24, 2020 – Defendant Derek Exley – interviews Kristina Haney, A. Forrest, and D. Burns
  12. July 24, 2020 – Defendant Derek Exley – second interview of “person of interest” Steve Long
  13. July 24, 2020 – Mark Sandoval’s Petition for Conservatorship and Guardianship to Control Marcella Sandoval’s Estate
• The Next Two Weeks After The Homicide – July 22, 2020 through August 5, 2020
  1. July 28, 2020 – Official citizen request for “Welfare Check” at Mark Sandoval’s Residence stopped, and covered-up by CSPD Doe Defendants
  2. July 31, 2020 – Marcella Sandoval’s friend, Jenna Shearn, is also denied access to Marcella Sandoval by Mark Sandoval
  3. August 5, 2020 – CSPD Detective Piazza’s official interview with Angela Gainer
  4. Defendant Marcus Lehmkuhl falsifies a police report in support of the Conspiracy- using the misleading date of August 6, 2020
• Three Weeks After the Homicide – August 5 through August 25, 2020
  1. August 10, 2020- Defendant Derek Exley’s second interview with Mark Sandoval
  2. August 11, 2020 – Defendant Derek Exley’s third interview of Steve Long
  3. Marcella Sandoval’s August 26, 2020 Statement at the POC
• LeChiffre arrested and trasnsferred to the El Paso County Jail, August 28,2020

III. Tying Up Loose Ends, September, 2020 through November, 2020

• Detendant Jennifer Martinez’s Contradictory “Voluntary” Statements to Lehmkuhl
• Marcella Sandoval’s Plea Agreement – November, 2020
• Lehmkuhl grooms Bradford Eblen (aka “Brad Michaels”, aka “Bradley Michaels”) a well-known “jail-house snitch witness”

IV. Follow the Money

• Mark Anthony Sandoval obtained actual financial benefits of at least $1,000,000.00 (one million dollars) before and after the homicide
• Mark Anthony Sandoval also acquired $6,100,000.00 in property from Marcella Sandoval through beneficiary deeds after the homicide
• Mark Sandoval begins a “fire sale” of Marcella Sandoval’s Real-Estate Portfolio after the homicide, amounting in $6,341,000.00 dollars in sales

V. Conviction / Secure the Money – June 3, 2022