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1 AARON D.

FORD
Attorney General
2 KELLI R. GALLIMORE (Bar No. 13428)
Senior Deputy Attorney General
3 State of Nevada
Office of the Attorney General
4 5420 Kietzke Lane, Suite 202
Reno, NV 89511
5 P: (775) 687-2103
F: (775) 688-1822
6 [email protected]
Attorneys for Plaintiff
7

8 IN THE JUSTICE COURT OF SPARKS TOWNSHIP

9 IN AND FOR THE COUNTY OF WASHOE, STATE OF NEVADA

10 STATE OF NEVADA,
Case No.
11 Plaintiff,
Dept. No.
12 v.

13 MARK ALLEN LAWSON, and LANCE


FORRESTER,
14
Defendants.
15

16 CRIMINAL COMPLAINT

17 The undersigned, AARON D. FORD, Attorney General of the State of Nevada, by and through

18 KELLI R. GALLIMORE, Senior Deputy Attorney General, complains and charges the above-named

19 defendants, MARK ALLEN LAWSON, and LANCE FORRESTER, with having committed the following

20 offenses:

21 MARK ALLEN LAWSON has committed the crimes of one (1) count of CONSPIRACY TO

22 VIOLATE THE UNIFORM CONTROLLED SUBSTANCES ACT, a category “C” felony, in violation of

23 NRS 453.401(a); one (1) count of POSSESSION OF A CONTROLLED SUBSTANCE, a category “C”

24 felony, in violation of NRS 453.336(2)(c); one count of POSSESSION OF A CONTROLLED

25 SUBSTANCE, a category “E” felony, in violation of NRS 453.336(2)(a); and one (1) count of SALE OF

26 A CONTROLLED SUBSTANCE, a category “D” felony, in violation of NRS 453.338(1) and (2)(a).

27 LANCE FORRESTER has committed the crimes of one (1) count of CONSPIRACY TO

28 VIOLATE THE UNIFORM CONTROLLED SUBSTANCES ACT, a category “C” felony, in violation of

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1 NRS 453.401(a); one (1) count of POSSESSION OF A CONTROLLED SUBSTANCE, a category “C”

2 felony, in violation of NRS 453.336(2)(c); and one (1) count of SALE OF A CONTROLLED

3 SUBSTANCE, a category “D” felony, in violation of NRS 453.338(1) and (2)(a).

4 COUNT I

5 CONSPIRACY TO VIOLATE THE UNIFORM CONTROLLED SUBSTANCE ACT


Category “C” Felony – NRS 453.401(a)
6

7 That on or between October 9, 2020, and July 8, 2021, the defendants, MARK ALLEN LAWSON
8 and LANCE FORRESTER, in the County of Washoe, State of Nevada, willfully, unlawfully, and
9 feloniously conspired with each other to commit an offense which is a felony violation of the Uniform
10 Controlled Substance Act, and in furtherance of said conspiracy, the defendants did commit one or more of
11 the acts as set forth in counts V and VI, those acts being incorporated by this reference as though fully set
12 forth herein.
13 COUNT II
14 POSSESSION OF A CONTROLLED SUBSTANCE
Category “C” Felony – NRS 453.336(2)(c)
15

16 That on or about August 26, 2021, the defendant, MARK ALLEN LAWSON, in the County of

17 Washoe, State of Nevada, unlawfully and knowingly or intentionally possessed a schedule III controlled

18 substance, to wit: approximately 34.614 grams of anabolic steroids, and/or Mesterolone, and/or

19 Oxandrolone, and/or Oxymetholone, and/or Methenolone, and/or Testosterone, and/or Stanozolol, and/or

20 Fluoxymesterone, and/or a mixture containing anabolic steroids.

21 COUNT III

22 POSSESSION OF A CONTROLLED SUBSTANCE


Category “E” Felony – NRS 453.336(2)(a)
23

24 That on or about August 26, 2021, the defendant, MARK ALLEN LAWSON, in the County of
25 Washoe, State of Nevada, unlawfully and knowingly or intentionally possessed a schedule IV controlled
26 substance, to wit: approximately .894 grams of Modafinil.
27 ///
28 ///

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1 COUNT IV

2 POSSESSION OF A CONTROLLED SUBSTANCE


Category “C” Felony – NRS 453.336(2)(c)
3

4 That on or about July 28, 2021, the defendant, LANCE FORRESTER, in the County of Washoe,

5 State of Nevada, unlawfully and knowingly or intentionally possessed a schedule III controlled substance,

6 to wit: approximately 45.19 grams of anabolic steroids, and/or Testosterone, and/or Drostanolone, and/or

7 Methenolone, and/or Oxymetholone, and/or a mixture containing anabolic steroids.

8 COUNT V

9 SALE OF A CONTROLLED SUBSTANCE


Category “D” Felony – NRS 453.338(1) and (2)(a)
10

11 That on or between October 9, 2020, and July 8, 2021, the defendant, MARK ALLEN LAWSON,

12 in the County of Washoe, State of Nevada, unlawfully possessed for the purpose of sale a schedule III

13 controlled substance, or a mixture containing a schedule III controlled substance, to wit: anabolic steroids,

14 and/or Mesterolone, and/or Oxandrolone, and/or Oxymetholone, and/or Methenolone, and/or Testosterone,

15 and/or Stanozolol, and/or Fluoxymesterone, and/or a mixture containing anabolic steroids.

16 COUNT VI

17 SALE OF A CONTROLLED SUBSTANCE


Category “D” Felony – NRS 453.338(1) and (2)(a)
18

19 That on or between March 16, 2021, and July 4, 2021, the defendant, LANCE FORRESTER, in the

20 County of Washoe, State of Nevada, unlawfully possessed for the purpose of sale a schedule III controlled

21 substance, or a mixture containing a schedule III controlled substance, to wit: anabolic steroids, and/or

22 Testosterone, and/or Drostanolone, and/or Methenolone, and/or Oxymetholone, and/or a mixture

23 containing anabolic steroids.

24 ///

25 ///

26 ///

27 ///

28 ///

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1 All of which is contrary to the form, force, and effect of the statutes in such cases, made and

2 provided, and against the peace and dignity of the State of Nevada.

3 The Complainant requests a Summons be issued at this time pursuant to NRS 171.106.

4 Said complainant makes this declaration under penalty of perjury.

5 AFFIRMATION PURSUANT TO NRS 239B.030

6 The undersigned does hereby affirm that the preceding document, CRIMINAL COMPLAINT,

7 filed in the Sparks Township Justice Court, in the matter of the State of Nevada v. Mark Allen Lawson and

8 Lance Forrester, does not contain the social security number of any person.

9 DATED this 8th day of December, 2022.

10 AARON D. FORD
Attorney General
11

12 By:
KELLI R. GALLIMORE (Bar No. 13428)
13 Senior Deputy Attorney General
Attorney for the State of Nevada
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