| District Court, City and County of Denver, Colorado
City and County Building, Room 424
1437 Bannock Street
Deaver, CO 80202
Plaintiff: THE PEOPLE OF THE STATE OF
COLORADO.
Defendant: BRANDON RAMOS
COURT USE ONLY
Case Number:
Grand Jury No, 22CR2B |
Div. Criminal Com: 424/___
| INDICTMENT
ASSAULT IN THE SECOND DEGREE, C.R.S. 18-3-203(1)(@), (F4) < 02027 > 1, 2 (2 counts)
ASSAULT IN THE THIRD DEGREE, C.R.S. 18-3-204(1}(a), (M1) < 02038 > 3, 4, 5 (3 counts)
ASSAULT IN THE THIRD DEGREE, C.R.S. 18-3-204(1)(a), (Mi) < 02039 > 6, 7,8 (@ counts)
PROHIBITED USE OF A WEAPON, CRS, 18-12-106(1)(b), (MI) < 3005C > 9 (1 count)
RECKLESS ENDANGERMENT, CRS. 18-3-208, (M2) < 02073 > 10, 11, 12, 13, 14
(S counts)
‘The Grand Jury presents the within Indictment and the same is ordered filed.
‘oh 3
Datedthis Uf day of see +2023.
Niger
Poo -
Presiding Judge
Denver District CourtSth Me
BETH MeCANN, Reg. No. 5834
District Attorney
Denvet District Attorney's Office
201 W. Colfax Ave., Dept. 801
Denver, CO 80202
720-913-9000COUNT ONE
ASSAULT IN THE SECOND DEGREE, C.RS. 18-3-203(1)(@), (F4) < 02027 >
On or about July 17, 2022, at or triable in the City and County of Denver, State of Colorado,
BRANDON RAMOS ualavfully, feloniously, and recklessly caused serious bodily injury to
by means of a deadly weapon, namely: FIREARM; in violation of
setion 18-3-203(1Kd), CRS.
COUNT TWO
ASSAULT IN THE SECOND DEGREE, CRS. 18-3-203(1X4), (F4) < 02027 >
On or about July 17, 2022, at or triable in the City and County of Denver, State of Colorado,
BRANDON RAMOS unlawfully, feloniously, and recklessly caused serious bodily injury to
by means of a deadly wospon, namely: FIREARM: in violation of section
18-3-203(1}(d), C.R.S.
COUNT TAREE
ASSAULT IN THE THIRD DEGREE, C.R.S. 18-3-204(1)(a), (M1) <02038>
On or about July 17, 2022, at or triable in the City and County of Denver, State of,
Bi 1OS unlawfully, and knowingly or recklessly, caused bodily injury tof
in violation of section 18-3-204(1X{a), CRS.
COUNT FOUR
ASSAULT IN THE THIRD DEGREE, CRS. 18-3-204(1)(a), (M1) < 02038>
On or about July 17, 2022, at or triable in the City and County of Denver, State of
10S unlawfully, ond knowingly or recklessly, caused bodily injury to|
in violation of seotion 18-3-204(1)(a), CRS.
COUNT FIVE
ASSAULT IN THE THIRD DEGREE, CR.S. 18-3-204(1)(a), (M1) < 02038 >
On or about July 17, 2022, at or triable in the City and County of Denver, State of Colorado,
N RAMOS unlawfully, and knowingly or recklessly, caused bodily injury to
violation of section 18-3-204(1)(a), C.R-S.COUNT SIX
ASSAULT IN THE THIRD DEGREE, C.RS, 18-3-204(1}(a), (M1) <02039>
On or about July 17, 2022, at or triable in the City and County of Denver, State of
BRANDON RAMOS unlavfllly and with criminal negligence caused bodily injury to|
[by means of a deadly weapon, namely: FIREARM; in violation of section 18-3-
Eh CRD.
COUNT SEVEN
ASSAULT IN THE THIRD DEGREE, C.R.S. 18-3-204(1)(a), (i1)-<02039>
On or about July 17, 2022, at or triable in the City and County of Denver, State of Colorado
BRAND (MOS unlawfully and with criminal negligence caused bodily injury to Ill
oy means of a deadly weapon, namely: FIREARM; in violation of section 183+
DOACIKA), CRS,
COUNT EIGHT
ASSAULT IN THE THIRD DEGREE, CRS. 18-3-204(1)(@), (M1) < 02039>
On or about July 17, 2022, ator triable in the City and County of Denver, Stae of:
IN RAMOS unlawfully and with eriminal negligence caused bodily injury to
means of a deadly weapon, namely: FIREARM; in violation of section Tet
204(1}fa), CRS,
COUNT NINE
PROHIBITED USE OF A WEAPON, CRS, 18-12-106(1)(b), (M1) < 3005C>
On or about July 17, 2022, at ot triable in the City and County of Denver, State of Colorado,
BRANDON RAMOS unlawfully, recklessly, or with criminal negligence discharged a firearm;
in violation of section 18-12-106(1)(b), CRS.
COUNT TEN
RECKLESS ENDANGERMENT, CRS. 18-3-208, (M2) < 02073>
On or about July 17, 2022, at or triable in the City and County of Denver, State of Colorado,
BRANDON RAMOS unlawfully and 1ct which created a substantial
risk of serious bodily injury 10] in violation of section 18-3-208,
CRS.COUNT ELEVEN
RECKLESS ENDANGERMENT, C.R.S. 18-3-208, (M2) < 02073 >
On or about July 17, 2022, at or triable in the City and County of Denver, State of Colorado,
BRANDON RAMOS unis igaged in conduct which created a substantial
tisk of serious bodily injury in violation of section 18-3-208, CRS.
COUNT TWELVE
RECKLESS ENDANGERMENT, C.R.S. 18-3-208, (M2) < 02073>
On of about July 17, 2022, at or triable in the City and County of Denver, State of Colorado,
BRANDON RAMOS unlawfully and recklessh in conduct which created a substantial
tisk of serious bodily injury to |: in violation of section 18-3-208, CRS,
COUNT THIRTEEN
RECKLESS ENDANGERMENT, C.R.S. 18-3-208, (M2) < 02073 >
On or about July 17, 2022, at or triable in the City and County of Denver, State of Colorado,
BRANDON RAMOS unlawfully and recklessly engaged in conduct which created a substantial
risk of serious bodily inn violation of section 18-3-208, C.R.S.
COUNT FOURTEEN
RECKLESS ENDANGERMENT, C-R.S, 18-3-208, (M2) < 02073 >
On ot about July 17, 2022, at or triable in the City and County of Denves, State of Colorado,
BRANDON RAMOS unlawii engaged in conduct which created a substantial
risk of serious bodily injury to in violation of section 18-3-208, CRS.
The facts supporting Counts 1 through 14 are as follows:
1. The facts supporting all other counts in this Indictment are incorporated herein by
reference.
2. Atapproximately 1:30 am on July 17, 2022, several Denver Police Officers, including
Officers Kenneth Rowland, Meghan Lieberson and Brandon Ramos were at a parking
lot on the comer of 20th Street and Larimer Street, in the lower downtown (LoDo) area
of Denver, Colorado. These officers were present as part of the Denver Police
Department’s LoDo Violence Mitigation Operation, an attempt to interrupt gua
violence in the area on weekend nights. Officers have broken up fights and retrieved
ffrearms in the past in the area. Larimer Street was closed to traffic for pedestrian’s
safety.10,
Immediately adjacent to the parking lot is a bar called the Larimer Beer Hall. Shortly
before 1:30 am the bar began to close. As a result, a large crowd of people —_ in
and around the and the adjacent ot. This crowd included
and many,
= —
IW PETSODS.
Jordan Waddy (Waddy) was also in and around the front of the Larimer Beer Hall.
While outside and in front ofthe bar Waddy punched an unknown person who later left
the area. During this assault Waddy made a motion to indicate he may have a firearm
on his person. A witness officer observed both the assault and Waddy’s motion. In
response, several officers, including Officers Kenneth Rowland, Meghan Lieberson
and Brandon Ramos, attempted to contact Waddy.
Officers shined their flashlights on Waddy and requested that he speak with them.
Instead, Waddy fled, walking quickly through the crowd on the sidewalk away from
the officers. The officers, including Officers Rowland, Lieberson, and Ramos, walked
paraliel on the street, keeping pace with Waddy. The officers intercepted Waddy as he
passed between two cars (0 go into the street. Officers again made commands to Waddy
asking him io “stop” and “show his hands.” Waddy briefly stopped and put his hands
up but then tumed back between the cars now with his left hand moving to his front
waistline area, Once on the sidewalk Waddy began to move back in the direction he
originally came toward the crowd in front of the Larimer Beer Hall.
Officer Ramos and another officer followed Waddy onto the sidewalk as Officers
Rowlend, Lieberson, and another officer stayed in the street and moved toward a space
between a food truck and a car to intercept Waddy.
‘As Waddy continued toward the crowd, he pulled a handgun from his hooded jacket’s
front pocket with his left hand.
Officer Rowland and Officer Lieberson were standing in the street facing southeast,
Both officers were directly in ftont of Waddy when he began to pull the handgun from
his hooded jacket. Fearing for their lives and those of their fellow officers these two
officers fired their weapons.
Officer Rowland fired his firearm four times and Officer Lieberson fired twice, both in
the direction of Waddy. From these officers’ view, a brick wall and the front of the
Larimer Beer Hall were behind Waddy and no persons were behind Waddy. No one
‘was between them and Waddy.
Officer Ramos was now standing on the sidewalk facing southwest. He was aware that
Officer Rowland and Officer Lieberson were armied and standing directly in front of
Waddy. Only seeing the side of Waddy, Officer Ramos fired his | tw
Ramos knew that a large crowd of people, i a14,
PE «I es ats ne
he did not have a clear back drop. At no point did Waddy turn and face Officer Ramos
with the firearm.
1es by officers’ bullets and received non-lethal injuries.
Waddy was struck several ti
was struck by a bullet in his upper right arm resulting in
as siruck by a bullet in her right lower leg striking an artery
a MR 62s struck by a bully
upper right rear shoulder area with an exit injury at the right shoulder cansin|
a — as suck Dre et
on her lower left leg with a
graze wound causing}
struck on the inside of his left foot with a
bullet causing
The grand jury heard testimony from 17 witnesses and received 140 exhibits,
Officers Rowland and Licberson did.nop cause the injuries (0 I
MMR. wren Wacey pulled a gun trom his
hooded jacket pocket Officers Rowland and Lieberson both reasonably believed that
their lives or their fellow offic lives were in danger. Their decisions to shoot were
legally justified because they reasonably believed they faced the imminent use of
unlawful physical force by Mr. Waddy. They both used a degree of force witch was
reasonably necessary to defend themselves and they put no one else at risk.
PE cased th injuries oI =
m
"| Officer Ramos was not in immediate danger himself’ wien
icy began to pull his gun from his hooded jacket while facing Officer Rowland and
Officer Lieberson. Officer Ramos’ decision to shoot was not legally justified because
it was reckless, unreasonable, and unnecessary for the purpose of protecting himself or
other officers and he consciously disregarded an unjustifiable risk of injury to the crowd
behind Mr. Waddy.