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UNITED STATES
DISTRICT COURT
for the Middle District of Oceana
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Grand Jury Sworn in on April 23rd, 2003
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UNITED
STATES OF AMERICA
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v.
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03-203-01-Cr
03-203-02-Cr
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ANGELA
SMITH
MICHAEL JONES
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The
Grand Jury charges:
FIRST COUNT:
On or about August 4th, 2003, Defendants Angela Smith and
Michael Jones unlawfully, knowingly, and intentionally distributed
approximately 19 ounces (540 grams) of cocaine, a controlled
substance, in violation of Title 21 U.S.C. Secs. 841(a)(1),
841(b)(1)(B).
SECOND COUNT:
From on or about August 1st, 2003, and continuing thereafter
up to and including August 30, 2003, the exact dates being
unknown to the Grand Jury, Defendants Angela Smith and Michael
Jones did unlawfully, knowingly, and willfully combine,
conspire, confederate, and agree together and with other
persons know and unkown to the Grand Jury to distribute
quantities of cocaine, a controlled substance, in violation
of Title 21 U.S.C. Secs(a)(1), 841(b)(1)(B).
Objects
of the Conspiracy
It was part of said conspiracy that
to obtain cash and other property, the defendants and
others would acquire, repackage, and distribute for profit
quantitites of cocaine, a controlled substance.
It
was futher part of said conspiracy that to obtain cash
and other property, the defendants and others, directly
and indirectly, would unlawfully prepare, dilute, and
package quantities of cocaine for sale and distribution
within the Bigtown area.
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