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 Oceana area.
