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, Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 1 of 28

FILEDD IN OPEN
FILE OPEN COURT
U .S.D.C Atlanta
U.S.D.C Atlanta

THE
IN TH UNITED
E UNIT STATES
E D STATE S DISTRICT COURT
COURT FFOR THE
OR TH E AUG 1)081006
AUG 8 2006

NORTHERN DISTRICT
NORTHERN DISTRICT OF
OF GEORGIA
GEORGIA jg*.S K. HATTER. 00r~
ur fh~ Vqx4'Cj0t*
DIVISION
ATLANTA DIVISION

UNITED STATES
UNITED STATES OF
OF AMERICA
AMERICA
CRIMINAL INDICTMENT
INDICTMENT
v.
V.

STOUFFLET,
CHRISTOPHER STOUFFLET,
TROY SOBERT,
SOBERT,
N°'1: 06---
NO . '
CR- 337
3
~ • O V
„~ O ~
~1

VLADIMIR ANDRIES,
VLADIMIR ANDRIES, MM.D.,
.D .,
THU ANH HOANG, M.D.,
THU ANH HOANG, M .D .,
STEVEN DANIEL
STEVEN DANIEL HOLLIS,
HOLLIS, MM.D.,
.D .,
AHSAN U
AHSAN U.. RASHID,
RASHID, MM.D., and
.D ., and
ANDRE DD.. SMITH,
ANDRE SMITH, MM.D.,
.D .,

Defendants.
Defendants

CHARGES THAT
THE GRAND JURY CHARGES THAT::

INTRODUCTION

times relevant
At times relevant to
to this
this Indictment
Indictment::

ACT
CONTROLLED SUBSTANCES ACT

11.. The
The Controlled
Controlled Substances
Substances Act
Act governed
governed the
the manufacture,
manufacture,

distribution, and
and dispensing
dispensing of
of controlled
controlled substances
substances in
in the
the United
united

States..
States

22.. Various
Various prescription
prescription drugs
drugs were
were scheduled
scheduled substances
substances under
under

the Controlled
the Controlled Substances
Substances Act
Act.. There
There were
were five
five schedules
schedules of
of

controlled substances
controlled substances -- schedules
schedules I, II, III,
I, II, III, IV,
IV, and
and VV.. Drugs
Drugs

scheduled into
were scheduled into these
these levels
levels based
based on
on their
their potentiality
potentiality for
for

abuse, among other


abuse, among other things
things.. Abuse
Abuse of
of Schedule
Schedule III
III drugs
drugs may
may lead
lead to
to

moderate or
moderate or low
low physical
physical dependence
dependence or
or high
highpsychological
psychological

dependence. Abuse of
dependence . Abuse of Schedule
Schedule IV
IV drugs
drugs may
may lead
lead to
to more
more limited
limited

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Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 2 of 28

physical dependence
physical dependence or psychological
psychological dependence
dependence relative
relative to
to the
the

drugs or other
other substances
substances in
in Schedule
Schedule III
III.. 21
21 U
U.S.C. §§ 812(b)
.S .C . §§ (3))
812(b)(3

and (4)
and (4)..

33.. Title
Title 21,
21, Code
Code of
of Federal
Federal Regulations,
Regulations, Section
Section 1306
1306.04(a)
.04(a)

provided::
provided

A prescription
A prescription for for aa controlled
controlled substance
substance to to
effective must
be effective must bebe issued
issued forfor aa legitimate
legitimate
medical purpose
medical purpose by by an
an individual
individual practitioner
practitioner
acting in the usual course of his professional
of his professional
practice.. The
practice The responsibility
responsibility for for the
the proper
proper
prescribing and
prescribing dispensing of
and dispensing of controlled
controlled
substances
substances is upon the
is upon the prescribing
prescribing
practitioner,
practitioner, but
but aa corresponding
corresponding
responsibility rests
responsibility rests with the the pharmacist
pharmacist whowho
fills prescription.. An
fills the prescription order purporting
An order purporting
to be aa prescription
prescription issued
issued notnot in
in the
the usual
usual
course of
course of· professional
professional treatment
treatment or in
or in
legitimate and
legitimate authorized research
and authorized research is not aa
is not
within the
prescription within the meaning
meaning and
and intent
intent of
of
section 309
309 of
of the
the Act
Act (21
(21 U
U.S.C.
.S .C . 829)
829) and the
the
person knowingly
person knowingly filling
filling suchsuch aa purported
purported
prescription, as
prescription, as well well as the person issuing
the person issuing
it, shall be subject to
it, to the
the penalties
penalties provided
for violations
for violations of the provisions
of the provisions of law
of law
relating toto controlled
controlled substances
substances..

44.. Phentermine,
Phentermine, aa stimulant,
stimulant, was
was classified
classified under
under federal
federal

laws as a
narcotics laws a Schedule IV
IV controlled
controlled substance
substance.. 21
21 CC.F.R.
.F .R . ~§

1308.14(e) (9).. Adipex-P


1308 .14(e)(9) Adipex-p was
was aa brand
brand name
name for
for aa prescription
prescription drug
drug

used for weight loss


loss that
that contained
contained Phentermine,
Phentermine, and
and was
was therefore
therefore

classified as
classified as Schedule
Schedule IV
IV controlled
controlled substances
substances..

55.. Phendimetrazine,
Phendimetrazine, aa stimulant,
stimulant I was
was classified
classified under
under federal
federal

narcotics laws as aa Schedule


Schedule III
III controlled
controlled substance
substance.. 21
21 CC.F.R.
.F .R .

§ 1308.13(b)
§ 13os (5).
.13(b ) (5 Bontri1 was
) . Bontril was aa prescription
prescription drug
drug used
used for
for weight
weight

phendimetrazine, and
loss that contained phendimetrazine, and was
was therefore
therefore classified
classified

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as aa Schedule III
as III controlled
controlled substance
substance..

66.. Sibutramine
Sibutramine hydrochloride,
hydrochloride, aa stimulant,
stimulant, was
was classified
classified

under federal
under federal narcotics
narcotics laws
laws as
as a
a Schedule IV controlled
Schedule IV substance..
controlled substance

C.F.R.
21 C .F .R . §§ 1308.14(e) (11). Meridia,
1308 .14(e)(11) Meridia, a a prescription
prescription drug
drug used
used for
for

loss, contained
weight loss, sibutramine hydrochloride,
contained sibutramine hydrochloride, and
and was
was therefore
therefore

a Schedule IV
classified as a IV controlled
controlled substance
substance..

FEDERAL FOOD, DRUG,


THE FEDERAL DRUG, AND COSMETIC
COSMETIC ACT
ACT

77.. The
The United
united States
States Food
Food and D
Drug
r u g Administration ("FDA") was
Adm i n i stratio n ("FDA") was

the agency of the united


the states charged
United States charged with
with the
the responsibility
responsibility of
of

protecting the
protecting the health
health and safety of
and safety of the
the American
American public
pUblic by
by

assuring, among
assuring, among other
other things,
things, that
that drugs
drugs sold
sold to
to humans
humans were
were safe
safe

for their
and effective for their intended
intended uses and bore labeling
labeling containing
containing

true and
true and accurate
accurate information
information.. FDA·
F s responsibilities
DA's responsibilities included
included

labels, labeling,
regulating the labels, labeling, distribution,
distribution, and
and manufacture
manufacture of
of

drugs shipped
prescription drugs shipped or
or received
received in
in interstate
interstate commerce
commerce..

8. FDAwas
8 . FDA wasalso
alsoresponsible
responsible for,
for, among
amongother
otherthings,
things,

of the
enforcing the provisions of the Federal
Federal Food,
Food, Drug,
Drug, and
and Cosmetic
Cosmetic

Act ("
(IIFD&C Act"), 21
F D&C Act"), 21 UU.S.C.
.S .C . §§ 301 et §§,g.
301 et sea .

99.. Under
Underthe
theFD&C
FD&CAct,
Act,the
theterm
term"drug"
"drug" included
included articles
articles

which were (1)


which were (1) intended
intended for
for use
use in
in the
the diagnosis,
diagnosis, cure,
cure, mitigation,
mitigation,

treatment, or prevention
treatment, prevention of disease
disease in mani; or
in man or (2)
(2) intended
intended to
to

structure or
affect the structure or any
any function
function of
of the
the body
body of
of man
man.. 21
21 U
U.S.C.
.S .C.

321 (g)(1)
§H § 321(g) (1) (B)
(B) and (C) ..
(C)

110. Some
0 . Some of of thedrugs
the drugsregulated
regulatedunder
under the
the FD&C
FD&C Act
Act were
were

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"prescription drugs.." "Prescription


"prescription drugs "prescription drugs"
1/ drugs" were
were those
those drugs,
drugs, which

because of
because of their
their toxicity
toxicity or
or other
other potential
potential harmful
harmful effects,
effects, or
or

the
the method of their use,
use, or
or the
the collateral
collateral measures
measures necessary
necessary for
for

their
their use,
use, were not safe
were not safe for
for use
use except
except under
under the
the supervision
supervision of
of aa

practitioner licensed
practitioner licensed by law
law to
to administer
administer such
such drugs,
drugs, or
or which
which

were required
required to be
be administered
administered under the
the professional supervision
professional supervision

of a
of a practitioner
practitioner licensed
licensed by
by law
law to
to administer
administer such
such drug
drug as
as aa

condition of FDA
FDA approving
approving the
the drug
drug to
to be placed
placed on
on the
the market
market.. 21
21

U.S.C.
U §§ 353
.S .C . §§ (b) (I) (A)
353(b)(1)(A) and (B).
(13) .

11. Viagra(Sildenafil
11 . Viagra (Sildenafil citrate)
citrate) was
was indicated
indicated for
for the
the

treatment
treatment of erectile dysfunction,
of erectile dysfunction, and
and was
was aa prescription
prescription drug
drug

within the
within the meaning
meaning of
of Title
Title 21,
21, United
United States
States Code,
Code, Sections
sections

353(b}
353 (I) (A)
(b) (1.) (A) and (B)..
and (B)

12. Xenical(Orlistat)
12 . Xenical (Orlistat) was
was indicated
indicated for
for weight
weight loss,
loss, and
and

was a
was a prescription
prescription drug
drug within
within the
the meaning
meaning of
of Title
Title 21,
21, United
united

Code, sections
States Code, Sections 353(b)(1)(A)
353(b} (1) (A) and
and (B)
(B)..

13. Phendimetrazine (Bontril),


13 . Phendimetrazine Phentermine ((~Adipex-P),
(Bontril), Phentermine e . g . Adipex-P),

and Sibutramine
Sibutramine hydrochloride
hydrochloride (Meridia),
(Meridia), described
described as
as controlled
controlled

substances in
substances in paragraphs
paragraphs 4-7
4-7 above,
above, were
were also
also prescription
prescription drugs
drugs

within the
within the meaning
meaning of
of Title
Title 21,
21, United
United States
States Code,
Code, Sections
Sections

353 (b) (I) (A)


353(b)(1)(A) and (B)
and (B)..

14.. The
14 TheFD&C
FD&CAct
Actprohibited
prohibitedthe
the misbranding
misbranding of
of aa drug
drug while
while

such drug
such drug was
was held
held for
for sale
sale after
after shipment
shipment in interstate commerce,
in interstate commerce,

the causing
or the causing of
of such
such misbranding
misbranding.. 21
21 UU.S.C. 331(k)..
§ 331(k)
.S .C . §

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15. The act


15 . The act of
of dispensing
dispensing aa prescription
prescription drug
drug without
without the
the

prescription of
prescription of aa practitioner
practitioner licensed
licensed by
by law
law to
to administer
administer such
such

an act
drug was an act that
that caused
caused the
the drug
drug to
to become
become misbranded
misbranded while
while

held for
held for sale
sale.. 21
21 U
U.S.C.
.S .C . 353 (b) (1) ..
353(b)(1)

STATE LAWS
STATE LAWS

16.. An
16 example of
An example of some
some state
state laws
laws which
which imposed
imposed requirements
requirements

upon doctors
doctors and
and healthcare
healthcare professionals
professionals to
to take
take certain
certain steps
steps

before they
before they could
could prescribe,
prescribe, distribute,
distribute, or
or dispense
dispense controlled
controlled

substances included
substances included::

Law
Georgia Law

17.. Georgia
17 Georgia law
law stated,
stated, in
in part,
part, that
that aa physician
physician engaged
engaged in
in

~unprofessional conduct"
"unprofessional conduct" if
if the
the physician
physician does
does the
the following
following::

* * * *
(5) Prescribing con
(5)Prescribing controlled substances and/or
t roll e d substances and/or dangerous
dangerous

a patient
drugs for a based solely
patient based solely on
on aa consultation
consultation via
via electronic
electronic

means w
means with the pat
i th the patient based solely
i ent based solely on
on aa consultation
consultation vvia
ia

electronic
elec t ro n i c means w
with
i th the patient,
patient, patient's guardian
guardian or
or pat
patient's
i ent's

agent..
agent . .

(6) providing
(6)Providing treatment
treatment and/or consultation
and/or consultation

via
recommendations v other means
i a electronic or other means unless
unless the
the llicensee
i censee

has performed
has performed a
a history
history and
and physical
physical examination
examination of
of the
the patient
patient

adequate to
adequate to establish
establish different
differential diagnoses and
i al diagnoses and , identify
identify

conditions and/or
underlying conditions and/or contra-indications
contra-indications to
to the
the treatment
treatment

recommended..
recommended .

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DEFENDANTS

18. Defendant CHRISTOPHER


18 . Defendant CHRISTOPHER STOUFFLET
STOUFFLET was
was the
the majority
majority

shareholder, owner,
owner, operator,
operator, corporate
corporate officer,
officer, and/or
and/or director
director of
of

businesses located
businesses in the
located in the Northern
Northern District
District of
of Georgia,
Georgia, that
that

operated websites
operated websites through
through which
which the
the defendants
defendants distributed
distributed and
and

controlled substances
dispensed controlled substances and
and other
other prescription
prescription drugs,
drugs, and
and

the proceeds thereof


laundered the thereof.. Some
Some of
of these
these businesses
businesses included
included

escripts-md.com,
escripts-md myemd.com,
.com, myemd Lifespan,
.com, Lifespan, and Virtual
and Virtual Wellness
Wellness

Networks..
Networks

19. Defendant TROY


1 9 . Defendant TROY SOBERT
SOBERT was
was aa part
part owner,
owner, operator,
operator, and
and

officer of
officer of businesses
businesses located
located in
in the
the Northern
Northern District
District of
of Georgia,
Georgia,

that operated websites through which the defendants


defendants distributed and
distributed and

dispensed controlled
dispensed controlled substances
substances and
and other
other prescription
prescription drugs,
drugs, and
and

laundered the
laundered the proceeds
proceeds thereof
thereof.. Some
Some of
of these
these businesses
businesses included
included

escripts-md.com,
escripts-md .com, Lifespan, virtual Wellness
Lifespan, and Virtual Wellness Networks
Networks.. TROY
TROY

SOBERT's responsibilities included


SOBERT's responsibilities included the
the recruitment
recruitment and
and hiring
hiring of
of

pharmacies and
pharmacies and physicians
physicians..

20.. Defendant
20 Defendant VLADIMIR
VLADIMIR ANDRIES,
ANDRIES, MM.D., was aa physician
.D ., was physician

licensed in
licensed in the
the State
State of
of New
New York
York.. Defendant
Defendant ANDRIES
ANDRIES authorized
authorized

his name
his name to
to appear
appear on
on vials
vials of
of drugs
drugs distributed
distributed and
and dispensed
dispensed by
by

defendants to
defendants to customers
customers of
of the
the Internet
Internet businesses
businesses.. From
From in
in or
or

about November 2002


about 2002 through
through in
in or
or about
about December
December 2003,
2003, defendant
defendant

ANDRIES authorized
ANDRIES authorized the
the distribution
distribution and dispensing
dispensing of
of at
at least
least

33,400 prescriptions,
33,400 prescriptions, including
including at
at least
least 1000
1000 prescriptions
prescriptions of
of

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Schedule
Schedule III substances and
III substances and at
at least
least 17,500
17,500 prescriptions of
prescriptions of

Schedule IV substances,
Schedule IV substances, which
which defendants
defendants sold
sold through
through their
their

Internet application
Internet application process
process..

21.. Defendant
21 Defendant THU
THU ANH
ANH HOANG,
HOANG, MM.D.,
.D ., was
was aa physician licensed
licensed

in the
in the State
State of
of Texas
Texas.. Defendant
Defendant HOANG
HOANG authorized
authorized her
her name
name to
to

appear on vials of drugs distributed and dispensed by defendants


dispensed by defendants to
to

of the
customers of the Internet
Internet businesses
businesses.. From
From in
in or
or about
about June
June 2002
2002

through in
through in or
or about
about November
November 2002,
2002, defendant
defendant HOANG
HOANG authorized
authorized the
the

distribution and
distribution dispensing of
and dispensing at least
of at least 16,500
16,500 prescriptions,

including at least 142


142 prescriptions
prescriptions of Schedule III substances
substances and

at least
at least 7000
7000 prescriptions
prescriptions of
of Schedule
Schedule IV
IV substances,
substances, which
which

sold through
defendants sold through their
their Internet
Internet application
application process
process..

22.. Defendant
22 Defendant STEVEN
STEVEN DANIEL
DANIEL HOLLIS,
HOLLIS, MM.D.,
.D ., was a physician
was a physician

licensed in
licensed in the
the State
State of
of Georgia
Georgia.. Defendant
Defendant HOLLIS
HOLLIS authorized
authorized his
his

name to
name to appear
appear on
on vials
vials of
of drugs
drugs distributed
distributed and
and dispensed
dispensed by
by

defendants to
defendants to customers
customers of
of the
the Internet
Internet businesses From in
businesses.. From in or
or

about August 2001


about 2001 through
through in
in or about
about August
August 2002,
2002, defendant HOLLIS
HOLLIS

authorized
authorized the distribution and
the distribution dispensing of
and dispensing at least
of at least 43,390
43,390

prescriptions, including
prescriptions, including at
at least
least 639
639 prescriptions
prescriptions of
of Schedule
Schedule III
III

substances and
substances at least
and at least 26,000 prescriptions of
prescriptions Schedule IV
of Schedule IV

substances,
substances, which defendants
which defendants sold through
sold through their
their Internet
Internet

application process
process..

23.. Defendant
23 Defendant AHSAN
AHSAN U
U.. RASHID, M.D.,
RASHID, M .D ., was
was aa physician licensed
physician licensed

California.. Defendant
in the State of California Defendant RASHID
RASHID authorized
authorized his
his name
name

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Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 8 of 28

to appear on on
to appear vials of of
vials drugs distributed
drugs distributedand
anddispensed
dispensed by
by defendants
defendants

to customers of the Internet


Internet businesses
businesses.. From
From in
in or
or about
about October

2002 through in or
or about
about February 2003, defendant
February 2003, defendant RASHID authorized
authorized

the
the distribution and dispensing
dispensing of
of at
at least
least 12,000
12,000 prescriptions,
prescriptions,

including at least 190 prescriptions


including prescriptions of Schedule III
III substances
substances and
and

at least
at least 8000 prescriptions of
prescriptions Schedule IV
of Schedule IV substances,
substances, which
which

defendants sold through their


their Internet
Internet application
application process
process..

24.. Defendant
24 Defendant ANDRE
ANDRE DD.. SMITH, M.D.,
SMITH, M .D ., was a physiciann
was a physician licensed
licensed

the State of Michigan


in the Michigan.. Defendant
Defendant SMITH
SMITH authorized
authorized his
his name
name to
to

appear on vials of
of drugs
drugs distributed
distributed and dispensed by defendants
dispensed by defendants to
to

customers of the Internet businesses. From in


businesses . From in or
or about
about April
April 2002
2002

through in or about November 2003,


2003, defendant
defendant SMITH
SMITH authorized
authorized the
the

distribution and
distribution dispensing of
and dispensing at least
of at least 65,000 prescriptions,
prescriptions,

at least
including at least 1750 prescriptions of
of Schedule
Schedule III
III substances
substances

IV substances,
and at least 39,800 prescriptions of Schedule IV substances, which
which

sold through
defendants sold through their
their Internet
Internet application
application process
process..

COUNT ONE
(Conspiracy to Violate the
the Controlled
Controlled Substances
Substances Act)
Act)

25.. The
25 The factual
factual allegations
allegations of
of paragraphs
paragraphs 11 through
through 23
23 above
above

are realleged
realleged and
and incorporated
incorporated herein
herein by
by reference
reference..

26.. Beginning
26 Beginning in
in or
or before
before July
July 2001, the exact
2001, the exact date
date being
being

unknown, and continuing


unknown, continuing until
until in
in or
or about
about December
December 2003, in the
2003, in the

Northern District
Northern District of
of Georgia
Georgia and
and elsewhere,
elsewhere,

CHRISTOPHER STOUFFLET,
CHRISTOPHER STOUFFLET,
TROY SOBERT,
TROY SOBERT,
VLADIMIR ANDRIES,
VLADIMIR ANDRIES, M
M.D.,
.D .,

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THU ANH HOANG


THU HOANG,, MM.D.,
.D .,
D.S.
D .S . HOLLIS,
HOLLIS , M.D.,
M .D .,
AHSAN U
AHSAN U.. RASHID,
RASHID, M.D.,
M .D ., and
and
ANDRE D
ANDRE D.. SMITH,
SMITH , MM.D.,
.D . ,

defendants herein,
defendants herein, knowingly
knowingly and
and intentionally
intentionally conspired
conspired and
and agreed
agreed

together, and with others known and unknown to


together, to the
the Grand
Grand Jury,
Jury, to
to

commit the following offenses


commit offenses::

(a) to
(a) to distribute
distribute and
and dispense
dispense Schedule
Schedule III
III and
and IV
IV controlled
controlled

substances, including
substances, including but
but not limited to,
not limited to, quantities
quantities of
of the
the

following controlled
following controlled substances
substances:: (1)
(1) Phentermine
Phentermine (including
(including brand
brand

name Adipex-P),
name Adipex-P), a Schedule
a Schedule IV
IV controlled
controlled substance
substance ; (2 )
i (2)

Phendimetrazine (brand
Phendimetrazine (brand name Bontril), a
name Bontril), a Schedule
Schedule III
III controlled
controlled

substance;; and
substance (3) sibutramine
and (3) sibutramine hydrochloride (brand name
hydrochloride (brand name Meridia),
Meridia),

a Schedule
a Schedule IV
IV controlled
controlled substance,
substance, other
other than
than for
for aa legitimate
legitimate

medical purpose,
medical purpose, and
and not
not in
in the
the course
course of
of professional practice, in
professional practice, in

violation of
violation of Title
Title 21,
21, United
united States
States Code,
Code, Sections
Sections 841(a)(1),
841 (a) (1) ,

841(b)
841 (b)(1)(1)
(D),(D)and 841{b)
, and (2), andandTitle
841(b)(2), Title 21, Code of
21, Code- Federal
of Federal

Regulations, SSection
e c ti o n 1306.04; and
1306 .0 4 ; a nd

(b) to use
(b) to use a a communication
communication facility
facility in
in committing
committing and
and in
in

causing and
causing and facilitating
facilitating the
the distribution
distribution and
and dispensing
dispensing of
of

Schedule III
Schedule III and
and IV
IV controlled
controlled substances,
substances, including
including but
but not
not

to, quantities of the


limited to, the following
following controlled substances
substances:: (1)
(1)

Phentermine
Phentermine (including brand
(including brand name
name Adipex-P),
Adipex-P), aa Schedule
Schedule IV
IV

substance;; (2)
controlled substance (2) Phendimetrazine
Phendimetrazine (brand
(brand name
name Bontril),
Bontril), aa

Schedule
Schedule III controlled
III controlled substance
sUbstance;; and
and (3) sibutramine
(3 ) sibutramine

hydrochloride (brand
hydrochloride (brand name Meridia), a
name Meridia), a Schedule
Schedule IV
IV controlled
controlled

-9-
-9-
Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 10 of 28

~ubstance, other than


substance, than for
for aa legitimate
legitimate medical
medical purpose
purpose and
and not
not in
in

the usual
the usual course
course of
of professionall
professional practice, in violation
practice, in violation of
of Title
Title

21, United
21, united States
States Code,
Code, Sections
Sections841(a)(1),
841 (a) (1) 841
, 841
(b)(b) (1
(1)) (D
(D)) ,,

841(b)
841 (2), and
( b)(2), and 843(b), 21, Code
and Title 21, Code of
of Federal
Federal Regulations,
Regulations,

section 1306.04.
Section 1306 .04 .

PURPOSE OF THE CONSPIRACY


CONSPIRACY

27.. It
27 It was
was the
the purpose
purpose of
of the
the conspiracy
conspiracy to
to sell,
sell, via
via the
the

Internet, controlled
Internet, controlled substances
substances to
to consumers
consumers in
in the
the United
United States
States..

profit, defendants
To maximize profit, defendants used
used mass
mass e-mailings,
e-mailings, advertising,
advertising,

and other marketing schemes


and schemes to
to sell
sell large
large quantities
quantities of
of controlled
controlled

to customers
substances to customers through
through the
the websites
websites.. Defendants'
Defendants' process
process

for selling
for selling drugs
drugs violated
violated the
the federal
federal requirement
requirement under
under the
the

Controlled Substances
Controlled Substances Act
Act that
that controlled
controlled substances
substances be
be dispensed
dispensed

only for
for aa legitimate
legitimate medical
medical purpose
purpose and
and in
in the
the usual
usual course
course of
of

professional medical
professionall medical practice.
practice .

MANNER AND
MANNER AND MEANS
MEANS OF
OF THE
THE CONSPIRACY
CONSPIRACY

28.. It
28 It was
was aa part of the
the conspiracy that defendants illegally
illegally

dispensed controlled
dispensed controlled substances
substances through
through several
several businesses
businesses using
using aa

variety of
variety of Internet
Internet websites
websites.. OnOnthese
thesewebsites,
websites, defendants
defendants

various controlled
advertised various controlled substances
substances.. Some
Some of
of the
the controlled
controlled

substances
substances defendants
defendants offered
offered were drugs commonly
were drugs commonly known
known as
as

Phentermine, Bontril,
Phentermine, Bontril, Adipex,
Adipex, and
and Meridia
Meridia..

29.. It
29 It was
was further
further part
part of
of the
the conspiracy
conspiracy that
that defendants
defendants

obtained information
obtained information from
from customers
customers over the
the Internet,
Internet, using
using an
an

-10-
R
Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 11 of 28

online ordering process


online ordering process.. InInthis
thisordering
ordering process,
process, customers
customers

filled
filled out
out an
an online
online order form and chose the
the type,
type, quantity,
quantity, and
and

dosage of
of the
the controlled
controlled substance the
the customer wished to purchase.
wished to purchase .

Customers
Customers also answered
answered questions
questions about
about their
their medical
medical conditions
conditions..

No one associated with


with the
the defendants
defendants checked
checked the
the accuracy
accuracy of
of the
the

information customers
information customers provided,
provided, including
including their
their identities,
identities, ages,
ages,

and qualifying medical conditions,


conditions, such
such as
as weight
weight..

30. It was
30 . It was further
further part
part of
of the
the conspiracy
conspiracy that
that the
the customers
customers

provided credit
provided credit card
card billing
billing information
information at
at the
the time
time they
they completed
completed

the
the online order form
form..

31.. It
31 It was
was further
further part
part of
of the
the conspiracy
conspiracy that
that the
the websites
websites

stated
stated that a physician
that a physician would
would review
review the
the online
online order
order form
form and
and

whether to
determine whether to authorize
authorize the
the distribution
distribution and
and dispensing
dispensing of
of

the requested
the requested drugs
drugs before
before defendants
defendants sent the drugs
sent the drugs to
to the
the

customers.. Physicians
customers Physicians had
had nonoface-to-face
face-to-face contact
contact with
with the
the

customers, who
customers, lived throughout
who lived throughout the
the United
united States
states.. Defendants
Defendants

caused the
caused the controlled
controlled substances
substances to
to be
be distributed
distributed and
and dispensed
dispensed to
to

customers without
customers without:: ananadequate
adequate patient
patient history
historYi; performing
performing aa

mental or physical exami; using


physical exam using appropriate
appropriate diagnostic or laboratory
diagnostic or laboratory

testing ;
testing or providing
i or providing aa means
means to
to monitor
monitor medication
medication response
response..

Generally, the
Generally, the order
order form
form was
was the
the only
only contact
contact with
with the
the customer
customer..

32.. ItIt was


32 was further
further part
part of
of the
the conspiracy
conspiracy that
that defendants
defendants

CHRISTOPHER STOUFFLET
CHRISTOPHER STOUFFLET and
and TROY
TROY SOBERT
SOBERT were
were owners,
owners, operators,
operators,

corporate officers,
officers, directors,
directors, and
and managers
managers of
of the
the companies
companies that
that

-ii-
-11-
Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 12 of 28

operated certain of the websites through which defendants


defendants sold
sold and
and

distributed controlled substances


substances..

33. It was
33 . It was further
further part
part of
of the
the conspiracy
conspiracy that
that defendants
defendants

VLADIMIR ANDRIES,
ANDRIES, M.D.,
M .D ., THU
THU ANH
ANH HOANG, M.D.,
HOANG, M .D ., STEVEN
STEVEN DANIEL HOLLIS,
DANIEL HOLLIS,

M.D.,
M .D ., AHSAN U.. RASHID,
AHSAN U RASHID, M
M.D.,
.D ., and ANDRE D
and ANDRE D.. SMITH,
SMITH, M
M.D., were
.D ., were

physicians
physicians who authorized the
who authorized the distribution
distribution and
and dispensing
dispensing of
of

controlled
controlled substances, including Phentermine,
substances, including Phentermine, Meridia,
Meridia, Bontril,
Bontril, and
and

Adipex, to
Adipex, to Internet
Internet customers
customers.. Defendants
Defendants VLADIMIR
VLADIMIR ANDRIES,
ANDRIES, M
M.D.,
.D .,

THU ANH HOANG,


HOANG, M
M.D.,
.D ., STEVEN
STEVEN DANIEL HOLLIS, M.D.,
HOLLIS, M .D ., AHSAN U.. RASHID,
AHSAN U RASHID,

M.D.,
M .D ., and
and ANDRE
ANDRE D.
D . SMITH, M.D.,
SMITH, M .D ., had
had no face-to-face contact
no face-to-face contact with
with

The controlled
customers.. The
these customers controlled substances
substances were
were distributed
distributed and
and

dispensed for
for other
other thann
than aa legitimate
legitimate medical and not
medical purpose and not in
in

the usual course of


the of professional practice
practice..

34.. ItIt was


34 was further
further part
part of
of the
the conspiracy
conspiracy that
that prior
prior to
to

Spring 2001, defendant


Spring 2001, defendant STOUFFLET
STOUFFLET founded,
founded, owned,
owned, and
and operated
operated

Youthspan, through
Youthspan, through which the Defendant,
which the Defendant, aided
aided and
and abetted
abetted by
by

others, dispensed testosterone


others, testosterone and
and human
human growth
growth hormone
hormone over
over the
the

Internet through
Internet through aa website
website named
named LIFESPANLONGEVZTY
LIFESPANLONGEVITY..COM
COM.. In
In or
or

about June
about June or
or July
July 2001,
2001, STOUFFLET
STOUFFLET changed
changed the
the company
company from
from

Youthspan d/b/a
Youthspan d/b/a Lifespan
Lifespan to
to eScripts
eScripts through
through which
which the
the Defendants,
Defendants,

and TROY
STOUFFLET and TROY SOBERT,
SOBERT, aided
aided and
and abetted
abetted by
by each
each other
other and
and by
by

and unknown
others known and unknown to
to the
the Grand
Grand Jury,
Jury, dispensed
dispensed controlled
controlled

substances, including
substances, including but
but not
not limited
limited to
to Phentermine,
Phentermine, by
by obtaining
obtaining

prescriptions without
prescriptions without the
the customers
customers entering
entering into
into aa legitimate
legitimate

--12-
1 2-
Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 13 of 28

doctor-patient relationship
doctor-patient relat ionship.. By
By on
on or
or about
about March
March 1,
I, 2003
2003 the
the

Defendants moved
Defendants moved offices
offices and
and renamed
renamed the
the company
company Virtual
Virtual Wellness
Wellness

Networks, while
Networks, while operating
operating the
the same
same or
or similar
similar business
business.. Youthspan
Youthspan

d/b/ a Lifespan,
d/b/a Lifespan, eScripts,
eScripts, and
and Virtual
Virtual Wellness
Wellness Networks
Networks each
each

operated out
operated of offices
out of offices located
located in
in the
the Northern
Northern District
District of
of

Georgia..
Georgia

Program
The Affiliate Program

35.. It
35 It was
was further
further part
part of
of the
the conspiracy
conspiracy that
that defendants
defendants

CHRISTOPHER STOUFFLET
CHRISTOPHER STOUFFLET and TROY SOBERT
and TROY SOBERT entered
entered into
into marketing
marketing

agreements with
agreements with persons
persons and
and entities
entities known
known and
and unknown
unknown to
to the
the Grand
Grand

Jury, in
Jury, in order to
to increase
increase sales
sales of
of controlled
controlled substances
substances.. These
These

marketing arrangements
marketing arrangements were known as
were known as "affiliate"
"affiliate" or
or "partner"
"partner"

programs.. AAperson
programs person who
who became
became an
an "affiliate"
"affiliate ll or
or "partner"
"partner u could
could

earn commissions
commissions on
on sales
sales generated
generated from
from customers
customers who
who linked
linked to
to

defendants' websites
defendants' websites through
through the ~affiliate" website
the "affiliate" website.. Affiliate
Affiliate

website were
website were paid
paid aa commission
commission for
for completed
completed drug
drug orders
orders..

36. It was
36 . It was further
further part
part of
of the
the conspiracy
conspiracy that
that defendants
defendants

received payment
received payment for
for controlled
controlled substance
substance drug
drug orders
orders from
from

customers in
customers in various
various ways,
ways, including
including by
by credit
credit cards
cards..

37. It was
37 . It was further
further part
part of
of the
the conspiracy
conspiracy that
that from
from the
the time
time

period of
period of in
in or
or about
about July
July 2001,
2001, through
through in
in or
or about
about December
December 2003,
2003,

defendants distributed
defendants distributed and dispensed through
and dispensed through their
their Internet
Internet

at least
application process at least 260,000
260,000 prescriptions,
prescriptions, including
including at
at

least 5,600
least 5,600 prescriptions
prescriptions units
units of
of Schedule
Schedule III
III substances
substances and
and at
at

--13-
13 -
Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 14 of 28

least 150,000 prescriptions of


of Schedule
Schedule IV
IV substances
substances on
on the
the basis
basis

of the
of the authorizations
authorizations of
of the
the physicians
physicians associated
associated with
with the
the

websites..
websites

38.. It
38 It was
was further
further part
part of
of the
the conspiracy
conspiracy that
that from
from on
on or
or

about February
about February 13,
13, 2002, the exact
2002, the exact date
date being
being unknown
unknown to
to the
the Grand
Grand

Jury, until
Jury, until in
in or
or about
about December,
December, 2003,
2003 I defendants
defendants and
and others
others

sales in
generated sales in excess
excess of
of $75
$75 million
million..

In violation of
In of Title
Title 21,
21, United
United States
States Code,
Code, Section
Section 846
846..

FOUR
COUNTS TWO THROUGH FOUR
(Unlawful
(Unlawful distribution and dispensing of controlled substances)
and dispensing of controlled substances)

39.. The
39 Thefactual
factual allegations
allegations in
in paragraphs
paragraphs 1-38
1-38 of
of the
the

Indictment are
Indictment are incorporated
incorporated by reference
reference and
and realleged
realleged as
as though
though

forth herein
fully set forth herein..

40.. On
40 On or
orabout
about the
the dates
dates listed
listed below,
below, in
in the
the Northern
Northern

of Georgia
District of Georgia and
and elsewhere,
elsewhere,

CHRISTOPHER STOU
STOUFFLET (Counts 2-4),
F FLET (Counts 2-4),
TROY SOBERT
TROY SOBERT (Counts
(Counts 2-4),
2-4),
VLADIMIR ANDRIES,
VLADIMIR ANDRIES, M M.D. (Count 3),
.D . (Count 3), and
and
ANDRE D
ANDRE D.. SMITH,
SMITH, M.D. (Counts 22 and
M .D . (Counts and 4),
4),

defendants herein,
defendants herein, aided and
and abetted
abetted by
by each
each other
other and
and by
by others
others

unknown to
known and unknown to the
the Grand
Grand Jury,
Jury, knowingly
knowingly and
and intentionally,
intentionally,

distributed and
distributed and dispensed,
dispensed, and
and caused to be
caused to be distributed
distributed and
and

dispensed, a
dispensed, a quantity of
of aa controlled
controlled substance
substance for
for other
other than
than aa

legitimate medical
legitimate medical purpose
purpose and
and not
not in the usual
in the usual course
course of
of

professional practice,
professional practice, as
as charged
charged inn
in the chart below,
the chart below, each
each such
such

-14
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Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 15 of 28

instance
instance being
being aa separate count
count of the
the Indictment
Indictment::

CTS DEFENDANTS
CTS DEFENDANTS DATE DATE CONTROLLED
CONTROLLED SUBSTANCE
SUBSTANCE
CHARGED
CHARGED DISTRIBUTED DISTRIBUTED
AND DISPENSEDAND DISPENSED
2 CHRISTOPHER
CHRISTOPHER 09/16/200309/16/2003 Received
Received in in Atlanta, GA,
Atlanta, GA,
STOUFFLET,
STOUFFLET, TROY TROY 30 doses 30 doses of Phentermine
of Phentermine
SOBERT, ANDRE D
SOBERT, D.. 37 37.5
.5 mg,
mg, prescribed
prescribed by by
SMITH, M.D.
SMITH, M .D . Andre Andre D D.. smith,
Smith, M.D.
M . D .,,
dispensed
dispensed to to R R.A.K.,
.A .K .,
Atlanta,
Atlanta, GA GA
3 CHRISTOPHER
CHRISTOPHER 10/01/200310/01/2003 Received
Received in in Atlanta, GA,
Atlanta, GA,
STOUFFLET,
STOUFFLET, TROY TROY 30 doses 30 doses Phentermine 37
Phentermine 37.5
.5
SOBERT,
SOBERT, VLADIMIR mg, prescribed
VLADIMIR mg, prescribed by Vladimir
by Vladimir
ANDRIES,
ANDRIES, M.D.
M .D . Andries, Andries,M M.D. , dispensed
.D ., dispensed
to K.M.,
K .M ., Atlanta,
Atlanta, GA GA
4 CHRISTOPHER
CH RISTOPHER 10/ 10/17/2003 Received
1 7/2003 Rec in At
e ived in Atlanta,
l anta, GA, GA,
STOUFFLET,
STOUFFLET, TROY TROY 90 doses 90 dosesAd Adipex-P
ip ex-P 37 37.5 mg,
.5 mg,
SOBERT,
SOBERT, ANDRE D.
ANDRE prescribed
D, prescribed by by Andre DD..
Andre
SMITH, M
SMITH, M.D.
.D . Smith, Smith,M M.D. , dispensed
.D ., dispensed to to
RR.A.K.
.A .K .,, Atlanta,
Atlanta, GA GA

In violation
In violation of
of Title
Title 21,
21, United
United States
States Code,
Code, Sections
Sections

841 (a) (1), 841(b)(2)


s4i(a)(i), 841 (b) (2);; Title
Title 18,
18, United
United States Code,
Code, Section
Section 22;; and

21, Code
Title 21, Code of
of Federal
Federal Regulations,
Regulations, Section
section 1306
1306.04.
.04 .

COUNT FIVE
FIVE
(Conspiracy to
(Conspiracy to Launder
Launder Money)
Money)

41.. Beginning
41 Beginning on
on or
or before
before February
February 13,
13, 2002,
2002, the
the exact
exact date
date

being unknown,
unknown, and
and continuing
continuing until
until in
in or
or about
about December
December 2003,
2003, in
in

the Northern
the Northern District
District of
of Georgia
Georgia and
and elsewhere,
elsewhere,

CHRISTOPHER STOUFFLET
CHRISTOPHER STOUFFLET and
and
TROY SOBERT,
TROY SOBERT,

defendants herein,
defendants herein, did
did knowingly
knowingly combine,
combine, conspire,
conspire, confederate
confederate and
and

agree, together,
agree, together, and with
with others
others known
known and
and unknown
unknown to
to the
the Grand
Grand

Jury, to
Jury, to commit
commit certain
certain offenses
offenses under
under Title
Title 18,
18, united States
United States

-15-
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Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 16 of 28

Code, Sections 1956


Code, 1956 and
and 1957,
1957, as
as follows
follows::

(a) to
(a) to conduct
conduct and
and attempt
attempt to conduct financial
financial transactions
transactions

affecting interstate
interstate and
and foreign
foreign commerce,
commerce, described
described below,
below, which
which

involved the
transactions involved the proceeds
proceeds of
of specified
specified unlawful
unlawful activity,
activity,

to wit,
to wit, the
the illegal
illegal distribution
distribution and
and dispensing
dispensing of
of controlled
controlled

sUbstances, in violation
substances, in violation of
of Title
Title 21,
21, United
united States
states Code,
Code, Sections
Sections

841(a}, 843(b},
841(a), 843 846, and
( b), 846, and 848(c),
848(c}, with
with the
the intent
intent to
to promote
promote the
the

carrying on
carrying on of
of such
such specified
specified unlawful
unlawful activity
activity and
and that
that while
while

conducting and attempting


attempting to
to conduct
conduct such
such financial
financial transactions,
transactions,

knew that
knew that the
the property
property involved
involved in
in the
the financial
financial transactions
transactions

represented the
represented the proceeds
proceeds of some form
of some form of
of unlawful
unlawful activity,
activity, in
in

violation
violation of Title 18,
of Title 18, United
United States
States Code,
Code, Section
Section

1956 (a) (1)


1956 (a) (A) (i);; and
(1)(A)(i) and

(b) to
(b) to knowingly engage and
knowingly engage and attempt
attempt to
to engage
engage in
in monetary
monetary

transactions by,
transactions by, through,
through, and
and to
to financial
financial institutions,
institutions, affecting
affecting

interstate commerce,
interstate commerce, in criminally derived
in criminally derived property
property of
of aa value
value

greater than
greater than $10,000,
$10, 000, such
such property
property having
having been
been derived
derived from
from aa

specified unlawful
specified unlawful activity,
activity, that
that is,
is, the
the illegal
illegal distribution
distribution and
and

dispensing of
dispensing of controlled
controlled substances,
substances, in
in violation
violation of
of Title
Title 21,
21,

United States
United StatesCode,
Code,Sections
Sections
841841(a}, 843(b},
(a) , 843 (b) , 846, and 848
846, and 848(c} and in
(c) and in

violation of
violation of Title
Title 18,
18, United
United States
States Code,
Code, Section
Section 1957
1957..

OBJECT OF THE CONSPIRACY

42.. The
42 The object
object of
of the
the conspiracy
conspiracy was
was for
for the
the conspirators
conspirators to
to

quantities of
obtain large quantities of funds,
funds, thereby
thereby enriching
enriching themselves,
themselves, in
in

-16-
Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 17 of 28

exchange for distributing and


and dispensing
dispensing controlled
controlled substances
substances for
for

other than aa legitimate medical


medical purpose
purpose and
and not
not in
in the
the usual
usual course
course

practice..
of professional practice

MANNER AND MEANS

43 It was
43.. It was part
part of
of the
the money
money laundering
laundering conspiracy
conspiracy that
that::

(a) defendants
(a) defendants solicited
solicited and
and serviced
serviced customers
customers seeking
seeking

to obtain controlled
controlled substances
substances in
in the
the manner
manner set
set out
out in
in paragraphs
paragraphs

1-40 above
abovei;

(b) defendants charged their


defendants charged their customers
customers fees
fees for
for the
the cost
cost

of controlled substances
substances illegally
illegally distributed
distributed and
and dispensed,
dispensed, for
for

shipping
shipping of those drugs,
of those drugs, and
and sometimes
sometimes for the review
for the review of
of aa

form by
customer's order form by aa physician,
physician, knowing
knowing that
that the
the payment
paYment of
of

fees constituted the proceeds of unlawful activity


those fees activity;;

(c) after
(c) after receiving
receiving funds
funds in
in payment
paYment of
of the
the fees
fees charged
charged

to the customers, caused the


customers, defendants caused the funds
funds to
to be
be deposited
deposited into
into

individuals involved
bank accounts of the various entities and individuals involved in
in

conspiracy;;
the conspiracy

(d) defendants
(d) defendants then
then caused
caused transfers
transfers of
of money
money from
from those
those

for the
bank accounts for the purpose
purpose of
of paying
paying the
the expenses
expenses incurred
incurred to
to

the unlawful
conduct the unlawful drug
drug sales,
sales, such
such as
as shipping
shipping bills,
bills, wholesale
wholesale

prescription drug
prescription bills, pharmacy
drug bills, pharmacy dispensing
dispensing bills,
bills, rent,
rent, and
and

salaries, with
employee salaries, with the
the intent
intent to
to further
further promote
promote the
the ongoing
ongoing

unlawful drug
unlawful drug sales
sales;; and

(e) after
(e) after receiving
receiving funds
funds from
from sales
sales of
of illegally
illegally

-17-
-17-
Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 18 of 28

prescribed drugs,
drugs r defendants caused
caused the
the funds
funds to
to be deposited
deposited into
into

bank accounts from


bank accounts from which
which they
they transferred
transferred the
the funds
funds in
in amounts
amounts

greater than $10 r OOO..


$10,000

OVERT ACTS

44 .
44. In furtherance
furtherance of and to
of the conspiracy and to effect
effect its
its aims
aims

and objects
objects,r one or more
more of
of the
the co-conspirators committed or
co-conspirators committed or caused
caused

to
to be
be committed at least
least one
one of
of the
the overt
overt acts
acts set
set forth
forth in
in Counts
Counts

6-48
6-48 in the
the Northern District of
of Georgia and
and elsewhere
elsewhere::

In violation of Title 18,


violation of 18, United States Code,
United States Coder Section
Section 1956(h)
1956(h)..

COUNTS SIX
SIX THROUGH
THROUGH THIRTY-ONE
THIRTY-ONE
((Promotional Money Launde
Promotional Money Laundering)
ri ng )

45.. The
45 The allegations
allegations in
in Paragraphs
Paragraphs 11 through
through 45
45 are
are realleged
realleged

by reference
and incorporated by reference..

46.. From
46 From in
in or
or about
about March
March 2002 through at
2002 through at least
least April
April 2003,
2003 r

defendants maintained bank accounts


defendants accounts at in
in the
the names
names and
and with
with the
the

as charged
account numbers as charged in
in the
the chart
chart below,
below r which
which accounts
accounts were
were

used to
used to receive
receive funds
funds from
from sales
sales of
of illegally
illegally distributed
distributed and
and

dispensed controlled
dispensed controlled substances
substances..

47.. From
47 From on
on or
or about
about March
March 2002 through at
2002 through at least
least April
April 2003,
2003 r

funds from
funds from these
these bank accounts
accounts were
were used
used to
to pay
pay expenses
expenses of
of the
the

drug scheme
illegal drug scheme..

48.. On
48 On or
or about
about the
the dates
dates enumerated
enumerated as
as to
to each
each count,
count r in
in the
the

Northern District
Northern District of Georgia
of Geo and eelsewhere
r g i a,r and l sewhe re,r

--18-
1 8-
Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 19 of 28

CHRISTOPHER STOUFFLET and


and
TROY SOBERT,

defendants
defendants herein,
herein, knowingly conducted and attempted
knowingly conducted attempted to
to conduct
conduct

financial
financial transactions affecting interstate
interstate and
and foreign
foreign commerce,
commerce,

in the approximate
in the approximate amounts
amounts set
set forth
forth below,
below, which
which involved
involved the
the

proceeds
proceeds of specified unlawful
of specified unlawful activity,
activity, that
that is
is the
the illegal
illegal

distributing and dispensing


dispensing of
of controlled
controlled substances
substances in
in violation
violation

of
of Title 21,
21, United
united States
States Code,
Coder Sections
Sections 841(a),
841(a), 843(b) and 846,
846,

with the intent


with the intent to
to promote
promote the
the carrying
carrying on
on of
of the
the specified
specified

unlawful activity, and


unlawful activity, and while
while conducting
conducting and
and attempting
attempting to
to conduct
conduct

such financial
such financial transactions
transactions knew the property
knew the property involved
involved in
in the
the

financial transactions
financial transactions represented
represented the
the proceeds some form
proceeds of some form of
of

unlawful activity;
activity ; that
that is,
is, the
the defendants, aiding and
defendants, aiding and abetting
abetting one
one

another,
another, caused
caused monies that had been
monies that been paid
paid to
to the
the defendants
defendants for
for

controlled substances defendants


controlled substances defendants had illegally
illegally distributed
distributed and
and

dispensed through
dispensed through websites
websites controlled
controlled by the defendants
by the defendants to
to be
be

transferred to
transferred to the
the payees
payees set
set forth
forth below,
below, to
to promote
promote the
the unlawful
unlawful

activity::
activity

Cts
Cts Date
Date Amountand
Amount and Account
Account Account
Account
Transaction Transaction Transaction
Transaction Transaction Transact To
ion To
From
From

66 6/26/2002
6/26/2002 $261,515.59
$261,515 .59 Speed
Speed Citibank
Citibank
Scripts
Scripts 3200011672
3200011672

7
7 7/2/2002
7/2/2002 $247,635.01
$247,635 .01 Speed
Speed Citibank
Citibank
Scripts
Scripts 3200011672
3200011672

88 7/3/2002
7/3/2002 $240,359.09
$240,359 .09 Speed
Speed Citibank
Citibank
scripts
Scripts 3200011672
3200011672

--19-
19-
Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 20 of 28

"
Cts Date
Cts Date Amountand
Amount Account
and Account Account
Account
Transaction Transaction Transaction
Transaction Transaction To
Transaction To
From
From

9
9 7/15/2002
7/15/2002 $208,663 .56 Speed
$208,663.56 Citibank
Speed Citibank
Scripts
Scripts 3200011672
3200011672

1.0
10 7/18/2002
7/18/2002 $227,261 .07 Speed
$227,261.07 citibank
Speed Citibank
Scripts 3200011672
Scripts 32000 1 1672

1.1
11 7/24/2005
7/24/2045 $221,804 .42 Speed
$221,804.42 Citibank
Speed Citibank
Scripts
scripts 3200011672
3200011672

12 8/22/2002
8/22/2002 $303,961 .68 Speed
$303,961.68 Citibank
Speed Citibank
Scripts 3200011672
scripts 3200011672

13
13 3/27/2003
3/27/2003 $230,967 .25 Speed
$230,967.25 citibank
Speed Citibank
Scripts 3200011672
Scripts 3200011672

14 4/03/2003
4/03/2003 $234,639.19
$23 Speed
4 ,639 .19 S p eed C citibank
i tibank
Scripts
Sc 3200011672
r ip t s 3200011672

15 4/10/2003
4/10/2003 $199,038 .17 Speed
$199,038.17 Citibank
Speed Citibank
Scripts 3200011672
Scripts 3200011672

16 3/19/2002 $370,824.46
3/19/2Q02 $370,824 Infustat,
.46 Infustat, Citibank
Citibank
Inc.. 3200274778
Inc 3200274778

17 3/26/2002
3/26/2002 $258,847.58
$258,847 Infustat,
.58 Infustat, citibank
Citibank
Inc. 3200274778
Inc . 3200274778

18
18 4/02/2002
4/02/2002 $287,390 .52 Infustat,
$287,390.52 Citibank
Infustat, Citibank
Inc. 3200274778
Inc . 3200274778

19 4/09/2002
4/09/2002 $292,138.95
$292,138 Infustat,
.95 Infustat, Citibank
Citibank
Inc. 3200274778
Inc . 3200274778

20
20 4/17/2002
4/17/2002 $272,612.79
$272,612 Infustat,
.79 Infustat, Citibank
Citibank
Inc.. 3200274778
Inc 3200274778

21
21 4/23/2002
4/23/2002 $256,376.62
$256,376 Infustat,
.62 Infustat, Citibank
Citibank
Inc.. 3200274778
Inc 3200274778

22
22 5/01/2002
S/O1/2002 $256,876.16
$256,876 Infustat,
.16 Infustat, Citibank
Citibank
Inc.. 3200274778
inc 3200274778

23
23 5/08/2002
5/08/2002 $225,019.75
$225,019 Infustat,
.75 Infustat, Citibank
Citibank
Inc.. 3200274778
Inc 3200274778
24
24 5/15/2002
5/ $200,825.77
1 S/2002 $200,825 .77 IInfustat, Citibank
nfustat, Ci t ibank
Inc.. 3200274778
Inc 3200274778

-20-
-20-
Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 21 of 28

Cts
Cts Date
Date Amountand
Amount and Account
Account Account
Account
Transaction
Transaction Transaction Transaction To
Transaction Transaction To
From
From

25
25 5/01/2002
5/01/2002 $127,016.10
$127,016 .10 Atlas
AtlasRXRX Colonial
ColonialBank
Bank
8010068214
8010068214

26 5/08/2002
5/08/2002 $128,045.42
$128,045 .42 Atlas
AtlasRXRX Colonial
Colonial Bank
Bank
8010068214
8010068214

27
27 5/15/2002
5/15/2002 $116,882.78
$1 1 6,882 .78 Atlas
AtlasRXRX Colonial
Colonial Bank
Bank
8010068214
8010068214

28 5/23/2002
5/23/2002 $135,946.10
$ 1 35,946 .10 Atlas Colonial Bank
AtlasRXRX Colonial Bank
8010068214
8010068214

29 6/19/2002
6/19/2002 $109,570.88
$109,570 .88 Atlas
AtlasRXRX Colonial
Colonial Bank
Bank
8010068214
8010068214

30 6/28/2002
30 6/28/2002 $110,560.14
$110,560 .14 Atlas
AtlasRXRX Colonial
Colonial Bank
Bank
8010068214
8010068214

31
31 8/22/2002
8/22/2002 $113,127 .42 Atlas
$113,127.42 AtlasRXRX Colonial
ColonialBank
Bank
8010068214
8010068214

In In
In violation of ofTitle
violation Title 18,
18, United States Code,
United States Code, Sections
Sections

1956 (a) (1)


1956 (a) (1) (A)
(A) (i)
(i) and
and 22..

THIRTY-TWO THROUGH
COUNTS THIRTY-TWO THROUGH FORTY-EIGHT
FORTY-EIGHT
Money Laundering)
(Transactional Money Laundering)

49.. The
49 The allegations
allegations in
in Paragraphs
Paragraphs 11 through
through 50
50 are
are realleged
realleged

incorporated by
and incorporated by reference
reference..

50.. From
50 From in
in or
or about
about September
September 28,
28, 2001
2001 through
through at
at least
least March
March

2003, defendants maintained


2003, maintained bank
bank accounts
accounts in
in the
the names
names and
and with
with the
the

account numbers
account numbers as
as charged
charged in
in the
the chart
chart below,
below, which
which accounts
accounts were
were

used to
used to receive
receive funds
funds from
from sales
sales of
of illegally
illegally distributed
distributed and
and

dispensed controlled
dispensed controlled substances
substances..

51.. On
51 Onor
orabout
about the
the dates
dates set
set forth
forth below,
below, in
in the
the Northern
Northern

-21-
-21-
Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 22 of 28

District Georgia
District of Georgia, l

CHRISTOPHER
CHRISTOPHER STOUFFLET and
TROY SOBERT,
TROY SOBERT,

defendants
defendants herein
herein, aided
aided and
l and abetted
abetted by each other
other and
and by
by others
others

known
known and
and unknown
unknown to
to the
the Grand
Grand Jury
Jury, knowingly
knowingly engaged and attempted
I

to
to engage transactions by,
engage in monetary transactions, by, through
through or
or to
I to aa financial
financial

institution affecting interstate


institution, affecting
l interstate and
and foreign commerce, in
in criminally
criminally

derived
derived property
property of a value
of a value greater
greater than
than $10,000,
$10 1000 that
that is,
is the
the I I

deposit of funds
deposit into and transfer of funds out
out of
of accounts
accounts set
set forth
forth in
in the
the

chart below,
chart below, such
such propertyy
property having
having been
been derived from aa specified
derived from specified

unlawful
unlawful activitYI
activity, that iS the
that is, the illegal
illegal dispensing
I dispensing of
of controlled
controlled

substances
substances in
in violation
violation of Title 21,
of Title 21, United
united States
States Code,
Code, Sections
Sections

841(a),
841 (a) , 843(b)
843 (b) and 846:
and 846

Cts Date Amount


CtsDate AmountBy By From
From Payee
Payee Re
Re
Account
Account

32
32 2/12/2003 $28,372
2/12/2003 $28 1 372.08
.08 Troy BoA327993 EEarl
Troy BoA327993 Small
arl S Fat Boy
mall Fat Boy
Sobert 3628 Harley
Sobert 3628 Harley HD HD
ck659
ck659

33
33 3/04/2003 $43,000
3/04/2003 $43 1 000.00
.00 Troy
Troy BoA327993Sessoms
BoA327993 Sessoms Annis-ton
Annis-ton
Sobert
Sobert 3628
3628 HomesHomes Ctct.. Prop-
Prop-
ck673
ck673 erty erty
334 3/18/2003 $220,000
4 3/18/2003 $220 1 000.00
.00 Troy BoA327993
Troy BoA327993 Troy Purchase
Troy Purchase
Sobert
Sobert 3628
3628 Cashiers
Sobert Cashiers
Sobert
ck687
ck687 Check Check
35
35 4/11/2003 $154,795
4/11/2003 $154 / 795.64
.64 Troy BoA327993 Solomon
Troy BoA327993 Solomon Loan
Loan
Sobert 3628 smith
Sobers 3628 Smith Repay Repay
ck704
ck704 Barney
Barney

36
36 6/14/2002 $100,000
6/14/2002- $100 1 000.00
.00 Chris
Chris BoA Stoufflet
BoA Stoufflet "startup
"start up
Stoufflet 003279934
Stoufflet 003279934 Consulting
Consulting funds"
funds"
618/
618/
ck698
ck698

-22-
-22-
Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 23 of 28

cts
Cts Date
Date Amount
AmountBy By From
From Payee
Payee Re
Re
Account
Account

337 9/16/2002 $15,000


7 9/16/2002 $15,000.00
.00 Chris
Chris BoA BoA Ron Ron
Stoufflet 003279934
Stoufflet 003279934 Stoufflet
Stoufflet
618/
618/
ck653
ck653

38
38 12/04/2002 $10,966
12/04/2002 $10,966.85
.85 Chris
Chris BOA003279 Wolf
BaA003279 IT invoice
Wolf "invoice
Stoufflet
Stoufflet 934618/ck
934618/ckDesign 1203 "
Design 123"
672
672 Group
Group

39
39 12/11/2002 $20,000.00
12/11/2002 $20,000 .00 Chris
Chris BoABoA RAUAM "deposit
RAUAM "deposit
Stoufflet
Stoufflet 003279934 Interiors
003279934 Interiors on
on
618/
618/ drapes" drapes"
ck673
ck673

40
40 5/25/2001 $5,000.00
5/25/2001 $5,000 .00 Chris
Chris SSuntrust
u ntrust First Deposit
First Deposit
Stoufflet
Stoufflet 813011494 American
813011494 2828
American 2828
/ck900
/ck900 Title
Title Peachtree
Peachtree
property
property

41 6/24/2001
41 $5,000.00
6/24/2001 $5,ooa .oo Chris
Chris Suntrust Caryle
Suntrust Caryle 2828
2828
Stoufflet
Stoufflet 813011494
813011494Group Peachtree
Group Peachtree
/ck906
/ck9o6

42
42 9/24/2001 $10,000.00
9/24/2001 $10,000 .00 Chris
Chris Suntrust . First
Suntrust First
Stoufflet 813011494 American
Stoufflet 813011494 American
/ck923
/ck923 Title
Title

43
43 9/28/2001 $40,000.00
9/28/2001 $40,000 .00 Chris
Chris Suntrust Emily's
Suntrust Emily's "Design
"Design
Stoufflet 813011494 Interiors for
Stoufflet 813011494 Interiors for
/ck924
/ck924 Condo"Condo"
44
44 $100,000.00
1/08/2002 $100,000
1/08/2002 .00 Chris SuntrustBoA BoA
Chris Suntrust (funds Funds
(funds Funds
Stoufflet 813011494 transfer)
Stoufflet 813011494 transfer) Transfer
Transfer
/ck945
45
45 1/08/2002
1/08/2002 $100,000 .00 Chris
$100,000.00 Suntrust BoABoA
Chris Suntrust (funds
(funds
stoufflet
Stoufflet 813011494 transfer)
813011494 transfer) Funds
Funds
/ck946
/ck946 Transfer Transfer
46
46 4/09/2002 $60,000.00
4/09/2002 $60,000 Chris
.00 Chris Suntrust Coldwell
Suntrust Coldwell real
real
Stoufflet
Stoufflet 813011494
813011494 Bankers estate
Bankers estate
/ck976
/ck976 earnest
earnest
deposit
47
47 4/09/2002 $$15,000.00
4/09/2002 1 5,000 .00 Chris Suntrust Clark
Chris Suntrust Clark "floors ll
"floors"
stoufflet 813011494 Interiors
Stoufflet 813011494 Interiors
/ck979

-23-
Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 24 of 28

,
f

cts
Cts Date
Date Amount By
By From Payee
From Re
Re
Account
Account

48 4/25/2002 $30,000.00
$30,000 .00 Chris Suntrust
Suntrust Emily's
Emily's
Stoufflet
Stoufflet 813011494
813011494 Interiors
Interiors
/ck983
/ck983

In violation of Title 18,


18, United States
States Code,
Code, Sections
Sections 1957
1957

and 22..
and

FORTY-NINE THROUGH
COUNTS FORTY-NINE THROUGH FIFTY-ONE
FIFTY-ONE

(Misbranded Drugs
Drugs While for Sale
while Held for Sale after
after
in Interstate
Shipment in Interstate Commerce)
Commerce)

52.. The
52 Thefactual
factual allegations
allegations in
in paragraphs
paragraphs 1-53
1-53 of
of the
the

Indictment are
Indictment incorporated by reference
are incorporated reference and
and realleged
realleged as
as though
though

forth herein
fully set forth herein..

53.. OnOnororabout
53 aboutthe
thedates
dateslisted
listed below,
below, in
in the
the Northern
Northern

of Georgia
District of Georgia and
and elsewhere,
elsewhere,

CHRISTOPHER STOUFFLET and


and
TROY SOBERT,
TROY SOBERT,

defendants herein,
defendants herein, aided
aided and abetted by
and abetted by each
each other
other and
and by
by others
others

known and
known and unknown
unknown to
to the
the Grand
Grand Jury,
Jury, with
with the
the intent
intent to
to defraud
defraud and
and

mislead, as
mislead, as set
set forth
forth in
in the
the chart
chart below
below each
each such
such instance
instance being
being aa

separate count of the Indictment,


Indictment, caused
caused prescription
prescription drugs
drugs that
that had
had

been shipped
been shipped in
in interstate
interstate commerce
commerce to
to become
become misbranded
misbranded while
while held
held

for
for sale
sale within the meaning
within the meaning of
of Title
Title 21,
21, United
United States
States Code,
Code, Section
Section

353(b) (1),
353 (b) (1 ) , to
to wit,
wit, the drugs were
the drugs were dispensed
dispensed without
without the
the prescription
prescription

practitioner licensed
of a practitioner licensed by
by law
law to
to administer
administer such
such drugs
drugs..

--24-
24-
e Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 25 of 28

.It

CTS DATE
CTS DATE PRESCRIPTION
PRESCRIPTION DRUGSDISTR
DRUGS DISTRIBUTED « DISPENSED
I BUTED & DISPENSED
49
49 09/16/2003 30
09/16/2003 30 Phentermine
Phentermine 37
37.5
.5 mg
mg doses
doses distributed
distributed
and dispensed to
to RR.A.K.
.A .K . in Atlanta
in Atlanta,
Georgla
Georgia . '

50 10/01/2003 30 Phentermine
10/01/2003 30 Phentermine 37
37.5
.5 mg doses distributedd
mg doses distributed
to K
and dispensed to K.M.
.M . in
in Atlanta,
Atlanta, Georgia

51 90 Adipex-P
10/17/2003 90
10/17/2003 Adipex-p 37
37.5
.5 mg
mg doses
doses distributed and
distributed and
dispensed to
to RR.A.K.
.A .K . in
in Atlanta, Georgia
Atlanta, Georgia

In violation of
In of Title
Title 21,
21, United
United States
States Code,
Code, Sections
Sections 331(k),
331(k),

333(a) (2), 353


333(a)(2), 353(b) (1)) ;
( b)(1 j and
and Title 18, United
Title 18, United States
States Code,
Code, Section
Section 22..

FORFEITURE NOTICE

54.. The
54 The allegations
allegations of
of Counts
Counts One
One through
through 48
48 of
of this
this Indictment
Indictment

are realleged
realleged and incorporated
incorporated by
by reference
reference as
as though
though set
set forth
forth fully
fully

for the
herein for the purpose
purpose of
of alleging
alleging forfeiture
forfeiture to
to the
the United
United States
States

to the
pursuant to the provisions of
of Title
Title 21,
21, United
United States
States Code,
Code, Section
Section

853, and Title


853, and Title 18 united States
18 United States Code,
Code, Section
Section 982
982..

55. Pursuant to
55 . Pursuant to Rule
Rule 32
32.2(a) FED.. R.
.2 (a) FED CRIM.. P
R . CpiM P.,
., the defendants
defendants

are hereby
are hereby notified
notified that,
that, if
if convicted
convicted of
of any
any of
of the
the offenses alleged
alleged

above, the
above, the defendants
defendants shall
shall forfeit
forfeit to
to the
the United
United States
States pursuant
pursuant to
to

Title 21,
Title 21, United
United States
States Code,
Code, Sections
sections 853,
853, and
and Title
Title 18,
18, United
United

Code, Section
States Code, Section 982(a)(1)
982(a) (1) their
their interest
interest in
in any
any property,
property, real
real

or personal,
personal, that
that constitutes
constitutes or
or is
is derived,
derived, directly
directly or
or indirectly,
indirectly,

from proceeds obtained,


from obtained, directly
directly or
or indirectly,
indirectly, as
as aa result
result of
of such
such

violation and
violation and any property used,
any property used, or intended to
or intended be used,
to be used, in
in any
any

manner or part,
manner part, to
to commit,
commit, or
or to
to facilitate
facilitate the
the commission
commission of
of the
the

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Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 26 of 28

violation, including
violation, including but
but not
not limited
limited to
to::

A.. Licenses
A Licenses

(I) All
(1) All DEA
DEA registrations
registrations and
and all
all medical
medical licenses
licenses in
in the
the name
name of
of
VLADIMIR ANDRIES
VLADIMIR ANDRIES;;

(2) All DEA


(2) All DEA registrations
registrations and
and all
all medical
medical licenses in the
licenses in the name
name of
of
THU ANH
THU ANH HOANG
HOANG;;

(3 )
(3) All DEA
All DEA registrations
registrations and
and all
all medical
medical licenses
licenses in
in the
the name
name of
of

STEVEN DANIEL
STEVEN DANIEL HOLLIS
HOLLIS;;

(4 )
(4) All DEA
All DEA registrations
registrations and
and all
all medical
medical licenses
licenses in
in the
the name
name of
of

AHSAN U
AHSAN U.. RASHID;
RASHID ;

All DEA
( 5) All
(5) DEA registrations
registrations and
and all
all medicall
medical licenses
licenses in
in the
the name
name of
of

ANDRE DD.. SMITH.


ANDRE SMITH .

B.. Money
B Money Judgment
Judgment

A sum
A sum of
of money
money equal
equal to
to at
at least
least $75
$75 million
million in
in United
United States
States

currency, the amount


currency, representing the amount of
of proceeds
proceeds obtained
obtained as
as aa result
result

of the
the conspiracy
conspiracy to violate the Controlled
Controlled Substances
Substances Act,
Act, for
for which
which

the
the defendants are jointly
jointly and
and severally
severally liable
liable..

56. Pursuant to
56 . Pursuant to Title
Title 21,
21, United
United States
states Code,
Code, Section
Section 853(p),
853(p),

and as
as incorporated by Title
incorporated by Title 18,
18, United
United States
States Code,
Code, Section
Section 982(b),
982(b),

shall forfeit
each defendant shall forfeit substitute
substitute property,
property, up
up to
to the
the value
value of
of

the amount described


the amount described in
in paragraph
paragraph 55
55 if,
if, by
by any
any act
act or
oromissionn
omission of
of

the defendant, the property


defendant, the property described
described in
in paragraph
paragraph 55,
55, or
or any
any portion
portion

thereof,
thereof, cannot
cannot be the exercise of due
be located upon the due diligence
diligence;; has

been transferred,
transferred, sold
sold to
to or
or deposited
deposited with
with aa third
third party
party;; has been
has been

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Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 27 of 28

placed beyond
placed beyond the
the jurisdiction
jurisdiction of
of the
the Court
Court;; has
has been
been substantially
substantially

diminished in
diminished in value
value;; or
or has
has been
been commingled
commingled with
with other
other property which
property which

cannot divided without


cannot be divided without difficulty
difficulty.. The
The property
property subject
subject to
to

forfeiture as
as substitute
substitute assets
assets includes,
includes, but
but is
is not
not limited
limited to,
to, the
the

items described in
items in paragraph 55
55 above,
above, and
and::

(a) All
(a) All right,
right, title,
title, and
and interest
interest in
in any
any and
and all
all property
property

involved in the conspiracy to commit money laundering,


laundering, in
in violation
violation

of Title
of Title 18,
18, United
United States
States Code,
Code, Sections
sections 1956
1956 and
and 1957,
1957, and
and all
all

property traceable
property traceable to
to such
such property, including
including the
the following
following:: (1)
(1) all

other property
money or other property that
that was
was the
the subject
SUbject of
of each
each transaction,
transaction,

transportation, transmission
transportation, transmission or transfer in violation
or transfer violation of
of Section
Section

1956; (2) all


1956 ; (2) all commissions,
commissions, fees
fees and
and other
other property
property constituting
constituting

proceeds obtained
proceeds obtained as
as aa result
result of
of those
those violations
violations;; and
and (3) all
aZ7l

property used
property used in
in any
any manner
manner or
or part
part to
to commit
commit or
or to
to facilitate
facilitate the
the

commission of
commission of those
those violations
violations.. Such
Such property
property shall
shall include,
include, but
but not
not

limited to,
be limited to, all
all items
items and
and property
property set
set forth
forth above
above in
in paragraph
paragraph

55.
55 .

(b) A sum
A sum of money equal to
to the total amount of
of money
money involved
involved

in the conspiracy
in the conspiracy to
to commit
commit money
money laundering I f more
laundering.. If more than
than one
one

defendant is
defendant is convicted
convicted of
of an
an offense, the
the defendants
defendants so
so convicted
convicted are
are

jointly and severally


jointly liable for
severally liable for the amount involved
involved in
in such
such offense
offense..

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Case 1:06-cr-00337-CC-JFK Document 1 Filed 08/08/2006 Page 28 of 28

All in
All in accordance
accordance with
with Title
Title 18,
18, United
united States
States Code,
Code, Section
Section

982 (a) (1) and


982(a)(1) and ((b)
b),I and Rule
and Rule 32
32.2 (a), , Federal
.2(x) Federal Rules of Criminal
Rules of Criminal

Procedure..
Procedure

A ~~ BILL
BILL

~!~=-N-~~------
01
J
.44 -
FOREPERSON

DAVID E . NAH SS

~
UNIXE'D--ST)M~S ATTORNEY

"'F/P.~~s.fl C HARTASH
CHARTASH
UNITEDSTATES
`SSI T UNITED STATES ATTORNEY
ATTORNEY
Bar No
Georg' Bar No.. 121760
C::X~-;r2,
LAWRENCE
LAWRENCE . SO
SO FELD
ASSIST TT UNIT
ASSIST UNIT DD STATES
STATES ATTORNEY
ATTORNEY
Bar No
Georgia Bar No.. 666936

600
600 UU.S.
.S . Courthouse
75
75 Spring Street, SS.W.
Street, .W .
Atlanta, GA
Atlanta, GA 30303
30303
Telephone 404/581-6000
404/581-6000
Facsimile 404/581-6181
Facsimile 404/581-6181

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