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UNITED STATES DISTRICT COURT FIL ID
EASTERN DISTRICT OF KENTUCKY APR 25 2019
SOUTHERN DIVISION
PIKEVILLE ATLO!iOON
ROBERT rt CARR
CLERK U.S. DISTRICT COURT
UNITED STATES OF AMERICA
KELSIE SPENCER
* * * * *
THE GRAND JURY CHARGES:
COUNT 1
18 U.S.C. § 1365(a)(4)
On or about November 13, 2018, through on or about November 14, 2018, the
KELSIE SPENCER
with reckless disregard for the risk that another person would be placed in danger of
death or bodily injury, and under circumstances manifesting extreme indifference to such
risk, did tamper with a consumer product that affected interstate commerce, to wit:
COUNT2
18 U.S.C. § 100l(a)(2)
Kentucky,
KELSIE SPENCER
did willfully and knowingly make and cause to be made materially false, fictitious, and
of the United States by falsely, fictitiously, and fraudulently stating to a special agent of
the U.S. Food and Drug Administration that she was not familiar with the AccuDose Rx
Station, when, as she then and there knew, such statement was false, fictitious, and
fraudulent, because she had, in fact, been previously trained on the operation and use of
the AccuDose Rx Station while working at Appalachian Regional Healthcare, and had
A TRUE~
PENALTIES
COUNT 1: Not more than 10 years imprisonment, a $250,000 fine, and 3 years
supervised release.
COUNT 2: Not more than 5 years imprisonment, a 250,000 fine, and 3 years
supervised release.