Indictment of Angela Lane


In July 2004, Angela De'Mere Lane of Clarksdale, Mississippi, was charged with 20 criminal counts in connection with the sale of dietary supplements alleged to enhance the breast ("Erdic" and "Phoenaz") and penis (Adagin"). The indictment alleges that from January 1998 to December 2001, she and Steven L. Lane conspired and executed a scheme to defraud consumers that involved false advertising, making unauthorized credit card charges, and failing to deliver products. Doing business as Busting Loose, Inc., Dazzle, Inc., and Phoenaz, Inc., the pair achieved total sales of over $6 million from more than 5,000 victims nationwide. Steven Lane has already pleaded guilty to conspiracy to commit mail fraud and wire fraud and agreed to permit the court to order restitution of all amounts obtained by fraud through the sale of the three products.


UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF MISSISSIPPI

UNITED STATES

v.

ANGELA DE’MERE LANE

CRIMINAL NO. 2:04CR / / /

18 U.S.C. § 371

18 U.S.C.  § 1341

18 U.S.C. § 1343

FILED JULY 29, 2004

INDICTMENT

The Grand Jury charges that:

COUNT ONE

From on or about January 18, 1998, to on or about December 31, 2001, in the Northern District of Mississippi and elsewhere, ANGELA DE’MERE LANE, defendant, did knowingly conspire with others to execute a scheme to defraud persons by the mails, interstate commercial carriers, and interstate wire communications, in violation of 18 U.S.C. §§ 1341 and 1343.

The following were parts of the conspiracy:

1) ANGELA DE’MERE LANE, defendant, and other conspirators would obtain merchandise to be sold as an all natural dietary supplement called Erdic, represented as having the ability to permanently enhance the fullness and firmness, and increase the cup size, of female breasts;

2) ANGELA DE’MERE LANE and another conspirator did devise a formula for all natural dietary supplements for products to be caned Phoenaz and Adagin purportedly to enhance permanently the fullness and firmness of female breasts and to increase permanently the cup sizes of female breasts, and to increase the size and girth of male penises and increase the libido of men who took the dietary supplements.

3) A conspirator contracted American Supplement Technologies and Preferred Price Plus/Healing America, dietary supplement manufacturers, to make the supplements based on the devised formula;

4) ANGELA DE’MERE LANE, defendant, and other conspirators would utilize three company names to sell the merchandise to the public, being Busting Loose, Inc., Dazzle, Inc., and Phoenaz, Inc., in directing the sale and distribution of the merchandise to the public from their business locations in Clarksdale, Mississippi;

5) ANGELA DE’MERE LANE, defendant, and other conspirators would sell the merchandise through radio advertisements, mailed advertisements, and other venues, making representations about the product which DE’MERE LANE, defendant, and other conspirators knew to be untrue or for which the defendants had reckless disregard as to the truth about the ability of the supplements to enhance and enlarge female breasts and male penises;

6) ANGELA DE’MERE LANE, defendant, and other conspirators would accept payment for the supplements by interstate wire communications, accepting credit card accounts and other access device accounts as payment by customers for the purported supplements;

7) ANGELA DE’MERE LANE, defendant, and other conspirators would accept payment for the supplements by mailings through the U. S. mails containing checks and money orders as payment by customers for the purported supplements;

8) ANGELA DE’MERE LANE, defendant, and other conspirators would ship the products to customers by interstate commercial carriers;

9) ANGELA DE’MERE LANE and other conspirators would lull customers by encouraging them to continue purchasing additional orders and using the supplements for longer time periods, explaining it took two or three months or even longer before the customers would see results, including making such representations [as] “if you haven’t seen results in the first couple of months, the product requires that you stay on the product longer because of your metabolism,” and “results depended on how well and how fast Phoenaz works with your individual. Chemistry and metabolism”;

10) ANGELA DE’MERE LANE, defendant, and other conspirators would instruct employees to sell more of the dietary supplement to customers who complained that the product was not working, by assuring them that the product sometimes took longer to work on some individuals;

11) ANGELA DE’MERE LANE, defendant, and other conspirators would refuse to cancel orders for complaining customers and instruct employees to refuse to cancel orders, refuse to ship products and continue to charge customers’ credit cards for products despite customers’ cancellations of orders, and fight and refuse attempts from customers to have charges refunded for cancelled orders.

OVERT ACTS

To accomplish the conspiracy and its objectives, ANGELA DE’MERE LANE, defendant, and other conspirators knowingly did commit overt acts, among which were the following:

1. On or about December 7, 1998, a conspirator created a formula for “Adagin” and negotiated with American Supplement Technologies to manufacture “Adagin.”

2. On or about January 11, 1999, a conspirator created a formula for “Phoenaz” and negotiated with American Supplement Technologies to manufacture “Phoenaz.”

3. On or about January 27, 1999, a conspirator promised customer SJW, New Brighton, Minnesota, that her credit card account would be credited for returned product, but the conspirator did not credit the account as promised.

4. On or about June 30, 1999; ANGELA DE’MERE LANE, defendant did not allow an employee to cancel an order for “Erdic” made by customer LB, but informed the employee to ship the product to LB, despite cancellation of the order.

5. On or about September 1, 1999, ANGELA DE’MERE LANE, defendant, and the other conspirators did send out, and cause to be sent, “Phoenaz” brochures, by the U.S. Mails, representing that the dietary supplement was a breast enhancement tablet.

6. On or about October 18, 1999, ANGELA DE’MERE LANE, defendant, directed an employee to tell customer DM that DM was not seeing enhanced size in her breasts because she had not been taking the product long enough and to encourage customer DM to purchase another two-month supply of “Erdic” for $495.00.

7. 0n or about December 1, 1999, ANGELA DE’MERE LANE, defendant, and the other conspirators did send out, and cause to be sent, “Adagin” brochures, by the U.S. Mails, representing that the dietary supplement was a male organ enhancement tablet.

8. On or about March 24, 2000, a conspirator promised customer EZ, Bloomfield Hills, Michigan, that her credit card account would be credited for a cancelled product order, but the conspirator did not credit the account as promised.

9. On or about April 26, 2000, a conspirator promised customer JH, Eagle, Minnesota, that her credit card account would be credited for a cancelled product order, but the conspirator did not credit the account as promised.

10. On or about May 1, 2000, a conspirator took an order from customer MG, Ross, Ohio, for product and charged her for the product but did not deliver the product as promised.

11. On or about June 21, 2000, a conspirator took an order from customer DS, Valparaiso, Indiana, for product and charged him for the product but did not deliver the product as promised.

12. On or about July 5, 2000, conspirator took an order from customer IM, Schaumburg, Illinois, for product and charged him for the product but did not deliver the product as promised.

13. On or about July 14, 2000, a conspirator took an order from customer CC, Taylor, Michigan, for product and charged her twice for the product.

14. On or about July 14, 2000, a conspirator took an order from customer EH, Rochester, New York, for product and charged him for the product but did not deliver the product as promised.

I5. On or about July 28, 2000, a conspirator made an unauthorized order for customer DF, North Rose, New York, for product, charged him for the product, and did not deliver the product.

16. On or about September 2, 2000, a conspirator took an order from customer SJ, Johnson City, Tennessee, for product and charged him twice for the product.

17. On or about September 4, 2000, a conspirator made an unauthorized order for customer ME, Columbia, Tennessee, for product, charged her for the product, and did not deliver the product.

18. On Or about September 11, 2000, a conspirator took an order for customer KC, Franklin, Kentucky, for product, charged him for the product, and did not deliver the product.

19. On or about September 13, 2000, a conspirator took an order for customer GL, Crandall, Georgia, for product, charged him for th~ product, and did not deliver the product.

20. On or about September 13, 2000, a conspirator took an order from customer MA, Murfreesboro, Tennessee, for product and charged him twice for the product.

21. On or about October 20, 2000, a conspirator took an order cram customer JI, Spring City, Tennessee, for product and charged him twice for the product

22. On or about October 29, 2000, a conspirator took an order cram customer NS, Visalia, California, for product and charged her twice for the product.

23. On or about June 17, 2001, a conspirator took an order from customer DM, Pittsbugh, Pennsylvania, for product and charged him twice for the product.

24. On or about August 7, 2001, a conspirator took an order for customer ML, Ukiah, California, for product, charged him for the product, and did not deliver the product.

25. On or about December 1, 2001, a conspirator took an order for customer EL, Stockton, California, for product, charged him for the product, and did not deliver the product.

All in violation of Title 18, United States Code, Section 371.

COUNT TWO

1. From on or about January 18, 1998 to on or about December 31, 2001, in the Northern District of Mississippi and elsewhere, ANGELA DE’MERE LANE, defendant, aided and abetted by others, did execute and attempt to execute a scheme and artifice to defraud and to obtain moneys of others by false and fraudulent pretenses, representations and promises, through the use of the United States Postal Service, commercial interstate carriers and wire and radio communications in interstate commerce. -

Scheme to Defraud

2. The following were parts of the scheme and artifice to defraud:

a. ANGELA DE’MERE LANE, defendant, aided and abetted by others would obtain merchandise to be sold as an “all natural” dietary supplement called “Erdic,” represented as having the ability to permanently enhance the fullness and firmness, and increase the cup size, of female breasts;

b. ANGELA DE’MERE LANE, aided and abetted by another, did devise a formula for “all natural” dietary supplements for products to be called “Phoenaz” and “Adagin” purportedly to enhance permanently the fullness and firmness of female breasts and to increase permanently the cup sizes of female breasts, and to increase the size and girth of male penises and increase the libido of men who took the dietary supplements.

c. Another person, not named as a defendant, who aided and abetted ANGELA DE’MERE LANE, contracted American Supplement Technologies and Preferred Price Plus/Healing America, dietary supplement manufacturers, to make the supplements based on the devised “formula;”

d. ANGELA DE’MERE LANE, defendant, aided and abetted by another, would utilize three company names to sell the merchandise to the public, those being “Busting Loose, Inc.,” “Dazzle, Inc.,” and “Phoenaz, Inc.,” in directing the sale and distribution of the merchandise to the public from their business location in Clarksdale, Mississippj;

e. ANGELA DE’MERE LANE, defendant, aided and abetted by others, would sell the merchandise through radio advertisements and other venues, making representations about the product ‘which ANGELA DE’MERE LANE, defendant, and others knew to be untrue or for which the defendant had reckless disregard as to the truth about the ability of the supplements to enhance female breasts and male penises;

f.. ANGELA DE’MERE LANE, defendant. aided and abetted by others, would ship the. products to customers by: interstate commercial carriers;

g.  A.NGELA DE’MERE. LANE, defendant, aided and abetted by others, would lull customers by encouraging them to continue purchasing additional orders and using the supplements for longer time periods explaining it took two or three before the customers would see results, including making such representations as “if you haven’t seen results in the first couple’ of months, the product requires that you stay on the product longer because of your metabolism,” and “results depended on bow well and how fast Phoenaz works with your individual chemistry and metabolism;”

h. ANGELA DE’MERE LANE, defendant, aided and abetted by others, would instruct employees to sell more of the dietary supplement to customers who complained that the product was not working, by assuring them that the product sometimes took longer to on some individuals;

i. ANGELA DE’MERE LANE, defendant, aided and abetted by others would refuse to cancel orders for complaining customers and instruct employees to refuse to cancel orders, ship products and charge a customer’s credit card for products despite customers’ cancellations of orders, and fight attempts from customers to have charges refunded for cancelled orders.

Execution of Scheme

2. On or about January 27, 1999, for the purpose of executing the aforesaid scheme and artifice, ANGELA DE’MERE LANE, defendant, aided and abetted by others, did receive an order in the Northern District of Mississippi from SW, New Brighton, Minnesota, for Erdic; charged SW’s credit card through interstate wire communications for the product after falsely and fraudulently pretending, representing, and promising that Erdic would enhance breast size and refused to credit her credit card account after SW returned the product after being promised by ANGELA DE’MERE LANE and others that her account would be credited; all in violation of Title 18, United States Code, Sections 1343 and 2.

COUNT THREE

1. The allegations of paragraph 1 of Count Two are incorporated herein by reference;

2. On or about March 20, 2000, for the purpose of executing the aforesaid scheme and artifice, ANGELA DE’MERE LANE, defendant, aided and abetted by others, did receive an order in the Northern District of Mississippi from EZ, Bloomfield Hills, Michigan, for Phoenaz and debited EZ’s checking account through interstate wire communications after falsely and fraudulently pretending, representing, and promising that Phoenaz would enhance breast size and after EZ canceled the order ANGELA DE’ MERE LANE and others charged for the order anyway; in violation of Title 18, United States Code, Sections 1343 and 2.

COUNT FOUR

1. The allegations of paragraph 1 of Count Two are incorporated herein by reference;

2. On or about April 26, 2000, for the purpose of executing the aforesaid scheme and artifice, ANGELA DE’MERE LANE, defendant, aided and abetted by others, did receive an order in the Northern District of Mississippi from JH, Eagle, Minnesota, for Phoenaz and thereafter charged JH’s credit card through interstate wire communication, after falsely and fraudulently pretending, representing, and promising that Phoenaz would enhance breast size, and thereafter shipped the product and refused to credit JH’s credit card despite JR’s cancellation order; in violation of Title 18, United States Code, Sections 1343 and 2.

COUNT FIVE

1. The allegations of paragraph 1 of Count Two are incorporated herein by reference;

2. On or about May I, 2000, for the purpose of executing the aforesaid scheme and artifice,ANGELA DE’MERE LANE, defendant, aided and abetted by others, did receive an order in the Northern District of Mississippi tram MG. Ross, Ohio for Phoenaz and charged the Goodwin’s credit card through interstate wire communications after falsely and fraudulently pretending, representing, and promising that Phoenaz would enhance breast size and thereafter did not ship the product as promised and-did not credit MG’s credit card account, in violation of Title 18, United States Code. Sections 1343 and 2.

COUNT SIX

1. The allegations of paragraph 1 of Count Three are incorporated herein by reference;

2. On or about July 14, 2000, for the purpose of executing the aforesaid scheme and artifice, ANGELA DE’MERE LANE. defendant, aided and abetted by others, did receive an order in the Northern District of Mississippi from CC, Taylor, Michigan for one shipment of Phoenaz and charged CC’s credit card for two orders of Phoenaz through interstate wire communications after falsely and fraudulently pretending, representing, and promising that Phoenaz would enhance breast size; in violation of Title 18, United States Code, Sections 1343 and 2.

COUNT SEVEN

1. The allegations of paragraph 1 of Count Three are incorporated herein by reference;

2. On or about July 14, 2000, for the purpose of executing the aforesaid scheme and artifice; ANGELA DE’MERE LAME, defendant, aided and abetted by others, did receive an order in the Northern District of Mississippi from EH. Rochester, New York for Adagin and charged EH’s credit card for two orders of Adagin through interstate Wire communications after falsely and fraudulently pretending, representing, and promising that Adagin would enhance penis size and ANGELA DE’MERE LANE did not ship the product and charged EH twice; in violation of Title 18, United States Code, Sections 1343 and 2.

COUNT EIGHT

1. The allegations of paragraph 1 of Count Three are incorporated herein by reference;

2. On or about July 28, 2000, for the purpose of executing the aforesaid scheme and artifice, ANGELA DE’MERE LANE, defendant, aided and abetted by others, did receive an order in the Northern District of Mississippi from S&DF, North Rose, New York for Adagin and charged the S&PF’s credit card though interstate wire communications after falsely and fraudulently pretending, representing, and promising that Adagin would enhance penis size and did not ship the product as promised and did not credit the S&DF’s credit card; in violation of Title 18, United States Code, Sections 1343 and 2.

COUNT NINE

1. The allegations of paragraph I of Count Three are incorporated herein by reference;

2. On or bout September 2, 2000, for the purpose of executing the aforesaid scheme and artifice, ANGELA DE’MERE LANE,  defendant, aided and abetted by-others, did receive an order in the Northern District of Mississippi from SJ, Johnson City, Tennessee for one shipment of Adagin and charged SJ’s credit card through interstate wire communications after falsely and fraudulently pretending, representing, and promising that Adagin would enhance penis size and thereafter charged SJ’s credit card twice; in violation of Title 18, United States Code, Sections 1343 and 2. -

COUNT TEN

1. The allegations of paragraph 1 of Count Three are incorporated herein by reference;

2. On or about September 4, 2000 for the purpose of executing the aforesaid scheme and artifice; ANGELA DE’MERE LANE, defendant, aided and abetted by others, did receive an order in the Northern District of Mississippi from ME, Columbia, Tennessee for Adagin and charged ME’s credit card through interstate wire communications, after falsely and fraudulently pretending, representing, and promising that Adagin would enhance penis size and ME canceled her order, ANGELA DE’MERE LANE did not ship the product and did not credit ME’s credit card; in violation of Title 18, United States Code, Sections 1343 and 2.

COUNT ELEVEN

1. The allegations of paragraph 1 of Count Three are incorporated herein by reference;

2. On or about September 13, 2000, for the purpose of executing the aforesaid scheme and artifice, ANGELA DE’MERE LANE, defendant; aided and abetted by others, did receive an did receive an order in the Northern District of Mississippi from GL, Crandall, Georgia. for Adagin and charged GL’s crediit card through interstate wire communications, after falsely and fraudulently pretending. representing, and promising that Adagin would enhance penis size did not ship the product and did not credit Ledford’s credit card; in violation of Title 18, United States Code, Sections 1343 and 2.

COUNT TWELVE

1. The allegations of paragraph 1 of Count Two are incorporated herein by reference;

2. On or about September 13, 2000, for the purpose of executing the aforesaid scheme and artifice, ANGELA DE’MERE LANE, defendant; aided and abetted by others, did receive an order in the Northern District of Mississippi from MA, Murfreesborough, Tennessee, for Adagin and charged MA’s bank debit card through interstate wire communications for two orders of the product while only delivering one order of the product, after falsely and fraudulently pretending, representing, and promising that Adagin would enhance penis; in violation of Title 18, United States Code, Sections 1343 and 2.

COUNT THIRTEEN

1. The allegations of paragraph 1 of Count Two are incorporated herein by reference;

2. On or about October 20,2000, in the Northern District of Mississippi, for the purpose of executing the aforesaid scheme ari.d artifice, ANGELA DE’MERE LANE, defendant, aided and abetted by others, did receive an order in the Northern District of Mississippi from JI, Spring City, Tennessee for Adagin and charged JI’s credit card though interstate wire communications for two orders of the product while only delivering one order of the product, after falsely and fraudulently pretending, representing, and promising that Adagin would enhance penis size; in violation of Title 18, United States Code, Sections 1343 and 2.

COUNT FOURTEEN

1. The allegations of paragraph 1 of Count Two are incorporated herein by reference;

2. On or about October 29, 2000, in the Northern District of Mississippi, for the purpose of executing the aforesaid scheme and artifice, ANGELA DE’MERE LANE, defendant, aided and abetted by others, did receive an order in the Northern District of Mississippi from NS, Visalia, California for Phoenaz and charged NS’s credit card though interstate wire communications for two orders of the product, while only delivering one order of the product, after fraudulently pretending, representing, and promising that Phoenaz would enhance breast size; in violation of Title 18, United States Code, Sections 1343 and 2.

COUNT FIFTEEN

1. The allegations of paragraph 1 of Count Three are incorporated herein by reference;

2. .On or about June 17, 2001, in the Northern District of Mississippi, for the purpose of executing the aforesaid scheme and artifice, ANGELA DE’MERE LANE, defendant, aided and abetted by others, did receive an order in the Northern District of Mississippi from DM, Pittsburgh, Pennsylvania for Adagin and charged DM’s credit card though interstate communications for two orders of the product, while only delivering one order of the product, after fraudulently pretending, representing, and promising that Phoenaz would enhance penis size; in violation of Title 18, United States Code, Sections 1343 and 2.

COUNT SIXTEEN

1. The allegations of paragraph 1 of Count Three are incorporated herein by reference;

2. On or about December 1, 2001, in the Northern District of Mississippi, for the purpose of executing the aforesaid scheme and artifice, ANGELA DE’MERE LANE, defendant, aided and abetted by others, did receive an order in the Northern District of Mississippi from EL, Stockton, California for Adagin and charged EL’s credit card though interstate wire communications for the product while not delivering the product as promised, after falsely and fraudulently pretending, representing) and promising that Adagin would enhance penis size; in violation of Title 18, United States Code, Sections 1343 and 2.

COUNT SEVENTEEN

1. From on or about January 18, 1998 to on or about June 21, 2000) in the Northern District of Mississippi and elsewhere, ANGELA DE)MERE LANE, defendant, aided and abetted by others, did knowingly devise a scheme and artifice to defraud and to obtain money and property by means of false and fraudulent pretenses, representations and promises through the use of the  States Postal Service in violation of Section 1341, Title 18, United States Code. The scheme was that the defendant would receive telephone orders for the fraudulent dietary supplements, Erdic, Phoenaz, and Adagin. Erdic and Phoenaz purportedly helped to enhance breast size in women, and Adagin was said to increase penis size in men.

2.  The following were parts of the scheme and artifice eo defraud:

a. ANGELA DE’MERE LANE, defendant, aided arid abetted by others would obtain merchandise to be sold as an ‘‘all natural” dietary supplement called “Erdic,” represented as having the ability to permanently enhance the fullness and firmness, and increase the cup size; of female breasts;

b. ANGELA DE’MERE LANE) aided and abetted by another) did devise a formula for “all naturaI” dietary supplements for products to be called “Phoenaz” and “Adagin” purportedly to enhance permanently the fullness and firmness of female breasts and to in crease permanently the cup sizes of female breasts, and to increase the size and girth of male penises and increase the libido of men who took the dietary supplements.

c. Another person, not named as a defendant, who aided and abetted ANGELA DE’MERE LANE, contacted American Supplement Technologies and Preferred Price Plus/Healing America, dietary supplement manufacturers, to make the supplements based on the devised “formula”;

d. ANGELA DE’MERE LANE, defendant, aided and abetted by another, would utilize three company names to sell the merchandise to the public, those being “Busting Loose, Inc,” “Dazzle, Inc.,” and “Phoenaz, Inc.,” in directing the sale and distribution of the merchandise to the public from their business location in Clarksdale, Mississippi;

e. ANGELA DE’MERE LANE.. defendant, aided and abetted by others, would sell the merchandise through radio advertisements and other venues, making representations about the product which, DE’MERE LANE, defendant, and others knew to be untrue or

for which the defendant had reckless disregard as to the truth about the ability of the supplements to enhance female breasts and male penises;

f. ANGELA DE’MERE LANE, defendant, aided and abetted by others, would ship the products to customers by interstate commercial carriers;

g. ANGELA DE’MERE LANE, defendant, aided and abetted by others, would lull customers by encouraging them to continue purchasing additional orders and using the supplements for longer time periods explaining it took two or three months or even longer before the customers would see results, including making such representations as “if you haven’t seen results in the first couple of months, the product requires that you stay on the product longer because of your metabolism,” and “results depended on how well and how fast Phoenaz works with your individual chemistry and metabolism.”

h. ANGELA DE’MERE LANE, defendant; aided and abetted by others, would instruct employees to sell more of the dietary supplement to customers who complained that the product was not working, by assuring them that the product sometimes took longer to work on some individuals.

i. ANGELA DE’MERE LANE, defendant; aided and abetted by others would refuse to cancel for complaining customers and instruct employees to refuse to cancel orders, ship products and charge a customer’s credit card for products despite customers cancellations of orders, and fight attempts from customers to have charges refunded for cancelled orders;

Execution of Scheme

3. On or about June 23, 2000, in the Northern District of Mississippi, for the purpose of executing the aforesaid scheme artifice, ANGELA DE’MERE LANE, defendant, aided and abetted by others, did receive an order through the United States mails, in the Northern District of Mississippi from DS, Valparaiso, Indiana for Adagin and cashed DS’s money orders for the product while not delivering the product as promised, after faIsely and fraudulently pretending, representing, and promising that Adagin would enhance penis size; in vioIation of Title 18, United States Code, Sections 1341 and 2.

COUNT EIGHTEEN

1. The allegations of paragraph 1 of Count Seventeen are incorporated herein by reference;

2. On Or about July 5, 2000, in the Northern District of Mississippi, for the purpose of executing the aforesaid scheme and artifice, ANGELA DE’MERE LANE, defendant, aided and abetted by others, did receive an order through the United States mails, in the Northern District of Mississippi from JM, Schaumburg, lllinois for Adagin and cashed JM’s money orders for the product while not delivering the product as promised, after falsely and fraudulently pretending, representing, and promising that Adagin would enhance penis size; in violation of Title 18, United States Code, Sections 1341 and 2.

COUNT NINETEEN

1. The allegations of paragraph 1 of Count seventeen are incorporated herein by reference.

2. 0n or about September 1, 2000; in the Northern District of Mississippi, for the purpose of executing the aforesaid scheme and artifice, ANGELA DE’MERE LANE, defendant, aided and abetted by others: did ‘receive an order through the United States mails, in the Northern District of Mississippi from KC, Franklin, Kentucky for Adagin and cashed KC’ s money orders for the product while not delivering the product as promised, after falsely and fraudulently pretending, representing, and promising that Adagin would enhance penis size; in violation of Title 18, United States Code, Sections 1341 and 2.

COUNT TWENTY

1. The allegations of paragraph 1 of Count Seventeen are incorporated herein by reference;

2. On or about August 7, 2001, fn the Northern District of Mississippi, for the purpose of executing the aforesaid scheme and artifice, ANGELA DE’MERE LANE, defendant, aided and abetted by others; did receive an order through the United States mails, in the Northern District of Mississippi from ML, Ukiah, California for Adagin and cashed ML’s money orders for the product while not delivering the product as promised, after falsely and fraudulently pretending, representing, and promising that Adagin would enhance penis size; in violation of Title 18, United States Code, Sections 1341 and 2.

A TRUE BILL

This page was posted on August 28, 2004.

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