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117.

Sample Information -- Prescription Drug Marketing Act -- Statement of Origin

THE UNITED STATES ATTORNEY CHARGES:

COUNT ONE

On or about July 3, 1991, within the Western District of New York, the defendant IDONT CARE, INC., [NOTE: names changed from original] a wholesale distributor of prescription drugs, sold a quantity of the prescription drug Advil to a wholesale distributor of prescription drugs without being an authorized distributor of record for the drugs, and without first providing any statement to the purchaser identifying each prior sale of the drugs.

All in violation of 21 U.S.C. §§ 353(e)(1), 331(t) and 333(a)(1).

COUNT TWO

On or about July 10, 1991, within the Western District of New York, the defendant IDONT CARE, INC., a wholesale distributor of prescription drugs, sold a quantity of the prescription drug Advil to a wholesale distributor of prescription drugs without being an authorized distributor of record for the drugs, and without first providing any statement to the purchaser identifying each prior sale of the drugs.

All in violation of 21 U.S.C. §§ 353(e)(1), 331(t) and 333(a)(1).

COUNT THREE

On or about December 11, 1991, within the Western District of New York, the defendant IDONT CARE, INC., a wholesale distributor of prescription drugs, sold a quantity of the prescription drug Motrin to a wholesale distributor of prescription drugs without being an authorized distributor of record for the drugs, and without first providing any statement to the purchaser identifying each prior sale of the drugs.

All in violation of 21 U.S.C. §§ 353(e)(1), 331(t) and 333(a)(1).

___________________________
DENNIS C. VACCO
United States Attorney
Western District of New York

[cited in Civil Resource Manual 113]