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UNITED STATES DISTRICT COURT
The United States of America, acting through its attorneys, charges:FALSE DECLARATIONS (18 U.S.C. § 1623)
1. Charles W. Johnson is hereby made a defendant on the charge stated below.
2. From 1986 until April, 1993, Charles W. Johnson was the President of the Dallas bakery location operated by Campbell Taggart Baking Companies, Inc. and its predecessor corporation Manor Baking Company of Dallas (hereinafter referred to as "the Dallas Rainbo bakery"), and was engaged in the manufacture, sale and distribution of bread and bread products from the Dallas Rainbo bakery.
3. On June 29, 1995, in the Northern District of Texas, Charles W. Johnson testified under oath as a witness before a grand jury of the United States District Court for the Northern District of Texas, sitting in Dallas, Texas, and knowingly made false material declarations concerning matters the grand jury was investigating, in violation of 18 U.S.C. § 1623.
4. At that time and place the grand jury was conducting an investigation to determine, among other things, whether any person or company engaged in the business of manufacturing and distributing bread and bread products, or their employees, had violated or was violating the Sherman Act (15 U.S.C. § 1), or other federal criminal laws, in the Northern District of Texas and elsewhere.
5. It was material to the grand jury's investigation to determine whether Charles W. Johnson, as former President of the Dallas Rainbo bakery:
6. On June 29, 1995, Charles W. Johnson, while under oath, knowingly declared falsely before the grand jury with respect to the material matters set out in paragraph 5 above, as illustrated in the following examples of his testimony:
(Page and line references are to the official grand jury transcript of Charles Johnson, dated June 29, 1995. Declarations charged as false are underscored.)********* Page 70, Lines 11-13
7. These declarations of Charles W. Johnson, as he then and there knew, were false in that (1) Charles W. Johnson did in fact discuss the prices being charged, and to be charged, for bread and bread products sold by the Dallas Rainbo bakery, and its competitors with competitors of the Dallas Rainbo bakery; and (2) Charles W. Johnson did in fact discuss raising and coordinating the prices to be charged for bread and bread products by the Dallas Rainbo bakery and its competitors with employees of competitors of the Dallas Rainbo bakery.
ALL IN VIOLATION OF TITLE 18, UNITED STATES CODE, SECTION 1623.
DATED this ______________day of ________________, 1995.