IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA OSWP NO.: FLL INFORMATION FOR:

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1 IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA STATE OF FLORIDA, vs. Plaintiff, CASE NO.: JUDGE: OSWP NO.: FLL JOHN COBEY, JOSEPH GONZALEZ, JOSE L. BENITEZ, (A) (B) (C) Defendant. / INFORMATION FOR: COUNT 1: Organized Scheme to Defraud F.S (4)(a)1 Defendants A,B,C (F1) COUNTS 2-13: Possession with Intent to Sell Legend Drugs (F3) F.S (1) Defendant C IN THE NAME AND BY THE AUTHORITY OF THE STATE OF FLORIDA COUNT 1 Organized Scheme to Defraud undersigned Assistant Statewide Prosecutor, under oath, charges that on or about November 1, 2001, and continuing through April 30, 2002, in the Eleventh and Seventeenth Judicial Circuits, to wit: Miami-Dade and Broward Counties, Florida, as part of a related transaction occurring in, or in Page 1 of 8

2 connection with, an organized criminal conspiracy affecting two or more judicial circuits of Florida, to wit: Miami-Dade and Broward Counties, Florida, to wit: the Eleventh and Seventeenth Judicial Circuits, to wit: the Defendants, JOHN COBEY, JOSEPH GONZALEZ and JOSE L. BENITEZ, did knowingly engage in a scheme to defraud prescription drug users residing inside and outside the State of Florida, through a systematic and ongoing course of conduct, by selling into the prescription drug wholesale market, what was purported to be genuine, unadulterated and legitimately acquired prescription drugs when, in fact, the said prescription drugs were, at different times, either counterfeit, relabeled, stolen, illegally purchased from Medicaid recipients, illegally purchased from unlicensed persons, illegally imported into the United States, stored in unlicensed facilities or sold with false, fraudulent or forged documentation. It was the intent and purpose of the various members of the scheme to hide or disguise their true source of the prescription drugs they sold by engaging in sham transactions, providing false documentation of the sales history of the prescription drugs and placing straw men on the corporate papers of drug wholesale companies inside and outside the State of Florida, and as a result of this scheme to defraud, the defendants did thereby obtain property with an aggregate value of $50,000 or more, contrary to section (4)(a)1, Florida Statutes. COUNT 2 undersigned Assistant Statewide Prosecutor, under oath, charges that on or about January 30, 2002, Page 2 of 8

3 COUNT 3 undersigned Assistant Statewide Prosecutor, under oath, charges that on or about February 1,2002, COUNT 4 undersigned Assistant Statewide Prosecutor, under oath, charges that on or about February 8, 2002, Page 3 of 8

4 COUNT 5 undersigned Assistant Statewide Prosecutor, under oath, charges that on or about February 11,2002, COUNT 6 undersigned Assistant Statewide Prosecutor, under oath, charges that on or about February 12, 2002, Page 4 of 8

5 COUNT 7 undersigned Assistant Statewide Prosecutor, under oath, charges that on or about February 19,2002, COUNT 8 undersigned Assistant Statewide Prosecutor, under oath, charges that on or about February 25,2002, Page 5 of 8

6 COUNT 9 undersigned Assistant Statewide Prosecutor, under oath, charges that on or about February 28, 2002, COUNT 10 undersigned Assistant Statewide Prosecutor, under oath, charges that on or about March 5, 2002, in the Eleventh Judicial Circuit, to wit: Miami-Dade County, Florida, as part of a related transaction Page 6 of 8

7 COUNT 11 undersigned Assistant Statewide Prosecutor, under oath, charges that on or about March 8, 2002, in the Eleventh Judicial Circuit, to wit: Miami-Dade County, Florida, as part of a related transaction COUNT 12 undersigned Assistant Statewide Prosecutor, under oath, charges that on or about March 15, 2002, Page 7 of 8

8 COUNT 13 undersigned Assistant Statewide Prosecutor, under oath, charges that on or about March 19, 2002, ALL OF SAID OFFENSES BEING AGAINST THE PEACE AND DIGNITY OF THE STATE OF FLORIDA. Dated this day of January, PETER WILLIAMS STATEWIDE PROSECUTOR OSCAR GELPI Assistant Statewide Prosecutor Florida Bar Number th 110 Southeast 6 Street, Suite 900 Ft. Lauderdale, Florida (954) Page 8 of 8