UNITED STATES OF AMERICA
IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF MARYLAND
l- C 1 Z .. -
c ..C U - \
KIMBERLY D. SMEDLEY andMARTIN FREEMAN,Defendants.
(Conspiracy to Introduce and Deliverfor Introduction Into InterstateCommerce an Adulterated andMisbranded Device with Intent toDefraud or Mislead, 18 U.S.c. ~ 371)INFORMATIONThe United States Attorney for the District of Maryland charges that:At all times relevant:1. Defendant KIMBERLY D. SMEDLEY is a resident of Georgia who traveledfrequently to Baltimore, Maryland; Washington D.C.; Detroit, Michigan; New York City, NewYork; Philadelphia, Pennsylvania and elsewhere to inject "100 centistoke dimethyl siloxanefluid," also known as liquid silicone, into the buttocks of customers for larger and fuller buttocksin exchange for money (hereinafter "customers" or "victims"). When used in this fashion, liquidsilicone is a medical medical device subject to the regulation of Food and Drug Administration(FDA).2. Defendant KIMBERLY D. SMEDLEY stored liquid silicone in a plastic water jug that was not labeled and was not approved by the FDA for the use described in Paragraph Iabove and the liquid silicone, therefore, was adulterated and misbranded.3. Defendant KIMBERLY D. SMEDLEY is not a licensed medical practitioner.4. Defendant KIMBERLY D. SMEDLEY falsely represented to customers and
Case 1:12-cr-00110-CCB Document 22 Filed 03/01/12 Page 1 of 2