IN THE IOWA DISTRICT COURT IN AND FOR POLK COUNTY

STATE OF IOWA,
                                   Plaintiff,
VS.
DAVID M. KENNIS,
LOIS KENNIS,
DANIEL KENNIS,
TRACY VARNADO,
and
DAN PATTERSON,
                                   Defendants.

CRIMINAL NO. 136642; 136691;
136641: 136644; 136640; 136643

 

 

TRAIL
INFORMATION

        Comes now John P. Sarcone, as County Attorney of Polk County, Iowa, and in the name and by the authority of the State of Iowa, accuses DAVID KENNIS, LOIS KENNIS, DANIEL KENNIS, TRACY VARNADO, CHRIS VARNADO and DAN PATTERSON of the crimes of.

COUNT I

CONSPIRACY TO DISTRIBUTE A CONTROLLED SUBSTANCE TO A MINOR in violation of Section 124.406 of the 1998 Code of Iowa, and charges that the above-named Defendants on or about March 1, 1999, through and including March 19, 1999, in the County of Polk and State of Iowa, committed or aided and abetted in the commission of Conspiracy to Distribute a Controlled Substance to Minor by unlawfully acting with, entering into a common scheme, designing with, or conspiring with one or more persons to unlawfully distribute a Schedule I controlled substance, to wit: marijuana, to a minor. (CLASS B FELONY)

 

COUNT II

 

DISTRIBUTION OF A CONTROLLED SUBSTANCE TO A MINOR in violation of Section 124.406 of the 1998 Code of Iowa, and charges that the above-named Defendants on or about March 1, 1999, through and including March 19, 1999, in the County of Polk and State of Iowa, committed or aided and abetted in the commission of Distribution of a Controlled Substance to a Minor by unlawfully distributing a Schedule I controlled substance, to wit: marijuana, to a minor. (CLASS B FELONY)

 

COUNT III

 

MANUFACTURING A CONTROLLED SUBSTANCE in violation of Section 124.401(l)(d) of the 1998 Code of Iowa, and charges that the above-named Defendants on or about March 19, 1999, in the County of Polk and State of Iowa, committed or aided and abetted in the commission of Manufacturing a Controlled Substance by unlawfully manufacturing a Schedule I controlled substance, to wit: marijuana. (CLASS D FELONY)

 

COUNT IV

 

POSSESSION OF A CONTROLLED SUBSTANCE WITH INTENT TO DELIVER in violation of Section 124.401(1)(d) of the 1998 Code of Iowa, and charges that the above-named Defendants on or about March 1, 1999, through and including March 19, 1999, in the County of Polk and State of Iowa, committed or aided and abetted in the commission of Possession of a Controlled Substance With Intent to Deliver by unlawfully possessing a Schedule I controlled substance, to wit: marijuana, with intent to deliver. (CLASS D FELONY)

 

COUNT V

 

FAILURE TO POSSESS A TAX STAMP in violation of Sections 45311.3 and 45311.12 of the 1997 Code of Iowa, and charges that the above-named Defendants on or about April 19, 1999, in the County of Polk and State of Iowa, committed or aided and abetted in the commission of Failure to Possess a Tax Stamp by possessing a taxable substance, to wit: over 42.5 grams of marijuana, not having paid state tax on said substance and not having affixed a tax stamp, label, or other official indicia thereto. (CLASS D FELONY)

STATE OF IOWA, POLK COUNTY ss:

        I, John P. Sarcone, being duly sworn, do depose and say that I am the County Attorney of Polk County, Iowa; that I have made a full and careful investigation of the facts upon which the above charge is based, and that the allegations contained in the above and foregoing instrument are true as I verily believe.  This is a True Information.

JOHN P. SARCONE, POLK COUNTY ATTORNEY

By DANIEL C. VOOGT, PK1985075
Assistant Polk County Attorney

        Subscribed and sworn to this 28th day of April, 1999.  I find that the evidence contained in the Trial Information and the minutes of testimony, if unexplained, would warrant a conviction by the trial jury.

Bond is fixed in the amount of $32.500 cash or surety.

Robert D. Wilson
JUDGE, FIFTH JUDICIAL DISTRICT OF IOWA

        Copy of Information and minutes received this _____ day of _______________, 19_____.

Defendant/Attorney for Defendant