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UNITED STATES OF AMERICA *
~A0#20IIR00374
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
. n. l- C 1 Z .. - Oll DCRIMINAL NO. c . .C U - \
*v .
KIMBERLY D. SMEDLEY and
MARTIN FREEMAN,
Defendants.
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*
*
*
*
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(Conspiracy to Introduce and Deliver
for Introduction Into Interstate
Commerce an Adulterated and
Misbranded Device with Intent to
Defraud or Mislead, 18 U.S.c. ~ 371)
INFORMATION
The 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
traveled
frequently to Baltimore, Maryland; Washington D.C.; Detroit,
Michigan; New York City, New
York; Philadelphia, Pennsylvania and elsewhere to inject "100
centistoke dimethyl siloxane
fluid," also known as liquid silicone, into the buttocks of
customers for larger and fuller buttocks
in exchange for money (hereinafter "customers" or "victims").
When used in this fashion, liquid
silicone 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 I
above 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
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8/2/2019 Kimberly Smedley and Martin Freeman Criminal
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victims to whom she administered liquid silicone injections for
a fee that she used medical grade
silicone when in fact the silicone was not medical grade
silicone.
5. Defendant MARTIN FREEMAN was a resident of the District of
Columbia, and
a former police officer. FREEMAN was paid by KIMBERLY D. SMEDLEY
to perform
security for her as she injected liquid silicone and received a
fee for the injections.
6. In or about and between 2009 and October 11, 201 I, in the
District of Maryland
and elsewhere, the defendants,
KIMBERLY D. SMEDLEY and
MARTIN FREEMAN,
did knowingly and willfully combine, conspire, confederate and
agree with each other and with
others known and unknown to the Grand Jury to commit an offense
against the United States,
that is, to introduce and deliver for introduction into
interstate commerce an adulterated and
misbranded device, specifically liquid silicone, with the intent
to defraud or mislead customers,
in violation of21 U.S.C. S S 33 I (a), 352()(2), and
333(a)(2)
OVERT ACT
In furtherance of the conspiracy and to achieve the objectives
thereof, at least one of the
conspirators performed and caused to be performed the following
overt act, among others, in the
District of Maryland: On or about March 30, 201 I , KIMBERLY
SMEDLEY administered nine
(9) injections of silicone into each buttock of victim Jane Doe
in a hotel room in Baltimore,
Maryland.
18 U.S.C. S 371.
( 2 0 1 . J, I 2u~ S fe< ' r 1 b@ROD J. ROSENSTEIN
United States Attorney
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