A. The Conspiracy and its Purpose:
From approximately in or about 2002, and continuing until approximately on or about March 18, 2011, in the Eastern District of Tennessee and elsewhere, defendants BARNEY DAVIS, CHRISTEN ALTMAN, JEFFERY BRADFORD, PAUL BLACKBURN, and others known and unknown to the grand jury, did wilfully, knowingly, and intentionally combine, conspire, confederate and agree together and with each other to commit offenses against the United States, that is: they conspired to violate the federal Horse Protection Act by intentionally transporting or delivering one or more horses, and showing, exhibiting, or entering one or more horses in a show or exhibition while knowing that the horse or horseswere in pain or otherwise sore (commonly known as to “sore” or “soring” horses), and falsifying entry forms and other related paperwork, in violation of Title 15, United States Code, Sections 1824(1), 1824(2)(B), and 1825(2)(B).
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