COUNT ONE 

That you, PAUL USORO SAN EMMANUEL UDOM (CURRENTLY CONSTUTIONALLY IMMUNED AGAINST CRIMINAL PROSECUTION) UWEMEDIMO THOMAS NWOKO (STILL AT LARGE), MFON JACOBSON UDOMAH (ACCOUNT GENERAL OF AKWA IBOM STATE) (STILL AT LARGE) AND MARGARENT THOMPSON UKPE (STILL AT LARGE) sometimes in 2015 in Nigeria, within the jurisdiction of this Honourable Court conspired amongst yourselves to commit an offence, to wit: Conversion of the sum of N1,410,000,000,000.00 (One Billion, Four Hundred and Ten Million, Naira) property of Government of Akwa Ibom State of Nigeria, which sum you reasonably ought to have knows  forms part of the proceeds of an unlawful activity to wit: criminal breach of trust and thereby committed an offence contrary to Section 18(a) of the Money Laundering (Prohibition) Act, 2011 as amended and punishable under section 15(3) of the same Act.

 COUNT TWO

That you, PAUL USORO SAN, EMMANUEL UDOM(CURRENTLY CONSTUTIONALLY IMMUNED AGAINST CRIMINAL PROSECUTION ), UWEMEDIMO THOMAS NWOKO(STIL AT LARGE), NSIKAN LINUS NKAN, (COMISSIONER OF  FINANCE AKWA IBOM STATE) (STILL AT LARGE). MFON JACOBSON UDOAH (ACCOUNTANT GENERAL OF AKWA IBOM STATE) (STILL AT LARGE AND MARGARET THOMPSON UKPE (STIL AT LARGE) on or about the 14^TH DAY OF March, 2016 in Nigeria within the jurisdiction of this Honourable Court Disguised the origin of the sum of N 300,000,000.00 (Three Hundred Million Naira). Property of Government of Akwa ibom forms of Nigeria which sum you reasonably act to wit: criminal breach of trust and thereby committed an offence contrary to section 15 (2) (b) of the Money Laundering (Prohibition) Act, 2011 as amended and punishable under Section 15 (3) of the same Act.

COUNT THREE

 PAUL USORO SAN, EMMANUEL UDOM (CURRENTLY CONSTUTIONALLY IMMUNED AGAINST CRIMINAL PROSECUTION), UWEMEDIMO THOMAS NWOKO (STIL AT LARGE), NSIKAN LINUS NKAN, (COMISSIONER OF FINANCE AKWA IBOM STATE) (STILL AT LARGE). MFON JACOBSON UDOAH (ACCOUNTANT GENERAL OF AKWA IBOM STATE) (STILL AT LARGE AND MARGARET THOMPSON UKPE (STIL AT LARGE) on or about the 14^TH DAY OF March, 2016 in Nigeria within the jurisdiction of this Honourable Court Disguised the origin of the sum of N 300,000,000.00 (Three Hundred Million Naira). Property of Government of Akwa Ibom forms of Nigeria which sum you reasonably act to wit: criminal breach of trust and thereby committed an offence contrary to section 15 (2) (a) of the Money Laundering (Prohibition) Act, 2011 as amended and punishable under Section 15 (3) of the same Act.

COUNT FOUR

PAUL USORO SAN, EMMANUEL UDOM (CURRENTLY CONSTUTIONALLY IMMUNED AGAINDT CRIMINAL PROSECUTION), UWEMEDIMO THOMAS NWOKO (STIL AT LARGE), NSIKAN LINUS NKAN, (COMISSIONER OF FINANCE AKWA IBOM STATE) (STILL AT LARGE). FON JACOBSON UDOAH(ACCOUNTANT GENERAL OF AKWA IBO STATE) (STILL AT LARGE AND MARGARET THOMPSON UKPE (STIL AT LARGE) on or about the 14^TH DAY OF March, 2016 in Nigeria within the jurisdiction of this Honourable Court Disguised the origin of the sum of N 300,000,000.00 (Three Hundred Million Naira). Property of Government of Akwa Ibom forms of Nigeria which sum you reasonably act to wit: criminal breach of trust and thereby committed an offence contrary to section 15 (2) (a) of the Money Laundering (Prohibition) Act, 2011 as amended and punishable under Section 15 (3) of the same Act.

COUNT FIVE

That you PAUL USORO,SAN on or about the 14^TH day of March, 2016 in Nigeria within jurisdiction of this Honourable Court used the total sum of N300,000,000.00 (Three Hundred  Million Naira), property of Government of Akwa Ibom State of Nigeria which sum you reasonably ought to have known forms parts of the proceeds of unlawful act wit: criminal breach of trust and thereby committed  an offence contrary to section 15(2)(d) of the Money Laundering (prohibition ) Act, 2011 as amended and punishable under section 15 (3) of the same Act.    

COUNT SIX

That you PAUL USORO,SAN on or about the 14^th day of March, 2016 in Nigeria within jurisdiction of this Honourable Court retained the total sum of N300,000,000.00 (Three Hundred  Million Naira), property of Government of Akwa Ibom State of Nigeria in your Paul Usoro& Co ‘s account No1014604466 domicile in Zenith Bank Plc which sum you reasonably ought to have known forms parts of the proceeds of unlawful act wit: criminal breach of trust and thereby committed  an offence contrary to section 15(2)(d) of the Money Laundering (prohibition ) Act, 2011 as amended and punishable under section 15 (3) of the same Act.    

COUNT SEVEN

That you, PAUL USORO, SAN on or about the day of August, 2015 in Nigeria within the jurisdiction of this Honourable Court retained the sum of N530, 000,000.00(Five Hundred And Thirty  Million Naira) property of government of Akwa Ibom state of Nigeria in Paul Usoro &Company’s Clients account NO. 0690123425 domicile  in Access Bank  Plc sum you reasonably ought to have known for part of the proceeds of unlawful act to wit: criminal breach of trust there committed an offence contrary to section 15(2)(d) of then money Laundering (prohibition) Act, 2011 as amended and punishable under section 15(13) of the same Act.

COUNT EIGHT

That you, PAUL USORO, SAN on or about the 18^th Day of September, 2015 in Nigeria with the jurisdiction of this Honourable Court retained the sum of N40, 000,000.00 (Forty Million Naira).property of Government of Akwa Ibom  State of Nigeria in Paul Usoro & Company ‘s Clients’ account No. 0690123425 domicile in Access Bank Plc which sum you reasonably ought to have known forms part of the proceeds of unlawful act to wit: criminal breach of trust and thereby committed an offence contrary to section 15(2)(d) of the Money Laundering (Prohibition) Act, 2011 as amended and punishable under Section 15(3) of the same Act.

COUNT NINE

That you PAUL USORO,SAN on or about the 3^rd day of December, 2015 in Nigeria within jurisdiction of this Honourable Court retained the total sum of N260,000,000.00 (Two Hundred and Sixty Million Naira), property of Government of Akwa Ibom State of Nigeria in Paul Usoro& Company ‘s account  Clients’No0690123425 domicile in Access Bank Plc which sum you reasonably ought to have known forms parts of the proceeds of unlawful act wit: criminal breach of trust and thereby committed  an offence contrary to section 15(2)(d) of the Money Laundering (prohibition ) Act, 2011 as amended and punishable under section 15 (3) of the same Act.

COUNT TEN

That you, PAUL USORO,SAN on or about the 27^th day of August, 2015 in Nigeria within jurisdiction of this Honourable Court transferred the total sum of N65,000,000.00 (Sixty  Five  Million Naira),property of Government of Akwa Ibom State of Nigeria in Paul Usoro and Company‘s account  Clients’No.0690123425 domicile in Access Bank Plc to UWEMEDIMO THOMAS NWOKO( HON.ATTRONEY –GENERAL AND COMISSINER OF JUSTICE, AKWA IBOM STATE ) which sum you reasonably ought to have known forms parts of the proceeds of unlawful act wit: criminal breach of trust and thereby committed  an offence contrary to section 15(2)(d) of the Money Laundering (prohibition ) Act, 2011 as amended and punishable under section 15 (3) of the same Act.