I need to prepare an indictment for violation of Natural Resources Code Sec. 151.105, for a timber purchaser (trustee) failing to pay for timber already harvested. If anyone has a form, I would like a copy. Please email me at: ken.sparks@co.colorado.tx.us

This is my attempt:

pursuant to one scheme and continuing course of conduct beginning on or about _________, 20__, and continuing through __________, 20__, purchase standing timber for harvest from [victim], sell the said timber after harvest, collect money for the said harvested timber, and knowingly and with intent to defraud the said [victim], directly or indirectly retain, use, disperse or otherwise divert more than five hundred dollars of the said money collected from the sale of the said harvested timber without first paying the beneficiary, the said [victim], the purchase price of the said standing timber.

I think that looks pretty good, but might change "money" to "money or a thing of value" in case defense attempts to claim no actual $$. Also, I think "disperse" should probably be "disburse". Just my 2 cents. I'm in west Texas, so we don't have much in the way of timber!