For a case when we've got a meth lab caught during production while the meth was still in solution, we have been using:

Then and there knowingly manufacture, by a combination of extraction and chemical synthesis, a controlled substance, namely, Methamphetamine, in an amount of 400 grams or more.

A suggestion was made to change it simply to:

Then and there knowingly manufacture by producing a controlled substance, namely, Methamphetamine, in an amount of 400 grams or more.

Or even:

Then and there knowingly manufacture by a production, preparation, propagation, compounding, conversion, or processing of a controlled substance, namely, Methamphetamine, in an amount of 400 grams or more.

Opinions? What do you guys use?

481.002(25)
481.112
and Charging manual, page 190

I'd sure appreciate any advice.

Philip:

I vote for your first suggestion--the one that leaves out the method of manufacture--because it would be the simplest one to prove at trial. No one but a chemistry major would know what the other suggested indictments means anyway.