The indictment, returned early yesterday by a Manhattan grand jury, describes a series of meetings between Ms. Stewart and investigators from the S.E.C., the Justice Department and the F.B.I. in February and April 2002. It lists various statements she made that prosecutors contend were false, and details meetings and phone conversations she had with Mr. Bacanovic before each of them was questioned.

''Stewart and Bacanovic agreed that rather than tell the truth about the communications with Stewart on Dec. 27, 2001, and the reasons for Stewart's sale of ImClone stock on Dec. 27, 2001, they would instead fabricate and attempt to deceive investigators with a fictitious explanation for her sale,'' according to the indictment. That explanation was the ''pre-existing agreement to sell the stock if and when the price dropped to $60 per share.''

A blue pen figured prominently in the case against Mr. Bacanovic. Prosecutors contend that some time after January, when he learned about the S.E.C. inquiry, Mr. Bacanovic scribbled the notation ''@60'' on a worksheet that listed Ms. Stewart's ImClone holdings and carried some comments that were written in blue ink on Dec. 21, 2001. ''Peter Bacanovic altered the worksheet, using ink that was blue ballpoint, but was scientifically distinguishable from the ink used elsewhere on the worksheet,'' the indictment said.

In accusing Ms. Stewart of securities fraud, the indictment, referring to her company by its initials, pointed to three statements she or her lawyer made proclaiming her innocence once her ImClone sale became widely known, it said, ''in an effort to stop or at least slow the steady erosion of MSLO's stock price caused by investor concerns.''

One of the statements was made to a reporter for The Wall Street Journal on June 6, 2002, and published the next day. The statement said Ms. Stewart's ImClone trade was ''executed because Ms. Stewart had a predetermined price at which she planned to sell the stock.''

''That determination,'' it added, ''made more than a month before the trade, was to sell if the stock ever went less than $60.''

Another statement, issued on June 12, also said that an existing agreement led to the stock sale.

But the indictment asserted, ''Stewart falsely stated that she 'did not have any nonpublic information' regarding ImClone when she sold her ImClone shares.'' The stock of her company rebounded by 7 percent after the statement, according to the indictment.