Defendant's argument was raised as early as 1984 and rejected by this Court. In People v Cortez, 131 Mich. App. 316, 321-322; 346 N.W.2d 540 (1984), the three defendants, tried in two separate trials, were convicted of possession with intent to deliver 650 or more grams of a mixture containing cocaine. On appeal, the defendants alleged that there was insufficient evidence to support the convictions because evidence of knowledge of the weight of the mixture had not been presented.

Having determined that quantity is an element of the delivery offense, we turn to the question whether knowledge of the amount is an element of a delivery offense. The Court of Appeals held that knowledge of the amount of cocaine involved is not an element of a charge of delivery of cocaine, citing People v Cortez, 131 Mich. App. 316, 331; 346 N.W.2d 540 (1984), and People v Northrup, 213 Mich. App. 494, 498; 541 N.W.2d 275 (1995). It is also the case that this Court stated as follows in People v Quinn, 440 Mich. 178, 189; 487 N.W.2d 194 (1992):

The initial development of this method of interpretation of statutes in the nature of police regulation began with laws concerning adulterated food, commerce, and liquor. Familiar contemporary examples include the fact that a reasonable or good-faith mistake regarding a victim's age is not a defense to third-degree criminal sexual conduct under MCL 750.520d(1)(a); MSA 28.788(4)(1)(a), People v Cash, 419 Mich. 230; 351 N.W.2d 822 (1984), that the prosecution need not prove as an element of the offense of carrying a concealed weapon, MCL 750.227; MSA 28.424, that the defendant knew his permit was expired, People v Combs, 160 Mich. App. 666, 673; 408 N.W.2d 420 (1987), and that a defendant need not know the quantity of narcotics possessed to be found guilty of possession of a controlled substance under MCL 333.7401; MSA 14.15(7401), People v Hamp, 170 Mich. App. 24; 428 N.W.2d 16 (1988), vacated in part 437 Mich. 865 (1990); People v Cortez, 131 Mich. App. 316; 346 N.W.2d 540 (1984), remanded on other grounds 423 Mich. 855 (1985). See, e.g., People v Ward, 364 Mich. 671; 112 N.W.2d 60 (1961) (an equally divided Court affirmed a truck owner's conviction for operating an overloaded truck on the highway even without the owner's knowledge of weight violation); People v Avery, 236 Mich. 549; 211 N.W. 349 (1926) (an equally divided Court affirmed a conviction for violation of liquor laws absent a showing of intent); People v Hatinger, 174 Mich. 333; 140 N.W. 648 (1913) (it would defeat the purpose of the statute to require the state to prove knowledge); People v Snowberger, 113 Mich. 86; 71 N.W. 497 (1897) (the Legislature, under its police power, may declare an act criminal without making intent an element of the offense); People v Welch, 71 Mich. 548; 39 N.W. 747 (1888) (ignorance of the facts that violate a statute is no excuse where intent is not an element of the offense); People v Roby, 52 Mich. 577, 579; 18 N.W. 365 (1884) (the "purpose [

People v Marion, 250 Mich App 446, 450-451; 647 NW2d 521 (2002). In People v Cortez, 131 Mich App 316, 322; 346 NW2d 540 (1984), remanded on other grounds 423 Mich 855 (1985), the defendant was convicted of possession with intent to deliver more than 650 grams of cocaine. On appeal, the defendant argued that there was insufficient evidence to support his conviction because "his trial showed two distinct quantities of cocaine, each weighing less than 650 grams."

[Id. (emphasis added).] This conclusion is in line with People v Cortez, 131 Mich App 316, 331-332; 346 NW2d 540 (1984), remanded on other grounds 423 Mich 855 (1985), which held that a defendant found hiding in a closet with a bag of cocaine, and in possession of another amount on a nearby table, was properly convicted for possession of the combined quantity of cocaine. However, while Green recognizes that the amount of a controlled substance is a factor affecting criminal liability, and while Cortez recognizes prosecutorial discretion to aggregate closely-linked quantities of a possessed substance, we decline to read Green and Cortez as requiring a prosecutor to aggregate all amounts of a controlled substance possessed by a defendant, at least under the facts of this case.

Rather, the majority relies on this Court's interpretation of the completed offense for assistance in interpreting Justice. In People v Cortez, 131 Mich. App. 316, 331; 346 N.W.2d 540 (1984), this Court held that knowledge of the weight of the controlled substance was not an essential element of the crime of possession. However, that case dealt with the completed crime of possession, a very different offense from conspiracy.

Michigan adheres to this general rule. People v Cortez, 131 Mich. App. 316, 330; 346 N.W.2d 540 (1984) ("documents prepared for use in litigation are excluded by this qualification [i.e., trustworthiness]"); Attorney General v John A Biewer Co, Inc, 140 Mich. App. 1, 17; 363 N.W.2d 712 (1985) ("documents prepared for use in litigation are not admissible as records of regularly conducted activities"). As explained in Biewer, "where the record is prepared for the purpose of litigation, the record does not have the inherent trustworthiness that a record kept in the regular course of business does."

MCL 333.7401 et seq.; MSA 14.15(7401) et seq. This Court has held that knowledge of the quantity is not an essential element of the crime, People v Cortez, 131 Mich. App. 316, 331; 346 N.W.2d 540 (1984); People v Hamp, 170 Mich. App. 24; 428 N.W.2d 16 (1988), and that the purpose of the statute with the mandatory minimums is to keep drug dealers away from society for long and definite periods by using harsh sentences, People v Hill, 192 Mich. App. 102, 115-116; 480 N.W.2d 913 (1991), ( After Remand) 202 Mich. App. 520; 509 N.W.2d 856 (1993). Finally, defendant claims that the penalties for the possession of 50 to 225 grams of cocaine is cruel and unusual punishment in view of the fact that the same mandatory penalties are prescribed for serious offenses of delivery of the same amount of cocaine and the fact that offenses involving other drugs have lesser penalties for mere possession as opposed to delivery offenses.

The phrase "aiding and abetting" describes all forms of assistance rendered to the perpetrator of the crime and comprehends all words or deeds which may support, encourage or incite the commission of a crime. People v Palmer, 392 Mich. 370; 220 N.W.2d 393 (1974); People v Cortez, 131 Mich. App. 316; 346 N.W.2d 540 (1984); People v Turner, 125 Mich. App. 8; 336 N.W.2d 217 (1983). Mere presence, even with knowledge that an offense is about to be committed, is not enough to make one an aider or abettor.

We disagree. See People v Cortez, 131 Mich. App. 316, 332; 346 N.W.2d 540 (1984). We also decline to accept defendant's analogy to those cases wherein other panels of this Court have disallowed the aggregation of separate instances of false pretenses under $100, in order to charge for false pretenses over $100.