INDICTMENT. SUPREME COURT OF THE STATE OF NEW YORK 5 KINGS COUNTY THE PEOPLE OF THE STATE OF NEW YORK, INDICTMENT NO. ~ against - 4155/2016 X. WILLIE MOORE, VIOLENT CRIMINAL DEFENDANT. ENTERPRISES BUREAU CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS P-L. § 220.44(2) - (8 COUNTS) CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE. PLL, § 220.39(1) - (8 COUNTS) AFO:N SEX CRIME: N CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE P.L. § 220.16(1) - (8 COUNTS) AFO:N SEX CRIME: N CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE SEVENTH DEGREE P.L. § 220.03 - (2 COUNTS) AFO:N SEX CRIME: N A TRUE BILL. KENNETH P. THOMPSON i Z. DISTRICT ATTORNEY FOREPERSON’COUNT ONE THE GRAND JURY OF THE COUNTY OF KINGS, by this Indictment, accuses the defendant, WILLIE MOORE, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 25" day of November 2015, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, heroin, to a person known to the Grand Jury, and such sale took place within one thousand feet of Public School 11, COUNT TWO AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, WILLIE MOORE, of the ctime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 25" day of November 2015, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, heroin, to a person known to the Grand Jury. COUNT THREE AND THE AFORESAID GRAND. JURY, by this indictment, further accuses the defendant, WILLIE MOORE, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §20.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 25" day of November 2015, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, to wit, heroin, with the intent to sell it.COUNT FOUR AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, WILLIE MOORE, while acting in concert with another individual, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE SEVENTH DEGREE in violation of §220.03 of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 25" day of November 2015, in the County of Kings, knowingly and unlawfully possessed a controlled substance, to wit, heroin. COUNT FIVE \dictment, further accuses the AND THE AFORESAID GRAND JURY, by thi defendants, WILLTE MOORE, while acting in concert with another individual, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendants, on or about the 25" day of November 2015, in the County of Kings, each aiding the other, knowingly and unlawfully sold a narcotic drug, to wit, crack cocaine, to a Person known to the Grand Jury, and such sale took place within one thousand feet of Achievement First Endeavor Middle School. COUNT SIX AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendants, WILLIE MOORE, while acting in concert with another individual, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in Violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendants, on or about the 25" day of November 2015, in the County of Kings, each aiding the other, knowingly and unlawfully sold a narcotic drug, to wit, crack cocaine, to a person known to the Grand Jury.COUNT SEVEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendants, WILLIE MOORE, while acting in concert with another individual, of the crime of CRIMINAL POSSESSION OF A’CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendants, on or about the 25" day of November 2015, in the County of Kings, each aiding the other, knowingly and unlawfully possessed a narcotic drug, to wit, crack cocaine, with the intent to sell it, COUNT EIGHT AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, WILLIE MOORE, while acting in concert with another individual, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE SEVENTH DEGREE in violation of §220.03 of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 25" day of November 2015, in the County of Kings, knowingly and unlawfully possessed a controlled substance, to wit, crack cocaine. COUNT NINE AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, WILLIE MOORE, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 4" day of December 2015, in the County of Kings, Knowingly and unlawfully sold a nareotic drug, to wit, heroin, to a person known to the Grand tury, and such sale took place within one thousand feet of Public School 11.COUNT TEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, WILLIE MOORE, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 4" day of December 2015, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, heroin, to a person known to the Grand Jury. COUNT ELEVEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, WILLIE MOORE, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 4" day of December 2015, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, to wit, heroin, with the intent to sell it. COUNT TWELVE AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, WILLIE MOORE, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 17” day of December 2015, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, heroin, to a person known to the Grand Jury, and such sale took place within one thousand fect of Public School 11.COUNT THIRTE) AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, WILLIE MOORE, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 17" day of December 2015, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, heroin, to a person known to the Grand Jury. COUNT FOURTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, WILLIE MOORE, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 17" day of December 2015, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, to wit, heroin, with the intent to sel it. COUNT FIFTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, WILLIE MOORE, while acting in concert with another individual, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 22" day of December 2015, in the County of Kings, each aiding the other, knowingly and unlawfully sold a narcotic drug, to wit, heroin, to a person Known to the Grand Jury, and such sale took place within one thousand feet of Achievement First Endeavor Middle School.COUNT SIXTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, WILLIE MOORE, while acting in concert with another individual, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 22 day of December 2015, in the County of Kings, each aiding the other, knowingly and unlawfully sold a narcotic drug, to wit, heroin, to a person known to the Grand Jury, COUNT SEVENTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, WILLIE MOORE, while acting in concert with another individual, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 22 day of December 2015, in the County of Kings, cach aiding the other, knowingly and unlawfully possessed a narcotic drug, to wit, heroin, with the intent to sell it. COUNT EIGHTE) AND THE AFORESAID GRAND. JURY, by this indictment, further accuses the defendant, WILLIE MOORE, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 22" day of January 2016, in the County of Kings, Knowingly and unlawfully sold a narcotic drug, to wit, heroin, to a person known to the Grand Jury, and such sale took place within one thousand feet of Public School 11.COUNT NINETEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, WILLIE MOORE, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 22" day of January 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wil, heroin, to a person known to the Grand Jury. COUNT TWENTY AND THE AFORESAID GRAND JURY, by this indictment, farther accuses the defendants, WILLIE MOORE, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220 16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 22" day of January 2016, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, to wit, heroin, with the intent to sell it COUNT TWENTY-ONE AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, WILLIE MOORE, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 23” day of February 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, heroin, to a person known to the Grand Jury, and such sale took place within one thousand feet of Public School 11.COUNT TWENTY-TWO AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, WILLIE MOORE, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 23” day of February 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, heroin, to a person known to the Grand Jury. COUNT TWENTY-THREE AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendants, WILLIE MOORE, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 23" day of February 2016, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, to wit, heroin, with the intent to sell it. COUNT TWENTY-FOUR AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, WILLIE MOORE, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 4" day of March 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, heroin, to a person known to the Grand Jury, and such sale took place within one thousand feet of Public School 11.COUNTY TWENTY-FIVE AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, WILLIE MOORE, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 4" day of March 2016, in the, County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, heroin, to a person known to the Grand Jury. COUNT TWENTY-SIX AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendants, WILLIE MOORE, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 4" day of March 2016, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, to wit, heroin, with the intent to sell it. ee Theo KENNETH P. THOMPSON DISTRICT ATTORNEY 10SERVICE OF PRE-TRIAL MOTIONS BY DEFENDANT TO DEFENDANT:. PLEASE TAKE NOTICE that Pursuant to C.P.L. Article 2: must ordinarily make all pre-trial motions within forty-five days afte) Upon expiration of the 55, defendant(s) cr arraignment and before commencement of trial, applicable period within which defendant(s) must make pre-trial motions, the People will move the Court to preclude any. pre-trial motions made thereafter, Sincerely, FES 3 t vay z * KENNETH P, THOMPSO District Attorney Kings County@LEA) ~INDICTMENT SUPREME COURT OF THE STATE OF NEW YORK KINGS COUNTY KH ‘THE PEOPLE OF THE STATE OF NEW YORK, INDICTMENT NO. ~ against - 4156/2016 X. MAURICE WRIGHT, VIOLENT CRIMINAL DEFENDANT. ENTERPRISES BUREAU CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS P.L. § 220.44(2) - (7 COUNTS) (CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE PLL. § 220.39(1) - (7 COUNTS) AFO: N SEX CRIME: N CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE P.L. § 220.16(1) - (7 COUNTS) AFO:N SEX CRIME: N CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE SEVENTH DEGREE PLL. § 220.03 - (1 COUNT) AFO: N SEX CRIME: N A TRUE BILL KENNETH P. THOMPSON Meg DISTRICT ATTORNEY FOREPERSO!COUNT ONE THE GRAND JURY OF THE COUNTY OF KINGS, by this Indictment, accuses the defendants, MAURICE WRIGHT, while acting in concert with another individual, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendants, on or about the 5" day of November 2015, in the County of Kings, each aiding the other, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury, and such sale took place within one thousand feet of Achievement First Endeavor Middle School. COUNT TWO AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendants, MAURICE WRIGHT, while acting in concert with another individual, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendants, on or about the 5" day of November 2015, in the County of Kings, each cocaine, to a person aiding the other, knowingly and unlawfully sold a narcotic drug, to known to the Grand Jury. COUNT THREE AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendants, MAURICE WRIGHT, while acting in concert with another individual, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendants, on or about the 5" day of November 2015, in the County of Kings, each aiding the other possessed a narcotic drug, to wit, cocaine, with the intent to sell it.COUNT FOUR AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, MAURICE WRIGHT, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 22" day of December 2015, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury, and such sale took place within one thousand feet of Achievement First Endeavor Middle School. COUNT FIVE AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, MAURICE WRIGHT, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 22" day of December 2015, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury. COUNT SIX AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, MAURICE WRIGHT, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 22" day of December 2015, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, to wit, cocaine, with the intent fo sell it.COUNT SEVEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, MAURICE WRIGHT, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE SEVENTH DEGREE in violation of §220.03 of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 22" day of December 2015, in the County of Kings, knowingly and unlawfully possessed a controlled substance, to wit, cocaine. COUNT EIGHT AND THE AFORESAID GRAND JURY, by this indictment, further accuses. the defendant, MAURICE WRIGHT, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 7" day of January 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury, and such sale took place within one thousand feet of Achievement First Endeavor Middle School. COUNT NINE AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, MAURICE WRIGHT, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 7" day of Janaury 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury.COUNT TEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, MAURICE WRIGHT, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 7" day of January 2016, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, to wit, cocaine, with the intent to sell it. COUNT ELEVEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, MAURICE WRIGHT, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 14" day of January 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury, and such sale took place within one thousand feet of Achievement First Endeavor Middle School. COUNT TWELVE AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, MAURICE WRIGHT, of the crime of CRIMINAL SALE OF 4 CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 14" day of January 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury.COUNT THIRTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, MAURICE WRIGHT, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 14" day of January 2016, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, to wit, cocaine, with the intent to sell it. COUNT FOURTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, MAURICE WRIGHT, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 4" day of February 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury, and such sale took place within one thousand feet of Achievement First Endeavor Middle School. COUNT FIFTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, MAURICE WRIGHT, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 4" day of February 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury.COUNT SIXTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses. the defendant, MAURICE WRIGHT, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 4" day of February 2016, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, to wit, cocaine, with the intent to sell it. COUNT SEVENTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, MAURICE WRIGHT, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 23" day of February 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury, and such sale took place within one thousand feet of Urban Assembly Unison School. COUNT EIGHTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, MAURICE WRIGHT, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 23" day of February 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury.COUNT NINETEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendants, MAURICE WRIGHT, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 23” day of February 2016, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, to wit, cocaine, with the intent to sell it. COUNT TWENTY AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, MAURICE WRIGHT, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 4" day of March 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury, and such sale took place within one thousand feet of Urban Assembly Unison School. COUNT TWENTY-ONE AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendants, MAURICE WRIGHT, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 4" day of March 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury.COUNT TWENTY-TWO [AND THE AFORESAID GRAND JURY; by this indictment, further accuses the defendant, MAURICE WRIGHT, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 4" day of March 2016, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, 0 wit, cocaine, with the intent to sell it KENNETH P. THOMPSON DISTRICT ATTORNEY [Tonpr—SERVICE OF PRE-TRIAL MOTIONS BY DEFENDANT TO DEFENDANT: PLEASE TAKE NOTICE that pursuant to C.P.L, Article 266, defendant(s) must ordinarily make all Pre-trial motions within forty-five days after arralgnment and before commencement: of trial, Upon expiration of the. applicable period within which defendant(s) must make pre-trial motions, the People will move the Court’ to preclude any. pre-trial motions made thereafter. Sincerely, ra = ' KENNETH P. THOMPSON District Attorney Kings County(TRIAT) : SUPREME couRT Come state OF NEW YORK ~KINGS COUNTY. INDICTMENT ren a it Pleads Ne bid Tudge ADA. Filed Pleads Not Guilty (PLEA) 7 Fudge . ADA Filed : PleadsNot GuiltyINDICTMENT. SUPREME COURT OF THE STATE OF NEW YORK KINGS COUNTY [ 5 THE PEOPLE OF THE STATE OF NEW YORK, INDICTMENT NO. 4154/2016 ~ against - VIOLENT CRIMINAL ENTERPRISES BUREA\ X. KEITH HARDING, DEFENDANT. CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS P.L. § 220.44(2) - (6 COUNTS) CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE PLL. § 220.39(1) - (6 COUNTS) AFO: N SEX CRIME: N CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE P.L. § 220.16(1) - (6 COUNTS) AFO: N SEX CRIME: N CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE P.L. § 220.06(5) - (i COUNT) AFO: N SEX CRIME: N CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE SEVENTH DEGREE PL. § 220.03 - (1 COUNT) AFO:N SEX CRIME: N A TRUE BILL. KENNETH P. THOMPSON ki DISTRICT ATTORNEY REPERSO!COUNT ONE THE GRAND JURY OF THE COUNTY OF KINGS, by this Indictment, accuses the defendants, KEITH HARDING, while acting in concert with Eben Barnes, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: ‘Such defendants, on or about the 25" day of November 2015, in the County of Kings, each aiding the other, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury, and such sale took place within one thousand feet of Public School 11. COUNT TWO AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendants, KEITH HARDING, while acting in concert with Eben Barnes, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendants, on or about the 25" day of November 2015, in the County of Kings, each aiding the other, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury, COUNT THREE AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendants, KEITH HARDING, while acting in concert with Eben Barnes, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendants, on or about the 25" day of November 2015, in the County of Kings, each aiding the other possessed a narcotic drug, to wit, cocaine, with the intent to sell it,COUNT FOUR AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, KEITH HARDING, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as fallows: Such defendant, on or about the 2"! day of December 2015, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury, and such sale took place within one thousand feet of Achievement First Endeavor Middle School. COUNT FIVE AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant. KEITH HARDING, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 2" day of December 2015, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury COUNT SIX AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant. KEITH HARDING, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 2" day of December 2015, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, to wit, cocaine, with the intent to sell itCOUNT SEVEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, KEITH HARDING, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE SEVENTH DEGREE in violation of §220.03 of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 2" day of December 2015, in the County of Kings, knowingly and unlawfully possessed a controlled substance, to wit, cocaine. COUNT EIGHT AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, KEITH HARDING, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New ‘York, committed as follows: Such defendant, on or about the 4" day of December 2015, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury, and such sale took place within one thousand feet of Achievement First Endeavor Middle School. COUNT NINE AND THE AFORESAID, GRAND JURY, by this indictment, further accuses the defendant, KEITH HARDING, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 4" day of December 2015, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury.COUNT TEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, KEITH HARDING, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 4" day of December 2015, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, to wit, cocaine, with the intent to sell it. COUNT ELEVEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, KEITH HARDING, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 17" day of December 2015, in the County of Kings, Knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury, and such sale took place within one thousand feet of Urban Assembly Unison School. COUNT TWELVE AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, KEITH HARDING, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 17" day of December 2015, in the County of Kings, Knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to @ person known to the Grand Jury.COUNT THIRTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, KEITH HARDING, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 17" day of December 2015, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, to wit, cocaine, with the intent to sell it. COUNT FOURTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, KEITH HARDING, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE in violation of §220.06 of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 17 day of December 2015, in the County of Kings, knowingly and unlawfully possessed cocaine, and said cocaine weighed 500 milligrams or more. COUNT FIFTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, KEITH HARDING, of the ctime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 7" day of January 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury, and such sale took place within one thousand feet of Achievement First Endeavor Middle School.COUNT SIXTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, KEITH HARDING, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 7" day of January 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury. COUNT SEVENTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, KEITH HARDING, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 7" day of January 2016, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, to wit, cocaine, with the intent to sell it. COUNT EIGHTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, KEITH HARDING, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 14" day of January 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury, and such sale took place within one thousand feet of Public School 11COUNT NINETEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, KEITH HARDING, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 14" day of January 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, cocaine, to a person known to the Grand Jury. COUNT TWENTY AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendants, KEITH -HARDING, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 14" day of January 2016, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, to wit, cocaine, with the intent to sell it. ae KENNETH P. THOMPSON DISTRICT ATTORNEYSERVICE OF PRE-TRIAL MOTIONS BY DEFENDANT TO DEFENDANT: . PLEASE TAKE NOTICE that pursuant 10 CPL, Article 255, defendant(s) Must ordingrlly make all pre-trial métions. within forty-five days after arralgnment and before commencement of trial, ‘Upon explration of the applicable period within which defendant(s) must make pre-trial motions, the People will move the Court’ to preclude any, pre-trial motions made thereafter, Sincerely, KENNETH P, THOMPSON District Attorney Kings CountyOF NEW YORK —KINGS COUNTY. INDICTMENT (TRIAL) "SUPREME COURT CeEIHE STATE KENNETH P. THOMPSON Indge. J ADA Verdict ; District Attomiey Pleads Not ot Gay Judge ADA. Filed - Pleads Not Guilty (PLEA) : : Indge ADA. Filed ds Not Guilty Pleads Guilty to_- = LLCRIMINAL COURT OF THE CITY OF NEW YORK PART APAR, COUNTY OF KINGS ‘THE PEOPLE OF THE STATE OF NEW YORK v. ‘STATE OF NEW YORK County oF Kincs SHANE LYONS, DEFENDANT. Detective Brian Depalo, shield number 1737, of Narcotics Borough Brooklyn North, states that: (1) On or about January 14, 2016, at approximately 11:02 A.M., inside of 1595 Fulton Street, Brooklyn, County of Kings, State of New York, the defendant, Shane Lyons, acting in concert with another individual, committed the offenses of: PL. § 220.39(1) Criminal Sale of a Controlled Substance in the Third Degree P.L. §220.16(1) Criminal Possession of a Controlled Substance in the Third Degree P.L. § 220.06(5) Criminal Possession of a Controlled Substance in the Fifth Degree PLL. § 220.03 Criminal Possession of a Controlled Substance in the Seventh Degree and that (2) on or about January 21, 2016, at approximately 10:06 A.M., inside of 1595 Fulton Street, Brooklyn, County of Kings, State of New York, the defendant, Shane Lyons, acting in concert with another individual, committed the offenses of: P.L. §220.39(1) Criminal Sale of a Controlled Substance in the Third Degree P.L. § 220.16(1) Criminal Possession of a Controlled Substance in the Third Degree PL. §220.09(1) Criminal Possession of a Controlled Substance in the Fourth Degree In that the defendant, Shane Lyons, acting in concert with another individual, did knowingly and unlawfully possesses one or more preparations, compounds, mixtures or substances containing a narcotic drug and said preparations, compounds, mixtures or substances are of an aggregate weight of one-eighth ounce or more; did knowingly and unlawfully possesses cocaine and said cocaine weighed five hundred milligrams or more; did knowingly and unlawfully sell a narcotic drug; did knowingly and unlawfully possess a narcotic drug with intent to sell; did knowingly and unlawfully ‘possess a controlled substance. ‘The source of deponent’s information and the grounds for deponent’s belief are as follows: Deponent is informed by an undercover police officer UC C0209 (hereinafter referred to as “UC 1”) who is known to the New York City Police Department and to the Kings County District Attomey's Office that, at the first above time and place, the defendant Shane Lyons, acting in concert with another individual, handed UC 1 a quantity of cocaine in exchange for a sum of United States currency. Deponent is further informed by the informant that, at the second above time and place, the defendant Shane Lyons, acting in concert with another individual, handed UC 1 a quantity of cocaine in exchange for a sum of United States currency. Shane Lyons: k16636661, 05/18/16.; Complaint Printed 5/18/16 11:23 AMDeponent states that the above-described substance from the first and second the above- mentioned times and locations was sent to the New York City Police Laboratory for analysis and said report indicates that the substance referred to as cocaine was determined to be cocaine. False statements made in this document are punishable as a class A misdemeanor pursuant to Section 210.45 of the Penal Law. ads 28K yy DATE SIGNATURES SIGNATURE Shane Lyons: k16636661, 05/18/16.; Complaint Printed 5/18/16 11:23 AMCRIMINAL COURT OF THE CITY OF NEW YORK PART APAR, COUNTY OF KINGS. ‘THE PEOPLE OF THE STATE OF NEW YORK v. STATE OF NEW YoRK Coury oF Kincs DEYSHAUN WIGFALL DEFENDANT. Detective Brian Depalo, shield number 1737, of Narcotics Borough Brooklyn North, states that: (1) On or about January 12, 2016 at approximately 4:45 P.M., at the corner of Fulton Street and St. James Place, Brooklyn, County of Kings, State of New York, defendant, Deyshaun Wiegfall, committed the offense(s) of: P.L. § 220.44(2) Criminal Sale of a Controlled Substance in or Near School Grounds P.L. § 220.39(1) Criminal Sale of a Controlled Substance in the Third Degree PL. §220.16(1) Criminal Possession of a Controlled Substance in the Third Degree PLL. § 220.03 Criminal Possession of a Controlled Substance in the Seventh Degree and that (2) on or about March 15, 2016, at approximately 5:38 P.M., inside of 916 Fulton Street, Brooklyn, County of Kings, State of New York, the defendant, Deyshaun Wigfall, committed the offenses of: P.L. §220.44(2) Criminal Sale of a Controlled Substance in or Near School Grounds PL. § 220.391) Criminal Sale of a Controlled Substance in the Third Degree P.L. §220.16(1) Criminal Possession of a Controlled Substance in the Third Degree and that (3) on or about March 15, 2016, shortly after 5:38 P.M., in front of 488 Waverly Avenue, Brooklyn, County of Kings, State of New York, the defendant Deyshaun Wigfall, committed the offenses of: P.L. §220.44(2) Criminal Sale of a Controlled Substance in or Near School Grounds PL. § 220.391) Criminal Sale of a Controlled Substance in the Third Degree P.L. §220.16(1) Criminal Possession of a Controlled Substance in the Third Degree and that (4) on or about March 15, 2016, at approximately 5:40 P.M., inside 488 Waverly Avenue, Brooklyn, County of Kings, State of New York, the defendant Deyshaun Wigfali, committed the offenses of: P.L. § 220.39(1) Criminal Sale of a Controlled Substance in the Third Degree P.L. § 220.16(1) _ Criminal Possession of a Controlled Substance in the Third Degree and that (5) on or about March 29, 2016, at approximately 4:37 P.M., inside of 916 Fulton Street, Brooklyn, County of Kings, State of New York, the defendant Deyshaun Wigfall, committed the offenses of: P.L. §220.44(2) Criminal Sale of a Controlled Substance in or Near School Grounds P.L. §220.39(1) Criminal Sale of a Controlled Substance in the Third Degree P.L. § 220.16(1) Criminal Possession of a Controlled Substance in the Third Degree P.L. § 220.06(5) Criminal Possession of a Controlled Substance in the Fifth Degree Deyshaun Wigfall: K16636682, 05/17/16 6:00 a.m.; Complaint Printed 5/18/2016 4:54 PMDeponent is further informed by UC | that, at the fifth above time and place, defendant handed UC 1 a quantity of cocaine in exchange, for a sum of United States currency. Deponent further reviewed the official records for the New York City Police Department Laboratory report which indicates the above-mentioned cocaine weighed in excess of five hundred milligrams. Deponent is further informed by UC 1 that, at the sixth above time and place, defendant handed UC 1 a quantity of cocaine in exchange, for a sum of United States currency. Deponent further reviewed the official records for the New York City Police Department Laboratory report which indicates the above-mentioned cocaine weighed in excess of five hundred milligrams. Deponent is further informed by UC 2 that, at the seventh above time and place, defendant handed UC 2 a quantity of cocaine in exchange, for a sum of United States currency. Deponent is further informed by UC 1 that, at the eighth above time and place, defendant handed UC 1 a quantity of cocaine in exchange, for a sum of United States currency. Deponent has further reviewed the official records of the New York City Police Department Laboratory which indicates that the above-mentioned cocaine weighed in excess of one-eighth of an ounce. Deponent is further informed by UC 2 that, at the ninth above time and place, defendant handed UC 2 a quantity of cocaine in exchange, for a sum of United States currency. Deponent states that the above-described substances from the above-mentioned times and locations were sent to the New York City Police Laboratory for analysis and said reports indicate that the substances referred to as cocaine were determined to be cocaine. Deponent further states that deponent is familiar with the first, second, third, fifth and six above- mentioned locations and that those locations are situated within one thousand feet of Achievement First Endeavor Middle School, False statements made in this document are punishable as a class A misdemeanor pursuant to Section 210.45 of the Penal Law. shelr \ h DATE SIGNATURE Deyshaun Wigfall: K16636682, 05/18/16; Complaint Printed 5/18/2016 4:54 PM Page 3 of 3and that (6) on or about April 15, 2016, at approximately 2:16 P.M., in front of 488 Waverly Avenue, Brooklyn, County of Kings, State of New York, the defendant Deyshaun Wiefall, committed the offenses of: P.L. §220.44(2) Criminal Sale of a Controlled Substance in or Near School Grounds PL. §220.39(1) Criminal Sale of a Controlled Substance in the Third Degree P-L. § 220.16(1) Criminal Possession of a Controlled Substance in the Third Degree PLL. § 220.06(5) Criminal Possession of a Controlled Substance in the Fifth Degree and that (7) on or about April 15, 2016, at approximately 2:22 P.M., inside 488 Waverly Avenue, Brooklyn, County of Kings, State of New York, the defendant Deyshaun Wigfall, committed the offenses of: PL. § 220.39(1) Criminal Sale of a Controlled Substance in the Third Degree P-L. § 220.16(1) Criminal Possession of a Controlled Substance in the Third Degree and that (8) on or about April 20, 2016, at approximately 3:33 P.M, inside 488 Waverly Avenue, Brooklyn, County of Kings, State of New York, the defendant Deyshaun Wigfall, committed the offenses of: PL. §220.39(1) Criminal Sale of a Controlled Substance in the Third Degree PLL. § 220.16(1) Criminal Possession of a Controlled Substance in the Third Degree P-L. §220.09(1) Criminal Possession of a Controlled Substance in the Fourth Degree and that (9) on or about April 20, 2016, at approximately 3:34 P.M,, inside 488 Waverly Avenue, Brooklyn, County of Kings, State of New York, the defendant Deyshaun Wigfall, committed the offenses of: P-L. §220.39(1) Criminal Sale of a Controlled Substance in the Third Degree PAL. § 220.16(1) Criminal Possession of a Controlled Substance in the Third Degree 4m that the defendant did: knowingly and unlawfully sell a controlled substance in violation of any cone of subdivisions one through eight of section 220.39 when such sale takes place upon school Grounds; knowingly and unlawfully sell a narcotic drug; knowingly and unlawfully possess a narcotic drug with intent to sell; knowingly and unlawfully possesses one or more preparations, compounds, mixtures or substances containing a narcotics drug and said preparations, compounds, mixtures or substances are of an aggregate weight of one-eighth ounce or more; knowingly and unlawfully possesses cocaine and said cocaine weighs five hundred milligrams or more; knowingly and unlawfully possess a controlled substance. The source of deponent’s information and the grounds for deponent’s belief are as follows: Deponent is informed by an undercover police officer UC C0053 (hereinafter referred to as “UC 1”) who is known to the New York City Police Department and to the Kings County District Attorney's Office that, at the first above time and place, the defendant handed UC 1 a quantity of cocaine in exchange, for a sum of United States currency. Deponent is further informed by UC 1 that, at the second above time and place, defendant handed UC 1 a quantity of cocaine in exchange, for a sum of United States currency, Deponent is further informed by UC 1 that, at the third above time and place, defendant handed UC 1 a quantity of cocaine in exchange, for a sum of United States currency, Deponent is informed by undercover police officer UC C0082 (hereinafter referred to as “UC 2”) who is known to the New York City Police Department and to the Kings County District Attomey’s Office that at the fourth above time and place, defendant handed UC 2 a quantity of cocaine in exchange, for a sum of United States currency. Deyshaun Wigfall: K16636682, 05/18/16; Complaint Printed 6/18/2016 4:54 PM Page 2 of 3CRIMINAL COURT OF THE CITY OF NEW YORK PART APAR, COUNTY OF KINGS ‘THE PEOPLE OF THE STATE OF NEW YORK STATE OF NEW YorK Coury oF KINGS v. EBEN BARNES DEFENDANT. Detective Brian Depalo, shield number 1737, of Narcotics Borough Brooklyn North, states that: (1) On or about November 5, 2015 at approximately 8:33 A.M., at the comer of Washington Avenue and Fulton Street, Brooklyn, County of Kings, State of New York, defendant, Eben Bames, while acting in concert with another individual, committed the offense(s) of: P.L. §220.44(2) Criminal Sale of a Controlled Substance in or Near Schoo! Grounds P.L. § 220.391) Criminal Sale of a Controlled Substance in the Third Degree P.L. §220.16(1) Criminal Possession of a Controlled Substance in the Third Degree PLL. § 220.03 Criminal Possession of a Controlled Substance in the Seventh Degree and that (2) on or about November 12, 2015, at approximately 8:08 A.M., in front of 226 St. James Place, Brooklyn, County of Kings, State of New York, the defendant, Eben Bares, committed the offenses of: P.L. §220.44(2) Criminal Sale of a Controlled Substance in or Near Schoo! Grounds P.L. § 220.39(1) Criminal Sale of a Controlled Substance in the Third Degree P.L. §220.16(1) Criminal Possession of a Controlled Substance in the Third Degree and that (3) on or about November 12, 2015, at approximately 8:08 A.M., in front of 226 St. James Place, Brooklyn, County of Kings, State of New York, the defendant Eben Barnes, committed the offenses of: PL. §220.44(2) Criminal Sale of a Controlled Substance in or Near School Grounds P.L. §220.39(1) Criminal Sale of a Controlled Substance in the Third Degree P.L. § 220.16(1) __ Criminal Possession of a Controlled Substance in the Third Degree and that (4) on or about November 20, 2015, at approximately 7:54 A.M., inside 500 Washington Avenue, Brooklyn, County of Kings, State of New York, the defendant Eben Bames, committed the offenses of: P.L. §220.39(1) Criminal Sale of a Controlled Substance in the Third Degree P.L. §220.16(1) Criminal Possession of a Controlled Substance in the Third Degree and that (5) on or about November 20, 2015, at approximately 7:55 A.M., inside 500 Washington Avenue, Brooklyn, County of Kings, State of New York, the defendant Eben Bames, committed the offenses of: P.L. §220,39(1) Criminal Sale of a Controlled Substance in the Third Degree PLL. §220.16(1) Criminal Possession of a Controlled Substance in the Third Degree Eben Bames: K16636655, 05/18/16; Complaint Printed 5/18/2016 11:51 AMand that (6) on or about November 25, 2015, at approximately 8:13 A.M., in front of 226 St. James Place, Brooklyn, County of Kings, State of New York, the defendant Eben Barnes, committed the offenses of: P.L. § 220.44(2) Criminal Sale of a Controlled Substance in or Near School Grounds PL. § 220.39(1) Criminal Sale of a Controlled Substance in the Thitd Degree PLL. § 220.16(1) Criminal Possession of a Controlled Substance in the Third Degree and that (7) on or about November 25, 2015, at approximately 8:22 A.M., in front of 226 St. James Place Brooklyn, County of Kings, State of New York, the defendant Eben Bames, while acting in concert with Keith Harding (Arrest No. K16636919), committed the offenses of: P.L. § 220.44(2) Criminal Sale of a Controlled Substance in or Near School Grounds PLL. § 220.39(1) Criminal Sale of a Controlled Substance in the Third Degree P.L. §220.16(1) __ Criminal Possession of a Controlled Substance in the Third Degree and that (8) on or about November 25, 2015, at approximately 8:25 A.M., in front of 226 St. James Place, Brooklyn, County of Kings, State of New York, the defendant Eben Barnes, committed the offenses of: P.L. §220.44(2) Criminal Sale of a Controlled Substance in or Near School Grounds PL, §220.39(1) Criminal Sale of a Controlled Substance in the Third Degree PLL. § 220.16(1) __ Criminal Possession of a Controlled Substance in the Third Degree and that (9) on or about December 4, 2015, at approximately 8:12 A.M., at the comer of Fulton Street and Cambridge Place, Brooklyn, County of Kings, State of New York, the defendant Eben Bares, committed the offenses of: PL. § 220.44(2) Criminal Sale of a Controlled Substance in or Near School Grounds P.L. § 220.39(1) Criminal Sale of a Controlled Substance in the Third Degree P.L. § 220.16(1) __ Criminal Possession of a Controlled Substance in the Third Degree and that (10) on or about February 4, 2016, at approximately 9:07 A.M., in front of 226 St. James Place, Brooklyn, County of Kings, State of New York, the defendant Eben Barnes, committed the offenses of: PL. § 220.44(2) Criminal Sale of a Controlled Substance in or Near School Grounds P.L. §220.39(1) _ Criminal Sale of a Controlled Substance in the Third Degree P.L. § 220.16(1) Criminal Possession of a Controlled Substance in the Third Degree and that (11) on or about February 4, 2016, at approximately 9:17 A.M., at the comer of St. James Place and Fulton Street, Brooklyn, County of Kings, State of New York, the defendant Eben Bames, committed the offenses of: P.L. § 220.44(2) Criminal Sale of a Controlled Substance in or Near School Grounds PL. § 220.39(1) Criminal Sale of a Controlled Substance in the Third Degree P.L. §220.16(1) Criminal Possession of a Controlled Substance in the Third Degree and that (12) on or about February 5, 2016, at approximately 9:35 A.M., inside 963 Fulton Street, Brooklyn, County of Kings, State of New York, the defendant Eben Bames, committed the offenses of P.L. §220.44(2) _ Criminal Sale of a Controlled Substance in or Near School Grounds P.L. § 220.39(1) Criminal Sale of a Controlled Substance in the Third Degree P.L. § 220.16(1) Criminal Possession of a Controlled Substance in the Third Degree and that (13) on or about March 4, 2016, at approximately 10:44 A.M., inside 963 Fulton Street, Brooklyn, County of Kings, State of New York, the defendant Eben Barnes, committed the offenses of: Eben Bares: K16636655, 05/18/16,; Complaint Printed 6/18/2016 11:51 AM Page 2 of 4P.L. §220.44(2) Criminal Sale of a Controlled Substance in or Near School Grounds P.L. § 220.391) Criminal Sale of a Controlled Substance in the Third Degree P.L. § 220.16(1) Criminal Possession of a Controlled Substance in the Third Degree and that (14) on or about March 4, 2016, at approximately 11:06 A.M., at the corner of St. James Place and Fulton Street, Brooklyn, County of Kings, State of New York, the defendant Eben Bares, committed the offenses of: P.L. §220.44(2) Criminal Sale of a Controlled Substance in or Near School Grounds P.L. §220.39(1) Criminal Sale of a Controlled Substance in the Third Degree P.L. §220.16(1) Criminal Possession of a Controlled Substance in the Third Degree In that the defendant did: knowingly and unlawfully sell a controlled substance in violation of any ‘one of subdivisions one through eight of section 220.39 when such sale takes place upon school grounds; knowingly and unlawfully sell a narcotic drug; knowingly and unlawfully possess a narcotic drug with intent to sell; knowingly and unlawfully possess a controlled substance. ‘The source of deponent’s information and the grounds for deponent’s belief are as follows: Deponent is informed by an undercover police officer UC C0053 (hereinafter referred to as “UC 1”) who is known to the New York City Police Department and to the Kings County District Attorney's Office that, at the first above time and place, defendant while acting in concert with another individual, in that the other individual introduced UC 1 to the defendant and then the defendant handed UC 1 a quantity of heroin in exchange, for a sum of United States currency. Deponent is further informed by UC | that, at the second above time and place, defendant handed UC 1 a quantity of heroin in exchange, for a sum of United States currency. Deponent is informed by undercover police officer UC C0082 (hereinafter referred to as “UC 2”) who is known to the New York City Police Department and to the Kings County District Attorney's Office that at the third above time and place, defendant handed UC 2 a quantity of heroin in exchange, for a sum of United States currency. Deponent is further informed by UC 2 that, at the fourth above time and place, defendant handed UC 2 a quantity of heroin in exchange, for a sum of United States currency. Deponent is further informed by UC | that, at the fifth above time and place, defendant handed UC 1 a quantity of heroin in exchange, for a sum of United States currency. Deponent is further informed by UC | that, at the sixth above time and place, defendant handed UC 1 a quantity of heroin in exchange, for a sum of United States currency. Deponent is further informed by UC 1 that, at the seventh above time and place, defendant while acting in concert with Keith Harding (Arrest No. K16636919) in that, defendant introduced UC 1 to Keith Harding and then Keith Harding handed UC 1 a quantity of cocaine in exchange, for a sum of United States currency. Deponent is further informed by UC 2 that, at the eighth above time and place, defendant handed UC 2a quantity of heroin in exchange, for a sum of United States currency. Deponent is further informed by UC | that, at the ninth above time and place, defendant handed UC 1 a quantity of heroin in exchange, for a sum of United States currency. Deponent is further informed by UC 1 that, at the tenth above time and place, defendant handed UC 1 a quantity of heroin in exchange, for a sum of United States currency. Deponent is further informed by UC 2 that, at the eleventh above time and place, defendant handed UC 2 a quantity of heroin in exchange, for a sum of United States currency. Eben Bares: K16636656, 05/18/18.; Complaint Printed 5/18/2016 11:51 AM Page 3 of 4Deponent is further informed by UC 2 that, at the twelfth above time and place, defendant handed UC 2 a quantity of heroin in exchange, for a sum of United States currency. Deponent is further informed by UC 1 that, at the thirteenth above time and place, defendant handed UC 1 a quantity of heroin in exchange, for a sum of United States currency. Deponent is further informed by UC 2 that, at the fourteenth above time and place, defendant handed UC 2 a quantity of heroin in exchange, for a sum of United States currency. Deponent states that the above-described substance from the first to sixth and eighth to the fourteenth, above-mentioned times and locations were sent to the New York City Police Laboratory for analysis and said reports indicate that the substance referred to as heroin were determined to be heroin. Deponent states that the above-described substance from the seventh above-mentioned time and location was sent to the New York City Police Laboratory for analysis and said report indicates that the substance referred to as crack cocaine was determined to be cocaine. ‘Deponent further states that deponent is familiar with the first, eleventh, twelfth, thirteenth, and fourteenth above-mentioned locations and that those locations are situated within one thousand feet of Achievement First Endeavor Middle School. Deponent further states that deponent is familiar with the ninth above-mentioned location and that location is situated within one thousand feet of Urban Assembly Unison School. Deponent further states that deponent is familiar with the second, third, sixth, seventh, eighth, and tenth above-mentioned locations and that those locations are situated within one thousand feet of Public School 11 False statements made in this document are punishable as a class A misdemeanor pursuant to Section 210.45 of the Penal Law. a\sAww ON Wr DATE SIGNATURE Eben Bares: K16636655, 05/18/16.; Complaint Printed 5/18/2016 11:51 AM Page 4 of 4INDICTMENT SUPREME COURT OF THE STATE OF NEW YORK KINGS COUNTY s THE PEOPLE OF THE STATE OF NEW YORK, INDICTMENT NO. ~ against - 4158/2016 X. OMAR ABDELKADER, VIOLENT CRIMINAL DEFENDANT. ENTERPRISES BUREAU CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS P.L. § 220.44(2) - (1 COUNT) CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE PLL. § 220.39(1) - (I COUNT) AFO:N SEX CRIME: N CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE P.L. § 220.16(1) - (1 COUNT) AFO:N SEX CRIME: N CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE PLL. § 220.31 - (5 COUNTS) AFO:N SEX CRIME: N CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE PL. § 220.06(1) - (5 COUNTS) AFO:N SEX CRIME: N CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE SEVENTH DEGREE PL. § 220.03 - (3 COUNTS) AFO: N SEX CRIME: N CRIMINAL SALE OF MARIHUANA IN THE FOURTH DEGREE PLL. § 221.40 - (1 COUNT) AFO: N SEX CRIME: N UNLAWFUL POSSESSION OF MARIHUANA P.L. § 221.05 - (1 COUNT) ATRUE BILL KENNETH P. THOMPSON he _ DISTRICT ATTORNEY FOREPERSONCOUNT ONE ‘THE GRAND JURY OF THE COUNTY OF KINGS, by this Indictment, accuses the defendant, OMAR ABDELKADER, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE in violation of §220.31 of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 17th day of December 2015, in the County of Kings, knowingly and unlawfully sold a controlled substance, to wit, alprazolam, to a person known to the Grand Jury. COUNT TWO AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, OMAR ABDELKADER, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE in violation of § 220.06(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 17th day of December 2015, in the County of Kings, knowingly and unlawfully possessed a controlled substance, to wit, alprazolam, with the intent to sell it. COUNT THREE AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, OMAR ABDELKADER, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE SEVENTH DEGREE in violation of § 220.03 of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 17th day of December 2015, in the County of Kings, knowingly and unlawfully possessed a controlled substance, to wit, alprazolam.COUNT FOUR THE GRAND JURY OF THE COUNTY OF KINGS, by this Indictment, accuses the defendant, OMAR ABDELKADER, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE in violation of §220.31 of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 5" day of February 2016, in the County of Kings, knowingly and unlawfully sold a controlled substance, to wit, alprazolam, to a person known to the Grand Jury. COUNT FIVE AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, OMAR ABDELKADER, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE in violation of § 220.06(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 5" day of February 2016, in the County of Kings, knowingly and unlawfully possessed a controlled substance, to wit, alprazolam, with the intent to sell it, COUNT SIX THE GRAND JURY OF THE COUNTY OF KINGS, by this Indictment, accuses the defendant, OMAR ABDELKADER, of the crime of CRIMINAL SALE OF MARIHUANA IN THE FOURTH DEGREE in violation of §221.40 of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 4" day of March 2016, in the County of Kings, knowingly and unlawfully sold marihuana to a person known to the Grand Jury.COUNT SEVEN THE GRAND JURY OF THE COUNTY OF KINGS, by this Indictment, accuses the defendant, OMAR ABDELKADER, of the crime of UNLAWFUL POSSESSION OF MARIHUANA in violation of §221.05 of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 4" day of March 2016, in the County of Kings, knowingly and unlawfully possessed marihuana, COUNT EIGHT AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, OMAR ABDELKADER, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE in violation of § 220.31 of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 11" day of March 2016, in the County of Kings, knowingly and unlawfully sold a controlled substance, to wit, alprazolam, to a person known to the Grand Jury. COUNT NINE AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, OMAR ABDELKADER, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE in violation of § 220.06(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 11" day of March 2016, in the County of Kings, knowingly and unlawfully possessed a controlled substance, to wit, alprazolam, with the intent to sell it,COUNT TEN THE GRAND JURY OF THE COUNTY OF KINGS, by this Indictment, accuses the defendant, OMAR ABDELKADER, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN OR NEAR SCHOOL GROUNDS in violation of §220.44(2) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 24" day of March 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, heroin, to a person known to the Grand Jury, and such sale took place within one thousand feet of Achievement First Endeavor Middle School. COUNT ELEVEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, OMAR ABDELKADER, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of § 220.39(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 24" day of March 2016, in the County of Kings, knowingly and unlawfully sold a narcotic drug, to wit, heroin, to a person known to the Grand Jury. COUNT TWELVE AND "THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, OMAR ABDELKADER, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE in violation of §220.16(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 24" day of March 2016, in the County of Kings, knowingly and unlawfully possessed a narcotic drug, to wit, heroin, with the intent to sell it.COUNT THIRTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, OMAR ABDELKADER, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE in violation of § 220.31 of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 24" day of March 2016, in the County of Kings, knowingly and unlawfully sold a controlled substance, to wit, clonazepam, to a person known to the Grand Jury. COUNT FOURTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, OMAR ABDELKADER, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE in violation of § 220.06(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 24'" day of March 2016, in the County of Kings, knowingly and unlawfully possessed a controlled substance, to wit, clonazepam, with the intent to sell it. COUNT FIFTE AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, OMAR ABDELKADER, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE SEVENTH DEGREE in violation of § 220.03 of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 24 day of March 2016, in the County of Kings, knowingly and unlawfully possessed a controlled substance, to wit, heroin.AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, OMAR ABDELKADER, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE SEVENTH DEGREE in violation of § 220.03 of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 24" day of March 2016, in the County of Kings, knowingly and unlawfully possessed a controlled substance, to wit, clonazepam, COUNT SEVENTEEN THE GRAND JURY OF THE COUNTY OF KINGS, by this Indictment, accuses the defendant, OMAR ABDELKADER, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE in violation of §220.31 of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 6" day of April 2016, in the County of Kings, knowingly and unlawfully sold a controlled substance, to wit, alprazolam, to a person known to the Grand Jury. COUNT EIGHTEEN AND THE AFORESAID GRAND JURY, by this indictment, further accuses the defendant, OMAR ABDELKADER, of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE in violation of § 220.06(1) of the Penal Law of the State of New York, committed as follows: Such defendant, on or about the 6" day of April 2016, in the County of Kings, knowingly and unlawfally possessed a controlled substance, to wit, alprazolam, with the intent to sell it. fp Mpr_— -ENNETH P. THOMPSON DISTRICT ATTORNEY.SERVICE OF PRE-TRIAL MOTIONS BY DEFENDANT TO DEFENDANT: , PLEASE TAKE NOTICE that pursuant to C.P:L, Article 258, defendant(s) must ordinarily make all pre-trial metions within forty-five days efter arraignment and before commencement of trial ‘Upon expiration of the applicable period within which defendant(s) must make pre-trial motions, tho People will move the Court’ to preclude any. pre-trial motlons made thereafter. Sincerely, * KENNETH P, THOMPSON : District Attorney Kings CountySUPREME COURT OF ae STATE OF NEW YORK ~KINGS COUNTY. INDICTMENT GENET. THOMSON District Attomiey: : Pleas Ne ot Guiy__ : @LEA) * Judge ADA Filed,