Indictment - Red Dawn - 10.2.20

STATE OF NEW YORK
COUNTY COURT: COUNTY OF SARATOGA

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THE PEOPLE OF THE STATE OF NEW YORK
-vs- SEALED INDICTMENT
PAMELA BACKUS,
JORDAN BLOUNT,
ANGEL BRACERO-ORTIZ,
OMAR CHILDRESS,
UNIKIA CROSS,
JAMES DAGGETT,
SHAWN DELMORE,
ERICA DUBRAY,
NANCY DUKES,
JAMES EGGLESTON,
LACY ENOUS, A/K/A “RED,”
NOELIA FUENTES,
DAVID GARCIA,
DOROTHY GETHERS, A/K/A “BRENDA,”
KIMBERLY GOODSON,
DEAN HARLAN,
RICHARD HENDERSON,
CARLOS HERNANDEZ,
CLARENCE JACKSON,
ADRIAN KELLEY, A/K/A “ACE,”
DEBORAH LATALLADI,
ERINA LEMPERLE,
CRYSTAL LEO,
AMANDA LOVELY-LAMARCHE,
WILLIAM MAYS,
ZOOLEIKA MENDEZ,
FRANKIE MERCADO,
JOSEPH MEUNIER,
SHALENA MURRAY, A/K/A “SHAY,”
DAMIR PARSONS,
MATTATHIAS PARSONS,
ADRIANE PIERCE,
NICOLE RICH,
ALEXANDER RIVERA,
PATRICK ROBINSON,
LUIS ROSA,
FRANK SAWYER,
YVONNE SMITH,
JANESSA SOTO,
NICOLE STRAINER,
PHILLIP TAYLOR,
DONALD THOMAS,
SHARROD THORTON,
SHETWANA VENABLE,
DRANAE WASHINGTON,
ERIC WILLIAMS,
LAMONT WILLIAMS,
ELRAHIM WRIGHT.
Defendants.
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COUNT 1
THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, accuses the
defendants, PAMELA BACKUS, JORDAN BLOUNT, ANGEL BRACERO-ORTIZ, OMAR
CHILDRESS, UNIKIA CROSS, JAMES DAGGETT, SHAWN DELMORE, ERICA DUBRAY,
NANCY DUKES, JAMES EGGLESTON, LACY ENOUS, A/K/A “RED,” NOELIA FUENTES,
DAVID GARCIA, DOROTHY GETHERS, A/K/A “BRENDA,” KIMBERLY GOODSON, DEAN
HARLAN, RICHARD HENDERSON, CARLOS HERNANDEZ, CLARENCE JACKSON,
ADRIAN KELLEY, A/K/A “ACE,” DEBORAH LATALLADI , ERINA LEMPERLE, CRYSTAL
LEO, AMANDA LOVELY-LAMARCHE, WILLIAM MAYS, ZOOLEIKA MENDEZ, FRANKIE
MERCADO, JOSEPH MEUNIER, SHALENA MURRAY, A/K/A “SHAY,” DAMIR PARSONS,
MATTATHIAS PARSONS, ADRIANE PIERCE, NICOLE RICH, ALEXANDER RIVERA,
PATRICK ROBINSON, LOUIS ROSA, FRANK SAWYER, YVONNE SMITH, JANESSA SOTO,
NICOLE STRAINER, PHILIP TAYLOR, DONALD THOMAS, SHARROD THORTON,
SHETWANA VENABLE, DRANAE WASHINGTON, ERIC WILLIAMS, LAMONT WILLIAMS
and ELRAHIM WRIGHT, of the crime of CONSPIRACY IN THE SECOND DEGREE in violation
of Section 105.15 of the Penal Law of the State of New York, committed as follows:
That the said defendants, in Albany County, Bronx County, Rensselaer County, Saratoga
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County, Schenectady County, Warren County and elsewhere in the State of New York, from on or
before May 2, 2019, until on or about May 1, 2020, with intent that conduct constituting the crimes
of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation
of Section 220.43(1) of the Penal Law of the State of New York, and/or CRIMINAL SALE OF A
CONTROLLED SUBSTANCE IN THE SECOND DEGREE, in violation of Section 220.41(1) of
the Penal Law of the State of New York, CRIMINAL POSSESSION OF A CONTROLLED
SUBSTANCE IN THE FIRST DEGREE in violation of Section 220.21(1) of the Penal Law of the
State of New York and/or CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN
THE SECOND DEGREE, in violation of Section 220.18(1) of the Penal Law of the State of New
York, said crimes being class A Felonies, be committed, did knowingly and unlawfully agree with
each other and with others, known and unknown, to engage in and cause the performance of such
conduct as would constitute any one or more of the above-mentioned class A felonies.
PREAMBLE
It was the purpose of this conspiracy to obtain, possess and control quantities of narcotics in
amounts greater than eight ounces or more, and to sell narcotics in amounts greater than two ounces
or more in Albany County, Bronx County, Rensselaer County, Saratoga County, Schenectady
County, Warren County and elsewhere in and outside of the State of New York, and to collect the
proceeds from those narcotics transactions.
It was also part of this conspiracy for DONALD THOMAS and SHARROD THORTON to
sell cocaine, up to kilograms at a time, in Bronx County to CLARENCE JACKSON, SHAWN
DELMORE, RICHARD HERNDERSON, CARLOS HERNANDEZ, FRANKIE MERCADO,
DOROTHY GETHERS, A/K/A “BRENDA,” LAMONT WILLIAMS, and others.
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It was also part of this conspiracy for CLARENCE JACKSON, SHAWN DELMORE,
RICHARD HERNDERSON, CARLOS HERNANDEZ, FRANKIE MERCADO, DOROTHY
GETHERS, A/K/A “BRENDA,” and LAMONT WILLIAMS to obtain cocaine from DONALD
THOMAS and/or SHARROD THORTON to sell to others.
It was also part of this conspiracy for ALEXANDER RIVERA to purchase cocaine from
FRANKIE MERCADO to sell to others.
It was also part of this conspiracy for DEBORAH LATALLADI to purchase narcotic drugs
from LACY ENOUS, A/K/A “RED,” WILLIAM MAYS, SHALENA MURRAY, A/K/A “SHAY,”
CLARENCE JACKSON, DAVID GARCIA and KIMBERLY GOODSON to sell to PAMELA
BACKUS, and others.
It was also part of this conspiracy for DEBORAH LATALLADI to purchase prescription
pills from LACY ENOUS, A/K/A “RED,” WILLIAM MAYS, SHALENA MURRAY, A/K/A
“SHAY,” ZOOLEIKA MENDEZ, ANGEL BRACERO-ORTIZ, and CLARENCE JACKSON to
sell to PAMELA BACKUS, NICOLE RICH, and others.
It was also part of this conspiracy for PAMELA BACKUS and NICOLE RICH to obtain
narcotic drugs and/or prescription pills from DEBORAH LATALLADI to sell to others and to sell
prescription pills to DEBORAH LATALLADI.
It was also part of this conspiracy for LACY ENOUS, A/K/A “RED,” to sell narcotic drugs
to JAMES DAGGETT, ADRIAN KELLEY, A/K/A “ACE,” AMANDA LOVELY-LAMARCHE,
JAMES EGGLESTON, CLARENCE JACKSON, DEBORAH LATALLADI and others.
It was also part of this conspiracy for JAMES DAGGETT, AMANDA LOVELY-
LAMARCHE, JAMES EGGLESTON, and CLARENCE JACKSON, to obtain narcotic drugs from
LACY ENOUS, A/K/A “RED,” to sell to others.
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It was also part of this conspiracy for LUIS ROSA to sell narcotic drugs to LACY ENOUS,
A/K/A “RED.”
It was also part of this conspiracy for WILLIAM MAYS to sell cocaine to JORDAN
BLOUNT, UNIKIA CROSS, NOELIA FUENTES, DEBORAH LATALLADI, CRYSTAL LEO,
PATRICK ROBINSON, YVONNE SMITH, PHILLIP TAYLOR, SHETWANA VENABLE, and
others.
It was also part of this conspiracy for JORDAN BLOUNT, UNIKIA CROSS, NOELIA
FUENTES, CRYSTAL LEO, PATRICK ROBINSON, YVONNE SMITH, PHILLIP TAYLOR, and
SHETWANA VENABLE, to obtain cocaine from WILLIAM MAYS to sell to others.
It was also part of this conspiracy for SHALENA MURRAY, A/K/A “SHAY,” to sell
cocaine to JOSEPH MEUNIER, DEBORAH LATALLADI, and others.
It was also part of this conspiracy for JOSEPH MEUNIER to obtain cocaine from
SHALENA MURRAY, A/K/A “SHAY,” to sell to others.
It was also part of this conspiracy for ZOOLEIKA MENDEZ and ANGEL BRACERO-
ORTIZ to sell prescription pills to DEBORAH LATALLADI.
It was also part of this conspiracy for MATTAHIAS PARSONS and ERIC WILLIAMS to
sell cocaine to LACY ENOUS A/K/A “RED,” ADRIAN KELLEY, A/K/A “ACE,” DAMIR
PARSONS, DRANAE WASHINGTON, ERINA LEMPERLE, OMAR CHILDRESS, and others.
It was also part of this conspiracy for DAMIR PARSONS, DRANAE WASHINGTON,
ERINA LEMPERLE, and OMAR CHILDRESS, to obtain cocaine from MATTAHIAS PARSONS
and/or ERIC WILLIAMS to sell to others.
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It was also part of this conspiracy for ADRIAN KELLEY, A/K/A “ACE,” to obtain narcotic
drugs from LACY ENOUS A/K/A “RED,” MATTAHIAS PARSONS and ERIC WILLIAMS, to
sell to others.
It was also part of this conspiracy for ELRAHIM WRIGHT to sell narcotic drugs to LACY
ENOUS, A/K/A “RED,” ADRIANE PIERCE, and others.
It was also part of this conspiracy for ADRIANE PIERCE to sell narcotic drugs to ERICA
DUBRAY, NANCY DUKES, DEAN HARLAN, FRANK SAWYER, JANESSA SOTO, NICOLE
STRAINER, and others.
It was also part of this conspiracy for ERICA DUBRAY, NANCY DUKES, DEAN
HARLAN, FRANK SAWYER, JANESSA SOTO, and NICOLE STRAINER, to obtain narcotic
drugs from ADRIANE PIERCE to sell to others.
It was also part of this conspiracy for DAVID GARCIA and KIMBERLY GOODSON to sell
narcotic drugs to DEBORAH LATALLADI.
It was also part of the conspiracy for members of the conspiracy to communicate with each
other and others over cellular telephones using codes and speaking in a guarded, cryptic manner.
OVERT ACTS
In furtherance of the conspiracy and to affect the objects thereof, from on or before May 2, 2019,
until on or about May 1, 2020, the following overt acts, among others, were committed:
1. On or about May 2, 2019, DEBORAH LATALLADI sold heroin in Saratoga County to a
person known to the Grand Jury.
2. On or about June 21, 2019, DEBORAH LATALLADI and LACY ENOUS, A/K/A “RED,”
acting in concert, sold fentanyl in Saratoga County to a person known to the Grand Jury.
3. On or about July 17, 2019, DEBORAH LATALLADI and LACY ENOUS, A/K/A “RED,”
acting in concert, sold fentanyl in Saratoga County to a person known to the Grand Jury.
4. On or about August 6, 2019, DEBORAH LATALLADI and AMANDA LOVELY-
LAMARCHE, acting in concert, sold heroin in Saratoga County to a person known to the
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Grand Jury.
5. On or about September 21, 2019, ZOOLEIKA MENDEZ, in a series of coded, guarded and
cryptic telephone communications, agreed to sell prescription pills to DEBORAH
LATALLADI in Saratoga County.
6. On or about September 21, 2019, in a series of coded, guarded and cryptic telephone
communications, LACY ENOUS, A/K/A “RED,” agreed to sell a narcotic drug to JAMES
DAGGETT, and in one such conversation ENOUS told DAGGETT “I have empties if you
need some” referring to bags with which to package the heroin to sell to his customers, and
DAGGETT responded that he did.
7. On or about September 23, 2019, in a series of coded, guarded and cryptic telephone
communications, JAMES EGGLESTON ordered both heroin and cocaine, which
EGGLESTON referred to as “2 and 2,” from LACY ENOUS, A/K/A “RED,” to sell to
others.
8. On or about September 25, 2019, CLARENCE JACKSON, in a series of coded, guarded and
cryptic telephone communications, agreed to sell heroin to DEBORAH LATALLADI in
Schenectady County.
9. On or about September 25, 2019, PAMELA BACKUS, in a series of coded, guarded and
cryptic telephone communications, agreed to sell suboxone to DEBORAH LATALLADI in
Saratoga County.
10. On or about September 27, 2019, WILLIAM MAYS, in a series of coded, guarded and
cryptic telephone communications, agreed to sell a narcotic drug to DEBORAH
LATALLADI in Saratoga County.
11. On or about September 28, 2019, LUIS ROSA, in a series of coded, guarded and cryptic
telephone communications, agreed to sell a narcotic drug to LACY ENOUS, A/K/A “RED”
in Schenectady County.
12. On or about October 23, 2019, in a series of coded, guarded and cryptic telephone
communications, ERIC WILLIAMS agreed to sell a narcotic drug to ADRIAN KELLEY,
A/K/A “ACE,” in Schenectady County.
communications, MATTAHIAS PARSONS and DRANAE WASHINGTON, acting in
concert, agreed to sell a narcotic drug to another person in Schenectady County.
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14. On or about October 24, 2019, in a coded, guarded and cryptic telephone communication,
UNIKIA CROSS told WILLIAM MAYS that she had sold a quantity of prescription pills to
JORDON BLOUNT and charged BOUNT “17 a piece,” meaning $17 per pill.
15. On or about October 26, 2019, DONALD THOMAS, in a series of coded, guarded and
cryptic telephone communications, agreed to sell a narcotic drug to FRANKIE MERCADO
in Bronx County.
communications, NOELIA FUENTES ordered “9,” referring to $900-worth of cocaine, from
WILLIAM MAYS, and made arrangements for another female to transport the cocaine from
MAYS to FUENTES.
communications with WILLIAM MAYS, YVONNE SMITH agreed to sell crack cocaine,
which MAYS referred to as “hard,” to another person in Saratoga County, and thereafter told
MAYS that she had received $195 from the customer.
communications, PHILLIP TAYLOR ordered a quantity of cocaine from WILLIAM MAYS
to sell to another person.
19. On or about November 1, 2019, in a series of coded, guarded and cryptic telephone
communications, MATTAHIAS PARSONS, ERINA LEMPERLE and OMAR CHILDRESS
discussed the various customers to whom they were delivering narcotics that day.
20. On or about November 4, 2019, CLARENCE JACKSON drove from Saratoga County to
Bronx County to purchase cocaine from DONALD THOMAS.
21. On or about November 5, 2019, ANGEL BRACERO-ORTIZ delivered narcotic pills to
DEBORAH LATALLADI at her residence in Saratoga County, which LATALLADI had
requested from BRACERO-ORTIZ the previous day in a series of coded, guarded and
cryptic telephone communications.
communications, MATTAHIAS PARSONS agreed to supply DAMIR PARSONS with an
ounce of powder cocaine, which DAMIR PARSONS referred to as “a whole one soft,” so
DAMIR PARSONS could make a profit selling it to others.
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communications, ADRIANE PIERCE and FRANK SAWYER, acting in concert, agreed to
sell a narcotic drug to another person in Rensselaer County.
communications, WILLIAM MAYS and SHETWANA VENABLE, acting in concert,
agreed to a quantity of powder cocaine, which MAYS referred to as the “soft,” to JORDAN
BLOUNT in Saratoga County.
25. On or about November 20, 2019, in a coded, guarded and cryptic telephone communication
with WILLIAM MAYS, JORDAN BLOUNT complained that he had put the cocaine he had
obtained from MAYS and VENABLE earlier that day “on a scale” and it was “light,” so
MAYS owes BLOUNT an additional “seven grams.”
communications, ERICA DUBRAY ordered “two separate” quantities of a narcotic drug
from ADRIANE PIERCE, and PIERCE arranged to meet DUBRAY near a library in
Rensselaer County to complete the transaction.
27. On or about November 25, 2019, NICOLE RICH, in a series of coded, guarded and cryptic
telephone communications, agreed to sell oxycodone to DEBORAH LATALLADI.
28. On or about December 2, 2019, ADRIANE PIERCE, in a series of coded, guarded and
cryptic telephone communications, agreed to sell “two folders” of heroin to NANCY
DUKES in Rensselaer County.
29. On or about December 3, 2019, in a series of coded, guarded and cryptic telephone
communications, ADRIANE PIERCE, FRANK SAWYER, and NICOLE STRAINER,
acting in concert, agreed to sell a narcotic drug to ERICA DUBRAY in Rensselaer County.
30. On or about December 19, 2019, in coded, guarded and cryptic telephone communication,
CRYSTAL LEO ordered “half of hard ball and half of soft ice cream,” referring to a quantity
of crack cocaine and powder cocaine, respectively, from WILLIAM MAYS in Saratoga
County.
31. On or about December 23, 2019, in a series of coded, guarded and cryptic telephone
communications, ADRIANE PIERCE directed DEAN HARLAN to sell a narcotic drug to
NANCY DUKES in Rensselaer County.
32. On or about January 3, 2020, in a series of coded, guarded and cryptic telephone
communications, JANESSA SOTO, acting in concert with ADRIANE PIERCE, agreed to
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sell a narcotic drug to DEAN HARLAN in Rensselaer County.
33. On or about January 3, 2020, ELRAHIM WRIGHT, in a series of coded, guarded and cryptic
telephone communications, agreed to sell a narcotic drug to LACY ENOUS, A/K/A “RED”
in Albany County.
34. On or about January 3, 2020, LACY ENOUS, A/K/A, “RED” possessed approximately 70
grams of fentanyl in Albany County.
35. On or about January 3, 2020, ADRIAN KELLEY, A/K/A “ACE,” possessed approximately
15 grams of cocaine in Albany County.
36. On or about January 17, 2020, WILLIAM MAYS, in a coded, guarded and cryptic telephone
communication, informed PATRICK ROBINSON that he a new supply of high-quality
cocaine that he was selling, which MAYS referred to as “new fire,” and suggested
ROBINSON apprise his “people,” referring to ROBINSON’s customers, and ROBINSON
agreed.
37. On or about January 24, 2020, in a series of coded, guarded and cryptic telephone
communications, CARLOS HERNANDEZ ordered “ten soft,” referring to a quantity of
powder cocaine, from SHARROD THORTON in Bronx County.
38. On or about January 28, 2020, in a coded, guarded and cryptic telephone communication
with SHARROD THORTON, LAMONT WILLIAMS complained about a quantity of
cocaine, which WILLIAMS referred to as “sneakers,” that he had previously obtained from
SHARROD THORTON and DONALD THOMAS and LAMONT WILLIAMS was having
difficulty selling to his customers.
39. On or about January 28, 2020, ELRAHIM WRIGHT possessed approximately 101 grams of
fentanyl in Albany County.
40. On or about February 17, 2020, FRANKIE MERCADO and ALEXANDER RIVERA, in a
series of coded, guarded and cryptic telephone communications, agreed to sell a narcotic
drug to another person in Bronx County.
41. On or about February 21, 2020, in a coded, guarded and cryptic telephone communication
with WILLIAM MAYS, CRYSTAL LEO ordered a quantity of crack cocaine, which LEO
referred to as “a whole of the hard,” to sell to another person.
42. On or about February 27, 2020, WILLIAM MAYS possessed cocaine and a digital scale in
his residence in Saratoga County.
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43. On or about March 3, 2020, in a series of coded, guarded and cryptic telephone
communications, JOSEPH MEUNIER requested that SHALENA MURRAY, A/K/A
“SHAY,” sell him two one-eighth quantity of cocaine, which MEUNIER referred to as “2
8s” and MURRAY agreed to the sale. After the transaction JOSEPH MEUNIER sent a text
message to MURRAY to let her know that his customers felt it was “not bad” referring to the
quality of the cocaine.
44. On or about March 10, 2020, LACY ENOUS, A/K/A “RED,” and DEBORAH
LATALLADI possessed heroin and assorted drug paraphernalia at LATALLADI’s residence
in Saratoga County.
45. On or about March 18, 2020, SHALENA MURRAY, A/K/A “SHAY,” possessed
approximately 16 grams of cocaine in Saratoga County.
46. On or about March 30, 2020, SHAWN DELMORE purchased approximately three
kilograms of cocaine from SHARROD THORTON at 314 East 178th Street in Bronx County.
47. On or about April 1, 2020, RICHARD HENDERSON, in a series of coded, guarded and
cryptic telephone communications, ordered cocaine from SHARROD THORTON to sell to
another person.
48. On or about April 10, 2020, in a coded, guarded and cryptic telephone communication
DOROTHY GETHERS, A/K/A “BRENDA,” acting in concert with SHARROD
THORTON, agreed to sell cocaine to another person at 314 East 178th Street in Bronx
County.
49. On or about April 10, 2020, SHARROD THORTON and DONALD THOMAS possessed
approximately four kilograms of cocaine in an apartment at 314 East 178th Street in Bronx
County.
50. On or about April 24, 2020, DAVID GARCIA, in a series of coded, guarded and cryptic
telephone communications, agreed to sell a quantity of crack cocaine, which he referred to as
“hard,” to another person in Warren County.
51. On or about April 30, 2020, DAVID GARCIA and KIMBERLY GOODSON possessed
cocaine, heroin, and assorted drug paraphernalia at their residence in Warren County.
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COUNT 2
THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

accuses the above-named defendant, DEBORAH LATALLADI, of the crime of CRIMINAL SALE
OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39
(Subdivision 1) of the Penal Law of the State of New York, committed as follows:
That the said defendant, DEBORAH LATALLADI, in the County of Saratoga, State of New
York, on or about May 2, 2019, did knowingly and unlawfully sell a narcotic drug, to wit: heroin.
COUNT 3

York, on or about May 14, 2019, did knowingly and unlawfully sell a narcotic drug, to wit: heroin
mixed with fentanyl and acetyl fentanyl.
COUNT 4

York, on or about June 7, 2019, did knowingly and unlawfully sell a narcotic drug, to wit: fentanyl
mixed with acetyl fentanyl.
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COUNT 5

accuses the above-named defendants, DEBORAH LATALLADI and LACY ENOUS, A/K/A
“RED,” of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD
DEGREE, in violation of Section 220.39 (Subdivision 1) of the Penal Law of the State of New York,
committed as follows:
That the said defendants, DEBORAH LATALLADI and LACY ENOUS, A/K/A “RED,”
acting in concert, in the County of Saratoga, State of New York, on or about June 21, 2019, did
knowingly and unlawfully sell a narcotic drug, to wit: fentanyl.
COUNT 6

“RED,” of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD
acting in concert, in the County of Saratoga, State of New York, on or about July 17, 2019, did
knowingly and unlawfully sell a narcotic drug, to wit: fentanyl.
COUNT 7

York, on or about July 23, 2019, did knowingly and unlawfully sell a narcotic drug, to wit: heroin
mixed with fentanyl.
13
COUNT 8

That the said defendants, DEBORAH LATALLADI, in the County of Saratoga, State of New
York, on or about July 23, 2019, did knowingly and unlawfully sell a narcotic drug, to wit: cocaine.
COUNT 9

accuses the above-named defendants, DEBORAH LATALLADI and AMANDA LOVELY-
LAMARCHE, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE
THIRD DEGREE, in violation of Section 220.39 (Subdivision 1) of the Penal Law of the State of
New York, committed as follows:
That the said defendants, DEBORAH LATALLADI AND AMANDA LOVELY-
LAMARCHE, acting in concert, in the County of Saratoga, State of New York, on or about August
6, 2019, did knowingly and unlawfully sell a narcotic drug, to wit: heroin mixed with fentanyl.
COUNT 10
York, on or about August 26, 2019, did knowingly and unlawfully sell a narcotic drug, to wit:
fentanyl.
COUNT 11

accuses the above-named defendant, LACY ENOUS, A/K/A “RED,” of the crime of CRIMINAL
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SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section
220.39 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:
That the said defendant, LACY ENOUS, A/K/A “RED,” in the County of Rensselaer, State
of New York, on or about September 19, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 12

of New York, on or about September 20, 2019, did knowingly and unlawfully sell a narcotic drug to
James Eggleston.
COUNT 13

of New York, on or about September 20, 2019, did knowingly and unlawfully sell a narcotic drug, to
wit: cocaine, to James Eggleston.
COUNT 14

accuses the above-named defendant, JAMES EGGLESTON, of the crime of ATTEMPTED
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
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violation of Sections 110.00 and 220.16 (Subdivision 1) of the Penal Law of the State of New York,
That the said defendant, JAMES EGGLESTON, in the County of Rensselaer, State of New
York, on or about September 20, 2019, did knowingly and unlawfully attempt to possess a narcotic
drug with the intent to sell it.
COUNT 15

drug, to wit: cocaine, with the intent to sell it.
COUNT 16

That the said defendant, LACY ENOUS, A/K/A “RED,” in the County of Schenectady, State
James Daggett.
COUNT 17

accuses the above-named defendant, JAMES DAGGETT, of the crime of ATTEMPTED
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That the said defendant, JAMES DAGGETT, in the County of Schenectady, State of New
COUNT 18

accuses the above-named defendants, LACY ENOUS, A/K/A “RED,” and JAMES DAGGETT, of
the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE,
in violation of Section 220.39 (Subdivision 1) of the Penal Law of the State of New York,
That the said defendants, LACY ENOUS, A/K/A “RED,” and JAMES DAGGETT, acting in
concert, in the County of Saratoga, State of New York, on or about September 20, 2019, did
knowingly and unlawfully sell a narcotic drug.
COUNT 19

accuses the above-named defendant, ZOOLEIKA MENDEZ, of the crime of CRIMINAL SALE OF
A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39
That the said defendant, ZOOLEIKA MENDEZ, in the County of Saratoga, State of New
York, on or about September 21, 2019, did knowingly and unlawfully sell a narcotic drug, to wit:
oxycodone.
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COUNT 20

A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE, in violation of Section 220.31 of the
Penal Law of the State of New York, committed as follows:
York, on or about September 21, 2019, did knowingly and unlawfully sell a controlled substance, to
wit: clonezapam.
COUNT 21

accuses the above-named defendant, NICOLE RICH, of the crime of CRIMINAL SALE OF A
CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39
That the said defendant, NICOLE RICH, in the County of Saratoga, State of New York, on
or about September 21, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 22

York, on or about September 21, 2019, did knowingly and unlawfully sell the narcotic drug.
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COUNT 23

York, on or about September 21, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 24

accuses the above-named defendant, NICOLE RICH, of the crime of CRIMINAL POSSESSION OF
or about September 21, 2019, did knowingly and unlawfully possess a narcotic drug with the intent
to sell it.
COUNT 25

accuses the above-named defendant, MATHIAS PARSONS, of the crime of CRIMINAL SALE OF
That the said defendant, MATHIAS PARSONS, in the County of Schenectady, State of New
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COUNT 26

James Daggett.
COUNT 27

James Eggleston.
COUNT 28

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COUNT 29

COUNT 30

That the said defendant, JAMES EGGLESTON, in the County of Schenectady, State of New
COUNT 31

21
COUNT 32

accuses the above-named defendant, CLARANCE JACKSON, of the crime of CRIMINAL SALE
That the said defendant, CLARANCE JACKSON, in the County of Schenectady, State of
New York, on or about September 22, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 33

accuses the above-named defendant, DEBORAH LATALLADI, of the crime of ATTEMPTED
That the said defendant, DEBORAH LATALLADI, in the County of Schenectady, State of
New York, on or about September 22, 2019, did knowingly and unlawfully attempt to possess a
narcotic drug with the intent to sell it.
COUNT 34

22
COUNT 35

accuses the above-named defendant, NICOLE RICH, of the crime of ATTEMPTED CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of
Sections 110.00 and 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed
as follows:
or about September 23, 2019, did knowingly and unlawfully attempt to possess a narcotic drug with
the intent to sell it.
COUNT 36

That the said defendant, CLARANCE JACKSON, in the County of Albany, State of New
COUNT 37

Deborah Latalladi.
23
COUNT 38

James Eggleston.
COUNT 39

COUNT 40

24
COUNT 41

COUNT 42

That the said defendant, CLARANCE JACKSON, in the County of Schenectady, State of
COUNT 43

25
COUNT 44

York, on or about September 25, 2019, did knowingly and unlawfully sell a narcotic drug, to wit:
heroin.
COUNT 45

accuses the above-named defendant, PAMELA BACKUS, of the crime of CRIMINAL SALE OF A
CONTROLLED SUBSTANCE IN THE FIFTH DEGREE, in violation of Section 220.31 of the
That the said defendant, PAMELA BACKUS, in the County of Saratoga, State of New York,
on or about September 25, 2019, did knowingly and unlawfully sell a controlled substance, to wit:
buprenorphine.
COUNT 46

on or about September 25, 2019, did knowingly and unlawfully sell a controlled substance.
26
COUNT 47

COUNT 48

wit: cocaine.
COUNT 49

27
COUNT 50

COUNT 51

That the said defendant, JAMES DAGGETT, in the County of Rensselaer, State of New
COUNT 52

28
COUNT 53

COUNT 54

COUNT 55

accuses the above-named defendant, NICOLE RICH, of the crime of ATTEMPTED CRIMINAL
as follows:
or about September 27, 2019, did knowingly and unlawfully attempt to possess a narcotic drug with
29
COUNT 56

on or about September 27, 2019, did knowingly and unlawfully sell a controlled substance.
COUNT 57

accuses the above-named defendant, CLARENCE JACKSON, of the crime of CRIMINAL SALE
That the said defendant, CLARENCE JACKSON, in the County of Schenectady, State of
COUNT 58

That the said defendant, CLARENCE JACKSON, in the County of Schenectady, State of
New York, on or about September 27, 2019, did knowingly and unlawfully sell a narcotic drug, to
wit: cocaine.
30
COUNT 59

accuses the above-named defendant, DEBORAH LATALLADI, of the crime of CRIMINAL
Section 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:
New York, on or about September 27, 2019, did knowingly and unlawfully possess a narcotic drug
with the intent to sell it.
COUNT 60

accuses the above-named defendant, WILLIAM MAYS, of the crime of CRIMINAL SALE OF A
That the said defendant, WILLIAM MAYS, in the County of Saratoga, State of New York,
on or about September 27, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 61

31
COUNT 62

accuses the above-named defendant, MATTAHIAS PARSONS, of the crime of CRIMINAL SALE
That the said defendant, MATTAHIAS PARSONS, in the County of Schenectady, State of
COUNT 63

James Eggleston.
COUNT 64

32
COUNT 65

COUNT 66

James Daggett.
COUNT 67

33
COUNT 68

COUNT 69

COUNT 70

accuses the above-named defendant, LUIS ROSA, of the crime of CRIMINAL SALE OF A
That the said defendant, LUIS ROSA, in the County of Schenectady, State of New York, on
or about September 28, 2019, did knowingly and unlawfully sell a narcotic drug.
34
COUNT 71

of New York, on or about September 28, 2019, did knowingly and unlawfully possess a narcotic
COUNT 72

COUNT 73

accuses the above-named defendant, JAMES DAGGETT, of the crime of CRIMINAL
35
COUNT 74

COUNT 75

wit: cocaine.
COUNT 76

accuses the above-named defendant, JAMES EGGLESTON, of the crime of CRIMINAL
York, on or about September 30, 2019, did knowingly and unlawfully possess a narcotic drug with
36
COUNT 77

CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FOURTH DEGREE, in
York, on or about September 30, 2019, did knowingly and unlawfully attempt to possess one or
more preparations, compounds, mixtures or substances containing a narcotic drug and the
preparations, compounds, mixtures or substances were of an aggregate weight of one-eighth ounce
or more.
COUNT 78

That the said defendant, CLARENCE JACKSON, in the County of Saratoga, State of New
York, on or about October 2, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 79

That the said defendant, CLARENCE JACKSON, in the County of Saratoga, State of New
York, on or about October 2, 2019, did knowingly and unlawfully sell a narcotic drug, to wit:
cocaine.
37
COUNT 80

York, on or about October 2, 2019, did knowingly and unlawfully attempt to possess a narcotic drug
COUNT 81

COUNT 82

York, on or about October 2, 2019, did knowingly and unlawfully sell the narcotic drug, to wit:
cocaine.
38
COUNT 83

A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE, in violation of Section c of the Penal
Law of the State of New York, committed as follows:
York, on or about October 13, 2019, did knowingly and unlawfully sell a controlled substance.
COUNT 84

OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE, in violation of Section 220.31 of
the Penal Law of the State of New York, committed as follows:
York, on or about October 13, 2019, did knowingly and unlawfully sell a controlled substance.
COUNT 85

or about October 16, 2019, did knowingly and unlawfully sell a controlled substance.
COUNT 86

39
New York, on or about October 18, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 87

accuses the above-named defendant, DAMIR PARSONS, of the crime of ATTEMPTED
That the said defendant, DAMIR PARSONS, in the County of Schenectady, State of New
York, on or about October 18, 2019, did knowingly and unlawfully attempt to possess a narcotic
COUNT 88

on or about October 20, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 89

40
COUNT 90

COUNT 91

COUNT 92

accuses the above-named defendants, MATTAHIAS PARSONS and ERIC WILLIAMS, of the
crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
41
violation of Section 220.39 (Subdivision 1) of the Penal Law of the State of New York, committed
as follows:
That the said defendants, MATTAHIAS PARSONS and ERIC WILLIAMS, acting in
concert, in the County of Schenectady, State of New York, on or about October 20, 2019, did
COUNT 93

COUNT 94

accuses the above-named defendant, ADRIAN KELLEY, A/K/A “ACE,” of the crime of
ATTEMPTED CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD
DEGREE, in violation of Sections 110.00 and 220.16 (Subdivision 1) of the Penal Law of the State
of New York, committed as follows:
That the said defendant, ADRIAN KELLEY, A/K/A “ACE,” in the County of Schenectady,
State of New York, on or about October 21, 2019, did knowingly and unlawfully attempt to possess
a narcotic drug with the intent to sell it.
COUNT 95

accuses the above-named defendant, ERIC WILLIAMS, of the crime of CRIMINAL SALE OF A
CONTROLLED SUBSTANCE IN THE SECOND DEGREE, in violation of Section 220.41
42
That the said defendant, ERIC WILLIAMS, in the County of Schenectady, State of New
York, on or about October 23, 2019, did knowingly and unlawfully sell one or more preparations,
compounds, mixtures or substances containing a narcotic drug and the preparations, compounds,
mixtures or substances were of an aggregate weight of one-half ounce or more.
COUNT 96

accuses the above-named defendant, ERIC WILLIAMS, of the crime of CRIMINAL POSSESSION
York, on or about October 23, 2019, did knowingly and unlawfully possess a narcotic drug with the
intent to sell it.
COUNT 97

accuses the above-named defendant, ERIC WILLIAMS, of the crime of CRIMINAL POSSESSION
York, on or about October 23, 2019, did knowingly and unlawfully possess one or more
preparations, compounds, mixtures or substances containing a narcotic drug and the preparations,
compounds, mixtures or substances were of an aggregate weight of one-half ounce or more.
COUNT 98

accuses the above-named defendant, MATTAHIAS PARSONS, of the crime of ATTEMPTED
43
New York, on or about October 23, 2019, did knowingly and unlawfully attempt to possess a
COUNT 99

violation of Sections 110.00 and 220.16 (Subdivision 12) of the Penal Law of the State of New
York, committed as follows:
New York, on or about October 23, 2019, did knowingly and unlawfully attempt to possess one or
preparations, compounds, mixtures or substances were of an aggregate weight of one-half ounce or
more.
COUNT 100

accuses the above-named defendants, MATTAHIAS PARSONS and DRANAE WASHINGTON, of
That the said defendants, MATTAHIAS PARSONS and DRANAE WASHINGTON, acting
in concert, in the County of Schenectady, State of New York, on or about October 23, 2019, did
44
COUNT 101

COUNT 102

COUNT 103

45
COUNT 104

York, on or about October 23, 2019, did knowingly and unlawfully possess a narcotic drug with the
intent to sell it.
COUNT 105

accuses the above-named defendants, WILLIAM MAYS and UNIKIA CROSS, of the crime of
CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE, in violation of
Section 220.31 of the Penal Law of the State of New York, committed as follows:
That the said defendants, WILLIAM MAYS and UNIKIA CROSS, acting in concert, in the
County of Saratoga, State of New York, on or about October 24, 2019, did knowingly and
unlawfully sell a controlled substance.
COUNT 106

accuses the above-named defendant, JORDAN BLOUNT, of the crime of ATTEMPTED
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE, in
That the said defendant, JORDAN BLOUNT, in the County of Saratoga, State of New York,
on or about October 24, 2019, did knowingly and unlawfully attempt to possess a controlled
substance with the intent to sell it.
46
COUNT 107

accuses the above-named defendant, SHALENA MURRAY, A/K/A “SHAY,” of the crime of
CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of
That the said defendant, SHALENA MURRAY, A/K/A “SHAY,” in the County of Saratoga,
State of New York, on or about October 25, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 108

COUNT 109

accuses the above-named defendant, PAMELA BACKUS, of the crime of ATTEMPTED
on or about October 25, 2019, did knowingly and unlawfully attempt to possess a narcotic drug with
47
COUNT 110

accuses the above-named defendants, DONALD THOMAS and SHARROD THORTON, of the
as follows:
That the said defendants, DONALD THOMAS and SHARRON THORTON, acting in
concert, in the County of Bronx, State of New York, on or about October 26, 2019, did knowingly
and unlawfully sell a narcotic drug.
COUNT 111

accuses the above-named defendant, CLARENCE JACKSON, of the crime of ATTEMPTED
That the said defendant, CLARENCE JACKSON, in the County of Bronx, State of New
COUNT 112

accuses the above-named defendant, DONALD THOMAS, of the crime of CRIMINAL SALE OF A
That the said defendant, DONALD THOMAS, in the County of Bronx, State of New York,
48
COUNT 113

accuses the above-named defendant, FRANKIE MERCADO, of the crime of CRIMINAL
That the said defendant, FRANKIE MERCADO, in the County of Bronx, State of New York,
on or about October 26, 2019, did knowingly and unlawfully possess a narcotic drug with the intent
to sell it.
COUNT 114

COUNT 115

accuses the above-named defendant, NOELIA FUENTES, of the crime of ATTEMPTED
That the said defendant, NOELIA FUENTES, in the County of Saratoga, State of New York,
49
COUNT 116

on or about October 27, 2019, did knowingly and unlawfully attempt to possess one or more
preparations, compounds, mixtures or substances containing a narcotic drug and said preparations,
compounds, mixtures or substances were of an aggregate weight of one-eighth ounce or more.
COUNT 117

accuses the above-named defendants, CLARENCE JACKSON, of the crime of CRIMINAL SALE
That the said defendants, CLARENCE JACKSON, in the County of Saratoga, State of New
cocaine.
COUNT 118

accuses the above-named defendants, CLARENCE JACKSON, of the crime of CRIMINAL SALE
That the said defendants, CLARENCE JACKSON, in the County of Saratoga, State of New
50
cocaine.
COUNT 119

accuses the above-named defendants, WILLIAM MAYS and YVONNE SMITH, of the crime of
That the said defendants, WILLIAM MAYS and YVONNE SMITH, acting in concert, in the
unlawfully sell a narcotic drug.
COUNT 120

COUNT 121

accuses the above-named defendant, PHILIP TAYLOR, of the crime of ATTEMPTED CRIMINAL
as follows:
That the said defendant, PHILIP TAYLOR, in the County of Saratoga, State of New York,
51
COUNT 122

COUNT 123

COUNT 124

accuses the above-named defendant, YVONNE SMITH, of the crime of CRIMINAL POSSESSION
That the said defendant, YVONNE SMITH, in the County of Saratoga, State of New York,
on or about October 31, 2019, did knowingly and unlawfully possess a narcotic drug with the intent
to sell it.
52
COUNT 125

accuses the above-named defendants, MATTAHIAS PARSONS, OMAR CHILDRESS and ERINA
LEMPERLE, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE
That the said defendants, MATTAHIAS PARSONS, OMAR CHILDRESS and ERINA
LEMPERLE, acting in concert, in the County of Schenectady, State of New York, on or about
November 1, 2019, did knowingly and unlawfully sell a narcotic drug to a male.
COUNT 126

accuses the above-named defendants, MATTAHIAS PARSONS, ERIC WILLIAMS, OMAR
CHILDRESS and ERINA LEMPERLE, of the crime of CRIMINAL SALE OF A CONTROLLED
SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39 (Subdivision 1) of the
That the said defendants, MATTAHIAS PARSONS, ERIC WILLIAMS, OMAR
CHILDRESS, DRANAE WASHINGTON and ERINA LEMPERLE, acting in concert, in the
County of Schenectady, State of New York, on or about November 1, 2019, did knowingly and
COUNT 127

accuses the above-named defendants, MATTAHIAS PARSONS, ERIC WILLIAMS, OMAR
CHILDRESS and ERINA LEMPERLE, of the crime of CRIMINAL SALE OF A CONTROLLED
SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39 (Subdivision 1) of the
That the said defendants, MATTAHIAS PARSONS, ERIC WILLIAMS, OMAR
53
CHILDRESS and ERINA LEMPERLE, acting in concert, in the County of Schenectady, State of
New York, on or about November 2, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 128

on or about November 2, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 129

COUNT 130

accuses the above-named defendant, CLARENCE JACKSON, of the crime of ATTEMPTED
That the said defendant, CLARENCE JACKSON, in the County of Bronx, State of New
York, on or about November 4, 2019, did knowingly and unlawfully attempt to possess a narcotic
54
COUNT 131

accuses the above-named defendant, ANGEL BRACERO-ORTIZ, of the crime of CRIMINAL
That the said defendant, ANGEL BRACERO-ORTIZ, in the County of Saratoga, State of
COUNT 132

COUNT 133

accuses the above-named defendants, MATTAHIAS PARSONS and OMAR CHILDRESS, of the
as follows:
That the said defendants, MATTAHIAS PARSONS and OMAR CHILDRESS, acting in
concert, in the County of Schenectady, State of New York, on or about November 8, 2019, did
55
COUNT 134

York, on or about November 13, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 135

A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE, in violation of Section 220.31 of the
York, on or about November 13, 2019, did knowingly and unlawfully sell a controlled substance.
COUNT 136

OF A CONTROLLED SUBSTANCE IN THE FIFTH DEGREE, in violation of Section 220.31 of
the Penal Law of the State of New York, committed as follows:
York, on or about November 13, 2019, did knowingly and unlawfully sell a controlled substance.
COUNT 137

56
OF A CONTROLLED SUBSTANCE IN THE SECOND DEGREE, in violation of Section 220.41
New York, on or about November 13, 2019, did knowingly and unlawfully sell one or more
COUNT 138

COUNT 139

York, on or about November 13, 2019, did knowingly and unlawfully attempt to possess one or
more.
57
COUNT 140

accuses the above-named defendant, LOUIS ROSA, of the crime of CRIMINAL SALE OF A
That the said defendant, LOUIS ROSA, in the County of Schenectady, State of New York,
COUNT 141
Sections 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:
of New York, on or about November 18, 2019, did knowingly and unlawfully possess a narcotic
COUNT 142

of New York, on or about November 18, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 143

58
State of New York, on or about November 18, 2019, did knowingly and unlawfully attempt to
possess a narcotic drug with the intent to sell it.
COUNT 144

accuses the above-named defendants, ADRIANE PIERCE and FRANK SAWYER, of the crime of
That the said defendants, ADRIANE PIERCE and FRANK SAWYER, acting in concert, in
the County of Rensselaer, State of New York, on or about November 18, 2019, did knowingly and
COUNT 145

accuses the above-named defendant, ADRIANE PIERCE, of the crime of CRIMINAL SALE OF A
That the said defendant, ADRIANE PIERCE, in the County of Rensselaer, State of New
COUNT 146

accuses the above-named defendant, FRANK SAWYER, of the crime of ATTEMPTED CRIMINAL
59
as follows:
That the said defendant, FRANK SAWYER, in the County of Rensselaer, State of New
COUNT 147

accuses the above-named defendants, WILLIAM MAYS and SHETWANA VENABLE, of the
as follows:
That the said defendants, WILLIAM MAYS and SHETWANA VENABLE, acting in
concert, in the County of Saratoga, State of New York, on or about November 18, 2019, did
COUNT 148

as follows:
60
COUNT 149

on or about November 20, 2019, did knowingly and unlawfully attempt to possess a narcotic drug
COUNT 150

accuses the above-named defendant, LOUIS ROSA, of the crime of CRIMINAL SALE OF A
That the said defendant, LOUIS ROSA, in the County of Schenectady, State of New York,
COUNT 151

Sections 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:
of New York, on or about November 20, 2019, did knowingly and unlawfully possess a narcotic
61
COUNT 152

of New York, on or about November 20, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 153

State of New York, on or about November 20, 2019, did knowingly and unlawfully attempt to
COUNT 154

as follows:
62
COUNT 155

COUNT 156

accuses the above-named defendant, ERICA DUBRAY, of the crime of ATTEMPTED CRIMINAL
as follows:
That the said defendant, ERICA DUBRAY, in the County of Rensselaer, State of New York,
COUNT 157

accuses the above-named defendants, WILLIAM MAYS and UNIKIA CROSS, of the crime of
That the said defendants, WILLIAM MAYS and UNIKIA CROSS, acting in concert, in the
County of Saratoga, State of New York, on or about November 25, 2019, did knowingly and
63
COUNT 158

COUNT 159

COUNT 160

accuses the above-named defendants, MATTAHIAS PARSONS, of the crime of CRIMINAL SALE
64
COUNT 161

or about November 25, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 162

COUNT 163

accuses the above-named defendant, FRANK SAWYER, of the crime of CRIMINAL POSSESSION
That the said defendant, FRANK SAWYER, in the County of Rensselaer, State of New
York, on or about November 29, 2019, did knowingly and unlawfully possess a narcotic drug with
65
COUNT 164

of New York, on or about December 2, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 165

State of New York, on or about December 2, 2019, did knowingly and unlawfully attempt to possess
the narcotic drug heroin with the intent to sell it.
COUNT 166

York, on or about December 2, 2019, did knowingly and unlawfully sell a narcotic drug.
66
COUNT 167

accuses the above-named defendant, ERICA DUBRAY, of the crime of ATTEMPTED CRIMINAL
as follows:
That the said defendant, ERICA DUBRAY, in the County of Rensselaer, State of New York,
on or about December 2, 2019, did knowingly and unlawfully attempt to possess a narcotic drug
COUNT 168

COUNT 169

accuses the above-named defendant, NANCY DUKES, of the crime of ATTEMPTED CRIMINAL
as follows:
That the said defendant, NANCY DUKES, in the County of Rensselaer, State of New York,
on or about December 2, 2019, did knowingly and unlawfully attempt to possess the narcotic drug
heroin with the intent to sell it.
67
COUNT 170

as follows:
That the said defendants, DONALD THOMAS and SHARROD THORTON, acting in
concert, in the County of Bronx, State of New York, on or about December 2, 2019, did knowingly
COUNT 171

accuses the above-named defendants, ADRIANE PIERCE, FRANK SAWYER and NICOLE
STRAINER, of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE
That the said defendants, ADRIANE PIERCE, FRANK SAWYER and NICOLE
STRAINER, acting in concert, in the County of Rensselaer, State of New York, on or about
December 3, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 172

accuses the above-named defendant, LACY ENOUS, A/K/A “RED,” of the crime of ATTEMPTED
as follows:
of New York, on or about December 5, 2019, did knowingly and unlawfully attempt to sell a
68
narcotic drug.
COUNT 173

as follows:
New York, on or about December 6, 2019, did knowingly and unlawfully attempt to sell a narcotic
drug.
COUNT 174

of New York, on or about December 7, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 175

State of New York, on or about December 7, 2019, did knowingly and unlawfully attempt to possess
69
a narcotic drug with the intent to sell it.
COUNT 176

That the said defendant, CLARENCE JACKSON, in the County of Albany, State of New
COUNT 177

That the said defendant, CLARENCE JACKSON, in the County of Albany, State of New
COUNT 178

accuses the above-named defendant, LACY ENOUS, A/K/A “RED,” of the crime of ATTEMPTED
as follows:
of New York, on or about December 9, 2019, did knowingly and unlawfully attempt to sell a
narcotic drug.
70
COUNT 179

as follows:
concert, in the County of Bronx, State of New York, on or about December 12, 2019, did knowingly
COUNT 180

accuses the above-named defendant, SHAWN DELMORE, of the crime of CRIMINAL
That the said defendant, SHAWN DELMORE, in the County of Bronx, State of New York,
on or about December 12, 2019, did knowingly and unlawfully possess a narcotic drug with the
intent to sell it.
COUNT 181

on or about December 19, 2019, did knowingly and unlawfully sell a narcotic drug.
71
COUNT 182

accuses the above-named defendant, CRYSTAL LEO, of the crime of CRIMINAL POSSESSION
That the said defendant, CRYSTAL LEO, in the County of Saratoga, State of New York, on
or about December 19, 2019, did knowingly and unlawfully possess a narcotic drug with the intent
to sell it.
COUNT 183

New York, on or about December 20, 2019, did knowingly and unlawfully sell a narcotic drug.
COUNT 184

York, on or about December 20, 2019, did knowingly and unlawfully attempt to possess a narcotic
72
COUNT 185

accuses the above-named defendants, ADRIAN PIERCE and DEAN HARLAN, of the crime of
That the said defendants, ADRIAN PIERCE and DEAN HARLAN, acting in concert, in the
County of Rensselaer, State of New York, on or about December 23, 2019, did knowingly and
COUNT 186

accuses the above-named defendant, NANCY DUKES, of the crime of CRIMINAL POSSESSION
That the said defendant, NANCY DUKES, in the County of Rensselaer, State of New York,
on or about December 23, 2019, did knowingly and unlawfully possess a narcotic drug with the
intent to sell it.
COUNT 187

accuses the above-named defendant, SHARROD THORTON, of the crime of CRIMINAL SALE
That the said defendant, SHARROD THORTON, in the County of Bronx, State of New
73
COUNT 188

accuses the above-named defendant, DEAN HARLAN, of the crime of CRIMINAL SALE OF A
That the said defendant, DEAN HARLAN, in the County of Albany, State of New York, on
or about January 1, 2020, did knowingly and unlawfully sell a narcotic drug.
COUNT 189

accuses the above-named defendants, ADRIANE PIERCE, JANESSA SOTO and DEAN HARLAN,
of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD
That the said defendants, ADRIANE PIERCE, JANESSA SOTO and DEAN HARLAN,
acting in concert, in the County of Rensselaer, State of New York, on or about January 3, 2020, did
COUNT 190

accuses the above-named defendant, ELRAHIM WRIGHT, of the crime of CRIMINAL SALE OF A
CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.43
That the said defendant, ELRAHIM WRIGHT, in the County of Albany, State of New York,
on or about January 3, 2020, did knowingly and unlawfully sell one or more preparations,
compounds, mixtures or substances containing a narcotic drug, to wit: fentanyl, and the preparations,
compounds, mixtures or substances were of an aggregate weight of two ounces or more.
74
COUNT 191

accuses the above-named defendant, ELRAHIM WRIGHT, of the crime of CRIMINAL
on or about January 3, 2020, did knowingly and unlawfully possess a narcotic drug, to wit: fentanyl,
COUNT 192

on or about January 3, 2020, did knowingly and unlawfully possess one or more preparations,
COUNT 193

That the said defendant, LACY ENOUS, A/K/A “RED,” in the County of Albany, State of
New York, on or about January 3, 2020, did knowingly and unlawfully possess a narcotic drug, to
wit: fentanyl, with the intent to sell it.
75
COUNT 194

New York, on or about January 3, 2020, did knowingly and unlawfully possess one or more
preparations, compounds, mixtures or substances containing a narcotic drug, to wit: fentanyl, and
said preparations, compounds, mixtures or substances were of an aggregate weight of one-half ounce
or more.
COUNT 195

SALE OF A CONTROLLED SUBSTANCE IN THE SECOND DEGREE, in violation of Section
New York, on or about January 3, 2020, did knowingly and unlawfully sell one or more
preparations, compounds, mixtures or substances containing a narcotic drug, to wit: fentanyl, and the
more.
COUNT 196

as follows:
76
That the said defendant, ADRIAN KELLEY, A/K/A “ACE,” in the County of Albany, State
of New York, on or about January 3, 2020, did knowingly and unlawfully possess a narcotic drug, to
wit: fentanyl, with the intent to sell it.
COUNT 197

as follows:
of New York, on or about January 3, 2020, did knowingly and unlawfully possess one or more
more.
COUNT 198

as follows:
of New York, on or about January 3, 2020, did knowingly and unlawfully attempt to possess a
narcotic drug, to wit: cocaine, with the intent to sell it.
77
COUNT 199

as follows:
of New York, on or about January 3, 2020, did knowingly and unlawfully possess one or more
preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and the
more.
COUNT 200

as follows:
New York, on or about January 3, 2020, did knowingly and unlawfully attempt to sell a narcotic
drug, to wit: cocaine.
COUNT 201

accuses the above-named defendants, MATTAHIAS PARSONS, of the crime of CRIMINAL
That the said defendants, MATTAHIAS PARSONS, in the County of Schenectady, State of
78
New York, on or about January 3, 2020, did knowingly and unlawfully possess a narcotic drug, to
wit: cocaine, with the intent to sell it.
COUNT 202

accuses the above-named defendant, MATTAHIAS PARSONS, of the crime of CRIMINAL
New York, on or about January 3, 2020, did knowingly and unlawfully possess one or more
preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and the
more.
COUNT 203

accuses the above-named defendant, MATTAHIAS PARSONS, of the crime of CRIMINALLY
USING DRUG PARAPHERNALIA IN THE SECOND DEGREE, in violation of Section 220.50
New York, on or about January 3, 2020, did knowingly possess diluents, dilatants or adulterants,
including but not limited to, any of the following: quinine hydrochloride, mannitol, mannite, lactose
or dextrose, adapted for the dilution of narcotic drugs or stimulants under circumstances evincing an
intent to use, or under circumstances evincing knowledge that some person intends to use, the same
for the purposes of unlawfully mixing, compounding, or otherwise preparing any narcotic drug or
stimulant.
79
COUNT 204

New York, on or about January 3, 2020, did knowingly possess gelatin capsules, glassine envelopes,
vials, capsules or any other material suitable for the packaging of individual quantities of narcotic
drugs or stimulants under circumstances evincing an intent to use, or under circumstances evincing
knowledge that some person intends to use, the same for the purpose of unlawfully manufacturing,
packaging or dispensing of any narcotic drug or stimulant.
COUNT 205

New York, on or about January 3, 2020, did knowingly possess a digital scale used or designed for
the purpose of weighing or measuring controlled substances, under circumstances evincing an intent
to use, or under circumstances evincing knowledge that some person intends to use, the same for
purpose of unlawfully manufacturing, packaging or dispensing of any narcotic drug or stimulant.
COUNT 206

accuses the above-named defendants, ADRIANE PEIRCE, JANESSA SOTO and DEAN HARLAN,
of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD
80
That the said defendants, ADRIANE PEIRCE, JANESSA SOTO and DEAN HARLAN,
acting in concert, in the County of Rensselaer, State of New York, on or about January 4, 2020, did
COUNT 207

accuses the above-named defendants, JANESSA SOTO and ADRIANE PIERCE, of the crime of
as follows:
That the said defendants, JANESSA SOTO and ADRIANE PIERCE, acting in concert, in the
County of Rensselaer, State of New York, on or about January 4, 2020, did knowingly and
unlawfully possess a narcotic drug with the intent to sell it.
COUNT 208

on or about January 17, 2020, did knowingly and unlawfully sell a narcotic drug.
COUNT 209

accuses the above-named defendant, PATRICK ROBINSON, of the crime of ATTEMPTED
81
That the said defendant, PATRICK ROBINSON, in the County of Saratoga, State of New
York, on or about January 17, 2020, did knowingly and unlawfully attempt to possess a narcotic
COUNT 210

York, on or about January 24, 2020, did knowingly and unlawfully sell a narcotic drug.
COUNT 211

accuses the above-named defendant, CARLOS HERNANDEZ, of the crime of ATTEMPTED
That the said defendant, CARLOS HERNANDEZ, in the County of Bronx, State of New
COUNT 212

accuses the above-named defendants, SHARROD THORTON and DONALD THOMAS, of the
82
as follows:
That the said defendants, SHARROD THORTON and DONALD THOMAS, acting in
concert, in the County of Bronx, State of New York, on or about January 28, 2020, did knowingly
COUNT 213

accuses the above-named defendant, LAMONT WILLIAMS, of the crime of ATTEMPTED
That the said defendant, LAMONT WILLIAMS, in the County of Bronx, State of New York,
on or about January 28, 2020, did knowingly and unlawfully attempt to possess a narcotic drug with
COUNT 214

accuses the above-named defendant, ELRAHIM WRIGHT, of the crime of ATTEMPTED
CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of
as follows:
on or about January 28, 2020, did knowingly and unlawfully attempt to sell one or more
preparations, compounds, mixtures or substances were of an aggregate weight of two ounces or
more.
83
COUNT 215

on or about January 28, 2020, did knowingly and unlawfully possess a narcotic drug, to wit:
fentanyl, with the intent to sell it.
COUNT 216

on or about January 28, 2020, did knowingly and unlawfully possess one or more preparations,
COUNT 217

accuses the above-named defendant, ADRIANE PIERCE, of the crime of ATTEMPTED
That the said defendant, ADRIANE PIERCE, in the County of Albany, State of New York,
on or about January 28, 2020, did knowingly and unlawfully attempt to possess a narcotic drug with
84
COUNT 218

accuses the above-named defendant, ADRIANE PIERCE, of the crime of ATTEMPTED
That the said defendant, ADRIANE PIERCE, in the County of Albany, State of New York,
on or about January 28, 2020, did knowingly and unlawfully attempt to possess one or more
COUNT 219

York, on or about January 30, 2020, did knowingly and unlawfully sell one or more preparations,
COUNT 220

85
York, on or about January 30, 2020, did knowingly and unlawfully sell a narcotic drug.
COUNT 221

accuses the above-named defendant, RICHARD HENDERSON, of the crime of ATTEMPTED
That the said defendant, RICHARD HENDERSON, in the County of Bronx, State of New
COUNT 222

York, on or about January 30, 2020, did knowingly and unlawfully attempt to possess one or more
COUNT 223

accuses the above-named defendants, SHARROD THORTON and DONALD THOMAS, of the
86
as follows:
That the said defendants, SHARROD THORTON and DONALD THOMAS, acting in
concert, in the County of Bronx, State of New York, on or about February 5, 2020, did knowingly
COUNT 224

accuses the above-named defendant, LAMONT WILLIAMS, of the crime of ATTEMPTED
That the said defendant, LAMONT WILLIAMS, in the County of Bronx, State of New York,
on or about February 5, 2020, did knowingly and unlawfully attempt to possess a narcotic drug with
COUNT 225

on or about February 5, 2020, did knowingly and unlawfully sell a narcotic drug.
COUNT 226

accuses the above-named defendant, SHAWN DELMORE, of the crime of ATTEMPTED
87
on or about February 5, 2020, did knowingly and unlawfully attempt to possess a narcotic drug with
COUNT 227

That the said defendant, WILLIAM MAYS, in the County of Albany, State of New York, on
or about or between February 2, 2020 through February 6, 2020, did knowingly and unlawfully sell a
narcotic drug.
COUNT 228

on or about or between February 2, 2020 through February 6, 2020, did knowingly and unlawfully
attempt to possess a narcotic drug with the intent to sell it.
COUNT 229

accuses the above-named defendant, FRANKIE MERCADO, of the crime of CRIMINAL SALE OF
88
COUNT 230

York, on or about February 10, 2020, did knowingly and unlawfully sell one or more preparations,
COUNT 231

York, on or about February 10, 2020, did knowingly and unlawfully sell a narcotic drug.
COUNT 232

accuses the above-named defendant, CARLOS HERNANDEZ, of the crime of ATTEMPTED
89
That the said defendant, CARLOS HERNANDEZ, in the County of Bronx, State of New
York, on or about February 10, 2020, did knowingly and unlawfully attempt to possess a narcotic
COUNT 233

accuses the above-named defendant, WILLIAM MAYS, of the crime of ATTEMPTED CRIMINAL
as follows:
That the said defendant, WILLIAM MAYS, in the County of Nassau, State of New York, on
or about February 13, 2020, did knowingly and unlawfully attempt to possess a narcotic drug with
COUNT 234

accuses the above-named defendants, FRANKIE MERCADO and ALEXANDER RIVERA, of the
as follows:
That the said defendants, FRANKIE MERCADO and ALEXANDER RIVERA, acting in
COUNT 235

90
COUNT 236

accuses the above-named defendant, PATRICK ROBINSON, of the crime of ATTEMPTED
That the said defendant, PATRICK ROBINSON, in the County of Saratoga, State of New
York, on or about February 18, 2020, did knowingly and unlawfully attempt to possess a narcotic
COUNT 237

COUNT 238

accuses the above-named defendant, PHILIP TAYLOR, of the crime of ATTEMPTED CRIMINAL
91
as follows:
That the said defendant, PHILIP TAYLOR, in the County of Saratoga, State of New York,
on or about February 19, 2020, did knowingly and unlawfully attempt to possess a narcotic drug
COUNT 239

COUNT 240

COUNT 241

accuses the above-named defendant, CRYSTAL LEO, of the crime of ATTEMPTED CRIMINAL
as follows:
That the said defendant, CRYSTAL LEO, in the County of Saratoga, State of New York, on
92
or about February 21, 2020, did knowingly and unlawfully attempt to possess a narcotic drug with
COUNT 242

accuses the above-named defendant, FRANKIE MERCADO, of the crime of ATTEMPTED
on or about February 22, 2020, did knowingly and unlawfully attempt to possess a narcotic drug
with intent to sell it.
COUNT 243

COUNT 244

93
COUNT 245

COUNT 246

accuses the above-named defendant, WILLIAM MAYS, of the crime of CRIMINAL POSSESSION
OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Sections 220.16
on or about February 27, 2020, did knowingly and unlawfully possess the narcotic drug, to wit:
cocaine, with the intent to sell it.
COUNT 247

accuses the above-named defendant, WILLIAM MAYS, of the crime of CRIMINALLY USING
DRUG PARAPHERNALIA IN THE SECOND DEGREE, in violation of Section 220.50
on or about February 27, 2020, did knowingly possess a digital scale used or designed for the
purpose of weighing or measuring controlled substances, under circumstances evincing an intent to
use, or under circumstances evincing knowledge that some person intends to use, the same for
94
COUNT 248
THE GRAND JURY OF THE COUNTY OF BRONX, by this Indictment, further accuses
the above-named defendants, FRANKIE MERCADO and ALEXANDER RIVERA, of the crime of
COUNT 249

That the said defendant, SHALENA MURRAY, A/K/A “SHAY, in the County of Saratoga,
State of New York, on or about March 3, 2020, did knowingly and unlawfully sell a narcotic drug.
COUNT 250

accuses the above-named defendant, JOSEPH MEUNIER, of the crime of CRIMINAL
That the said defendant, JOSEPH MEUNIER, in the County of Saratoga, State of New York,
on or about March 3, 2020, did knowingly and unlawfully possess a narcotic drug with the intent to
sell it.
95
COUNT 251

accuses the above-named defendant, JOSEPH MEUNIER, of the crime of ATTEMPTED
on or about March 3, 2020, did knowingly and unlawfully attempt to possess one or more
compounds, mixtures or substances were of an aggregate weight of one-eighth ounce or more.
COUNT 252

CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE SECOND DEGREE, in violation
of Section 220.41 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:
State of New York, on or about March 5, 2020, did knowingly and unlawfully sell one or more
preparations, compounds, mixtures or substances containing the narcotic drug cocaine and the
more.
COUNT 253

96
on or about March 5, 2020, did knowingly and unlawfully attempt to possess a narcotic drug with the
intent to sell it.
COUNT 254

on or about March 5, 2020, did knowingly and unlawfully attempt to possess one or more
COUNT 255

crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD
concert, in the County of Bronx, State of New York, on or about March 7, 2020, did knowingly and
unlawfully possess a narcotic drug with the intent to sell it.
COUNT 256

97
on or about March 7, 2020, did knowingly and unlawfully sell a narcotic drug.
COUNT 257

as follows:
concert, in County of Bronx, State of New York, on or about March 8, 2020, did knowingly and
COUNT 258

“RED,” of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE
acting in concert, in the County of Saratoga, State of New York, on or about March 10, 2020, did
knowingly and unlawfully possess a narcotic drug, to wit: heroin, with the intent to sell it.
COUNT 259

98
“RED,” of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE
FOURTH DEGREE, in violation of Sections 110.00 and 220.09 (Subdivision 1) of the Penal Law of
the State of New York, committed as follows:
knowingly and unlawfully possess one or more preparations, compounds, mixtures or substances
containing a narcotic drug, to wit: heroin, and said preparations, compounds, mixtures or substances
were of an aggregate weight of one-eighth ounce or more.
COUNT 260

“RED,” of the crime of CRIMINALLY USING DRUG PARAPHERNALIA IN THE SECOND
knowingly possess gelatin capsules, glassine envelopes, vials, capsules or any other material suitable
for the packaging of individual quantities or narcotic drugs or stimulants under circumstances
evincing an intent to use, or under circumstances evincing knowledge that some person intends to
use, the same for the purpose of unlawfully manufacturing, packaging or dispensing of any narcotic
drug or stimulant.
COUNT 261

“RED,” of the crime of CRIMINALLY USING DRUG PARAPHERNALIA IN THE SECOND
99
knowingly possess a digital scale used or designed for the purpose of weighing or measuring
controlled substances, under circumstances evincing an intent to use, or under circumstances
evincing knowledge that some person intends to use, the same for purpose of unlawfully
manufacturing, packaging or dispensing of any narcotic drug or stimulant.
COUNT 262

accuses the above-named defendants, ANGEL BRACERO-ORTIZ and ZOOLEIKA MENDEZ, of
That the said defendants, ANGEL BRACERO-ORTIZ and ZOOLEIKA MENDEZ, acting in
concert, in the County of Saratoga, State of New York, on or about March 11, 2020, did knowingly
COUNT 263

York, on or about March 11, 2020, did knowingly and unlawfully possess a narcotic drug with the
intent to sell it.
100
COUNT 264

York, on or about March 11, 2020, did knowingly and unlawfully sell a narcotic drug.
COUNT 265
THE GRAND JURY OF THE COUNTY OF BRONX, by this Indictment, further accuses
the above-named defendant, SHARROD THORTON, of the crime of CRIMINAL SALE OF A
York, on or about March 11, 2020, did knowingly and unlawfully sell a narcotic drug.
COUNT 266

accuses the above-named defendant, DOROTHY GETHERS, A/K/A “BRENDA,” of the crime of
That the said defendant, DOROTHY GETHERS, A/K/A “BRENDA,” in the County of
Bronx, State of New York, on or about March 11, 2020, did knowingly and unlawfully attempt to
101
COUNT 267

ATTEMPTED CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE SECOND
That the said defendant, SHALENA MURRAY, A/K/A “SHAY,” County of Saratoga, State
of New York, on or about March 19, 2020, did knowingly and unlawfully attempt to sell one or more
COUNT 268

CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE SECOND DEGREE, in
as follows:
State of New York, on or about March 19, 2020, did knowingly and unlawfully possess one or more
preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and
said preparations, compounds, mixtures or substances were of an aggregate weight of four ounces or
more.
COUNT 269

102
as follows:
State of New York, on or about March 19, 2020, did knowingly and unlawfully possess a narcotic
COUNT 270

accuses the above-named defendant, RICHARD HENDERSON, of the crime of CRIMINAL
York, on or about March 25, 2020, did knowingly and unlawfully possess a narcotic drug, to wit:
cocaine, with the intent to sell it.
COUNT 271

crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in
as follows:
concert, in the County of Bronx, State of New York, on or about March 30, 2020, did knowingly and
unlawfully sell one or more preparations, compounds, mixtures or substances containing a narcotic
drug, to wit: cocaine, and the preparations, compounds, mixtures or substances were of an aggregate
weight of two ounces or more.
103
COUNT 272

POSSESSION OF A CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of
on or about March 30, 2020, did knowingly and unlawfully possess one or more preparations,
compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and said
preparations, compounds, mixtures or substances were of an aggregate weight of eight ounces or
more.
COUNT 273

on or about March 30, 2020, did knowingly and unlawfully possess a narcotic drug, to wit: cocaine,
COUNT 274

York, on or about April 1, 2020, did knowingly and unlawfully sell a narcotic drug.
104
COUNT 275

York, on or about April 1, 2020, did knowingly and unlawfully attempt to possess a narcotic drug
COUNT 276

accuses the above-named defendant, DAVID GARCIA, of the crime of CRIMINAL SALE OF A
That the said defendant, DAVID GARCIA, in the County of Saratoga, State of New York, on
or about April 3, 2020, did knowingly and unlawfully sell a narcotic drug.
COUNT 277

accuses the above-named defendants, DAVID GARCIA and KIMBERLY GOODSON, of the crime
of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation
That the said defendants, DAVID GARCIA and KIMBERLY GOODSON, acting in concert,
in the County of Warren, State of New York, on or about April 6, 2020, did knowingly and
105
COUNT 278

That the said defendant, DAVID GARCIA, in the County of Warren, State of New York, on
COUNT 279

in the County of Saratoga, State of New York, on or about April 5, 2020, did knowingly and
COUNT 280

106
COUNT 281

in the County of Saratoga, State of New York, on or about April 9, 2020, did knowingly and
COUNT 282

accuses the above-named defendants, SHARROD THORTON and DOROTHY GETHERS, A/K/A
“BRENDA,” of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE
That the said defendants, SHARROD THORTON and DOROTHY GETHERS, A/K/A
“BRENDA,” acting in concert, in the County of Bronx, State of New York, on or about April 10,
2020, did knowingly and sell a narcotic drug.
COUNT 283

accuses the above-named defendants, SHARROD THORTON and DOROTHY GETHERS, A/K/A
“BRENDA,” of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE
That the said defendants, SHARROD THORTON and DOROTHY GETHERS, A/K/A
“BRENDA,” acting in concert, in the County of Bronx, State of New York, on or about April 10,
2020, did knowingly and unlawfully sell a narcotic drug.
107
COUNT 284

York, on or about April 10, 2020, did knowingly and unlawfully attempt to possess a narcotic drug
COUNT 285

crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FIRST
That the said defendants, DONALD THOMAS AND SHARROD THORTON, acting in
concert, in the County of Bronx, State of New York, on or about April 10, 2020, did knowingly and
unlawfully possess one or more preparations, compounds, mixtures or substances containing a
narcotic drug, to wit: cocaine, and said preparations, compounds, mixtures or substances were of an
aggregate weight of eight ounces or more.
COUNT 286

crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD
108
concert, in the County of Bronx, State of New York, on or about April 10, 2020, did knowingly and
unlawfully possess a narcotic drug, to wit: cocaine, with the intent to sell it.
COUNT 287

crime of CRIMINALLY USING DRUG PARAPHERNALIA IN THE SECOND DEGREE, in
as follows:
concert, in the County of Bronx, State of New York, on or about April 10, 2020, did knowingly
possess diluents, dilatants or adulterants, including but not limited to, any of the following: quinine
hydrochloride, mannitol, mannite, lactose or dextrose, adapted for the dilution of narcotic drugs or
stimulants under circumstances evincing an intent to use, or under circumstances evincing
knowledge that some person intends to use, the same for the purposes of unlawfully mixing,
compounding, or otherwise preparing any narcotic drug or stimulant.
COUNT 288

as follows:
concert, in the County of Bronx, State of New York, on or about April 10, 2020, did knowingly
possess gelatin capsules, glassine envelopes, vials, capsules or any other material suitable for the
packaging of individual quantities of narcotic drugs or stimulants under circumstances evincing an
intent to use, or under circumstances evincing knowledge that some person intends to use, the same
109
for the purpose of unlawfully manufacturing, packaging or dispensing of any narcotic drug or
stimulant.
COUNT 289

as follows:
concert,, in the County of Bronx, State of New York, on or about April 10, 2020, did knowingly
possess a digital scale used or designed for the purpose of weighing or measuring controlled
substances, under circumstances evincing an intent to use, or under circumstances evincing
knowledge that some person intends to use, the same for purpose of unlawfully manufacturing,
packaging or dispensing of any narcotic drug or stimulant.
COUNT 290

COUNT 291

110
That the said defendant, DAVID GARCIA, in the County of Schenectady, State of New
York, on or about April 24, 2020, did knowingly and unlawfully sell a narcotic drug.
COUNT 292

COUNT 293

COUNT 294

111
COUNT 295

COUNT 296

of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
as follows:
unlawfully possess a narcotic drug, to wit: cocaine and heroin, with the intent to sell it.
COUNT 297

of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FOURTH DEGREE,
112
unlawfully possess one or more preparations, compounds, mixtures or substances containing a
narcotic drug, to wit: heroin, and said preparations, compounds, mixtures or substances were of an
aggregate weight of one-eighth of an ounce or more.
COUNT 298

of CRIMINALLY USING DRUG PARAPHERNALIA IN THE SECOND DEGREE, in violation of
in the County of Warren, State of New York, on or about April 30, 2020, did knowingly possess
diluents, dilatants or adulterants, including but not limited to, any of the following: quinine
hydrochloride, mannitol, mannite, lactose or dextrose, adapted for the dilution of narcotic drugs or
stimulants under circumstances evincing an intent to use, or under circumstances evincing
knowledge that some person intends to use, the same for the purposes of unlawfully mixing,
compounding, or otherwise preparing any narcotic drug or stimulant.
COUNT 299

in the County of Warren, State of New York, on or about April 30, 2020, did knowingly possess
gelatin capsules, glassine envelopes, vials, capsules or any other material suitable for the packaging
of individual quantities of narcotic drugs or stimulants under circumstances evincing an intent to use,
or under circumstances evincing knowledge that some person intends to use, the same for the
113
COUNT 300

That the said defendants, DAVID GARCIA and KIMBERLY GOODSON, acting in concert,,
in the County of Warren, State of New York, on or about April 30, 2020, did knowingly possess a
digital scale used or designed for the purpose of weighing or measuring controlled substances, under
circumstances evincing an intent to use, or under circumstances evincing knowledge that some
person intends to use, the same for purpose of unlawfully manufacturing, packaging or dispensing of
any narcotic drug or stimulant.
COUNT 301

accuses the above-named defendant, DONALD THOMAS, of the crime of OPERATING AS A
MAJOR TRAFFICKER, in violation of Section 220.77(3) of the Penal Law of the State of New
That the said defendant, DONALD THOMAS, acting in concert with others, in Bronx
County, and elsewhere in and outside of the State of New York, on or about October 25, 2019,
through April 10, 2020, acting as a profiteer, did knowingly and unlawfully possess, on one or more
occasions within six months or less, a narcotic drug with the intent to sell the same, and such
narcotic drugs have a total aggregate value of seventy-five thousand dollars or more.
COUNT 302

accuses the above-named defendant, SHAWN DELMORE, of the crime of OPERATING AS A
114
That the said defendant, SHAWN DELMORE, acting in concert with others, in Bronx
COUNT 303

accuses the above-named defendant, SHARROD THORTON, of the crime of OPERATING AS A
That the said defendant, SHARROD THORTON, acting in concert with others, in Bronx
Dated: October ___, 2020

Saratoga, New York
___________________________________
Grand Jury Foreperson
NICOLE KEARY
Deputy Attorney General
N.Y.S. Attorney General's Organized Crime Task Force
By:
Andrew McElwee
Assistant Deputy Attorney General
N.Y.S. Attorney General's Organized Crime Task Force
115

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STATE OF NEW YORK

COUNTY COURT: COUNTY OF SARATOGA

THE PEOPLE OF THE STATE OF NEW YORK

-vs- SEALED INDICTMENT

defendants, PAMELA BACKUS, JORDAN BLOUNT, ANGEL BRACERO-ORTIZ, OMAR

CHILDRESS, UNIKIA CROSS, JAMES DAGGETT, SHAWN DELMORE, ERICA DUBRAY,

DAVID GARCIA, DOROTHY GETHERS, A/K/A “BRENDA,” KIMBERLY GOODSON, DEAN

HARLAN, RICHARD HENDERSON, CARLOS HERNANDEZ, CLARENCE JACKSON,

ADRIAN KELLEY, A/K/A “ACE,” DEBORAH LATALLADI , ERINA LEMPERLE, CRYSTAL

LEO, AMANDA LOVELY-LAMARCHE, WILLIAM MAYS, ZOOLEIKA MENDEZ, FRANKIE

MERCADO, JOSEPH MEUNIER, SHALENA MURRAY, A/K/A “SHAY,” DAMIR PARSONS,

MATTATHIAS PARSONS, ADRIANE PIERCE, NICOLE RICH, ALEXANDER RIVERA,

NICOLE STRAINER, PHILIP TAYLOR, DONALD THOMAS, SHARROD THORTON,

SHETWANA VENABLE, DRANAE WASHINGTON, ERIC WILLIAMS, LAMONT WILLIAMS

of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation

CONTROLLED SUBSTANCE IN THE SECOND DEGREE, in violation of Section 220.41(1) of

State of New York and/or CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN

proceeds from those narcotics transactions.

sell cocaine, up to kilograms at a time, in Bronx County to CLARENCE JACKSON, SHAWN

DELMORE, RICHARD HERNDERSON, CARLOS HERNANDEZ, FRANKIE MERCADO,

DOROTHY GETHERS, A/K/A “BRENDA,” LAMONT WILLIAMS, and others.

RICHARD HERNDERSON, CARLOS HERNANDEZ, FRANKIE MERCADO, DOROTHY

THOMAS and/or SHARROD THORTON to sell to others.

FRANKIE MERCADO to sell to others.

CLARENCE JACKSON, DAVID GARCIA and KIMBERLY GOODSON to sell to PAMELA

BACKUS, and others.

“SHAY,” ZOOLEIKA MENDEZ, ANGEL BRACERO-ORTIZ, and CLARENCE JACKSON to

sell to PAMELA BACKUS, NICOLE RICH, and others.

prescription pills to DEBORAH LATALLADI.

to JAMES DAGGETT, ADRIAN KELLEY, A/K/A “ACE,” AMANDA LOVELY-LAMARCHE,

JAMES EGGLESTON, CLARENCE JACKSON, DEBORAH LATALLADI and others.

LACY ENOUS, A/K/A “RED,” to sell to others.

BLOUNT, UNIKIA CROSS, NOELIA FUENTES, DEBORAH LATALLADI, CRYSTAL LEO,

PATRICK ROBINSON, YVONNE SMITH, PHILLIP TAYLOR, SHETWANA VENABLE, and

SHETWANA VENABLE, to obtain cocaine from WILLIAM MAYS to sell to others.

cocaine to JOSEPH MEUNIER, DEBORAH LATALLADI, and others.

SHALENA MURRAY, A/K/A “SHAY,” to sell to others.

ORTIZ to sell prescription pills to DEBORAH LATALLADI.

PARSONS, DRANAE WASHINGTON, ERINA LEMPERLE, OMAR CHILDRESS, and others.

and/or ERIC WILLIAMS to sell to others.

ENOUS, A/K/A “RED,” ADRIANE PIERCE, and others.

STRAINER, and others.

drugs from ADRIANE PIERCE to sell to others.

narcotic drugs to DEBORAH LATALLADI.

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further