STATE OF NEW YORK COUNTY COURT COUNTY OF CHENANGO THE PEOPLE OF THE STATE OF NEW YORK Plaintiff, ERNEST F. FRANKLIN ll, Defendant. INDICTMENT NO. OFFICE OF CHENANGO COUNTY DISTRICT ATTORNEY FIRST COUNT THE GRAND JURY OF THE COUNTY OF CHENANGO, by this Indictment, accuse the defendant, ERNEST F. FRANKLIN ll, of the crime of MURDER IN THE SECOND DEGREE, a Class A-1 violent felony, in violation of Section 125.25, subdivision 1 of the Penal Law of the State of New York, committed as follows: That the defendant, ERNEST F. FRANKLIN II, on or about February 28, 2017, in the Town of Guilford, County of Chenango and State of New York, with intent to cause the death of another person he did cause the death of such person or of a third person; to wit; at the aforesaid time and place, at 457 State Highway 8, the defendant, while acting in concert with another, did intentionally cause the death of one Jeffery R. Franklin, date of birth 07/22/2000. OFFICE OF CHENANGO COUNTY DISTRICT ATTORNEY SECOND COUNT THE GRAND JURY OF THE COUNTY OF CHENANGO by this Indictment, accuse the defendant, ERNEST F. FRANKLIN ll, of the crime of ARSON IN THE THIRD DEGREE, a Class felony in violation of Section 150.10, subdivision 1 of the Penal Law of the State of New York committed as follows: That the Defendant, ERNEST F. FRANKLIN II, on or about February 28, 2017 in the Town of Guilford, County of Chenango and State of New York did intentionally damage a building or motor vehicle by starting a fire or causing an explosion; to wit; at the aforesaid time and place, at 457 State Highway 8, the defendant, while acting in concert with another, did intentionally damage his double wide trailer by intentionally starting a fire within, causing a complete loss to said property. OFFICE OF CHENANGO COUNTY DISTRICT ATTORNEY THIRD COUNT THE GRAND JURY OF THE COUNTY OF CHENANGO, by this indictment, accuse the defendant, ERNEST F. FRANKLIN ll, of the crime of TAMPERING WITH PHYSICAL EVIDENCE, a Class felony in violation of Section 215.40 subdivision 2 of the Penal Law of the State of New York, committed as follows: That the defendant, ERNEST F. FRANKLIN II, on or about February 28, 2017, in the Town of Guilford, County of Chenango and State of New York, believing that certain physical evidence is about to be produced or used in an official proceeding or a prospective official proceeding, and intending to prevent such production or use, he suppresses it by any act of concealment, alteration or destruction, or by employing force, intimidation or deception against any person; to wit; at the aforesaid time and place, at 457 State Highway 8, the defendant believing that a prospective official investigation in a homicide would take place, and while acting in concert with another, did intentionally prevent the production of the body of Jeffery R. Franklin, DOB: 07/22/2000 by attempting to destroy said body by starting a fire at the above address. OFFICE OF CHENANGO COUNTY DISTRICT ATTORNEY GRAND JURY FOREMAN OFFICE OF CHENANGO COUNTY DISTRICT ATTORNEY