STATE OF NEW YORK
COUNTY COURT: COUNTY OF SARATOGA


THE PEOPLE OF THE STATE OF NEW YORK

-VS- SEALED INDICTMENT
Indictment 1 1-2018
ROBERT ALLEN,
JESSICA BAKER,
TARA BROWN,
COLLEEN CONNOLLY, COLLEEN SYMAN,
ANGELA COX,
RASHAUN CREEL, 
JAMES DUPREY,
SHANE FRAISER,
VANESSA FRENCH,
VANESSA GRAHAM,
MELVINA GROVENBURG, 
STEVEN LATHROP,
DONALD LAYMAN,
EDWARD LEE, 
MATTHEW MALU, 
AMEL MILLER,
ELIZABETH MONAHAN, a/k/a 
JESSICA NICHOLS,
PATRICK 
RENEE PASSINO,
JAMEL PEARSON, II, 
BRENDA PERRY,
HARDLEY PIERRE,
TARA REID,
TREMEL ROSARIO, 
LAURA RUS SO,
MANA SAMBOLA, MANA SAMBOLE, 
KIMBERLY SCHWARTFIGURE,
MARK TAI, and
NICHOLAS TORCHETTI,

Defendants.



COUNT 1

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, accuses the
defendants, ROBERT ALLEN, JESSICA BAKER, TARA BROWN, COLLEEN CONNOLLY,
. COLLEEN SYMAN, ANGELA COX, RASHAUN CREEL, 
JAMES DUPREY, SHANE RAISER, VANESSA FRENCH, VANESSA GRAHAM, MELVIN A
GROVENBURG, STEVEN LATHROP, DONALD LAYMAN, EDWARD LEE,
MATTHEW MALU, JAMEL MILLER,
ELIZABETH MONAHAN, a/k/a JESSICA NICHOLS, PATRICK RENEE
PASSINO, JAMEL PEARSON, II, BRENDA PERRY, HARDLEY PIERRE,
TARA REID, TREMEL ROSARIO, LAURA RUSSO, MANA SAMBOLA,
MANA SAMBOLE, KIMBERLY SCHWARTFIGURE, MARK TAI,
and NICHOLAS TORCHETTI, 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, Saratoga County, Schenectady County, Warren
County, Washington County, and elsewhere in the State of New York, from on or before August 3,
2017, until on or about September 5, 2018, 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, 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 both of the above-

mentioned class A felonies.
PREAMBLE

It was the purpose of this conspiracy to sell narcotics in amounts greater than one-half ounce
7 or more in Albany County, Saratoga County, Schenectady County, Warren County, Washington
County, and elsewhere in the State of New York, and to collect the proceeds from those narcotics
transactions.

It was also part of the conspiracy for Robert Allen and Tremel Rosario, a/k/a ?Skinny,? to
supply cocaine to each other, which they would then re-sell in the Capital Region of New York
State. I

It was also part of the conspiracy for Jessica Baker to allow Tremel Rosario, a/k/a ?Skinny,?
to sell cocaine out of her residence, located at 9 Harrison Avenue in South Glens Falls, New York
(Saratoga County), and to assist Tremel Rosario, a/k/a ?Skinny,? with his cocaine sales.

It was also part of the conspiracy for Tara Brown to sell cocaine out of the residence of
James Duprey, located at 17 Windsong Drive in Queensbury, New York (Warren County).

It was also part of the conspiracy for Colleen Connolly, a/k/a Colleen Syman, to sell cocaine
to Edward Lee, a/k/a ?Eddie,? which Lee would re-sell in Saratoga and Warren Counties.

It was also part of the conspiracy for Angela Cox to buy cocaine from Jamel Miller, which.
Cox would then re-sell in the Capital Region of New York State.

It was also part of the conspiracy for Rashaun Creel, a/k/a ?Broadway,? to sell cocaine and
heroin in Albany and Schenectady Counties.

It was also part of the conspiracy for Rashaun Creel, a/k/a ?Broadway,? to obtain cocaine
from Tremel Rosario, a/k/a ?Skinny,? which Creel would then re-sell in the Capital Region of New

York State.

It was also part of the conspiracy for James Duprey to sell cocaine and to allow individuals,
including Tara Brown and Jamel Pearson, II, a/k/a ?James,? to stay at and sell cocaine out of his
residence, located at 17 Windsong Drive, Queensbury, New York (Warren County).

It was also a part of the conspiracy for Shane Frasier to purchase cocaine from Tremel
Rosario, a/k/a ?Skinny,? which Frasier would then re-sell in Saratoga and Warren Counties.

It was also a part of the conspiracy for Vanessa French to obtain cocaine from Tremel
Rosario, a/k/a ?Skinny,? which French would then re-sell in Warren County.

It was also part of the conspiracy for Vanessa Graham to sell cocaine to Edward Lee a/k/a
?Eddie,? which Lee wOuld then re?sell in Saratoga and Warren Counties.

It was also part of the conspiracy for Melvina Grovenburg, a/k/a ?Mel,? to obtain cocaine
from Tremel Rosario a/k/a ?Skinny,? Edward Lee, a/k/a ?Eddie,? and Matthew Malu, a/k/a a/k/a
?Capo,? which Grovenburg would then re-sell in Saratoga and Warren Counties.

It was also part of the conspiracy for Melvina Grovenburg, a/k/a ?Mel,? to sell Hydrocodone
pills to Vanessa Graham in Saratoga County, and, in exchange, receive cocaine to sell to others from
Graham.

It was also part of the conspiracy for Steven Lathrop to obtain cocaine from Tremel Rosario
a/k/a ?Skinny,? which Lathrop would then re-sell in Washington County.

It was also part of the conspiracy for Donald Layman to purchase cocaine from Tremel
Rosario, a/k/a ?Skinny,? which Layman would then re-sell in Warren County.

It was also part of the conspiracy for Donald Layman to allow Matthew Malu, a/k/a a/k/a
?Capo,? and Jamel Pearson, II, a/k/a ?James,? and Tremel Rosario, a/k/a ?Skinny,? to sell cocaine

out of his residence, located at 14 Madison Street, Glens Falls, New York (Warren County).

It was also part of the conspiracy for Edward Lee, a/k/a ?Eddie,? to purchase cocaine from
Tremel Rosario, a/k/a ?Skinny,? Mana Sambole, a/k/a ?Mana Sambola,? a/k/a ?Mike,? Kimberly
Schwart?gure and Colleen Connolly, a/k/a Colleen Syman, which Lee would then re-sell in Albany,
Saratoga and Warren Counties.

It was also part of the conspiracy for Matthew Malu, a/k/a a/k/a ?Capo,? to sell cocaine
with Tremel Rosario, a/k/a ?Skinny,? in Albany, Saratoga and Warren Counties.

It was also part of the conspiracy for Matthew Malu, a/k/a a/k/a ?Capo,? to sell cocaine
with Jamel Pearson, II, a/k/a ?James,? in Warren County.

It was also part of the conspiracy for Jamel Miller to obtain cocaine from Tremel Rosario,
a/k/a ?Skinny,? which Miller would then re-sell in Schenectady County.

It was also part of the conspiracy for Jamel Miller to obtain cocaine from Tremel Rosario,
a/k/a ?Skinny,? and Hardley Pierre, which Miller would then re-sell in Schenectady County.

It was also part of the conspiracy for Elizabeth Monahan, a/k/a ?Beth,? to purchase cocaine
from Tremel Rosario, a/k/a ?Skinny,? which Monahan would then re-sell in Albany County.

Is was also part of the conspiracy for Jessica Nichols to obtain cocaine from Tremel Rosario,
a/k/a ?Skinny,? which Nichols would then re-sell in Saratoga County.

It is also part of the conspiracy for Patrick O?Keefe to obtain cocaine from Tremel Rosario,
a/k/a ?Skinny,? and Matthew Malu, a/k/a a/k/a ?Capo,? which O?Keefe would then re-sell in
Warren County.

It was also part of the conspiracy for Renee Passino to sell cocaine to Edward Lee, a/k/a

?Eddie,? which Lee would then re-sell in Saratoga and Warren Counties.

It was also part of the conspiracy for Jamel Pearson, II, a/k/a ?James,? to sell cocaine out of
the residence of James Duprey, located at 17 Windsong Drive, Queensbury, New York (Warren
County). I

It was also part of the conspiracy for Brenda Perry to assist Edward Lee, a/k/a ?Eddie,? with
his cocaine sales in Warren County.

It was also part of the conspiracy for Hardley Pierre to supply cocaine to Jamel Miller, which
Miller would then re-sell in Schenectady County.

It was also part of the conspiracy for Hardley Pierre to obtain cocaine from Tremel Rosario,
a/k/a ?Skinny,? which Pierre would then re-sell in Schenectady County.

It was also part of the conspiracy for Tara Reid to obtain cocaine from Mark Tai, a/k/a
?Juan,? which Reid wOuld then re-sell in Schenectady County.

It was also part of the conspiracy for Tara Reid to assist Tremel Rosario, a/k/a ?Skinny,? with
the sale of cocaine to Shane Frasier.

It was also part of the conspiracy for Tremel Rosario, a/k/a ?Skinny,? to sell cocaine to
Jessica Baker, Rashaun Creel, a/k/ a ?Broadway,? Shane Frasier, Vanessa French, Melvina
Grovenburg, a/k/a ?Mel,? Steven Lathrop, Donald Layman, Edward Lee, a/k/a ?Eddie,? Jamel
Miller, Elizabeth Monahan, a/k/a ?Beth,? Jessica Nichols, Patrick O?Keefe, Hardley Pierre, Mark
Tai, a/k/a ?Juan,? and others. I

It was also part of the conspiracy for Tremel Rosario, a/k/a ?Skinny,? to sell cocaine in
Albany, Saratoga and/or Warren Counties with the assistance of Edward Lee, a/k/a ?Eddie,? Mark
Tai, a/k/a ?Juan,? and Matthew Malu, a/k/a a/k/a ?Capo.?

It was also part of the conspiracy for Laura Russo to obtain cocaine from Jamel Miller, which

Russo would then re-sell in Schenectady County.

It was also part of the conspiracy for Mana Sambole, a/k/a ?Mana Sarnbola,? a/k/ a ?Mike,? to
sell cocaine to Edward Lee, a/k/a ?Eddie,? which Lee would then re-sell in Warren and Saratoga
Counties.

It was also part of the conspiracy for Kimberly Schwart?gure to sell cocaine to Edward Lee,
a/k/a ?Eddie,? which Lee would then re-sell in Warren and Saratoga Counties.

It was also part of the conspiracy for Mark Tai, a/k/a ?Juan,? to obtain cocaine from Tremel
Rosario, a/k/a ?Skinny,? which Tai would then re-sell to Vanessa French, Tara Reid, Eddie Lee,
Nick Torchetti, and others in Schenectady, Warren and Saratoga Counties.

It was also part of the conspiracy for Nicholas Torchetti to purchase cocaine from Mark Tai,

a/k/a ?Juan,? which Torchetti would then re-sell in Warran and Saratoga Counties.

OVERT ACTS

In furtherance of the conspiracy, and to effect the obj ects thereof, from on or before August
3, 2017, until on or about September 5, 2018, the following overt acts, among others, were
comr'nitted:

1. On or about August 3, 2017, RASHAUN CREEL, sold
approximately 50 grams of heroin to a person known to the Grand Jury.

2. On or about January 20, 2018, RASHAUN CREEL, sold
approximately 75 grams of heroin to a person know to the Grand Jury.

3. On or about February 18, 2018, in a series of coded, guarded and telephone
conversations, TREMEL ROSARIO, agreed to sell approximately 50 grams of
cocaine to RASHAUN CREEL, 

4. On or about February 18, 2018, in a series of coded, guarded and telephone

conversations, AMEL MILLER arranged to meet RASHAUN CREEL, in

the City of Schenectady in order to obtain cocaine to re-sell from CREEL.

5. On or about March 16, 2018, in a series of coded, guarded and telephone
communications, JAMEL MILLER offered to sell one-eighth ounce of cocaine, which MILLER
referred to as ?Ball,? to ANGELA COX, and then made arrangements to meet COX in the City of
Schenectady to complete the transaction.

6. On or about March 16, 2018, in a series of coded, guarded and telephone
conversations, LAURA RUS SO arranged to purchase one-eighth ounce of cocaine, which RUSSO
referred to as ?a bizzy,? from JAMEL MILLER to re-sell to another person.

7. On or about March 26, 2018, in a series of coded, guarded and telephone
conversations, ANGELA COX arranged to purchase one-eighth ounce of cocaine, which COX 
referred to as a ?whole one,? from JAMEL MILLER to re-sell to another person.

8. On or about May 5, 2018, in a series of coded, guarded and telephone
conversations, KIMBERLY SCHWARTFIGURE agreed to sell cocaine to EDWARD LEE, 


9. On or about May 5, 2018, in a series of coded, guarded and telephone
conversations, KIMBERLY SCHWARTFIGURE agreed to sell cocaine to EDWARD LEE, 
for a second time that day.

10. On or about May 5, 2018, in a series of coded, guarded and telephone
conversations, EDWARD LEE, arranged to purchase cocaine from COLLEEN
CONNOLLY, COLLEEN SYMAN, to re-sell to another person.

11. On or about May 7, 2018, in a series of coded, guarded and telephone
conversations, RENEE PASSINO agreed to sell cocaine to EDWARD LEE, 

12. On or about May 7, 2018, in a series of coded, guarded and telephone

conversations with EDWARD LEE NICHOLAS TORCHETTI ordered ?a buck
and a half,? referring to a quantity of cocaine, from LEE, and LEE agreed to the sale.

13. On or about May 9, 2018, in a series of coded, guarded and telephone
conversations, BRENDA PERRY and EDWARD LEE, arranged to sell cocaine to
another person.

14. On or about May 9, 2018, in a series of coded, guarded and telephone
conversations, COLLEEN CONNOLLY, COLLEEN SYMAN, and EDWARD LEE, 
arranged to sell cocaine to another person.

15 . On or about May 1 1, 2018, VANESSA FRENCH, in a series of coded, guarded and
telephone conversations with TREMEL ROSARIO, a/k/ a MATTHEW MALU,
and EDWARD LEE, arranged to purchase more
cocaine to re-sell.

16. On or about May 11, 2018, PATRICK E, in a series of coded, guarded and
telephone communications with TREMEL ROSARIO, and MATTHEW
MALU, arranged to purchase cocaine to re-sell to another person.

17. On or about May 11, 2018, MANA SAMBOLA, 
sold cocaine to a person known to the Grand Jury.

18. On or about May 12, 2018, in a series of coded, guarded and telephone
communications, PATRICK arranged to purchase one-eighth ounce of cocaine, which
referred to as ?a game of pool 8 from TREMEL ROSARIO, 
to re-sell to another person.

19. On or about May 12, 2018, in a series of coded, guarded and telephone

conversations, BRENDA PERRY and EDWARD LEE, arranged to sell cocaine to

another person.

20. On or about May 14, 2018, in a series of coded, guarded and telephone
communications, MELVINA GROVENBURGH, arranged to purchase one-eighth
ounce of cocaine, which GROVENBURGH referred to as ?a game,? to re?sell from TREMEL
ROSARIO, 

21. On or about May 14, 2018, in a series of coded, guarded and telephone
conversations, NICHOLAS TORCHETTI arranged to purchase cocaine from TREMEL ROSARIO,
to re-sell to another person.

22. On or about May 15, 2018, in a series of coded, guarded and telephone
conversations, TARA REID and TREMEL ROSARIO, working together,
arranged to sell cocaine to SHANE FRASIER.

23. On or about May 15, 2018, in a series of coded, guarded and telephone
conversations, RENEE PASSINO agreed to sell cocaine to EDWARD LEE, 

24. On or about May 15, 2018, in a series of coded, guarded and telephone
conversations, SHANE FRAISER purchased $100-worth of cocaine, which FRAISER referred to as
?a buck,? from TREMEL ROSARIO, a/k/a to re-sell to another person.

25. On or about May 15, 2018, in a series of coded, guarded and telephone
communications, JESSICA NICHOLS arranged to purchase cocaine from TREMEL ROSARIO,
to re-sell to another person.

26. On or about May 16, 2018, in a series of coded, guarded and telephone
conversations, TREMEL ROSARIO, agreed to provide JESSICA NICHOLS
with cocaine to re-sell, but noted that he needed time to prepare the cocaine, stating, gotta cook, I

gotta put it together.?

10

27. On or about May 16, 2018, in a series of coded, guarded and telephone
conversations, SHANE FRAIZER arranged to purchase cocaine from TREMEL ROSARIO, 
to re-sell to another person.

28. On or about May 19, 2018, in a series of coded, guarded and telephone
conversations, STEVEN LATHROP arranged to purchase cocaine from TREMEL ROSARIO,
to re-sell to another person.

29. On or about May 20, 2018, in a series of coded, guarded and telephone
conversations, EDWARD LEE, arranged to purchase cocaine to re-sell from
MATTHEW MALU, 

30. On or about May 20, 2018, in a series of coded, guarded and telephone
communications, JESSICA BAKER arranged to obtain cocaine to re-sell from TREMEL
ROSARIO, a/k/a 

31. On or about May 21, 2018, MANA SAMBOLA, 
possessed more than one-half ounce of cocaine and drug paraphernalia.

32. On or about May 22, 2018, in a coded, guarded and telephone conversation,
STEVEN LATHROP agreed to sell cocaine for TREMEL ROSARIO, a/k/a 
LATHROP told ROSARIO that he could sell both ?soft serve and hard ice cream,? referring to
powder and crack cocaine, respectively, and offered to manufacture crack cocaine for ROSARIO,
referring to himself as ?Chef-boy-R-dee.?

33. On or about May 27, 2018, in a series of coded, guarded and telephone
conversations, VANESSA GRAHAM agreed to sell cocaine to MELVINA GROVENBURGH,
and GROVENBURGH, agreed to sell Hydrocodone to VANESSA

GRAHAM.

11

34. On or about May 30, 2018, in a series of coded, guarded and telephone
conversations, VAN ES SA GRAHAM agreed to sell cocaine to EDWARD LEE, 

35. On or about June 9, 2018, in a series of coded, guarded and telephone
conversations, MARK TAI, agreed to sell cocaine to an unknown female.

36. On or about June 1 1, 2018, in a coded, guarded and telephone conversation,
TREMEL ROSARIO, a/k/a offered to sell one-eighth ounce of cocaine, which
ROSARIO referred to as a ?ball,? to ROBERT ALLEN for $200, and ALLEN indicated he would
buy the narcotics after he obtained money from a third party.

37. On or about June 14, 2018, in a series of coded, guarded and telephone
conversations, ROBERT ALLEN arranged to purchase cocaine to re?sell from TREMEL ROSARIO,
a/k/a 

38. On or about, June 15, 2018, in a series of coded, guarded and telephone
communications, ELIZABETH MONAHAN, arranged to purchase an ounce of
cocaine from TREMEL ROSARIO, a/k/a to sell to others, and ROSARIO assured
MONAHAN the cocaine was ?grade A shit?.

39. On or about June 18, 2018, DONALD LYMAN sold cocaine out of his residence,
located at 14 Madison Avenue, Apt Glens Falls, New York, along with MATTHEW MALU,
and JAMEL PEARSON, II, 

40. On or about June 19, 2018, in a series of coded, guarded and telephone
conversations, DONALD LAYMAN told TREMEL ROSARIO, a/k/a in sum and
substance, that he had customers lined up and needed ROSARIO to supply him with cocaine to sell,
and ROSARIO responded, got you.?

41. On or about June 19, 2018, in a coded, guarded and telephone conversations,

12

ELIZABETH MONAHAN, agreed to sell cocaine for TREMEL ROSARIO,
on the understanding that she would be paid $100 for every $200 worth of
cocaine that she sold.

42. On or about June19, 2018, MARK TAI, sold cocaine to NICHOLAS
TORCHETTI.

43. On or about June 21, 2018, in a series of coded, guarded and telephone
communications, VANESSA FRENCH ordered three grams of cocaine from MARK TAI, 
and TAI agreed to sell it to her for $250.00.

44. On or about and between June 21, 2018, and June 22,2018, in a series of coded,
guarded and telephone communications, TARA REID arranged to purchase one-eighth ounce
of cocaine, which REID referredto as a ?ball,? from MARK TAI, to re-sell to
another person.

'45. On or about June 25, 2018, TREMEL ROSARIO, possessed
more than one-eighth ounce of cocaine and assorted drug paraphernalia.

46. During the time period of July 3, 2018, through July 12, 2018, JAMES DUPREY
allowed several individuals to sell cocaine out of this residence, located at 17 WindsongDrive,
Queensbury, New York, in exchange for money and free cocaine.

47. On or about July 3, 2018, AMEL PEARSON, II, sold cocaine to a
person known to the Grand Jury.

48. On or about July 12, 2018, JAMEL PEARSON, II, possessed more
than one-eighth ounce of cocaine.

49. On or about July 12, 2018, TARA BROWN sold cocaine to a person knowto the

Grand Jury.

13

50. On or about July 12, 2018, JAMES DUPREY sold cocaine to a person know to the
Grand Jury.

COUNT 2

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, RASHAUN CREEL, of the crime of
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:

That the said defendant, RASHAUN CREEL, in the County of
Schenectady, State of New York, on or about August 3 2017, did knowingly and unlawfully sell one
or more preparations, compounds, mixtures or substances containing the narcotic drug heroin and
the preparations, compounds, mixtures or substances were of an aggregate weight of one-half ounce
or more.

COUNT 3

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, RASHAUN CREEL, of the crime of
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:

That the said defendant, RASHAUN CREEL, in the County of
Schenectady, State of New York, on or about November 21, 2017, did knowingly and unlawfully
sell one or more preparations, compounds, mixtures or substances containing the narcotic drug
heroin and the preparations, compounds, mixtures of substances were of an aggregate weight of one-

half ounce or more.
COUNT 4
THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

accuses the above-named defendant, RASHAUN CREEL, of the crime of
CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of

14

Section 220.43 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, RASHAUN CREEL, in the County of
Schenectady, State of New York, on or about January 20, 2018, did knowingly and unlawfully sell
one or more preparations, compounds, mixtures or substances containing the narcotic drug heroin
and the preparations, compounds, mixtures or substances were of an aggregate weight of two ounces

or more.
COUNT 5

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, TREMEL ROSARIO, of the crime of
CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE SECOND violation
of Section 220.41 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, TREMEL ROSARIO, in the County of
Schenectady, State of New York, on or about February 18, 2018, did knowingly and unlawfully sell
one or more preparations, compounds, mixtures or substances containing the narcotic drug cocaine
and the preparations, compounds, mixtures or substances were of an aggregate weight of one-half

ounce or more.
COUNT 6

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, of the crime of
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
violation of Section 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed
as follows:

That the said defendant, TREMEL ROSARIO, in the County of
Schenectady, State of New York, on or about February 18, 2018, did knowingly and unlawfully

possess the narcotic drug cocaine with the intent to sell it.

15

COUNT 7

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the aboye-named defendant, TREMEL ROSARIO, of the crime of
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
Violation of Section 220.16 (Subdivision 12) of the Penal Law of the State of New York, committed
as follows:

That the said defendant, TREMEL ROSARIO, in the County of
Schenectady, State of New York, on or about February 18, 2018, did knowingly and unlawfully
possess one or more preparations, compounds, mixtures or substances containing the narcotic drug
cocaine and said preparations, compounds, mixtures or substances were of an aggregate weight of

one-half ounce or more.
COUNT 8

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, RASHAUN CREEL, of the crime of
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:

That the said defendant, RASHAUN CREEL, in the County of
Schenectady, State of New York, on or about February 18, 2018, did knowingly and unlawfully sell
one or more preparations, compounds, mixtures or substances containing the narcotic drug cocaine
and the preparations, compounds, mixtures or substances were of an aggregate weight of one-half

ounce or more.
COUNT 9
THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

accuses the above-named defendant, RASHAUN CREEL, of the crime of
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in

16

violation of Section 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed
as follows:

That the said defendant, RASHAUN CREEL, in the County of
Schenectady, State of New York, on or about February 18, 2018, did knowingly and unlawfully

possess the narcotic drug cocaine with the intent to sell it.
COUNT 10

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, RASHAUN CREEL, of the crime of
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
violation of Section 220.16 (Subdivision 12) of the Penal Law of the State of New York, committed
as follows:

That the said defendant, RASHAUN CREEL, in the County of
Schenectady, State of New York, on or about February 18, 2018, did knowingly and unlawfully
possess one or more preparations, compounds, mixtures or substances containing the narcotic drug
cocaine and said preparations, compounds, mixtures or substances were of an aggregate weight of

one-half ounce or more.
COUNT 11

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, JAMEL MILLER, of the crime of CRIMINAL POSSESSION
OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16
(Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, JAMEL MILLER, in the County of Schenectady, State of New
York, on or about February 18,2018, did knowingly and unlawfully possess the narcotic drug

cocaine with the intent to sell it.

17

 

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the abOVe-named defendant, JAMEL MILLER, of the crime of CRIMINAL POSSESSION
OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16
(Subdivision 12) of the Penal Law of the State of New York, committed as follows:

That the said defendant, JAMEL MILLER, in the County of Schenectady, State of New
York, on or about February 18, 2018, did knowingly and unlawfully possess one or more
preparations, compounds, mixtures or substances containing the narcotic drug cocaine and said
preparations, compounds, mixtures or substances were of an aggregate weight of one-half ounce or

more.
COUNT 13

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, HARDLEY PIERRE, 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, HARDLEY PIERRE, in the County of Schenectady, State of New
York, on or about March 16, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 14

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, JAMEL MILLER, 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, JAMEL MILLER, in the County of Schenectady, State of New
York, on or about March 16, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

18

COUNT 15

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, ANGELA COX, of the crime of ATTEMPTED CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of
Sections 1 10.00 and 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed
as follows:

That the said defendant, ANGELA COX, in the County of Schenectady, State of New York,
on or about March 16, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it.
COUNT 16

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, ANGELA COX, of the crime of ATTEMPTED CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE FOURTH DEGREE, in violation of
Sections 1 10.00 and 220.09 (Subdivision 12) of the Penal Law of the State of New York, committed
as follows:

That the said defendant, ANGELA COX, in the County of Schenectady, State of New York,
on or about March 16, 2018, did knowingly and unlawfully attempt to possess one or more
preparations, compounds, mixtures or substances containing the narcotic drug cocaine and said
preparations, compounds, mixtures or substances were of an aggregate weight of one-eighth ounce

or more.
COUNT 17

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, HARDLEY PIERRE, 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, HARDLEY PIERRE, in the County of Schenectady, State of New

19

York, on or about March 16, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.
COUNT 18

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, JAMEL MILLER, 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, JAMEL MILLER, in the County of Schenectady, State of New
York, on or about March 16, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 19

THE GRAND JURY OF THE COUNTY OF this Indictment, further
accuses the above-named defendant, LAURA RUSSO, 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, LAURA RUSSO, in the County of Schenectady, State of New York,
on or about March 16, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it.
COUNT 20

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, LAURA RUS SO, of the crime of ATTEMPTED CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE FOURTH DEGREE, in violation of
Sections 1 10.00 and 220.09 (Subdivision 12) of the Penal Law of the State of New York, committed
as follows:

That the said defendant, LAURA RUSSO, in the County of Schenectady, State of New York,
on or about March 16, 2018, did knowingly and unlawfully attempt to possess one or more

20

preparations, compounds, mixtures or substances containing the narcotic drug cocaine and said
preparations, compounds, mixtures or substances were of an aggregate weight of one-eighth ounce

or more.
COUNT 21

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, JAMEL MILLER, 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, JAMEL MILLER, in the County of Schenectady, State of New
York, on or about March 22, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 22

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, JAMEL MILLER, 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, JAMEL MILLER, in the County of Schenectady, State of New
York, on or about March 23, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 23

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, JAMEL MILLER, 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, JAMEL MILLER, in the County of Schenectady, State of New
York, on or about March 24, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

21

COUNT 24

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, HARDLEY PIERRE, 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, HARDLEY PIERRE, in the County of Schenectady, State of New
York, on or about March 26, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 25

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, JAMEL MILLER, 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, JAMEL MILLER, in the County of Schenectady, State of New
York, on or about March 26, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 26

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, ANGELA COX, 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: I 

That the said defendant, ANGELA COX, in the County of Schenectady, State of New York,
on or about March 26, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it.

22

COUNT 27

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, ANGELA COX, of the crime of ATTEMPTED CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE FOURTH DEGREE, in violation of
Sections 1 10.00 and 220.09 (Subdivision 12) of the Penal Law of the State of New York, committed
as follows: i

That the said defendant, ANGELA COX, in the County of Schenectady, State of New York,
on or about March 26, 2018, did knowingly and unlawfully attempt to possess one or more
preparations, compounds, mixtures or substances containing the narcotic drug cocaine and said
preparations, compounds, mixtures or substances were of an aggregate weight of one-eighth ounce

or more.
COUNT 28

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, TREMEL ROSARIO, of the crime of
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
violation of Section 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed
as follows:

That the said defendant, TREMEL ROSARIO, in the County of Albany,
State of New York, on or about April 17, 2018, did knowingly and unlawfully possess the narcotic

drug cocaine with the intent to sell it.
COUNT 29

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, of the crime of
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in

violation of Section 220.16 (Subdivision 12) of the Penal Law of the State of New York, committed

as follows:

23

That the said defendant, TREMEL ROSARIO, in the County of Albany,
State of New York, on or about April 17, 2018, did knowingly and unlawfully possess one or more
preparations, compounds, mixtures or substances containing the narcotic drug cocaine and said
preparations, compounds, mixtures or substances were of an aggregate weight of one?half ounce or

more.
COUNT 30

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the. County of Albany,
State of New York, on or about April 1 7, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 31

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, MATTHEW MALU, 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, MATTHEW MALU, in the County of
Albany, State of New York, on or about April 17, 2018, did knowingly and unlawfully attempt to

possess the narcotic drug cocaine with the intent to sell it.


THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MATTHEW MALU, of the crime

24

of ATTEMPTED CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE
FOURTH DEGREE, in Violation of Sections 1 10.00 and 220.09 (Subdivision 12) of the Penal Law
of the State of New York, committed as follows:

That the said defendant, MATTHEW MALU, in the County of
Albany, State of New York, on or about April 17, 2018, did knowingly and unlawfully attempt
possess one or more preparations, compounds, mixtures or substances containing the narcotic drug
cocaine and said preparations, compounds, mixtures or substances were of an aggregate weight of

one-eighth ounce or more.
COUNT 33

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Warren,
State of New York, on or about April 19, 2018, did knowingly and unlawfully sell the narcotic drug
cocame.

COUNT 34

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, of the crime of CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of
Section 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, EDWARD LEE, in the County of Warren, State
of New York, on or about April 19, 2018, did knowingly and unlawfully possess the narcotic drug

cocaine with the intent to sell it.

25

COUNT 3 5

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Warren,
State of New York, on or about April 19, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 36

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, 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: i

That the said defendant, EDWARD LEE, in the County of Warren, State
of New York, on or about April 19, 2018, did knowingly and unlawfully attempt to possess the

narcotic drug cocaine with the intent to Sell it.
COUNT 37

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of
Saratoga, State of New York, on or about April 19, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.

26

COUNT 38

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendants, TREMEL ROSARIO, and MATTHEW
MALU, of the crime of CRIMINAL POSSESSION OF A
CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16
(Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendants, TREMEL ROSARIO, and MATTHEW
MALU, in the County of Albany, State of New York, on or about April
20, 2018, did knowingly and unlawfully possess the narcotic drug cocaine with the intent to sell it.

COUNT 39

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendants, TREMEL ROSARIO, and MATTHEW
MALU, of the crime of CRIMINAL POSSESSION OF A
CONTROLLED SUBSTANCE IN THE FOURTH DEGREE, in violation of Section and 220.09
(Subdivision 12) of the Penal Law of the State of New York, committed as follows:

That the said defendants, TREMEL ROSARIO, and MATTHEW
MALU, in the County of Albany, State of New York, on or about April
20, 2018, did knowingly and unlawfully possess one or more preparations, compounds, mixtures or
substances containing the narcotic drug cocaine and said preparations, compounds, mixtures or

substances were of an aggregate weight of one-eighth ounce or more.
COUNT 40

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendants, TREMEL ROSARIO, and MATTHEW
MALU, 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:

27

That the said defendants, TREMEL ROSARIO, and
MATTHEW MALU, in the County of Warren, State of New York, on
or about May 11, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 41

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, PATRICK of the crime of CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of
Section 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, PATRICK in the County of Warren, State of New York,
on or about May 1 1, 2018, did knowingly and unlawfully possess the narcotic drug cocaine with the

intent to sell it.


THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Albany,
State of New York, on or about May 1 1, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 43

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendants, TREMEL ROSARIO, MATTHEW
MALU, AND EDWARD LEE, 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:

28

That the said defendants, TREMEL ROSARIO, MATTHEW MALU,
AND EDWARD LEE, in the County of Warren,
State of New York, on or about May 11, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 44

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, VANESSA FRENCH, of the crime of ATTEMPTED
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
violation of Sections 1 10.00 and 220.16 (Subdivision 1) of the Penal Law of the State of New York,
committed as follows:

That the said defendant, VANESSA FRENCH, in the County of Warren, State of New York,
on or about May 11, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it.
COUNT 45

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Albany,
State of New York, on or about May 12, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 46

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, EDWARD LEE, of the crime of CRIMINAL

29

POSSESSION OF A CONTROLLED SUBSTANCE THE THIRD DEGREE, in violation of
Section 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, EDWARD LEE, in the County of Albany, State of
New York, on or about May 12, 2018, did knowingly and unlawfully possess the narcotic drug

cocaine with the intent to sell it.
COUNT 47

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Warren,
State of New York, on or about May 12, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 48

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, PATRICK of the crime of ATTEMPTED
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
violation of Sections 1 10.00 and 220.16 (Subdivision 1) of the Penal Law of the State of New York,
committed as follows:

That the said defendant, PATRICK in the County of Warren, State of New York,
on or about May 12, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it.
COUNT 49

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, PATRICK of the crime of ATTEMPTED

30

CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FOURTH DEGREE, in
violation of Sections 110.00 and 220.09 (Subdivision 12) of the Penal Law of the State of New
York, committed as follows:

That the said defendant, PATRICK in the County of Warren, State of New York,
on or about May 12, 2018, did knowingly and unlawfully attempt to possess one or more
preparations, compounds, mixtures or substances containing the narcotic drug cocaine and said

preparations, compounds, mixtures or substances were of an aggregate weight of one-eighth ounce

01' more.
COUNTSO

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of
Saratoga, State of New York, on or about May 14, 2018, did knowingly and unlawfully sell-the

narcotic drug cocaine.

COUNT 51

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, NICHOLAS TORCHETTI, of the crime of CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of
Section 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, NICHOLAS TORCHETTI, in the County of Saratoga, State of New
York, on or about May 14, 2018, did knowingly and unlawfully possess the narcotic drug cocaine

with the intent to sell it.

31

COUNT 52

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Warren,
State of New York, on or about May 14, 2018, did knowingly and unlawfully sell the narcotic drug

. cocaine.
COUNT 53

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further.
accuses the above-named defendant, MELVINA GROVENBURG, 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, MELVINA GROVENBURG, in the County of I
Warren, State of New York, on or about May 14, 2018, did knowingly and unlawfully attempt to

possess the narcotic drug cocaine with the intent to sell it.
COUNT 54

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MELVINA GROVENBURG, of the crime of
ATTEMPTED CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE
FOURTH DEGREE, in Violation of Sections 1 10.00 and 220.09 (Subdivision 12) of the Penal Law
of the State of New York, committed as follows:

That the said defendant, MELVINA GROVENBURG, in the County of
Warren, State of New York, on or about May 14, 2018, did knowingly and unlawfully attempt to

possess one or more preparations, compounds, mixtures or substances containing the narcotic drug

32

cocaine and said preparations, compounds, mixtures or substances were of an aggregate weight of

one-eighth ounce or more.
COUNT 55

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of
Saratoga, State of New York, on or about May 14, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.
COUNT 56

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, of the crime of CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of
Section 220. 1 6 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, EDWARD LEE, in the County of Saratoga, State
of New York, on or about May 14, 2018, did knowingly and unlawfully possess the narcotic drug

cocaine with the intent to sell it.
COUNT 57

THE GRAND JURY OF THE COUNTY OF this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of I
Saratoga, State of New York, on or about May 15, 2018, did knowingly and unlawfully sell the

33

narcotic drug cocaine.
COUNT 58

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Warren,
State of New York, on or about May 15, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 59

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, NICHOLAS TORCHETTI, of the crime of ATTEMPTED
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
violation of Sections 1 10.00 and 220.16 (Subdivision 1) of the Penal Law of the State of New York,
committed as follows:

That the said defendant, NICHOLAS TORCHETTI, in the County of Warren, State of New
York, on or about May 15, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it.
COUNT 60

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of
Saratoga, State of New York, on or about May 15, 2018, did knowingly and unlawfully sell the

34

narcotic drug cocaine.
COUNT 61

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, of the crime of CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of
Section 220.16 (Subdivision 1) of the Pen-a1 Law of the State of New York, committed as follows:

That the said defendant, EDWARD LEE, in the County of Saratoga, State
of New York, on or about May 15, 2018, did knowingly and unlawfully possess the narcotic drug

cocaine with the intent to sell it.


THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of
Saratoga, State of New York, on or about May 15, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.
COUNT 63

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, 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, EDWARD LEE, in the County of Saratoga, State
of New York, on or about May 15, 2018, did knowingly and unlawfully attempt to possess the

35

narcotic drug cocaine with the intent to sell it.
COUNT 64

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of
Saratoga, State of New York, on or about May 15, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.
COUNT 65

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, JESSICA NICHOLS, of the crime of ATTEMPTED
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
violation of Sections 1 10.00 and 220.16 (Subdivision 1) of the Penal Law of the State of New York,
committed as follows:

That the said defendant, JESSICA NICHOLS, in the County of Saratoga, State of New York,
on or about May 15, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it.
COUNT 66

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of
Saratoga, State of New York, on or about May 15, 2018, did knowingly and unlawfully sell the

36

narcotic drug cocaine.
COUNT 67

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, NICHOLAS TORCHETTI, of the crime of ATTEMPTED
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
Violation of Sections 1 10.00 and 220.16 (Subdivision 1) of the Penal Law of the State of New York,
committed as follows:

That the said defendant, NICHOLAS TORCHETTI, in the County of Saratoga, State of New
York, on or about May 15, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it.
COUNT 68

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendants, TREMEL ROSARIO, and TARA REID,
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, TREMEL ROSARIO, and TARA REID, in the
County of Warren, State of New York, on or about May 15, 2018, did knowingly and unlawfully sell

the narcotic drug cocaine.
COUNT 69

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of

37

Saratoga, State of Neerork, on or about May 15, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.
COUNT 70

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further 
accuses the above-named defendant, SHANE FRAISER, of the crime of CRIMINAL POSSESSION
OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16
(Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, SHANE FRAISER, in the County of Saratoga, State of New York,
on or about May 15, 2018, did knowingly and unlawfully possess the narcotic drug cocaine with the

intent to sell it.
COUNT 71

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, TREMEL 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, TREMEL ROSARIO, in the County of
Saratoga, State of New York, on or about May 15, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.



THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, SHANE FRAISER, of the crime of CRIMINAL POSSESSION
OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16
(Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, SHANE FRAISER, in the County of Saratoga, State of New York,

38

on or about May 15, 2018, did knowingly and unlawfully possess the narcotic drug cocaine with the

intent to sell it.
COUNT 73

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMELROSARIO, 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, TREMEL ROSARIO, in the County of
Saratoga, State of New York, on or about May 15, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.
COUNT 74

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, SHANE FRAISER, 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, SHANE FRAISER, in the County of Saratoga, State of New York,
on or about May 15, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it.
COUNT 75

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of

39

Saratoga, State of New York, on or about May 15, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.
COUNT 76

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, JESSICA NICHOLS, of the crime of ATTEMPTED
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
violation of Sections 1 10.00 and 220.16 (Subdivision 1) of the Penal Law of the State of New York,
committed as follows:

That the said defendant, JESSICA NICHOLS, in the County of Saratoga, State of New York,
on or about May 15, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it.
COUNT 77

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of
Saratoga, State of New York, on or about May 16, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.
COUNT 78

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, JESSICA NICHOLS, 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:

40

That the said defendant, JESSICA NICHOLS, in the County of Saratoga, State of New York,
on or about May 16, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it.
COUNT 79

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, of the crime of
CRIMINAL SALE OF A CONTROLLED SUBSTANCE 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, TREMEL ROSARIO, in the County of
Saratoga, State of New York, on or about May 16, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.
COUNT 80

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, SHANE FRAISER, of the crime of ATTEMPTED CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of
. Sections 1 10.00 and 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed
as follows: A

That the said defendant, SHANE FRAISER, in the County of Saratoga, State of New York,
on or about May 16, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it.

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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:

41

That the said defendant, TREMEL ROSARIO, in the County of
Saratoga, State of New York, on or about May 16, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.


THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Warren,
State of New York, on or about May 17, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 83

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, SHANE FRAISER, of the crime of CRIMINAL POSSESSION .
OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16
(Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, SHANE FRAISER, in the County of Warren, State of New York, on
or about May 17, 2018, did knowingly and unlawfully possess the narcotic drug cocaine with the

intent to sell it.
COUNT 84

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Albany,

42

State of New York, on or about May 17, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 85

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, SHANE FRAISER, of the crime of ATTEMPTED CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of
Sections 1 10.00 and 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed
as follows:

That the said defendant, SHANE FRAISER, in the County of Warren, State of New York, on
or about May 17, 2018, did knowingly and unlawfully attempt to possess the narcotic drug cocaine

with the intent to sell it.
COUNT 86

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Warren,
State of New York, on or about May 17, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine;
COUNT 87

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, of the crime of
ATTEMPTED CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD
DEGREE, in violation of Sections 1 10.00 and 220.16 (Subdivision 1) of the Penal Law of the State

of New York, committed as follows:

43

That the said defendant, EDWARD LEE, in the County of Warren, State
of New York, on or about May 17, 2018, did knowingly and unlawfully attempt to possess the

narcotic drug cocaine with the intent to sell it.
COUNT 88

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of
Washington, State of New York, on or about May 19, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.

COUNT 89

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, STEVEN LATHROP, of the crime of ATTEMPTED
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
violation of Sections 1 10.00 and 220.16 (Subdivision 1) of the Penal Law of the State of New York,
committed as follows:

That the said defendant, STEVEN LATHROP, in the County of Washington, State of New
York, on or about May 19, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it.
COUNT 90
THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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:

44

That the said defendant, TREMEL ROSARIO, in the County of Albany,
State of New York, on or about May 20, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.


THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, JESSICA BAKER, of the crime of CRIMINAL POSSESSION
OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16
(Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, JESSICA BAKER, in the County of Albany, State of New York, on
or about May 20, 2018, did knowingly and unlawfully possess the narcotic drug cocaine with the

intent to sell it.
ICOUNT92

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of
Saratoga, State of New York, on or about May 22, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.
COUNT 93

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, STEVEN LATHROP, 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:

45

That the said defendant, STEVEN LATHROP, in the County of Saratoga, State of New
York, on or about May 22, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it.
COUNT 94

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Albany,
State of New York, on or about June 9, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 95

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, of the crime of
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:

That the said defendant, TREMEL ROSARIO, in the County of Albany,
State of New York, on or about June 9, 2018, did knowingly and unlawfully sell one or more
preparations, compounds, mixtures or substances containing the narcotic drug cocaine and the
preparations, compounds, mixtures or substances were of an aggregate weight of one-half ounce or

more.
COUNT 96
THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

accuses the above-named defendant, TREMEL ROSARIO, of the crime of
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in

46

Violation of Section 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed
as follows:

That the said defendant, TREMEL ROSARIO, in the County of Albany,
State of New York, on or about June 9, 2018, did knowingly and unlawfully possess the narcotic

drug cocaine with the intent to sell it.
COUNT 97

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, TREMEL ROSARIO, of the crime of
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
Violation of Section 220.16 (Subdivision 12) of the Penal Law of the State of New York, committed
as follows: I

That the said defendant, TREMEL ROSARIO, in the County of Albany,
State of New York, on or about June 9, 2018, did knowingly and unlawfully possess one or more
preparations, compounds, mixtures or substances containing the narcotic drug cocaine and said
preparations, compounds, mixtures or substances were of an aggregate weight of one-half ounce or
more.

COUNT 98

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Albany,
State of New York, on or about June 1 l, 2018, did knowingly and unlawfully sell the narcotic drug
cocaine.

COUNT 99

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, of the crime of

47

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, TREMEL ROSARIO, in the County of
Saratoga, State of New York, on or about June 11, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.
COUNT 100

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, ROBERT ALLEN, 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, ROBERT ALLEN, in the County of Saratoga, State of New York,
on or about June 11, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it.
COUNT 101

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, ROBERT ALLEN, of the crime of ATTEMPTED CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE FOURTH DEGREE, in violation of
Sections 110.00 and 220.09 (Subdivision 12) of the Penal Law of the State of New York, committed
as follows:

That the said defendant, ROBERT ALLEN, in the County of Saratoga, State of New York,
on or about June 11, 2018, did knowingly and unlawfully attempt to possess one or more
preparations, compounds, mixtures or substances containing the narcotic drug cocaine and said
preparations, compounds, mixtures or substances were of an aggregate weight of one-eighth ounce

01? more .

48

COUNT 102

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Warren,
State of New York, on or about June 14, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 103

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, ROBERT ALLEN, 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, ROBERT ALLEN, in the County of Warren, State of New York, on
or about June 14, 2018, did knowingly and unlawfully attempt to possess the narcotic drug cocaine

with the intent to sell it.
COUNT 104

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, ROBERT ALLEN, of the crime of ATTEMPTED CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE FOURTH DEGREE, in violation of
Sections 1 10.00 and 220.09 (Subdivision 12) of the Penal Law of the State of New York, committed
as follows:

That the said defendant, ROBERT ALLEN, in the County of Warren, State of New York, on
or about June 14, 2018, did knowingly and unlawfully attempt to possess one or more preparations,

compounds, mixtures or substances containing the narcotic drug cocaine and said preparations,

49

compounds, mixtures or substances were of an aggregate weight of one-eighth ounce or more.
COUNT 105

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, of the crime of
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:

That the said defendant, TREMEL ROSARIO, in the County of Albany,
State of New York, on or about June 15, 2018, did knowingly and unlawfully sell one or more
preparations, compounds, mixtures or substances containing the narcotic drug cocaine and the
preparations, compounds, mixtures or substances were of an aggregate weight of one-half ounce Or

more.
COUNT106

THE GRAND JURY THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, ELIZABETH MONAHAN, a/k/a of the crime of
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
Violation of Section 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed
as follows: A 

That the said defendant, ELIZABETH MONAHAN, a/k/a in the County of Albany,
State of New York, on or about June 15, 2018, did knowingly and unlawfully possess the narcotic

drug cocaine with the intent to sell it.
COUNT 107
THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further

accuses the above-named defendant, ELIZABETH MONAHAN, a/k/a of the crime of
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in

50

violation of Section 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed
as follows:

That the said defendant, ELIZABETH MONAHAN, a/k/a in the County of Albany,
State of New York, on or about June 15, 2018, did knowingly and unlawfully possess one or more
preparations, compounds, mixtures or substances containing the narcotic drug cocaine and said
preparations, compounds, mixtures or substances were of an aggregate weight of one-half ounce or

more.
COUNT 108

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of
Saratoga, State of New York, on or about June 19, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.
COUNT 109

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment,
further accuses the above-named defendant, DONALD LAYMAN, of the crime of CRIMINAL
NUISAN CE IN THE FIRST DEGREE, in violation of Section 240.46 of the Penal Law of the State
of New York, committed as follows: I

That the said defendant, DONALD LAYMAN, in the County of Warren, State of New York,
on June 18, 2018, did knowingly conducted or maintained a premise, place, or resort where persons
came or gathered for purposes of engaging in the unlawful sale of controlled substance in violation

of sections 220.39, 220.41, or 220.43 and thereby derived the bene?t from such unlanul conduct.

51

COUNT 110

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Warren,
State of New York, on or about June 19, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 1 11

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, DONALD LAYMAN, of the crime of ATTEMPTED
CRIMINAL POSSESSION OF-A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
Violation of Sections 1 10.00 and 220.16 (Subdivision 1) of the Penal Law of the State of New York,
committed as follows:

That the said defendant, DONALD LAYMAN, in the County of Warren, State of New York,
on or about June 19, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it. .
COUNT 1 12

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, DONALD LAYMAN, of the crime of ATTEMPTED
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FOURTH DEGREE, in
violation of Sections 110.00 and 220.09 (Subdivision 12) of the Penal Law of the State of New
York, committed as follows:

That the said defendant, DONALD LAYMAN, in the County of Warren, State of New York,
on or about June 19, 2018, did knOwingly and unlawfully attempt to posseSs one or more

preparations, compounds, mixtures or substances containing the narcotic drug cocaine and said

52

preparations, compounds, mixtures or substances were of an aggregate weight of one-eighth ounce

or more.
COUNT 1 13

THE GRAND JURY THE COUNTY OF SARATOGA, by this indictment, further
accuses the above?named defendant, MARK TAI, 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, MARK TAI, in the County of Schenectady, State
of New York, on or about June 9, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 114

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, MARK TAI, 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, MARK TAI, in the County of Schenectady, State
of New York, on or about June 19, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 15

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MARK TAI, 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, MARK TAI, in the County of Warren, State of
New York, on or about June 19, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

53

COUNT 116

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MARK TAI, 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, MARK TAI, in the County of Warren, State of
New York, on or about June 21 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 117

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, VANESSA FRENCH, of the crime of ATTEMPTED
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
violation of Sections 1 10.00 and 220.16 (Subdivision 1) of the Penal Law of the State of New York,
committed as follows:

That the said defendant, VANESSA FRENCH, in the County of Warren, State of New York,
on or about June 21, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it.
COUNT 18

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MARK TAI, 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, MARK TAI, in the County of Warren, State of

New York, on or about June 21, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

54

COUNT 119

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MARK TAI, 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, MARK TAI, in the County of Schenectady, State.
of New York, on or about June 22, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 120

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TARA REID, 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, TARA REID, in the County of Schenectady, State of New York, on
or about June 22, 2018, did knowingly and unlawfully attempt to possess the narcotic drug cocaine

with the intent to sell it.


THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TARA REID, of the crime of ATTEMPTED CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE FOURTH DEGREE, in violation of
Sections 1 10.00 and 220.09 (Subdivision 12) of the Penal Law of the State of New York, committed
as follows:

That the said defendant, TARA REID, in the County of Schenectady, State of New York, on
or about June 22, 2018, did knowingly and unlawfully attempt to possess one or more preparations,

compounds, mixtures or substances containing the narcotic drug cocaine and said preparations,

55

compounds, mixtures or substances were of an aggregate weight of one-eighth ounce or more.
COUNT 122

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MARK TAI, 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, MARK TAI, in the County of Saratoga, State of

New York, on or about June 22, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.
COUNT 123

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MARK TAI, of the crime of CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE THE THIRD DEGREE, in violation of
Section 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, MARK TAI, in the County of Saratoga, State of
New York, on or about June 22, 2018, did knowingly and unlawfully possess the narcotic drug

cocaine with the intent to sell it.
COUNT 124

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, MARK TAI, of the crime of CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of
Section 220.16 (Subdivision 12) of the Penal Law of the State of New York, committed as follows:

That the said defendant, MARK TAI, in the County of Saratoga, State of
New York, on or about June 22, 2018, did knowingly and unlawfully possess one or more
preparations, compounds, mixtures or substances containing the narcotic drug cocaine and said

preparations, compounds, mixtures or substances were of an aggregate weight of one-half ounce or

56

more.
COUNT 125

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MARK TAI, 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: I

That the said defendant, MARK TAI, in the County of Schenectady, State
of New York, on or about June 22, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 126

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, COLLEEN CONNOLLY, 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, COLLEEN CONNOLLY, in the
County of Warren, State of New York, on or about May 5, 2018, did knowingly and unlawfully sell

the narcotic drug cocaine.
COUNT 127

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, EDWARD LEE, 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, EDWARD LEE, in the County of Warren, State
of New York, on or about May 5, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

57



THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, KIMBERLY SCHWARTZFIGURE, 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, KIMBERLY SCHWARTZFIGURE, in the County
of Warren, State of New York, on or about May 5, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.
COUNT 129

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, of the crime of CRIMINAL
SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section
I 220.39 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, EDWARD LEE, in the COunty of Warren, State
of New York, on or about May 5, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 130

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, KIMBERLY SCHWARTZFIGURE, 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, KIMBERLY SCHWARTZFIGURE, in the County
of Warren, State of New York, on or about May 5, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.

58

COUNT 131

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, 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, EDWARD LEE, in the County of Warren, State
of New York, on or about May 5, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.



THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TARA REID, 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: I

That the said defendant, TARA REID, in the County of Warren, State of New York, on or
about May 5, 2018, did knowingly and unlawfully attempt to possess the narcotic drug cocaine with

the intent to sell it.

COUNT 133
THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, RENEE PAS SINO, 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, RENEE PASSINO, in the County of Warren, State of New York, on
or about May 7, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

59

COUNT 134

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Warren,
State of New York, on or about May 7, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 135

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, 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, EDWARD LEE, in the County of Warren, State
of New York, on or about May 7, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 136

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, NICHOLAS TORCHETTI, of the crime of ATTEMPTED
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
violation of Sections 1 10.00 and 220.16 (Subdivision 1) of the Penal Law of the State of New York,
committed as follows:

That the said defendant, NICHOLAS TORCHETTI, in the County of Warren, State of New
York, on or about May 7, 2018, did knowingly and unlawfully attempt to possess the narcotic drug

cocaine with the intent to sell it.

60

COUNT 137

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendants, EDWARD LEE, and BRENDA PERRY, 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, EDWARD LEE, and BRENDA PERRY, in the
County of Warren, State of New York, on or about May 9, 2018, did knowingly and unlawfully sell

the narcotic drug cocaine.
COUNT 138

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendants, EDWARD LEE, and COLLEEN
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, EDWARD LEE, AND COLLEEN
CONNOLLY, in the County of Warren, State of New York, on or
about May 9, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 139

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, and BRENDA PERRY 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, EDWARD LEE, and BRENDA PERRY in the
County of Albany, State of New York, on or about May 12, 2018, did knowingly and unlawfully sell

61

the narcotic drug cocaine.
COUNT 140

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, RENNEE PAS SIN O, 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, RENNEE PASSION in the County of Saratoga, State of New York,
on or about May 15, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 141

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, 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, EDWARD LEE, in the County of Warren, State
of New York, on or about May 18, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 142

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, EDWARD LEE, AND BRENDA PERRY 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, EDWARD LEE, AND BRENDA PERRY in the
County of Warren, State of New York, on or about May 18, 2018, did knowingly and unlawfully sell

the narcotic drug cocaine.

62

COUNT 143

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MAN A SAMBOLA, MAN A SAMBOLE, 
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, MAN A SAMBOLA, MAN A SAMBOLE, 
in the County of Saratoga, State of New York, on or about May 19, 2018, did knowingly and

unlawfully sell the narcotic drug cocaine.

COUNT 144

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, EDWARD LEE, of the crime of
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
violation of Section 220.16 (subdivision 1) of the Penal Law of the State of New York,
committed as follows:

That the said defendant, EDWARD LEE, in the County of Warren,
State of New York, on or about May 19, 2018, did knowingly and unlawfully possess the

narcotic drug cocaine with the intent to sell it.

COUNT 145 .

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, 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: i

That the said defendant, EDWARD LEE, in the County of Warren,
State of New York, on or about May 19, 2018, did knowingly and unlawfully sell the narcotic

drug cocaine.

63

COUNT 146

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, BRENDA PERRY, 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, BRENDA PERRY, in the County of Warren, State of New York,
on or about May 19, 2018, did knowingly and unlawfully sell the narcotic drug cocaine. I

COUNT 147

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, 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, EDWARD LEE, in the County of Warren, State
of New York, on or about May 19, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 148

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MANA SAMBOLA, MANA SAMBOLE, 
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, MAN A SAMBOLA, MAN A SAMBOLE, 
in the County of Saratoga, State of New York, on or about May 19, 2018, did knowingly and

unlawfully sell the narcotic drug cocaine.

64

COUNT 149

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, of the crime of CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in Violation of
Section 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, EDWARD LEE, in the County of Saratoga, State
of New York, on or about May 19,2018, did knowingly and unlawfully possess the narcotic drug

cocaine with the intent to sell it.
COUNT 150

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, 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, EDWARD LEE, in the County of Saratoga, State
of New York, on or about May 19, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 1 5 1

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MELVINA GROVENBURG, 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, MELVINA GROVENBURG, in the County of
Saratoga, State of New York, on or about May 19, 2018, did knowingly and unlawfully attempt to

possess the narcotic drug cocaine with the intent to sell it.

65

COUNT 152

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, '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, TREMEL ROSARIO, in the County of
Saratoga, State of New York, on or about May 19, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.
COUNT 153

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, 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, EDWARD LEE, in the County of Saratoga, State
of New York, on or about May 19, 2018, did knowingly and unlawfully attempt to possess the

narcotic drug cocaine 'with the intent to sell it.
COUNT 154

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MANA SAMBOLA, MANA SAMBOLE, 
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, MAN A SAMBOLA, MAN A SAMBOLE, 
in the County of Saratoga, State of New York, on or about May 19, 2018, did knowingly and

unlawfully sell the narcotic drug cocaine.

66

COUNT 155

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendants, EDWARD LEE, AND BRENDA PERRY,
of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD
DEGREE, in Violation of Section 220.16 (Subdivision 1) of the Penal Law Of the State of New York,
committed as follows:

I That the said defendants, EDWARD LEE, AND BRENDA PERRY, in the
County of Saratoga, State of New York, on or about May 20, 2018, did knowingly and unlawfully

possess the narcotic drug cocaine with the intent to sell it.
COUNT 156

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, RENEE PASSINO, of the crime of CRIMINAL SALE OF A
CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in Violation of Section 220.39
(Subdivision 1) ofthe Penal Law of the State of New York, committed as follows:

That the said defendant, RENEE PAS SIN O, in the County of Saratoga, State of New York,
on or about May 20, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 157

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, of the crime of
ATTEMPTED CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD
DEGREE, in violation of Sections 1 10.00 and 220.16 (Subdivision 1) of the Penal Law of the State
of New York, committed as follows:

That the said defendant, EDWARD LEE, in the County of Saratoga, State
of New York, on or about May 20, 2018, did knowingly and unlawfully attempt to possess the

narcotic drug cocaine with the intent to sell it.

67

COUNT 158

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, MATTHEW MALU, 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, MATTHEW MALU, in the County of
Warren, State of New York, on or about May 20, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.
COUNT 159

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, of the crime of CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of
Section 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, EDWARD LEE, in the County of Warren, State
of New York, on or about May 20, 2018, did knowingly and unlawfully possess the narcotic drug

cocaine with the intent-to sell it.


THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, EDWARD LEE, 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, EDWARD LEE, in the County of Warren, State
of New York, on or about May 20, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.

68

COUNT 161

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, EDWARD LEE, 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:

I That the said defendant, EDWARD LEE, in the County of Warren, State
of New York, on or about May 20, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 162

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, AMEL PEARSON, II, 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, AMEL PEARSON, II, in the County of Warren,
State of New York, on or about May 20, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
ME

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, of the crime of CRIMINAL
POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of
Section 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, EDWARD LEE, in the County of Warren, State
of New York, on or about May 20, 2018, did knowingly and unlawfully possess the narcotic drug

cocaine with the intent to sell it.

69

COUNT 164

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MATTHEW MALU, of the crime
of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation
of Section 220.3 9 (Subdivision 1) of the Penal Law of the State of New York, committed as follows:

That the said defendant, MATTHEW MALU, in the County of
Warren, State of New York, on or about May 20, 2018, did knowingly and unlawfully sell the

narcotic drug cocaine.

COUNT 166

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, VANESSA GRAHAM, 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, VANESSA GRAHAM, in the County of Saratoga, State of New
York, on or about May 27, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 167

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further accuses the
above-named defendant, MELVINA GROVENBURG, 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, MELVINA GROVENBURG, in the County of
Saratoga, State of New York, on or about May 27, 2018, did knowingly and unlawfully sell the

narcotic drug hydrocodone.

70

COUNT 168

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MELVINA GROVENBURG, of the crime of
ATTEMPTED CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD
DEGREE, in violation of Sections 1 10.00 and 220.16 (Subdivision 1) of the Penal Law of the State
of New York, committed as follOws:

That the said defendant, MELVINA GROVENBURG, in the County of
Saratoga, State of New York, on or about May 27, 2018, did knowingly and unlawfully attempt to

possess the narcotic drug cocaine with the intent to sell it.
COUNT 169

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, VANESSA GRAHAM, 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, VANESSA GRAHAM, in the County of Saratoga, State of New
York, on or about May 30, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 170

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, 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, EDWARD LEE, in the County of Saratoga, State
of New York, on or about May 30, 2018, did knowingly and unlawfully attempt to possess the

narcotic drug cocaine with the intent to sell it.

71

COUNT 171

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, VANESSA GRAHAM, 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, VANESSA GRAHAM, in the County of Saratoga, State of New
York, on or about May 31, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 172

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, 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, EDWARD LEE, in the County of Saratoga, State
of New York, on or about May 31, 2018, did knowingly and unlawfully attempt to possess the

narcotic drug cocaine with the intent to sell it.
COUNT 173

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MARK TAI, 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, MARK TAI, in the County of Warren, State of
New York, on or about June 1, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

72

COUNT 174

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, of the crime of
ATTEMPTED CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD 
DEGREE, in violation of Sections 11000 and 220.16 (Subdivision 1) of the Penal Law of the State
of New York, committed as follows:

That the said defendant, EDWARD LEE, in the County of Warren, State
of New York, on or about June 1, 2018, did knowingly and unlawfully attempt to possess the

narcotic drug cocaine with the intent to Sell it.
COUNT 175

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Warren,
State of New York, on or about June 5, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 176

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, 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, EDWARD LEE, in the County of Warren, State
of New York, on or about June 5, 2018, did knowingly and unlawfully attempt to possess the

narcotic drug cocaine with the intent to sell it.

73

COUNT 177

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, VANESSA GRAHAM, 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, VANESSA GRAHAM, in the County of Saratoga, State of New

York, on or about June 6, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.


THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, 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, EDWARD LEE, in the County of Saratoga, State
of New York, on or about June 6, 2018, did knowingly and unlawfully attempt to possess the

narcotic drug cocaine with the intent to sell it.
COUNT 179

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, 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, EDWARD LEE, in the County of Warren, State
of New York, on or about June 9, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

74

COUNT 180 

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Warren,
State of New York, on or about June 19, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 1 81

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, EDWARD LEE, 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, EDWARD LEE, in the County of Warren, State
of New York, on or about June 22, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.


THEGRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, JAMEL PEARSON, II, 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, AMEL PEARSON, II, in the County of Warren,
State of New York, on or about July 3, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.

75

COUNT 183

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, JAMEL PEARSON, II, 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, JAMEL PEARSON, II, in the County of Warren,
State of New York, on or about July 3, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 184

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TARA BROWN, 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, TARA BROWN, in the County of Warren, State of New York, on or
about July 12, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 185

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, JAMES DUPREY, 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, JAMES DURPEY, in the County of Warren, State of New York, on
or about July 12, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

76

COUNT 186

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, JAMEL PEARSON, II, of the crime of
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
violation of Section 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed
as follows: .

That the said defendant, JAMEL PEARSON, II, in the County of Warren,
State of New York, on or about July 12, 2018, did knowingly and unlawfully possess the narcotic

drug cocaine with the intent to sell it.
COUNT 187

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, JAMEL PEARSON, II, of the crime of
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FOURTH DEGREE, in
violation of Section 220.09 (Subdivision 12) of the Penal Law of the State of New York, committed
as follows:

That the said defendant, JAMEL PEARSON, II, in the County of Warren,
State of New York, on or about July 12, 2018, did knowingly and unlawfully possess one or more
preparations, compounds, mixtures or substances containing the narcotic drug cocaine and said
preparations, compounds, mixtures or substances were of an aggregate weight of one-eighth ounce

or more.
COUNT 188

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, JAMES DUPREY, of the crime of CRIMINAL NUISAN CE IN
THE FIRST DEGREE, in violation of Section 240.46 of the Penal Law of the State of New York,
committed as follows:

That the said defendant, JAMES DUPREY, in the County of Warren, State of New York,

77

from July 3, 2018 through July 12, 2018, did conducted or maintained a premise, place,
or resort where persons came or gathered for purposes of engaging in the unlawful sale of controlled
substance in Violation of sections 220.39, 220.41, or 220.43 and thereby derived the bene?t from

such unlawful conduct.
COUNT 189

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendants, AMEL PEARSON, II, and JAMES
DUPREY, of the crime of CRIMINALLY USING DRUG PARAPHERNALIA IN THE SECOND
DEGREE in Violation of Section 220.50 (3) of the Penal Law of the State of New York, committed
as follows:

That the said defendants, AMEL PEARSON, II, and JAMES DUPREY,
in the County of Warren, State of New York, on July 12, 2018, 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 190

I THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MAN A SAMBOLA, MAN A SAMBOLE, 
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, MAN A SAMBOLA, MAN A SAMBOLE, 
in the County of Saratoga, State of New York, on or about May 11, 2018, did knowingly and

unlawfully sell the narcotic drug cocaine.

78

COUNT 191

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, MAN A SAMBOLA, MAN A SAMBOLE, 
of the crime of CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD
DEGREE, in violation of Section 220.3 9 (Subdivision 1) of the Penal Law of the State of New York,
committed as follows:

That the said defendant, MAN A SAMBOLA, in the County of Saratoga, State of New York,
on or about May 11, 2018, did knowingly and unlawfully sell the narcotic drug cocaine.

COUNT 192

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MANA SAMBOLA, MANA SAMBOLE, 
of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE
THIRD DEGREE, in violation of Section 220.16 (Subdivision 1) of the Penal Law of the State of
New York, committed as follows: i

That the said defendant, MAN A SAMBOLA, MAN A SAMBOLE, 
in the County of Saratoga, State of New York, on or about May 21, 2018, did knowingly and.

unlawfully possess the narcotic drug cocaine with the intent to sell it.
COUNT 193

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MANA SAMBOLA, MANA SAMBOLE, 
of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE THE
THIRD DEGREE, in violation of Section 220.16 (Subdivision 12) of the Penal Law of the State of
New York, committed as follows:

That the said defendant, MAN A SAMBOLA, MAN A SAMBOLE, 
in the County of Saratoga, State of New York, on or about May 21, 2018, did knowingly and

unlawfully possess one or more preparations, compounds, mixtures or substances containing the

79

narcotic drug cocaine and said preparations, compounds, mixtures or substances were of an

aggregate weight of one-half ounce or more.
COUNT 194

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MANA SAMBOLA, MANA SAMBOLE, 
of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE
THIRD DEGREE, in violation of Section 220.16 (Subdivision 1) of the Penal Law of the State of
New York, committed as follows:

That the said defendant, MAN A SAMBOLA, MAN A SAMBOLE, 
in the County of Saratoga, State of New York, on or about May 21, 2018, did knowingly and

unlawfully possess the narcotic drug cocaine with the intent to sell it.
COUNT 195

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MANA SAMBOLA, MANA SAMBOLE, 
of the crime of CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE THE
THIRD DEGREE, in Violation of Section 220.16 (Subdivision 12) of the Penal Law of the State of
New York, committed as follows: I

That the said defendant, MAN A SAMBOLA, MANA SAMBOLE, 
in the County of Saratoga, State of New York, on or about May 21, 2018, did knowingly and
unlawfully possess one or more preparations, compounds, mixtures or substances containing the
narcotic drug cocaine and said preparations, compounds, mixtures or substances were of an

aggregate weight of one-half ounce or more.
COUNT 196

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, MANA SAMBOLA, MANA SAMBOLE, 

80

 of the crime of CRIMINALLY USING DRUG PARAPHERNALIA IN THE SECOND
DEGREE in violation of Section 220.50 (2) of the Penal Law of the State of New York, committed
as follows: . .
That the said defendant, MAN A SAMBOLA, MAN A SAMBOLE, 
in the County of Saratoga, State of New York, on May-21, 2018, 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 197

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, of the crime of
CRIMINAL SALE OF A CONTROLLED SUBSTANCE 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, TREMEL ROSARIO, in the County of Albany,
State of New York, on or about April 6, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.
COUNT 198

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, 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, TREMEL ROSARIO, in the County of Albany,
State of New York, on or about June 18, 2018, did knowingly and unlawfully sell the narcotic drug

cocaine.

81

COUNT 199

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, of the crime of
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in
violation of Section 220.16 (Subdivision 1) of the Penal Law of the State of New York, committed
as follows:

That the said defendant, TREMEL ROSARIO, in the County of Albany,
State of New York, on or about June 25, 2018, did knowingly and unlawfully possess the narcotic

drug cocaine with the intent to sell it.
COUNT 200

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, of the crime of
CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FOURTH DEGREE, in
violation of Section 220.09 (Subdivision 12) of the Penal Law of the State of New York, committed
as follows:

That the said defendant, TREMEL ROSARIO, in the County of Albany,
State of New York, on or about June 25 2018, did knowingly and unlawfully possess one or more
preparations, compounds, mixtures or substances containing the narcotic drug cocaine and said
preparations, compounds, mixtures or substances were of an aggregate weight of one-eighth ounce

or more.


THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, of the crime of
CRIMINALLY USING DRUG PARAPHERNALIA IN THE SECOND DEGREE, in violation of
Section 220.50 (2) of the Penal Law of the State of New York, committed as follows:

That the said defendant, TREMEL ROSARIO, in the County of Albany,

82

State of New York, on June 25, 2018, 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 202

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above?named defendant, TREMEL ROSARIO, of the crime of
CRIMINALLY USING DRUG PARAPHERNALIA IN THE SECOND DEGREE, in violation of
Section 220.50 (3) of the Penal Law of the State of New York, committed as follows:

That the said defendant, TREMEL ROSARIO, in the County of Albany,
State of New York, on June 25, 2018, 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 203

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, TREMEL ROSARIO, of the crime of
CRIMINALLY USING DRUG PARAPHERNALIA IN THE SECOND DEGREE, in violation of
Section 220.50 (3) of the Penal Law of the State of New York, committed as follows:

7 That the said defendant, TREMEL ROSARIO, in the County of Albany,
State of New York, on June 25, 2018, 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.

83

COUNT 204

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MARK TAI, of the crime of CRIMINALLY
USING DRUG PARAPHERNALIA IN THE SECOND DEGREE, in violation of Section 220.50 (3)
of the Penal Law of the State of New York, committed as follows: 

That the said defendant, MARK TAI, in the County of Schenectady, State
of New York, on September 5, 2018, 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 205

THE GRAND JURY OF THE COUNTY OF SARATOGA, by this Indictment, further
accuses the above-named defendant, MARK TAI, of the crime of CRIMINALLY
USING DRUG PARAPHERNALIA IN THE SECOND DEGREE, in Violation of Section 220.50 (2)
of the Penal Law of the State of New York, committed as follows:

That the said defendant, MARK TAI, in the County of Schenectady, State
of New York, on September 5, 2018, 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.

84

Dated: October LS, 2018
Saratoga, New York

By:



Grand Jury Foreperson

NICOLE KEARY
Deputy Attorney General
N.Y.S. Attorney General's Organized Crime Task Force

lW??m

Michael A. Sharpe
Assistant Deputy Attorney General
N.Y.S. Attorney General's Organized Crime Task Force

85