STATE OF NEW YORK
COUNTY COURT BROOME COUNTY

THE PEOPLE OF THE STATE OF NEW YORK
I I 

 

(Felony Pleading No. 19?165)
KEVIN L. WILCOX,

2019 BROOME COUNTY TERM 
Defendant.

THE GRAND JURY OF THE COUNTY OF BROOME, by this Indictment,
accuse the above defendant, KEVIN L. WILCOX, of the crime of
AGGRAVATED VEHICULAR HOMICIDE, in violation of Section 125.14,
Subdivision 5, of the Penal Law of the State of New York, a Class
Felony, committed as follows:

That the said defendant, KEVIN L. WILCOX, in the City of
Binghamton, County of Broome and State of New York, at
approximately on or about the 11th day of March, 2019, did
commit the crime of Vehicular Manslaughter in the Second Degree
as defined in Section 125.12 of the Vehicle and Traffic Law, and
committed such crime while engaging in Reckless Driving, as
defined in Section 1212 of the Vehicle and Traffic Law, and did
cause the death of one person and the serious physical injury of
at least one other person, to wit: at the aforementioned time and
place, said defendant did operate a 1995 Jeep motor vehicle on
Beethoven Street, ea public highway, in said City, County and
State, in a manner which unreasonably interfered with the free
and proper use of the public highway and/or unreasonably
endangered users of the public highway, and did so while his
ability to operate a motor vehicle was impaired by the use of a
drug, and as a result of such impairment by the use of a drug,
did operate said motor vehicle in a manner that caused the death
of Harper Stantz and caused serious physical injury to Britney
Laserinko, all contrary to the provisions of the statute in such

case made and provided.

SECOND COUNT

THE GRAND JURY OF THE COUNTY OF BROOME, by this Indictment,
accuse the above defendant, KEVIN L. WILCOX, of the crime of
MANSLAUGHTER IN THE SECOND DEGREE, in violation of Section 125.15,
Subdivision 1, of the Penal Law of the State of New York, a Class
Felony, committed as follows:

That the said defendant, KEVIN L. WILCOX, in the City of
Binghamton, County of Broome and State of New York, at
approximately on or about the ll?lday of March, 2019, did
recklessly cause the death of another person, to wit: at the
aforementioned 'time and jplace, said defendant did recklessly
cause the death of Harper Stantz, all contrary to the provisions

of the statute in such case made and provided.

THIRD COUNT

THE GRAND JURY OF THE COUNTY OF BROOME, by this Indictment,
accuse the above defendant, KEVIN L. WILCOX, of the crime of
VEHICULAR MANSLAUGHTER IDJ THE SECOND DEGREE, in Violation of
Section 125.12, Subdivision 1, of the Penal Law of the State of
New York, a Class Felony, committed as follows:

That the said defendant, KEVIN L. WILCOX, in the City of
Binghamton, County of Broome and State of New York, at
approximately on or about the 11th day of March, 2019, did
cause the death of such other person by operation of a vehicle in
violation of subdivision 2, 3, 4, or 4-a of section eleven hundred
ninety?two of the Vehicle and Traffic Law or by operation of a
vessel or public vessel in violation of paragraph 
or of subdivision two of section forty?nine?a of the
navigation law, and as a result of such intoxication or impairment
by the use of a drug, or by the combined influence of drugs or of
alcohol and any drug or drugs, operates such motor vehicle, vessel
or public vessel in a manner that causes the death of another
person, to wit: at the aforementioned 'time and. place, said
defendant c?xi operate ea 1995 Jeep nm?xn: vehicle (n1 Beethoven
Street, a public highway, in said City, County and State, while
his ability to operate a motor vehicle was impaired by the use of
a drug, and as a result of such impairment by the use of a drug,
did operate said motor vehicle in a manner that caused the death
of Harper Stantz, all contrary to the provisions of the statute

in such case made and provided.

FOURTH COUNT

THE GRAND JURY OF THE COUNTY OF BROOME, by this Indictment,
accuse the above defendant, KEVDV L. WILCOX, of the crime of
AGGRAVATED VEHICULAR ASSAULT, in violation of Section 120.04?a,
Subdivision 4, of the Penal Law of the State of New York, a Class
Felony, committed as follows:

That the said defendant, KEVIN L. WILCOX, in the City of
Binghamton, County of Broome and State of New York, at
approximately on or about the 11UIday of March, 2019, did
commit the crime of Vehicular Assault in the Second Degree as
defined in Section 120.03 of the Vehicle and Traffic Law, and
committed such crime while engaging in Reckless Driving as defined
in Section 1212 of the Vehicle and Traffic Law, and did cause
serious physical injury to more than one person, to wit: at the
aforementioned time and place, said defendant did operate a 1995
Jeep motor vehicle on Beethoven Street, a public highway in said
City, County and State, in a manner which unreasonably interfered
with the free and proper use of the public highway and/or
unreasonably endangered users of the public highway and did so
while his ability to operate a motor vehicle was impaired by the
use of a drug, and that as a result of such impairment by the use
of a drug, did operate said motor vehicle in a manner that caused
serious physical injury to Harper Stantz and Britney Laserinko,
all contrary to the provisions of the statute in such case made

and provided.

FIFTH COUNT

THE GRAND JURY OF THE COUNTY OF BROOME, by this Indictment,
accuse the above defendant, KEVDN L. WILCOX, of the crime of
VEHICULAR ASSAULT IN THE FIRST DEGREE, in Violation Of Section
120.04, Subdivision 4, of the Penal Law of the State of New York,
a Class Felony, committed as follows:

That the said defendant, KEVIN L. WILCOX, in the City of
Binghamton, County of Broome and State of New York, at
approximately on or about the 11UIday of March, 2019, did
commit the crime of Vehicular Assault in the Second Degree as
defined in Section 120.03 of the Vehicle and Traffic Law and did
cause serious physical injury to more than one person by operation
of a motor vehicle in violation of subdivision 2, 3, 4, or 4?a of
section eleven hundred ninety?two of the Vehicle and Traffic Law,
to wit: at the aforementioned time and place, said defendant did
operate a 1995 Jeep motor vehicle on Beethoven Street, a public
highway in said City, County and State, while his ability to
operate a motor vehicle was impaired by the use of a drug and as
a result of such impairment by the use of a drug, did operate
said motor vehicle in a manner that caused serious physical injury
to Harper Stantz and Britney Laserinko, all contrary to the

provisions of the statute in such case made and provided.

SIXTH COUNT

THE GRAND JURY OF THE COUNTY OF BROOME, by this Indictment,
accuse the above defendant, KEVIN L. WILCOX, of the crime of
ASSAULT IN THE SECOND DEGREE, in violation of Section 120.05,
Subdivision 4, of the Penal Law of the State of New York, a Class
Felony, committed as follows:

That the said defendant, KEVIN L. WILCOX, in the City of
Binghamton, County of Broome and State of New York, at
approximately on or about the llm-day of March, 2019, did
recklessly cause serious physical injury to another person by
means of a deadly weapon or a dangerous instrument, to wit: at
the aforementioned time and place, said defendant did recklessly
cause serious physical injury to Harper Stantz, by means of a
dangerous instrument, a 1995 Jeep motor vehicle, all contrary to

the provisions of the statute in such case made and provided.

SEYENTH COUNT

THE GRAND JURY OF THE COUNTY OF BROOME, by this Indictment,
accuse the above defendant, KEVIN L. WILCOX, of the crime of
ASSAULT IN THE SECOND DEGREE, in violation of Section 120.05,
Subdivision 4, of the Penal Law of the State of New York, a Class
Felony, committed as follows:

That the said defendant, KEVIN L. WILCOX, in the City of
Binghamton, County of Broome and State of New York, at
approximately on or about the llw-day of March, 2019, did
recklessly cause serious physical injury to another person by
means of a deadly weapon or a dangerous instrument, to wit: at
the aforementioned time and place, said defendant did recklessly
cause serious physical injury to Britney Laserinko, by means of
a dangerous instrument, a 1995 Jeep motor vehicle, all contrary

to the provisions of the statute in such case made and provided.

EIGHTH COUNT

THE GRAND JURY OF THE COUNTY OF BROOME, by this Indictment,
accuse the above defendant, KEVDN L. WILCOX, of the crime of
VEHICULAR ASSAULT IN THE SECOND DEGREE, in Violation of Section
120.03, Subdivision 1, of the Penal Law of the State of New York,
a Class Felony, committed as follows:

That the said defendant, KEVIN L. WILCOX, in the City of
Binghamton, County of Broome and State of New York, at
approximately on or about the ll?lday of March, 2019, did
cause serious physical injury to another person by operation of
a motor vehicle in violation of subdivision 2, 3, 4, or 4?a of
section eleven hundred ninety?two of the Vehicle and Traffic Law,
to wit: at the aforementioned time and place, said defendant did
operate a 1995 Jeep motor vehicle on Beethoven Street, a public
highway in said City, County and State, while his ability to
operate a motor vehicle was impaired by the use of a drug and as
a result of such impairment by the use of a drug, did operate
said.motor vehicle in a manner that caused serious physical injury
to Harper Stantz, all contrary to the provisions of the statute

in such case made and provided.

NINTH COUNT

THE GRAND JURY OF THE COUNTY OF BROOME, by this Indictment,
accuse the above defendant, KEVIN L. WTLCOX, of the crime of
VEHICULAR ASSAULT IN THE SECOND DEGREE, in violation of Section
120.03, Subdivision 1, of the Penal Law of the State of New York,
a Class Felony, committed as follows:

That the said. defendant, KEVIKI L. WILCOX, in 'the City of
Binghamton, County of Broome and State of New York, at
approximately on or about the ll?lday of March, 2019, did
cause serious physical injury to another person by operation of
a motor vehicle in violation of subdivision 2, 3, 4, or 4?a of
section eleven hundred ninety?two of the Vehicle and Traffic Law,
to wit: at the aforementioned time and place, said defendant did
operate a 1995 Jeep motor vehicle on Beethoven Street, a public
highway in said City, County and State, while his ability to
operate a motor vehicle was impaired by the use of a drug and as
a result of such impairment by the use of a drug, did operate
said motor vehicle in a manner that caused serious physical injury
to Britney" Laserinko, all contrary' to the provisions of the

statute in such case made and provided.

TENTH COUNT
THE GRAND JURY OF THE COUNTY OF BROOME, by this Indictment,
accuse the above defendant, KEVDN L. WILCOX, of the crime of
RECKLESS ENDANGERMENT IN THE SECOND DEGREE, in violation of
Section 120.20 of the Penal Law of the State of New York, a Class

A Misdemeanor, committed as follows:

That the said defendant, KEVIN L. WILCOX, in the City of
Binghamton, County of Broome and State of New York, at
approximately on or about the llm-day of March, 2019, did
recklessly engage in conduct which created a substantial risk of
serious physical injury to another person, to wit: at the
aforementioned. time and. place, said. defendant did. recklessly
engage in conduct which created a substantial risk of serious
physical injury to Harper Stantz, all contrary to the provisions

of the statute in such case made and provided.

ELEVENTH COUNT

 

THE GRAND JURY OF THE COUNTY OF BROOME, by this Indictment,
accuse the above defendant, KEVIN L. WILCOX, of the crime of
RECKLESS ENDANGERMENT IN THE SECOND DEGREE, in violation of
Section 120.20 of the Penal Law of the State of New York, a Class

A Misdemeanor, committed as follows:

That the said defendant, KEVIN L. WILCOX, in the City of
Binghamton, County of Broome and State of New York, at
approximately on or about the ll?lday of March, 2019, did
recklessly engage in conduct which created a substantial risk of
serious physical injury to another person, to wit: at the
aforementioned. time and. place, said. defendant did recklessly
engage in conduct which created a substantial risk of serious
physical injury to Britney Laserinko, all contrary to the

provisions of the statute in such case made and provided.

TWELFTH COUNT

 

THE GRAND JURY OF THE COUNTY OF BROOME, by this Indictment,
accuses the above defendant, KEVIN L. WILCOX, of the crime of
DRIVING WHILE ABILITY IMPAIRED BY DRUGS, in violation of Section
1192, Subdivision 4, of the Vehicle and Traffic Law of the State
of New York, an Unclassified Misdemeanor, committed as follows:

That the said defendant, KEVIN L. WILCOX, in the City of
Binghamton, County of Broome and State of New York, at
approximately on or about the llw-day of March, 2019, did
operate a Hmtor vehicle while his ability to operate a nwtor
vehicle was impaired. by the use of' a drug, to wit: at the
aforementioned time and place, said defendant did operate a 1995
Jeep motor vehicle on Beethoven Street, a public highway in said
City, County and State, while said defendant?s ability to operate
said motor vehicle was impaired by the use of a drug, all contrary

to the provisions of the statute in such case made and provided.

THIRTEENTH COUNT

 

THE GRAND JURY OF THE COUNTY OF BROOME, by this Indictment,
accuses the above defendant, KEVIN L. WILCOX, of the crime of
RECKLESS DRIVING, in violation of Section 1212 of the Vehicle and
Traffic Law of the State of New York, an Unclassified Misdemeanor,
committed as follows:

That the said defendant, KEVIN L. WILCOX, in the City of
Binghamton, County of Broome and State of New York, at
approximately on or about the lj?h day of March, 2019,
operated.a motor vehicle in a manner which unreasonably interfered
with the free and. proper use of the public highway and/or
unreasonably endangered users of the public highway, to wit: at
the aforementioned time and place, said defendant did operate a
1995 Jeep motor vehicle on Beethoven Street, a public highway, in
said City, County and State, and at that time did drive in a
manner which unreasonably interfered with the free and proper use
of the public highway and/or unreasonably endangered users of the
public highway, all contrary to the provisions of the statute in

such case made and provided.

FOURTEENTH COUNT

 

THE GRAND JURY OF THE COUNTY OF BROOME, by this Indictment,
accuses the above defendant, KEVIN L. WILCOX, of the crime of
FAILURE TO KEEP RIGHT, in violation of Section 1120(a) of the
Vehicle and Traffic Law of the State of New York, a Traffic
Infraction, committed as follows:

That the said defendant, KEVIN L. WILCOX, in the City of
Binghamton, County of Broome and State of New York, at
approximately on or about the 11th day of March, 2019, did
fail to drive on the right half of a roadway of sufficient width,
to wit: at the aforementioned time and place, said defendant did
operate a 1995 Jeep motor vehicle on Beethoven Street, a public
highway of sufficient width, in said City, County and State, and
at that time did fail to drive on the right half of said roadway,

all contrary to the provisions of the statute in such case made

and provided.

FIFTEENTH COUNT

 

THE GRAND JURY OF THE COUNTY OF BROOME, by this Indictment,
accuses the above defendant, KEVIN L. WILCOX, of the crime of
FAILURE TO YIELD RIGHT OF WAY TO EMERGENCY VEHICLE, in violation
of Section 1144(a) of the Vehicle and Traffic Law of the State of
New York, a Traffic Infraction, committed as follows:

That the said defendant, KEVIN L. WILCOX, in the City of
Binghamton, County of Broome and State of New York, at
approximately on or about the llUIday of March, 2019, upon
the immediate approach of an authorized emergency vehicle
equipped with at least one lighted lamp exhibiting red light
visible under normal atmospheric conditions from a distance of
five hundred feet to the front of such vehicle other than a police
vehicle or bicycle when operated as an authorized emergency
vehicle, and. when audible signals are sounded front any said
vehicle by siren, exhaust whistle, bell, air?horn or electronic
equivalent; did fail to yield the right of way and failed to
immediately drive ix) a position parallel to, and as close as
possible to the right-hand edge or curb of the roadway, and stop
and remain in such position until the authorized emergency vehicle
has passed, unless otherwise directed by 51 police officer, to
wit: at the aforementioned time and place, said defendant did
operate a 1995 Jeep motor vehicle on Beethoven Street, a public
highway, and upon the approach of a Binghamton Fire Department
Fire Medic Vehicle with emergency lights and sirens activated,
did fail to yield the right of way and did fail to pull to the
right?hand edge or curb of the roadway, and did fail to stop and
remain in such position until the Binghamton Fire Department Fire
Medic Vehicle had passed, all contrary to the provisions of the
statute in such case made and provided.

Dated: April 25, 2019

Foreperson

 

s/Stephen K. Cornwell, Jr.

 

District Attorney for Broome County