7/25/2019 Youngren B Felony 6-8-16

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Investigator R.A. Kotin employed by the New York State Police, by this information makes

written accusation as follows:

That KENNETH C. YOUNGREN and KORDELL J. JACKSON, acting in concert

from on or before January 18, 2013, through on or about August 20, 2013, at the premises known

as Jackson Guns and Ammo, 1555 East Henrietta Road, in the Town of Henrietta, New York, didcommit the armed felony offense of Criminal Sale of a Firearm in the first degree, a class B

felony, contrary to the provisions of Section 265.13(2) of the Penal Law of the State of New

York (Penal Law).

CHARGES: A person is guilty of criminal sale of a firearm in the first degree when such person:

(2) unlawfully sells, exchanges, gives or disposes of to another person or persons a total of ten or

more firearms in a period of not more than one year.

THE FACTS ON WHICH THIS ACCUSATION IS MADE ARE OF MY OWN

KNOWLEDGE OR ON INFORMATION AND BELIEF AS FOLLOWS:

That your complainant is a police officer for the New York State Police, and is currently

assigned to the Community Narcotics Enforcement Unit. During the aforementioned time period,

Kordell J. Jackson operated and Kenneth C. Youngren was an employee of a business known asJackson Guns and Ammo located at 1555 East Henrietta Road in the Town of Henrietta, County of

Monroe, State of New York, and said defendants, acting in concert, unlawfully sold, exchanged,

gave or disposed of ten (10) or more firearms, specifically assault weapons as defined by New York

State Penal section 265.00(22), to persons in a period of not more than one year. On the dates

indicated below, the defendants did sell, exchange, give or dispose of the following weapons:

DATE MANUFACTURER MODEL SERIAL NO.

01/18/2013 Bushmaster XM15-E25 L076509

01/18/2013 FN AR 319ZM03335

01/21/2013 ARFCOM AR15 ARF00015201/22/2013 DPMS Panther 15032

01/28/2013 Mossberg 715T ELI3482533

01/28/2013 Stag Arms Model 3 19595502/01/2013 Smith and Wesson M&P 15-22 DYY6780

FELONY

COMPLAINT

STATE OF NEW YORK COUNTY OF MONROE

TOWN COURT TOWN OF HENRIETTA

The People of the State of New York

-against-

KENNETH C. YOUNGREN DOB; 12/10/19854 Spruce St Alfred, NY 14802

KORDELL J. JACKSON DOB: 12/30/1975

107 Grangerford Heights, West Henrietta, NY 14586

Defendants

Complaint # ________

7/25/2019 Youngren B Felony 6-8-16

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02/08/2013 Mossberg 715T ELK3557669

02/11/2013 Century Arms WASR10 1980KV230002/13/2013 Stag Arms Model 2 28888

02/15/2013 German Sport Gun 522CB A497368

02/18/2013 DPMS LR308 7381

02/18/2013 Mossberg 715T ELK355810702/18/2013 Mossberg 715T ELK3558301

02/19/2013 Mossberg 715T ELK355803702/19/2013 Mossberg 715T ELK355815602/20/2013 Hi Point 995TS F16342

02/27/2013 Windham Weaponry M4 WW070903

03/06/2013 Windham Weaponry R16M4CH WW07474303/12/2013 Keltec Sub29 EGG65

03/18/2013 Armalite AR10 US385862

03/19/2013 Smith and Wesson M&P 15 04587

04/30/2013 Smith and Wesson M&P 15 5689605/20/2013 Hi Point 4595FGTS R20383

07/09/2013 Diamondback DB15 DB1505042

07/22/2013 Hi Point 995 E2355108/20/2013 UMA Uzi/Israel DR005779

Each of the aforementioned weapons were recovered and subsequently examined by

members of the New York State Police and deemed to be operable.

The basis of this complainant is my personal knowledge, training and experience, my

conversations with other law enforcement officials, including members of the New York StatePolice, the Depositions of John Marshall, Charles Vitale, Christian Loomis, James Nardozzi,

Fred Lennon, Alan Gerber Michael Ray, David Geraghty, William Hanifin, Steven Broutman,

John Piano, Peter Timm, Patrick Lawler, Donald Christmas, Mark Ambrose, Jorge Canete, Brian

Walker, Matthew Vaisey, as well as New York State Police Firearms Reports, and FirearmsTransaction Records, which are attached hereto and made a part of this accusatory instrument.

I realize that false statements made in the foregoing instrument are punishable as a ClassA Misdemeanor pursuant to Section 210.45 of the Penal Law. Accordingly and with notice of

the foregoing, I hereby affirm that the foregoing statements of facts are true, this ___ day of

June, 2016.

____________________________________ ______________________________

Witness Investigator R.A. Kotin