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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 about August 5, 2014, and December 17, 2014, at the premises known as Jackson

Guns and Ammo, 1555 East Henrietta Road, in the Town of Henrietta, New York, did committhe offense of Manufacture, transport, disposition and defacement of weapons anddangerous instruments and appliances, a class D felony, contrary to the provisions of Section

265.10(3) of the Penal Law of the State of New York.

CHARGES: A person is guilty of Manufacture, transport, disposition and defacement of weapons

and dangerous instruments and appliances when; (3) said person disposes of any machine gun,

assault weapon, large capacity ammunition feeding device or firearm silencer.

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 committed the

offense of commit the offense of Manufacture, transport, disposition and defacement of weapons

and dangerous instruments and appliances, as follows:

(1) On or about August 5, 2014, the defendants, acting in concert, disposed of a Bushmaster

308 caliber rifle, serial number BRD012899, specifically an assault weapon as defined by Section265.00(22) of the Penal Law, to Gregory Mytych.

(2) On or about December 17, 2014, the defendants, acting in concert, disposed of a

Legion Saiga 410 semi-automatic shotgun, serial number H09204332L, specifically an assaultweapon as defined by Section 265.00(22) of the Penal Law, to Cory McQueen.

Each of the aforementioned weapons were recovered and subsequently examined bymembers of the New York State Police and deemed to be operable.

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 # ________

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The basis of this complainant is my personal knowledge, training and experience, myconversations with other law enforcement officials, including members of the New York State

Police, the Depositions of Gregory Mytych and Cory McQueen, as well as New York State

Police Firearms Reports, and Firearms Transaction Records, which are attached hereto and made

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

June, 2016.

____________________________________ ______________________________

Witness Investigator R.A. Kotin