You are on page 1of 4

Qi 3656573 CRIMINAL COURT OF THE CITY OF NEW YORK PART APAR, COUNTY OF QUEENS

THE PEOPLE OF THE STATE OF NEW YORK I I COUNTY OF QUEENS

STATE OF NEW YORK

V.

ROBERTO ESPINAL (44Y) DEFENDANTI

DETECTIVE JOSEPH DEMARTINI OF INTERNAL AFFAIRS DIVISION, TAX REG#: 893945, BEING DULY SWORN, DEPOSES AND SAYS THAT BETWEEN MAY 202013 8:00AM AND SEPTEMBER 182013 3:00PM, AT THE INTERSECTION OF JUNCTION BLVD AND ROOSEVELT AVENUE, COUNTY OF QUEENS, STATE OF NEW YORK, THE DEFENDANT COMMITTED THE OFFENSES OF: PL 20010 [DF] BRIBE RECEIVING IN THE THIRD DEGREE - (DNA SAMPLE REQUIRED UPON CONVICTION) (2 COUNTS) PL 200.25 [EF] RECEIVING REWARD FOR OFFICIAL MISCONDUCT IN THE SECOND DEGREE - (DNA SAMPLE REQUIRED UPON CONVICTION) (6 COUNTS) PL 195.00-1 [AM] OFFICIAL MISCONDUCT - (DNA SAMPLE REQUIRED UPON CONVICTION) PL 200.10 [DF] BRIBE RECEIVING IN THE THIRD DEGREE - (DNA SAMPLE REQUIRED UPON CONVICTION) (2 COUNTS) BEING A PUBLIC SERVANT, SOLICIT, ACCEPT OR AGREE TO ACCEPT A BENEFIT FROM ANOTHER PERSON UPON AN AGREEMENT OR UNDERSTANDIG THAT HIS VOTE, OPINION, JUDGMENT, ACTION, DECISION OR EXERCISE OF DISCRETION AS A PUBLIC SERVANT WOULD THERBY BE INFLUENCED; PL 200.25 [EF] RECEIVING REWARD FOR OFFICIAL MISCONDUCT IN THE SECOND DEGREE - (DNA SAMPLE REQUIRED UPON CONVICTION) (6 COUNTS) BEING A PUBLIC SERVANT, SOLICIT, ACCEPT OR AGREE TO ACCEPT A BENEFIT FROM ANOTHER PERSON FOR HAVING VIOLATED HIS DUTY AS SUCH; PL 195.00-1 [AM] OFFICIAL MISCONDUCT - (DNA SAMPLE REQUIRED UPON CONVICTION) BEING A PUBLIC SERVANT, WITH INTENT TO OBTAIN A BENEFIT OR TO DEPRIVE ANOTHER PERSON OF A BENEFIT, COMMIT AN ACT RELATING TO HIS OFFICE BUT CONSTITUTING AN UNAUTHORIZED EXERCISE OF HIS OFFICIAL FUNCTIONS, KNOWING THAT SUCH ACT WAS UNAUTHORIZED. THE ABOVE OFFENSES WERE COMMITTED AS FOLLOWS: DEPONENT STATES THAT HE IS ASSIGNED TO THE INTERNAL AFFAIRS BUREAU OF THE NEW YO RK CITY POLICE DEPARTMENT AND IS CHARGED, IN PART, WITH INVESTIGATION OF ALLEGED CORRUPTION BY EMPLOYEES OF THE NEW YORK CITY POLICE DEPARTMENT. DEPONENT FURTH ER STATES THAT HE IS CURRENTLY ENGAGED IN THE INVESTIGATION OF ALLEGATIONS THAT EMPLOYEES OF THE NEW YORK CITY POLICE DEPARTMENT ARE ENGAGED IN THE PRACTICE OF SELLING ACCIDENT REPORTS AND INFORMATION CONTAINED THEREIN TO CIVILIANS WHO ARE REFERRED TO AS RUNNERS, WHO FIND ACCIDENT VICTIMS AND THEREAFTER BRING INJURED ACCIDENT VICTIMS TO PARTICULAR MEDICAL CLINICS AND PHYSICIANS AS PART OF A SCHE ME TO MAXIMIZE CASES INVOLVING INSURANCE PROVIDERS. DEPONENT STATES THAT ON ABOUT AND BETWEEN THE ABOVE CAPTIONED DATES, THE DEFENDA NT ROBERTO ESPINAL WAS EMPLOYED BY THE NEW YORK CITY POLICE DEPARTMENT AS A POLl CE OFFICER AND WAS ASSIGNED TO THE 110TH POLICE PRECINCT LOCATED AT 94-41 43RD A VENUE, ELMHURST, QUEENS COUNTY, NEW YORK. DEPONENT FURTHER STATES THAT EMPLOYEE S HOLDING THE RANK OF POLICE OFFICER ARE NOT AUTHORIZED TO SELL OR ACCEPT PERSON AL PAYMENT OF MONIES FOR NEW YORK CITY POLICE DEPARTMENT DOCUMENTS OR INFORMATIO N CONTAINED THEREIN. DEPONENT IS INFORMED BY A PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT A TTORNEY THAT ON MAY 20, 2013 AT APPROXIMATELY 0833 HOURS, SAID PERSON KNOWN TOT HE DEPONENT AND THE QUEENS DISTRICT ATTORNEY SENT A TEXT TO THE DEFENDANT ROBERT O ESPINAL REQUESTING A COPY OF THE POLICE ACCIDENT REPORT CONCERNING AN ACCIDENT VICTIM KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY, REFERRED TO HERE IN AS JANE DOE #1. DEPONENT IS INFORMED BY SAID PERSON KNOWN TO THE DEPONENT AN D THE QUEENS DISTRICT ATTORNEY THAT ON MAY 20, 2013 AT APPROXIMATELY 1334 HOURS, THE DEFENDANT POLICE OFFICER ROBERTO ESPINAL ADVISED THE PERSON KNOWN TO THE DE PONENT AND THE QUEENS DISTRICT ATTORNEY THAT HE HAD THE REQUESTED REPORT. DEPON ENT IS INFORMED BY SAID PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATT

ORNEY THAT ON MAY 20, 2013 AT APPROXIMATELY 1618 HOURS, THE DEFENDANT POLICE OFF ICER ROBERTO ESPINAL MET THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRIC T ATTORNEY AT JUNCTION BOULEVARD AND ROOSEVELT AVENUE, QUEENS COUNTY, NEW YORK W HERE THE DEFENDANT ENTERED THE VEHICLE OF SAID PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY AND GAVE THE PERSON KNOWN TO THE DEPONENT AND THE Q UEENS DISTRICT ATTORNEY AN OFFICIAL NEW YORK CITY POLICE DEPARTMENT ACCIDENT RE PORT, THE ASSIGNED NUMBER OF WHICH IS KNOWN TO THE DEPONENT AND THE QUEENS DISTR ICT ATTORNEYS OFFICE; FURTHER, SAID ACCIDENT REPORT CONTAINED, IN PART, THE NAM E AND ADDRESS OF AN ACCIDENT VICTIM REFERRED TO AS JANE DOE #1. DEPONENT STATES THAT HE HAS REVIEWED THE AFOREMENTIONED ACCIDENT REPORT AND FURTHER STATES THAT IT IS AN OFFICIAL NEW YORK CITY POLICE DEPARTMENT ACCIDENT REPORT. DEPONENT FU RTHER STATES THAT SAID ACCIDENT REPORT CONTAINED, IN PART, THE NAME AND ADDRESS OF AN ACCIDENT VICTIM REFERRED TO AS JANE DOE #1. DEPONENT IS INFORMED BY A PER SON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY THAT ON MAY 28, 2013 AT APPROXIMATELY 1553 HOURS, SAID PERSON KNOWN TO THE DEPONENT AND THE QUEENS DI STRICT ATTORNEY MET THE DEFENDANT ROBERTO ESPINAL ON THE NORTHEAST CORNER OF 135 TH STREET AND HOOVER AVENUE, QUEENS COUNTY, AT WHICH TIME SAID PERSON KNOWN TO T HE DEPONENT AND THE QUEENS DISTRICT ATTORNEY GAVE $40.00 TO THE DEFENDANT FOR PR OVIDING THE AFOREMENTIONED NEW YORK CITY POLICE DEPARTMENT ACCIDENT REPORT CONCE RNING JANE DOE #1. DEPONENT IS INFORMED BY A PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT A TTORNEY THAT ON JUNE 1, 2013 AT APPROXIMATELY 0944 HOURS, SAID PERSON KNOWN TO T HE DEPONENT AND THE QUEENS DISTRICT ATTORNEY SENT A TEXT TO THE DEFENDANT ROBERT O ESPINAL REQUESTING A COPY OF THE POLICE ACCIDENT REPORT CONCERNING AN ACCIDENT VICTIM KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY, REFERRED TO HERE IN AS JANE DOE #2. DEPONENT IS INFORMED BY SAID PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY THAT ON JUNE 3, 2013 AT APPROXIMATELY 1502 HOURS, THE DEFENDANT POLICE OFFICER ROBERTO ESPINAL ADVISED THE PERSON KNOWN TO THE DEP ONENT AND THE QUEENS DISTRICT ATTORNEY THAT HE HAD THE REQUESTED REPORT. DEPONENT IS INFORMED BY SAID PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRIC T ATTORNEY THAT ON JUNE 5, 2013 AT APPROXIMATELY 1130 HOURS, THE DEFENDANT POLIC E OFFICER ROBERTO ESPINAL MET THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DI STRICT ATTORNEY AT THE NORTHEAST CORNER OF 135TH STREET AND 82ND DRIVE, QUEENS C OUNTY, NEW YORK WHERE THE DEFENDANT ENTERED THE VEHICLE OF PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY AND GAVE THE PERSON KNOWN TO THE DEPON ENT AND THE QUEENS DISTRICT ATTORNEY AN OFFICIAL NEW YORK CITY POLICE DEPARTMENT ACCIDENT REPORT, THE ASSIGNED NUMBER OF WHICH IS KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEYS OFFICE; FURTHER, SAID ACCIDENT REPORT CONTAINED, IN P ART, THE NAME AND ADDRESS OF AN ACCIDENT VICTIM REFERRED TO AS JANE DOE #2. DEPO NENT IS INFORMED BY THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATT ORNEY GAVE THE DEFENDANT $40.00 IN EXCHANGE FOR THE AFOREMENTIONED ACCIDENT REPO RT. DEPONENT STATES THAT HE HAS REVIEWED THE AFOREMENTIONED ACCIDENT REPORT AND FURTHER STATES THAT IT IS AN OFFICIAL NEW YORK CITY POLICE DEPARTMENT ACCIDENT R EPORT AND FURTHER STATES THAT SAID REPORT CONTAINED, IN PART, THE NAME AND ADDRE SS OF AN ACCIDENT VICTIM REFERRED TO ABOVE AS JANE DOE #2. DEPONENT IS INFORMED BY A PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT A TTORNEY THAT ON JUNE 18, 2013 AT APPROXIMATELY 0831 HOURS, THE PERSON KNOWN TO T HE DEPONENT AND THE QUEENS DISTRICT ATTORNEY SENT A TEXT TO THE DEFENDANT ROBERT O ESPINAL REQUESTING A COPY OF THE POLICE ACCIDENT REPORT CONCERNING AN ACCIDENT VICTIM KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY, REFERRED TO HERE IN AS JOHN DOE #1. DEPONENT IS INFORMED BY THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY THAT ON JUNE 18, 2013 AT APPROXIMATELY 1658 HOURS, THE DEFENDANT POLICE OFFICER ROBERTO ESPINAL ADVISED THE PERSON KNOWN TO THE DEP ONENT AND THE QUEENS DISTRICT ATTORNEY HEREIN THAT HE HAD THE REQUESTED REPORT A ND CONFIRMED THE CORRECT NAME OF JOHN DOE #1. DEPONENT IS INFORMED BY THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY THAT ON JUNE 20, 2013 AT APPROXIMATELY 1735 HOURS, THE DEFENDANT POLIC E OFFICER ROBERTO ESPINAL MET THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DI STRICT ATTORNEY ON 85TH STREET APPROXIMATELY 75 FEET NORTH OF NORTHERN BOULEVARD QUEENS COUNTY, NEW YORK WHERE A PERSON KNOWN TO THE DEPONENT AND THE QUEENS DI STRICT ATTORNEY ENTERED THE DEFENDANTS VEHICLE AND THE DEFENDANT GAVE THE PERSO N KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY AN OFFICIAL NEW YORK C ITY POLICE DEPARTMENT ACCIDENT REPORT, THE ASSIGNED NUMBER OF WHICH IS KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEYS OFFICE; FURTHER, SAID ACCIDENT R EPORT CONTAINED, IN PART, THE NAME AND ADDRESS OF AN ACCIDENT VICTIM REFERRED TO AS JOHN DOE #1. DEPONENT STATES THAT HE HAS REVIEWED THE AFOREMENTIONED ACCIDE NT REPORT AND FURTHER STATES THAT IT IS AN OFFICIAL NEW YORK CITY POLICE DEPARTM ENT ACCIDENT REPORT. DEPONENT FURTHER STATES THAT SAID ACCIDENT REPORT CONTAINE D, IN PART, THE NAME AND ADDRESS OF AN ACCIDENT VICTIM REFERRED TO AS JOHN DOE # 1. DEPONENT IS INFORMED BY A PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRI CT ATTORNEY THAT SAID PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTO RNEY GAVE $40.00 TO THE DEFENDANT FOR THE PROVISION OF THE AFOREMENTIONED NEW YO RK CITY POLICE DEPARTMENT ACCIDENT REPORT CONCERNING JOHN DOE #1. DEPONENT IS INFORMED BY A PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT A TTORNEY THAT ON JULY 2, 2013 AT APPROXIMATELY 1222 HOURS, SAID PERSON KNOWN TOT HE DEPONENT AND THE QUEENS DISTRICT ATTORNEY SENT A TEXT TO THE DEFENDANT ROBERT O ESPINAL REQUESTING A COPY OF THE POLICE ACCIDENT REPORT CONCERNING AN ACCIDENT VICTIM KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY, REFERRED TO HERE

IN AS JOHN DOE #2.DEPONENT IS INFORMED BY THE PERSON KNOWN TO THE DEPONENT AND T HE QUEENS DISTRICT ATTORNEY THAT ON JULY 3, 2013 AT APPROXIMATELY 0857 HOURS, TH E DEFENDANT POLICE OFFICER ROBERTO ESPINAL CALLED AND ADVISED THE PERSON KNOWN T O THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY THAT THE REQUESTED REPORT WAS NO T READY. DEPONENT IS INFORMED BY THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY THAT ON JULY 5, 2013 AT APPROXIMATELY 1552 HOURS, THE DEFENDA NT POLICE OFFICER ROBERTO ESPINAL CALLED AND ADVISED THE PERSON KNOWN TO THE DEP ONENT AND THE QUEENS DISTRICT ATTORNEY HEREIN THAT THE REQUESTED REPORT WAS NOW READY. DEPONENT IS INFORMED BY A PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT A TTORNEY THAT ON JULY 5, 2013 AT APPROXIMATELY 1610 HOURS, THE PERSON KNOWN TO TH E DEPONENT AND THE QUEENS DISTRICT ATTORNEY MET THE DEFENDANT AT JUNCTION BOULEV ARD AND 40TH ROAD, QUEENS COUNTY; THAT THE DEFENDANT ENTERED THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEYS VEHICLE ON JUNCTION BOULEVARD W HERE THE DEFENDANT PROVIDED THE AFOREMENTIONED ACCIDENT REPORT CONCERNING JOHN D QE #2 AND IN EXCHANGE FOR THE SAID REPORT, THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY PAID THE $40.00 TO THE DEFENDANT IN EXCHANGE FOR PR OVIDING THE AFOREMENTIONED ACCIDENT REPORT. DEPONENT STATES THAT HE HAS REVIEWED THE AFOREMENTIONED ACCIDENT REPORT AND STATES THAT IT IS AN OFFICIAL NEW YORK C ITY POLICE DEPARTMENT ACCIDENT REPORT AND FURTHER STATES THAT SAID REPORT CONTAI NED, IN PART, THE NAME AND ADDRESS OF AN ACCIDENT VICTIM REFERRED TO ABOVE AS JO HN DOE #2.

DEPONENT IS INFORMED BY A PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT A TTORNEY THAT ON JULY 15, 2013 AT APPROXIMATELY 1204 HOURS, THE PERSON KNOWN TOT HE DEPONENT AND THE QUEENS DISTRICT ATTORNEY SENT A TEXT TO THE DEFENDANT ROBERT O ESPINAL REQUESTING A COPY OF THE POLICE ACCIDENT REPORT CONCERNING AN ACCIDENT VICTIM KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY, REFERRED TO HERE IN AS JOHN DOE #3. DEPONENT IS INFORMED BY A PERSON KNOWN TO THE DEPONENT AND T HE QUEENS DISTRICT ATTORNEY THAT ON JULY 17, 2013 AT APPROXIMATELY 1230 HOURS, T HE DEFENDANT MET THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORN EY ON JUNCTION BOULEVARD IN THE VICINITY OF 38TH AVENUE, QUEENS COUNTY; THAT THE DEFENDANT ENTERED THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTO RNEYS VEHICLE IN THE VICINITY OF JUNCTION BOULEVARD NORTH OF 38TH AVENUE, QUEEN S COUNTY. DEPONENT IS INFORMED BY A PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY THAT WHILE INSIDE THE VEHICLE THE DEFENDANT PROVIDED THE PERS ON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY WITH AN OFFICIAL NEW Y ORK CITY POLICE DEPARTMENT ACCIDENT REPORT CONCERNING THE ACCIDENT VICTIM REFERR ED TO HEREIN AS JOHN DOE #3, IN EXCHANGE FOR WHICH THE DEFENDANT WAS PAID $40.00 DEPONENT STATES THAT HE HAS REVIEWED THE AFOREMENTIONED ACCIDENT REPORT AND ST ATES THAT IT IS AN OFFICIAL NEW YORK CITY POLICE DEPARTMENT ACCIDENT REPORT AND FURTHER STATES THAT SAID REPORT CONTAINED, IN PART, THE NAME AND ADDRESS OF AN A CCIDENT VICTIM REFERRED TO ABOVE AS JANE DOE #3. DEPONENT IS INFORMED BY A PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT A TTORNEY THAT ON JULY 23, 2013 AT APPROXIMATELY 1330 HOURS, THE DEFENDANT SENT A TEXT MESSAGE TO THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNE Y WHICH INCLUDED INFORMATION CONCERNING AND ACCIDENT VICTIM, REFERRED TO HEREIN AS JOHN DOE #4. DEPONENT IS INFORMED BY A PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY THAT ON AUGUST 1, 2013 AT APPROXIMATELY 1511 HOURS, THE DEFENDANT MET THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY IN FRONT OF 37-58 JUNCTION BOULEVARD WHERE THE DEFENDANT ENTERED THE VEHICLE OF THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY. DEPONENT IS FURTHER INFORMED BY A PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTO RNEY THAT IN EXCHANGE FOR THE PREVIOUSLY PROVIDED INFORMATION FROM AN NEW YORK C ITY POLICE DEPARTMENT ACCIDENT REPORT CONCERNING JOHN DOE #4, THE PERSON KNOWN T O THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY PAID THE $500.00 TO THE DEFENDAN T. DEPONENT STATES THAT HE HAS REVIEWED THE ACCIDENT REPORT THAT CONTAINED THE I NFORMATION REGARDING JOHN DOE #4 AND STATES THAT IT IS AN OFFICIAL NEW YORK CITY POLICE DEPARTMENT ACCIDENT REPORT AND FURTHER STATES THAT SAID REPORT CONTAINED IN PART, THE NAME AND CONTACT INFORMATION OF AN ACCIDENT VICTIM REFERRED TO AB OVEAS JOHN DOE #4.

DEPONENT IS INFORMED BY A PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT A TTORNEY THAT ON AUGUST 2, 2013 AT APPROXIMATELY 0826 HOURS, THE DEFENDANT SENT A TEXT MESSAGE TO THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT AHORN EY WHICH PROVIDED CONTACT INFORMATION REGARDING AN ACCIDENT VICTIM KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY, REFERRED TO HEREIN AS JOHN DOE #5. DE PONENT IS INFORMED BY A PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATT ORNEY THAT ON AUGUST 5, 2013 AT APPROXIMATELY 1600 HOURS, THE DEFENDANT ROBERTO ESPINAL MET WITH THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORN EY AT WHICH TIME THE DEFENDANT GAVE TO THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY A COPY OF THE NEW YORK CITY POLICE DEPARTMENT ACCIDENT REPORT REGARDING JOHN DOE #5. DEPONENT IS INFORMED BY A PERSON KNOWN TO THE DEP ONENT AND THE QUEENS DISTRICT ATTORNEY THAT ON AUGUST 8, 2013 AT APPROXIMATELY 1 340 HOURS, THE DEFENDANT MET THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DIS TRICT ATTORNEY IN THE VICINITY OF JUNCTION BOULEVARD AND ROOSEVELT AVENUE, QUEEN S COUNTY, WHERE THE DEFENDANT ENTERED THE VEHICLE OF THE PERSON KNOWN TO THE DE PONENT AND THE QUEENS DISTRICT ATTORNEY. DEPONENT IS FURTHER INFORMED BY A PERS

ON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY THAT THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY PAID $800.00 TO THE DEFENDANT IN EXCHANGE FOR PROVIDING THE AFOREMENTIONED ACCIDENT REPORT, AND NAME OF THE AC CIDENT VICTIM. DEPONENT STATES THAT HE HAS REVIEWED THE AFOREMENTIONED ACCIDENT REPORT AND STAT ES THAT IT IS AN OFFICIAL NEW YORK CITY POLICE DEPARTMENT ACCIDENT REPORT AND FU RTHER STATES THAT SAID REPORT CONTAINED, IN PART, THE NAME AND CONTACT INFORMATI ON OF AN ACCIDENT VICTIM REFERRED TO ABOVE AS JOHN DOE #5. DEPONENT IS INFORMED BY A PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT A TTORNEY THAT ON SEPTEMBER 15, 2013, THE PERSON KNOWN TO THE DEPONENT AND THE QUE ENS DISTRICT ATTORNEY CONTACTED THE DEFENDANT ROBERTO ESPINAL AND REQUESTED AN A CCIDENT REPORT REGARDING AN ACCIDENT VICTIM REFERRED TO HEREIN AS JOHN DOE #6. DEPONENT IS INFORMED BY A PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT A TTORNEY THAT ON SEPTEMBER 18, 2013 AT 1220 HOURS, THE DEFENDANT MET THE PERSON K NOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY AT THE NORTHEAST CORNER OF 135TH STREET AND HOOVER AVENUE, QUEENS COUNTY, WHERE THE DEFENDANT GAVE THE PER SON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY THE REQUESTED NEW YOR K CITY POLICE DEPARTMENT ACCIDENT REPORT REGARDING JOHN DOE #6. DEPONENT IS FUR THER INFORMED BY THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORN EY THAT IN EXCHANGE FOR THE AFOREMENTIONED ACCIDENT REPORT, THE PERSON KNOWN TO THE DEPONENT AND THE QUEENS DISTRICT ATTORNEY GAVE THE DEFENDANT $40.00 UNITED S TATES CURRENCY. DEPONENT STATES THAT HE RECOVERED FROM THE DEFENDANT THE AFOREM ENTIONED $40.00. DEPONENT STATES THAT HE HAS REVIEWED THE AFOREMENTIONED NEW YO RK CITY POLICE DEPARTMENT ACCIDENT REPORT REGARDING JOHN DOE #6 AND STATES THAT IT IS A COPY OF A NEW YORK CITY POLICE DEPARTMENT ACCIDENT REPORT.

You might also like