SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK THE PEOPLE OF THE STATE OF NEW YORK

-againstDan Sandler, Defendant.

THE GRAND JURY OF THE COUNTY OF NEW YORK, by this indictment, accuses the defendant of the crime of AN ATTEMPT TO COMMIT THE CRIME OF GRAND LARCENY IN THE FIRST DEGREE, in violation of Penal Law 110/155.42, committed as follows: The defendant, in the County of New York, during the period from on or about September 28, 2012 to on or about April 16, 2013, attempted to steal property, by extortion, from the Girl Scouts of the USA and the value of the property exceeded one million dollars.

SECOND COUNT: AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of AGGRAVATED HARASSMENT IN THE SECOND DEGREE, in violation of Penal Law 240.30(1)(a), committed as follows: The defendant, in the County of New York, during the period from on or about July 5, 2012 to on or about April 17, 2013, with intent to harass, annoy, threaten and alarm communicated with ,

anonymously and otherwise, by telephone, mail and any form of

written communication, in a manner likely to cause annoyance and alarm.

THIRD COUNT: AND THE GRAND JURY AFORESAID, by this indictment, further accuses the defendant of the crime of STALKING IN THE THIRD DEGREE, in violation of Penal Law 120.50(3), committed as follows: The defendant, in the County of New York, during the period from on or about July 5, 2012 to on or about April 17, 2013, with intent to harass, annoy and alarm engaged in a course of conduct directed at , intentionally

, in a manner which was likely to cause

to reasonably fear physical injury or serious physical injury, the commission of a sex offense against, or the kidnapping, unlawful imprisonment or death of herself or a member of her immediate family.

CYRUS R. VANCE, JR. District Attorney