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STATE OF NEW YORK

TOWN COURT

COUNTY OF MONROE
TOWN OF HENRIETTA

Complaint # ________

The People of the State of New York


-againstKENNETH C. YOUNGREN
4 Spruce St Alfred, NY 14802

FELONY
COMPLAINT

DOB; 12/10/1985

KORDELL J. JACKSON
DOB: 12/30/1975
107 Grangerford Heights, West Henrietta, NY 14586
Defendants

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, did
commit 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 as
Jackson 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
01/18/2013
01/21/2013
01/22/2013
01/28/2013
01/28/2013
02/01/2013

Bushmaster
FN
ARFCOM
DPMS
Mossberg
Stag Arms
Smith and Wesson

XM15-E25
AR
AR15
Panther
715T
Model 3
M&P 15-22

L076509
319ZM03335
ARF000152
15032
ELI3482533
195955
DYY6780

02/08/2013
02/11/2013
02/13/2013
02/15/2013
02/18/2013
02/18/2013
02/18/2013
02/19/2013
02/19/2013
02/20/2013
02/27/2013
03/06/2013
03/12/2013
03/18/2013
03/19/2013
04/30/2013
05/20/2013
07/09/2013
07/22/2013
08/20/2013

Mossberg
Century Arms
Stag Arms
German Sport Gun
DPMS
Mossberg
Mossberg
Mossberg
Mossberg
Hi Point
Windham Weaponry
Windham Weaponry
Keltec
Armalite
Smith and Wesson
Smith and Wesson
Hi Point
Diamondback
Hi Point
UMA

715T
WASR10
Model 2
522CB
LR308
715T
715T
715T
715T
995TS
M4
R16M4CH
Sub29
AR10
M&P 15
M&P 15
4595FGTS
DB15
995
Uzi/Israel

ELK3557669
1980KV2300
28888
A497368
7381
ELK3558107
ELK3558301
ELK3558037
ELK3558156
F16342
WW070903
WW074743
EGG65
US385862
04587
56896
R20383
DB1505042
E23551
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 State
Police, 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 Firearms
Transaction 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 Class
A 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