STATE OF NEW YORK

SUPREME/COUNTY COURT : COUNTY OF ERIE

THE PEOPLE OF THE STATE OF NEW YORK,

-v- SEALED INDICTMENT

Defendants.
_____________________________________________________

FIRST COUNT

THE GRAND JURY OF THE COUNTY OF ERIE, by this Indictment, accuses the

defendants, RONNIE CASON, MICHAEL CLARK, JR., MELANIE DUCHNIK, ANTHONY

FUGATE, TEVIN JETER, DEVON JONES, A/K/A “DUTCH,” JASPER LEWIS, NEGMARIE

MARCANO, MICHAEL MCPHEE, MUSA RAMADAN, ERIC RICHMOND, CHARLES

SIMS, and RONALD WASHINGTON, of the crime of CONSPIRACY IN THE SECOND

DEGREE, in violation of Section 105.15 of the Penal Law of the State of New York, committed

as follows:

The defendants, in Erie County, Monroe County, Niagara County, in the State of New York

and elsewhere, from on or before August 4, 2021, through on or about March 28, 2022, with intent
that conduct constituting the crimes of Criminal Possession of a Controlled Substance in the First

Degree, Criminal Possession of a Controlled Substance in the Second Degree, Criminal Sale of a

Controlled Substance in the First Degree, and/or Criminal Sale of a Controlled Substance in the

Second Degree, said crimes being Class A felonies, be committed, did knowingly and intentionally

agree with each other and with others, known and unknown, to engage in and cause the

performance of such conduct as would constitute any one or more of the above-mentioned class A

felonies.

PREAMBLE

It was the purpose of this conspiracy to possess narcotics in amounts of four ounces or

more and/or to sell narcotics in amounts of one-half ounce or more in Erie County, Monroe County,

Niagara County, and elsewhere in the State of New York, and elsewhere.

It was the role of CHARLES SIMS to procure narcotics from MUSA RAMADAN, ERIC

RICHMOND, TEVIN JETER, and others for redistribution to DEVON JONES, A/K/A

“DUTCH,” JASPER LEWIS, MICHAEL MCPHEE, GREGORY MILLER and others.

It was the role of MUSA RAMADAN to supply CHARLES SIMS, NEGMARIE

MARCANO, RONALD WASHINGTON, and others with narcotics to sell.

It was the role of ERIC RICHMOND to supply CHARLES SIMS and others with narcotics

to sell.

It was the role of ANTHONY FUGATE to procure narcotics from MICHAEL CLARK,

JR. and others for redistribution to MELANIE DUCHNIK, RONNIE CASON, and others.

It was the role of MICHAEL CLARK, JR. to supply ANTHONY FUGATE, MELANIE

DUCHNIK, GREGORY MILLER and others with narcotics to sell.

It was the role of TEVIN JETER to supply CHARLES SIMS and others with narcotics to

sell.

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 It was the role of DEVON JONES, A/K/A “DUTCH,” JASPER LEWIS, and MICHAEL

MCPHEE to procure narcotics from CHARLES SIMS for redistribution to others.

It was the role of NEGMARIE MARCANO and RONALD WASHINGTON to procure

narcotics from MUSA RAMADAN for redistribution to others.

It was the role of MELANIE DUCHNIK and RONNIE CASON to procure narcotics from

MICHAEL CLARK, JR. and ANTHONY FUGATE for redistribution to others.

It was also part of this conspiracy for members of the conspiracy to communicate with each

other and others over cellular telephones, using codes and speaking in a guarded, cryptic manner.

OVERT ACTS

In furtherance of the conspiracy and to affect the objects thereof, from on or about and

between August 4, 2021, through on or about March 28, 2022, the following overt acts, among

others, were committed:

1. On or about August 18, 2021, CHARLES SIMS delivered cocaine to Gregory

Miller, who is an unindicted co-conspirator, in the city of Buffalo, and waited as Miller

immediately sold the cocaine to a person known to the grand jury.

2. On or about August 20, 2021, MICHAEL CLARK, JR. delivered pills containing

fentanyl to Gregory Miller, who is an unindicted co-conspirator, in the city of Buffalo, and waited

as Miller immediately sold the controlled substances to a person known to the grand jury.

3. On or about September 14, 2021, MICHAEL CLARK, JR. delivered pills

containing fentanyl to Gregory Miller, who is an unindicted co-conspirator, in the city of Buffalo,

and waited as Miller immediately sold the controlled substances to a person known to the grand

jury.

4. On or about November 10, 2021, in a series of coded, guarded and/or cryptic

telephone conversations, ANTHONY FUGATE ordered “fifty”, referring to a quantity of pills

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containing fentanyl, from MICHAEL CLARK, JR. on behalf of one of his customers, and then

arranged for MICHAEL CLARK, JR. to deliver the pills to directly the customer.

5. On or about November 23, 2021, in a series of coded, guarded and/or cryptic

telephonic communications, MELANIE DUCHNIK ordered “100”, referring to a quantity of pills

containing fentanyl, from ANTHONY FUGATE.

6. On or about November 23, 2021, in a series of coded, guarded and/or cryptic

telephonic communications, TEVIN JETER and CHARLES SIMS discussed JETER’s collection

of money from SIMS on behalf of “Primo”, JETER’S cocaine source of supply of cocaine.

7. On or about November 23, 2021, TEVIN JETER met CHARLES SIMS at SIMS’

residence in the city of Buffalo in furtherance of their narcotics trafficking activities.

8. On or about December 8, 2021, RONNIE CASON possessed approximately 50

counterfeit prescription pills containing a narcotic drug.

9. On or about December 8, 2021, in a series of coded, guarded and/or cryptic

telephone conversations, MELANIE DUCHNIK told ANTHONY FUGATE, “Lay low, my dude

left and got pulled over,” referring to law enforcement’s interdiction of RONNIE CASON earlier

that evening.

10. On or about December 23, 2021, JASPER LEWIS drove to CHARLES SIMS’

residence in the city of Buffalo to procure cocaine.

11. On or about January 3, 2022, in a series of coded, guarded and/or cryptic telephone

conversations, MICHAEL MCPHEE ordered a quantity of cocaine from CHARLES SIMS.

12. On or about January 3, 2022, JASPER LEWIS drove to CHARLES SIMS’

residence in the city of Buffalo to procure cocaine from SIMS on behalf of MICHAEL MCPHEE.

13. On or about January 18, 2022, ERIC RICHMOND delivered a quantity of cocaine

to CHARLES SIMS at SIMS’ residence in the city of Buffalo.

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 14. On or about January 19, 2022, in a coded, guarded and/or cryptic telephone

conversation, ERIC RICHMOND and CHARLES SIMS discussed the quality of the cocaine that

RICHMOND had previously delivered to SIMS, with RICHMOND stating, “that shit is like A-

one though.” SIMS agreed and noted, “… the look and … my smelling, knowing coke and knowing

what it feels like … it’s, it’s great.”

15. On or about February 2, 2022, in a coded, guarded and/or cryptic telephone

conversation, DEVON JONES, A/K/A “DUTCH,” asked CHARLES SIMS, “What was you

gimme for the deuce?”, referring to two ounces of cocaine, and SIMS replied, “twenty two fifty,”

meaning $2,250.

16. On or about February 9, 2022, DEVON JONES, A/K/A “DUTCH,” drove to

CHARLES SIMS’ residence in the city of Buffalo to procure cocaine from SIMS.

17. On or about February 16, 2022, in a coded, guarded and/or cryptic telephone

conversation, NEGMARIE MARCANO placed an order for a controlled substance with MUSA

RAMADAN, and noted that she needs “three of the small ones, but the other way. Not fentanyl.”

18. On or about February 16, 2022, in a coded, guarded and/or cryptic telephone

conversation, NEGMARIE MARCANO asked MUSA RAMADAN how much it would cost for

“nine pieces of chicken”, referring to a quantity of cocaine, and RAMADAN replied, “four, eight

each.”

19. On or about February 16, 2022, in a series of coded, guarded and/or cryptic

telephone communications, MICHAEL MCPHEE arranged to purchase cocaine from CHARLES

SIMS and asked SIMS to deliver the cocaine to him.

20. On or about February 17, 2022, in a series of coded, guarded and/or cryptic

telephone conversations, MUSA RAMADAN arranged to procure narcotics proceeds from

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CHARLES SIMS, who noted that he presently had “twenty-eight,” referring to $28,000, and was

still waiting for other customers.

21. On or about March 4, 2022, in a coded, guarded and/or cryptic telephone

conversation, RONALD WASHINGTON asked MUSA RAMADAN to supply him with cocaine

and noted that his customers had complained that the cocaine that RAMADAN had previously

supplied to him was “shaky.”

22. On or about March 7, 2022, CHARLES SIMS delivered a quantity of cocaine to

MICHAEL MCPHEE in Lockport, Niagara County, New York.

23. On or about March 25, 2022, RONALD WASHINGTON drove to MUSA

RAMADAN’s residence in the city of Buffalo to procure cocaine from RAMADAN.

24. On or about March 28, 2022, CHARLES SIMS possessed more than four ounces

of cocaine at his residence in the city of Buffalo.

25. On or about March 28, 2022, MUSA RAMADAN possessed more than eight

ounces of cocaine at his residence in the city of Buffalo.

SECOND COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.43(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

18th day of August 2021, in Erie County, knowingly and unlawfully sold one or more preparations,

compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and said

preparations, compounds, mixtures or substances were of an aggregate weight of two ounces or

more.

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 THIRD COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

18th day of August 2021, in Erie County, knowingly and unlawfully possessed a narcotic drug, to

wit: cocaine, with the intent to sell it.

FOURTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(12)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

18th day of August 2021, in Erie County, knowingly and unlawfully possessed one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of one-half

ounce or more.

FIFTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MICHAEL CLARK, JR., of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE SECOND DEGREE, in violation of Section 220.41(1)

of the Penal Law of the State of New York, in that he, the said MICHAEL CLARK, JR., on or

about the 20th day of August 2021, in Erie County, knowingly and unlawfully sold one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: fentanyl, and

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said preparations, compounds, mixtures or substances were of an aggregate weight of one-half

ounce or more.

SIXTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MICHAEL CLARK, JR., of the crime of CRIMINAL POSSESSION OF

A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said MICHAEL CLARK, JR., on or

about the 20th day of August 2021, in Erie County, knowingly and unlawfully possessed a narcotic

drug, to wit: fentanyl, with the intent to sell it.

SEVENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MICHAEL CLARK, JR., of the crime of CRIMINAL POSSESSION OF

A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section

220.16(12) of the Penal Law of the State of New York, in that he, the said MICHAEL CLARK,

JR., on or about the 20th day of August 2021, in Erie County, knowingly and unlawfully possessed

one or more preparations, compounds, mixtures or substances containing a narcotic drug, to wit:

fentanyl, and said preparations, compounds, mixtures or substances were of an aggregate weight

of one-half ounce or more.

EIGHTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MICHAEL CLARK, JR., of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE SECOND DEGREE, in violation of Section 220.41(1)

of the Penal Law of the State of New York, in that he, the said MICHAEL CLARK, JR., on or

about the 14th day of September 2021, in Erie County, knowingly and unlawfully sold one or more

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preparations, compounds, mixtures or substances containing a narcotic drug, to wit: fentanyl, and

said preparations, compounds, mixtures or substances were of an aggregate weight of one-half

ounce or more.

NINTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MICHAEL CLARK, JR., of the crime of CRIMINAL POSSESSION OF

A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said MICHAEL CLARK, JR., on or

about the 14th day of September 2021, in Erie County, knowingly and unlawfully possessed a

narcotic drug, to wit: fentanyl, with the intent to sell it.

TENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MICHAEL CLARK, JR., of the crime of CRIMINAL POSSESSION OF

A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section

220.16(12) of the Penal Law of the State of New York, in that he, the said MICHAEL CLARK,

JR., on or about the 14th day of September 2021, in Erie County, knowingly and unlawfully

possessed one or more preparations, compounds, mixtures or substances containing a narcotic

drug, to wit: fentanyl, and said preparations, compounds, mixtures or substances were of an

aggregate weight of one-half ounce or more.

ELEVENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MICHAEL CLARK, JR., of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE SECOND DEGREE, in violation of Section 220.41(1)

of the Penal Law of the State of New York, in that he, the said MICHAEL CLARK, JR., on or

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about the 3rd day of November 2021, in Erie County, knowingly and unlawfully sold one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: fentanyl, and

said preparations, compounds, mixtures or substances were of an aggregate weight of one-half

ounce or more.

TWELFTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MICHAEL CLARK, JR., of the crime of CRIMINAL POSSESSION OF

A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said MICHAEL CLARK, JR., on or

about the 3rd day of November 2021, in Erie County, knowingly and unlawfully possessed a

narcotic drug, to wit: fentanyl, with the intent to sell it.

THIRTEENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MICHAEL CLARK, JR., of the crime of CRIMINAL POSSESSION OF

A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section

220.16(12) of the Penal Law of the State of New York, in that he, the said MICHAEL CLARK,

JR., on or about the 3rd day of November 2021, in Erie County, knowingly and unlawfully

possessed one or more preparations, compounds, mixtures or substances containing a narcotic

drug, to wit: fentanyl, and said preparations, compounds, mixtures or substances were of an

aggregate weight of one-half ounce or more.

FOURTEENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.43(1)

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of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

4th day of November 2021, in Erie County, knowingly and unlawfully sold one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of two ounces

or more.

FIFTEENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE SECOND DEGREE, in violation of Section 220.18(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

4th day of November 2021, in Erie County, knowingly and unlawfully possessed one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of four ounces

or more.

SIXTEENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

4th day of November 2021, in Erie County, knowingly and unlawfully possessed a narcotic drug,

to wit: cocaine, with the intent to sell it.

SEVENTEENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendants, MICHAEL CLARK, JR. and ANTHONY FUGATE, of the crime of

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CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in

violation of Section 220.39(1) of the Penal Law of the State of New York, in that they, the said

MICHAEL CLARK, JR. and ANTHONY FUGATE, acting in concert, on or about the 11th day

of November 2021, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit:

fentanyl.

EIGHTEENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about and

between the 11th and 13th days of November 2021, in Erie County, knowingly and unlawfully sold

a narcotic drug, to wit: cocaine.

NINETEENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendants, MICHAEL CLARK, JR. and ANTHONY FUGATE, of the crime of

CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in

violation of Section 220.39(1) of the Penal Law of the State of New York, in that they, the said

MICHAEL CLARK, JR. and ANTHONY FUGATE, acting in concert, on or about the 12th day

of November 2021, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit:

fentanyl.

TWENTIETH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendants, MICHAEL CLARK, JR. and ANTHONY FUGATE, of the crime of

CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in

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violation of Section 220.39(1) of the Penal Law of the State of New York, in that they, the said

MICHAEL CLARK, JR. and ANTHONY FUGATE, acting in concert, on or about the 14th day

of November 2021, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit:

fentanyl.

TWENTY-FIRST COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendants, MICHAEL CLARK, JR. and ANTHONY FUGATE, of the crime of

CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in

violation of Section 220.39(1) of the Penal Law of the State of New York, in that they, the said

MICHAEL CLARK, JR. and ANTHONY FUGATE, acting in concert, on or about the 16th day

of November 2021, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit:

fentanyl.

TWENTY-SECOND COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MELANIE DUCHNIK, of the crime of CRIMINAL POSSESSION OF

A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that she, the said MELANIE DUCHNIK, on or

about the 16th day of November 2021, in Erie County, knowingly and unlawfully possessed a

narcotic drug, to wit: fentanyl, with the intent to sell it.

TWENTY-THIRD COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, ANTHONY FUGATE, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said ANTHONY FUGATE, on or about

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the 20th day of November 2021, in Erie County, knowingly and unlawfully sold a narcotic drug,

to wit: fentanyl.

TWENTY-FOURTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MELANIE DUCHNIK, of the crime of ATTEMPTED CRIMINAL

POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation

of Sections 110.00 and 220.16(1) of the Penal Law of the State of New York, in that she, the said

MELANIE DUCHNIK, on or about the 20th day of November 2021, in Erie County, knowingly

and unlawfully attempted to possess a narcotic drug, to wit: fentanyl, with the intent to sell it.

TWENTY-FIFTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, TEVIN JETER, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.43(1)

of the Penal Law of the State of New York, in that he, the said TEVIN JETER, on or about and

between the 21st and 22nd days of November 2021, in Erie County, knowingly and unlawfully sold

one or more preparations, compounds, mixtures or substances containing a narcotic drug, to wit:

cocaine, and said preparations, compounds, mixtures or substances were of an aggregate weight

of two ounces or more.

TWENTY-SIXTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, TEVIN JETER, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said TEVIN JETER, on or about and

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between the 21st and 22nd days of November 2021, in Erie County, knowingly and unlawfully sold

a narcotic drug, to wit: cocaine.

TWENTY-SEVENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, TEVIN JETER, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.21(1)

of the Penal Law of the State of New York, in that he, the said TEVIN JETER, on or about and

between the 21st and 22nd days of November 2021, in Erie County, knowingly and unlawfully

possessed one or more preparations, compounds, mixtures or substances containing a narcotic

drug, to wit: cocaine, and said preparations, compounds, mixtures or substances were of an

aggregate weight of eight ounces or more.

TWENTY-EIGHTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, TEVIN JETER, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said TEVIN JETER, on or about and

between the 21st and 22nd days of November 2021, in Erie County, knowingly and unlawfully

possessed a narcotic drug, to wit: cocaine, with the intent to sell it.

TWENTY-NINTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.21(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

22nd day of November 2021, in Erie County, knowingly and unlawfully possessed one or more

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preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of eight ounces

or more.

THIRTIETH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

22nd day of November 2021, in Erie County, knowingly and unlawfully possessed a narcotic drug,

to wit: cocaine, with the intent to sell it.

THIRTY-FIRST COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendants, MICHAEL CLARK, JR. and ANTHONY FUGATE, of the crime of

CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in

violation of Section 220.39(1) of the Penal Law of the State of New York, in that they, the said

MICHAEL CLARK, JR. and ANTHONY FUGATE, acting in concert, on or about the 23rd day of

November 2021, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit: fentanyl.

THIRTY-SECOND COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MELANIE DUCHNIK, of the crime of ATTEMPTED CRIMINAL

POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation

of Sections 110.00 and 220.16(1) of the Penal Law of the State of New York, in that she, the said

MELANIE DUCHNIK, on or about the 23rd day of November 2021, in Erie County, knowingly

and unlawfully attempted to possess a narcotic drug, to wit: fentanyl, with the intent to sell it.

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 THIRTY-THIRD COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.43(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

23rd day of November 2021, in Erie County, knowingly and unlawfully sold one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of two ounces

or more.

THIRTY-FOURTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

23rd day of November 2021, in Erie County, knowingly and unlawfully sold a narcotic drug, to

wit: cocaine.

THIRTY-FIFTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.43(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

23rd day of November 2021, in Erie County, knowingly and unlawfully sold one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of two ounces

17
or more.

THIRTY-SIXTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

23rd day of November 2021, in Erie County, knowingly and unlawfully sold a narcotic drug, to

wit: cocaine.

THIRTY-SEVENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendants, MICHAEL CLARK, JR. and ANTHONY FUGATE, of the crime of

CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in

violation of Section 220.39(1) of the Penal Law of the State of New York, in that they, the said

MICHAEL CLARK, JR. and ANTHONY FUGATE, acting in concert, on or about the 24th day of

November 2021, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit: fentanyl.

THIRTY-EIGHTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MELANIE DUCHNIK, of the crime of ATTEMPTED CRIMINAL

POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation

of Sections 110.00 and 220.16(1) of the Penal Law of the State of New York, in that she, the said

MELANIE DUCHNIK, on or about the 24th day of November 2021, in Erie County, knowingly

and unlawfully attempted to possess a narcotic drug, to wit: fentanyl, with the intent to sell it.

THIRTY-NINTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

18
accuses the defendants, MICHAEL CLARK, JR. and ANTHONY FUGATE, of the crime of

CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in

violation of Section 220.39(1) of the Penal Law of the State of New York, in that they, the said

MICHAEL CLARK, JR. and ANTHONY FUGATE, acting in concert, on or about the 28th day of

November 2021, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit: fentanyl.

FORTIETH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MELANIE DUCHNIK, of the crime of ATTEMPTED CRIMINAL

POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation

of Sections 110.00 and 220.16(1) of the Penal Law of the State of New York, in that she, the said

MELANIE DUCHNIK, on or about the 28th day of November 2021, in Erie County, knowingly

and unlawfully attempted to possess a narcotic drug, to wit: fentanyl, with the intent to sell it.

FORTY-FIRST COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendants, MICHAEL CLARK, JR. and ANTHONY FUGATE, of the crime of

CRIMINAL SALE OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in

violation of Section 220.39(1) of the Penal Law of the State of New York, in that they, the said

MICHAEL CLARK, JR. and ANTHONY FUGATE, acting in concert, on or about the 3rd day of

December 2021, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit: fentanyl.

FORTY-SECOND COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MELANIE DUCHNIK, of the crime of ATTEMPTED CRIMINAL

POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation

of Sections 110.00 and 220.16(1) of the Penal Law of the State of New York, in that she, the said

19
MELANIE DUCHNIK, on or about the 3rd day of December 2021, in Erie County, knowingly and

unlawfully attempted to possess a narcotic drug, to wit: fentanyl, with the intent to sell it.

FORTY-THIRD COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, ANTHONY FUGATE, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said ANTHONY FUGATE, on or about

the 8th day of December 2021, in Erie County, knowingly and unlawfully sold a narcotic drug, to

wit: a fentanyl analog.

FORTY-FOURTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendants, RONNIE CASON and MELANIE DUCHNIK, of the crime of

CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD

DEGREE, in violation of Section 220.16(1) of the Penal Law of the State of New York, in that

they, the said RONNIE CASON and MELANIE DUCHNIK, acting in concert, on or about the 8th

day of December 2021, in Erie County, knowingly and unlawfully possessed a narcotic drug, to

wit: a fentanyl analog, with the intent to sell it.

FORTY-FIFTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendants, RONNIE CASON and MELANIE DUCHNIK, of the crime of

CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE FOURTH

DEGREE, in violation of Section 220.09(1) of the Penal Law of the State of New York, in that

they, the said RONNIE CASON and MELANIE DUCHNIK, acting in concert, on or about the 8th

day of December 2021, in Erie County, knowingly and unlawfully possessed one or more

20
preparations, compounds, mixtures or substances containing a narcotic drug, to wit: a fentanyl

analog, and said preparations, compounds, mixtures or substances were of an aggregate weight of

one-eighth ounce or more.

FORTY-SIXTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

23rd day of December 2021, in Erie County, knowingly and unlawfully sold a narcotic drug, to

wit: cocaine.

FORTY-SEVENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, JASPER LEWIS, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said JASPER LEWIS, on or about the

23rd day of December 2021, in Erie County, knowingly and unlawfully possessed a narcotic drug,

to wit: cocaine, with the intent to sell it.

FORTY-EIGHTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.43(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

3rd day of January 2022, in Erie County, knowingly and unlawfully sold one or more preparations,

compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and said

21
preparations, compounds, mixtures or substances were of an aggregate weight of two ounces or

more.

FORTY-NINTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

3rd day of January 2022, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit:

cocaine.

FIFTIETH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendants, MICHAEL MCPHEE and JASPER LEWIS, of the crime of CRIMINAL

POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation

of Section 220.16(1) of the Penal Law of the State of New York, in that they, the said MICHAEL

MCPHEE and JASPER LEWIS, acting in concert, on or about the 3rd day of January 2022, in Erie

County and elsewhere, knowingly and unlawfully possessed a narcotic drug, to wit: cocaine, with

the intent to sell it.

FIFTY-FIRST COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendants, MICHAEL MCPHEE and JASPER LEWIS, of the crime of CRIMINAL

POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation

of Section 220.16(12) of the Penal Law of the State of New York, in that they, the said MICHAEL

MCPHEE and JASPER LEWIS, acting in concert, on or about the 3rd day of January 2022, in Erie

County and elsewhere, knowingly and unlawfully possessed one or more preparations,

22
compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and said

preparations, compounds, mixtures or substances were of an aggregate weight of one-half ounce

or more.

FIFTY-SECOND COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, ERIC RICHMOND, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.43(1)

of the Penal Law of the State of New York, in that he, the said ERIC RICHMOND, on or about

the 18th day of January 2022, in Erie County, knowingly and unlawfully sold one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of two ounces

or more.

FIFTY-THIRD COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, ERIC RICHMOND, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said ERIC RICHMOND, on or about

the 18th day of January 2022, in Erie County, knowingly and unlawfully sold a narcotic drug, to

wit: cocaine.

FIFTY-FOURTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, ERIC RICHMOND, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.21(1)

of the Penal Law of the State of New York, in that he, the said ERIC RICHMOND, on or about

23
the 18th day of January 2022, in Erie County, knowingly and unlawfully possessed one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of eight ounces

or more.

FIFTY-FIFTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, ERIC RICHMOND, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said ERIC RICHMOND, on or about

the 18th day of January 2022, in Erie County, knowingly and unlawfully possessed a narcotic drug,

to wit: cocaine, with the intent to sell it.

FIFTY-SIXTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.21(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

18th day of January 2022, in Erie County, knowingly and unlawfully possessed one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of eight ounces

or more.

FIFTY-SEVENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

24
of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

18th day of January 2022, in Erie County, knowingly and unlawfully possessed a narcotic drug, to

wit: cocaine, with the intent to sell it.

FIFTY-EIGHTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

20th day of January 2022, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit:

cocaine.

FIFTY-NINTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

20th day of January 2022, in Erie County, knowingly and unlawfully possessed a narcotic drug, to

wit: cocaine, with the intent to sell it.

SIXTIETH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, ERIC RICHMOND, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.21(1)

of the Penal Law of the State of New York, in that he, the said ERIC RICHMOND, on or about

the 22nd day of January 2022, in Erie County, knowingly and unlawfully possessed one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

25
said preparations, compounds, mixtures or substances were of an aggregate weight of eight ounces

or more.

SIXTY-FIRST COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, ERIC RICHMOND, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said ERIC RICHMOND, on or about

the 22nd day of January 2022, in Erie County, knowingly and unlawfully possessed a narcotic drug,

to wit: cocaine, with the intent to sell it.

SIXTY-SECOND COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.43(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

and between the 25th and 29th days of January 2022, in Erie County, knowingly and unlawfully

sold one or more preparations, compounds, mixtures or substances containing a narcotic drug, to

wit: cocaine, and said preparations, compounds, mixtures or substances were of an aggregate

weight of two ounces or more.

SIXTY-THIRD COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

26
and between the 25th and 29th days of January 2022, in Erie County, knowingly and unlawfully

sold a narcotic drug, to wit: cocaine.

SIXTY-FOURTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.21(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN on or about

the 29th day of January 2022, in Erie County, knowingly and unlawfully possessed one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of eight ounces

or more.

SIXTY-FIFTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

the 29th day of January 2022, in Erie County, knowingly and unlawfully possessed a narcotic drug,

to wit: cocaine, with the intent to sell it.

SIXTY-SIXTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.21(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS on or about the

29th day of January 2022, in Erie County, knowingly and unlawfully possessed one or more

27
preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of eight ounces

or more.

SIXTY-SEVENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

29th day of January 2022, in Erie County, knowingly and unlawfully possessed a narcotic drug, to

wit: cocaine, with the intent to sell it.

SIXTY-EIGHTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

26th day of January 2022, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit:

cocaine.

SIXTY-NINTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

26th day of January 2022, in Erie County, knowingly and unlawfully possessed a narcotic drug, to

wit: cocaine, with the intent to sell it.

28
 SEVENTIETH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, TAJINE BENNING, of the crime of CRIMINAL POSSESSION OF A

WEAPON IN THE SECOND DEGREE, in violation of Section 265.03(3) of the Penal Law of

the State of New York, in that he, the said TAJINE BENNING, on or about the 26th day of January

2022, in Erie County, knowingly and unlawfully possessed a loaded firearm, to wit: a loaded .45

caliber pistol, and said possession did not take place in the defendant’s home or place of business.

The subject matter of this count is an Armed Felony as that term is defined in Section 1.20

of the Criminal Procedure Law.

SEVENTY-FIRST COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, TAJINE BENNING, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE FIFTH DEGREE, in violation of Section 220.06(5)

of the Penal Law of the State of New York, in that he, the said TAJINE BENNING, on or about

the 26th day of January 2022, in Erie County, knowingly and unlawfully possessed cocaine and

said cocaine weighed five hundred milligrams or more.

SEVENTY-SECOND COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE SECOND DEGREE, in violation of Section 220.41(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

7th day of February 2022, in Erie County, knowingly and unlawfully sold one or more preparations,

compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and said

29
preparations, compounds, mixtures or substances were of an aggregate weight of one-half ounce

or more.

SEVENTY-THIRD COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

7th day of February 2022, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit:

cocaine.

SEVENTY-FOURTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE SECOND DEGREE, in violation of Section 220.41(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

8th day of February 2022, in Erie County, knowingly and unlawfully sold one or more preparations,

compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and said

preparations, compounds, mixtures or substances were of an aggregate weight of one-half ounce

or more.

SEVENTY-FIFTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

8th day of February 2022, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit:

30
cocaine.

SEVENTY-SIXTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

15th day of February 2022, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit:

cocaine.

SEVENTH-SEVENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, DEVON JONES, A/K/A “DUTCH,” of the crime of ATTEMPTED

CRIMINAL POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD

DEGREE, in violation of Sections 110.00 and 220.16(1) of the Penal Law of the State of New

York, in that he, the said DEVON JONES, A/K/A “DUTCH,” on or about the 15th day of February

2022, in Erie County, knowingly and unlawfully attempted to possess a narcotic drug, to wit:

cocaine, with the intent to sell it.

SEVENTY-EIGHTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.43(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

and between the 15th and 16th days of February 2022, in Erie County, knowingly and unlawfully

sold one or more preparations, compounds, mixtures or substances containing a narcotic drug, to

wit: cocaine, and said preparations, compounds, mixtures or substances were of an aggregate

31
weight of two ounces or more.

SEVENTY-NINTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

and between the 15th and 16th days of February 2022, in Erie County, knowingly and unlawfully

sold a narcotic drug, to wit: cocaine.

EIGHTIETH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, NEGMARIE MARCANO, of the crime of ATTEMPTED CRIMINAL

POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation

of Sections 110.00 and 220.16(1) of the Penal Law of the State of New York, in that she, the said

NEGMARIE MARCANO, on or about the 16th day of February 2022, in Erie County, knowingly

and unlawfully attempted to possess a narcotic drug, to wit: cocaine, with the intent to sell it.

EIGHTY-FIRST COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.43(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

16th day of February 2022, in Niagara County, knowingly and unlawfully sold one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of two ounces

or more.

32
 EIGHTY-SECOND COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

16th day of February 2022, in Niagara County, knowingly and unlawfully sold a narcotic drug, to

wit: cocaine.

EIGHTY-THIRD COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MICHAEL MCPHEE, of the crime of ATTEMPTED CRIMINAL

POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation

of Sections 110.00 and 220.16(1) of the Penal Law of the State of New York, in that he, the said

MICHAEL MCPHEE, on or about the 16th day of February 2022, in Niagara County, knowingly

and unlawfully attempted to possess a narcotic drug, to wit: cocaine, with the intent to sell it.

EIGHTY-FOURTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MICHAEL MCPHEE, of the crime of ATTEMPTED CRIMINAL

POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation

of Sections 110.00 and 220.16(12) of the Penal Law of the State of New York, in that he, the said

MICHAEL MCPHEE, on or about the 16th day of February 2022, in Niagara County, knowingly

and unlawfully attempted to possess one or more preparations, compounds, mixtures or substances

containing a narcotic drug, to wit: cocaine, and said preparations, compounds, mixtures or

substances were of an aggregate weight of one-half ounce or more.

33
 EIGHTY-FIFTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, ERIC RICHMOND, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.43(1)

of the Penal Law of the State of New York, in that he, the said ERIC RICHMOND, on or about

and between the 16th and 17th days of February 2022, in Erie County, knowingly and unlawfully

sold one or more preparations, compounds, mixtures or substances containing a narcotic drug, to

wit: cocaine, and said preparations, compounds, mixtures or substances were of an aggregate

weight of two ounces or more.

EIGHTY-SIXTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, ERIC RICHMOND, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said ERIC RICHMOND, on or about

and between the 16th and 17th days of February 2022, in Erie County, knowingly and unlawfully

sold a narcotic drug, to wit: cocaine.

EIGHTY-SEVENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, ERIC RICHMOND, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.21(1)

of the Penal Law of the State of New York, in that he, the said ERIC RICHMOND, on or about

and between the 16th and 17th days of February 2022, in Erie County, knowingly and unlawfully

possessed one or more preparations, compounds, mixtures or substances containing a narcotic

34
drug, to wit: cocaine, and said preparations, compounds, mixtures or substances were of an

aggregate weight of eight ounces or more.

EIGHTY-EIGHTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, ERIC RICHMOND, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said ERIC RICHMOND, on or about

and between the 16th and 17th days of February 2022, in Erie County, knowingly and unlawfully

possessed a narcotic drug, to wit: cocaine, with the intent to sell it.

EIGHTY-NINTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.21(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

17th day of February 2022, in Erie County, knowingly and unlawfully possessed one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of eight ounces

or more.

NINETIETH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

35
17th day of February 2022, in Erie County, knowingly and unlawfully possessed a narcotic drug,

to wit: cocaine, with the intent to sell it.

NINETY-FIRST COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

24th day of February 2022, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit:

cocaine.

NINETY-SECOND COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, DEVON JONES, A/K/A “DUTCH,” of the crime of CRIMINAL

POSSESSION OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation

of Section 220.16(1) of the Penal Law of the State of New York, in that he, the said DEVON

JONES, A/K/A “DUTCH,” on or about the 24th day of February 2022, in Erie County, knowingly

and unlawfully possessed a narcotic drug, to wit: cocaine, with the intent to sell it.

NINETY-THIRD COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.43(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

the 1st day of March 2022, in Erie County, knowingly and unlawfully sold one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of two ounces

36
or more.

NINETY-FOURTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

1st day of March 2022, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit:

cocaine.

NINETY-FIFTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

the 1st day of March 2022, in Erie County, knowingly and unlawfully possessed a narcotic drug,

to wit: cocaine, with the intent to sell it.

NINETY-SIXTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(12)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

the 1st day of March 2022, in Erie County, knowingly and unlawfully possessed one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of one-half

ounce or more.

37
 NINETY-SEVENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, RONALD WASHINGTON, of the crime of CRIMINAL POSSESSION

OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section

220.16(1) of the Penal Law of the State of New York, in that he, the said RONALD

WASHINGTON, on or about the 1st day of March 2022, in Erie County, knowingly and unlawfully

possessed a narcotic drug, to wit: cocaine, with the intent to sell it.

NINETY-EIGHTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.43(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

and between the 1st and 3rd days of March 2022, in Erie County, knowingly and unlawfully sold

one or more preparations, compounds, mixtures or substances containing a narcotic drug, to wit:

cocaine, and said preparations, compounds, mixtures or substances were of an aggregate weight

of two ounces or more.

NINETY-NINTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

and between the 1st and 3rd days of March 2022, in Erie County, knowingly and unlawfully sold a

narcotic drug, to wit: cocaine.

38
 ONE HUNDREDTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

and between the 1st and 3rd days of March 2022, in Erie County, knowingly and unlawfully

possessed a narcotic drug, to wit: cocaine, with the intent to sell it.

ONE HUNDRED FIRST COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, NEGMARIE MARCANO, of the crime of CRIMINAL POSSESSION

OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section

220.16(1) of the Penal Law of the State of New York, in that she, the said NEGMARIE

MARCANO, on or about the 3rd day of March 2022, in Erie County, knowingly and unlawfully

possessed a narcotic drug, to wit: cocaine, with the intent to sell it.

ONE HUNDRED SECOND COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.43(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about and

between the 4th and 7th days of March 2022, in Niagara County, knowingly and unlawfully sold

one or more preparations, compounds, mixtures or substances containing a narcotic drug, to wit:

cocaine, and said preparations, compounds, mixtures or substances were of an aggregate weight

of two ounces or more.

39
 ONE HUNDRED THIRD COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about and

between the 4th and 7th days of March 2022, in Niagara County, knowingly and unlawfully sold a

narcotic drug, to wit: cocaine.

ONE HUNDRED FOURTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MICHAEL MCPHEE, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said MICHAEL MCPHEE, on or about

the 7th day of March 2022, in Niagara County, knowingly and unlawfully possessed a narcotic

drug, to wit: cocaine, with the intent to sell it.

ONE HUNDRED FIFTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MICHAEL MCPHEE, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(12)

of the Penal Law of the State of New York, in that he, the said MICHAEL MCPHEE, on or about

the 7th day of March 2022, in Niagara County, knowingly and unlawfully possessed one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of one-half

ounce or more.

40
 ONE HUNDRED SIXTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.43(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

9th day of March 2022, in Niagara County, knowingly and unlawfully sold one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of two ounces

or more.

ONE HUNDRED SEVENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

9th day of March 2022, in Niagara County, knowingly and unlawfully sold a narcotic drug, to wit:

cocaine.

ONE HUNDRED EIGHTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MICHAEL MCPHEE, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said MICHAEL MCPHEE, on or about

the 9th day of March 2022, in Niagara County, knowingly and unlawfully possessed a narcotic

drug, to wit: cocaine, with the intent to sell it.

41
 ONE HUNDRED NINTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MICHAEL MCPHEE, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(12)

of the Penal Law of the State of New York, in that he, the said MICHAEL MCPHEE, on or about

the 9th day of March 2022, in Niagara County, knowingly and unlawfully possessed one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of one-half

ounce or more.

ONE HUNDRED TENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

13th day of March 2022, in Niagara County, knowingly and unlawfully sold a narcotic drug, to wit:

cocaine.

ONE HUNDRED ELEVENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MICHAEL MCPHEE, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said MICHAEL MCPHEE, on or about

the 13th day of March 2022, in Niagara County, knowingly and unlawfully possessed a narcotic

drug, to wit: cocaine, with the intent to sell it.

42
 ONE HUNDRED TWELVETH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE SECOND DEGREE, in violation of Section 220.41(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

the 18th day of March 2022, in Erie County, knowingly and unlawfully sold one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of one-half

ounce or more.

ONE HUNDRED THIRTEENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

the 18th day of March 2022, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit:

cocaine.

ONE HUNDRED FOURTEENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.43(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

the 25th day of March 2022, in Erie County, knowingly and unlawfully sold one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

43
said preparations, compounds, mixtures or substances were of an aggregate weight of two ounces

or more.

ONE HUNDRED FIFTEENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL SALE OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.39(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

the 25th day of March 2022, in Erie County, knowingly and unlawfully sold a narcotic drug, to wit:

cocaine.

ONE HUNDRED SIXTEENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, RONALD WASHINGTON, of the crime of CRIMINAL POSSESSION

OF A CONTROLLED SUBSTANCE IN THE SECOND DEGREE, in violation of Section

220.18(1) of the Penal Law of the State of New York, in that he, the said RONALD

WASHINGTON, on or about the 25th day of March 2022, in Erie County, knowingly and

unlawfully possessed one or more preparations, compounds, mixtures or substances containing a

narcotic drug, to wit: cocaine, and said preparations, compounds, mixtures or substances were of

an aggregate weight of four ounces or more.

ONE HUNDRED SEVENTEENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, RONALD WASHINGTON, of the crime of CRIMINAL POSSESSION

OF A CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section

220.16(1) of the Penal Law of the State of New York, in that he, the said RONALD

WASHINGTON, on or about the 25th day of March 2022, in Erie County, knowingly and

44
unlawfully possessed a narcotic drug, to wit: cocaine, with the intent to sell it.

ONE HUNDRED EIGHTEENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE SECOND DEGREE, in violation of Section 220.18(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

28th day of March 2022, in Erie County, knowingly and unlawfully possessed one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of four ounces

or more.

ONE HUNDRED NINETEENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the

28th day of March 2022, in Erie County, knowingly and unlawfully possessed a narcotic drug, to

wit: cocaine, with the intent to sell it.

ONE HUNDRED TWENTIETH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINALLY USING DRUG

PARAPHERNALIA IN THE SECOND DEGREE, in violation of Section 220.50(2) of the

Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the 28th

day of March 2022, in Erie County, knowingly possessed gelatin capsules, glassine envelopes,

vials, capsules or any other material suitable for the packaging of narcotic drugs or stimulants

45
under circumstances evincing an intent to use, or under circumstances evincing knowledge that

some person intends to use the same for the purpose of unlawfully manufacturing, packaging, or

dispensing of any narcotic drug or stimulant.

ONE HUNDRED TWENTY-FIRST COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of CRIMINALLY USING DRUG

PARAPHERNALIA IN THE SECOND DEGREE, in violation of Section 220.50(3) of the

Penal Law of the State of New York, in that he, the said CHARLES SIMS, on or about the 28th

day of March 2022, in Erie County, knowingly possessed scales and balances used or designed

for the purpose of weighing or measuring controlled substances, under circumstances evincing an

intent to use, or under circumstances evincing knowledge that some person intends to use the same

for the purpose of unlawfully manufacturing, packaging, or dispensing of any narcotic drug or

stimulant.

ONE HUNDRED TWENTY-SECOND COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE FIRST DEGREE, in violation of Section 220.21(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

the 28th day of March 2022, in Erie County, knowingly and unlawfully possessed one or more

preparations, compounds, mixtures or substances containing a narcotic drug, to wit: cocaine, and

said preparations, compounds, mixtures or substances were of an aggregate weight of eight ounces

or more.

ONE HUNDRED TWENTY-THIRD COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

46
accuses the defendant, MUSA RAMADAN, of the crime of CRIMINAL POSSESSION OF A

CONTROLLED SUBSTANCE IN THE THIRD DEGREE, in violation of Section 220.16(1)

of the Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about

the 28th day of March 2022, in Erie County, knowingly and unlawfully possessed a narcotic drug,

to wit: cocaine, with the intent to sell it.

ONE HUNDRED TWENTY-FOURTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINALLY USING DRUG

PARAPHERNALIA IN THE SECOND DEGREE, in violation of Section 220.50(1) of the

Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about the 28th

day of March 2022, in Erie County, knowingly possessed diluents, dilutants or adulterants,

including but not limited to, any of the following: quinine hydrochloride, mannitol, mannite,

lactose or dextrose, adapted for the dilution of narcotic drugs or stimulants under circumstances

evincing an intent to use, or under circumstances evincing knowledge that some person intends to

use, the same for purposes of unlawfully mixing, compounding or otherwise preparing any narcotic

drug or stimulant.

ONE HUNDRED TWENTY-FIFTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINALLY USING DRUG

PARAPHERNALIA IN THE SECOND DEGREE, in violation of Section 220.50(2) of the

Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about the 28th

day of March 2022, in Erie County, knowingly possessed gelatin capsules, glassine envelopes,

vials, capsules or any other material suitable for the packaging of narcotic drugs or stimulants

under circumstances evincing an intent to use, or under circumstances evincing knowledge that

47
some person intends to use the same for the purpose of unlawfully manufacturing, packaging, or

dispensing of any narcotic drug or stimulant.

ONE HUNDRED TWENTY-SIXTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, MUSA RAMADAN, of the crime of CRIMINALLY USING DRUG

PARAPHERNALIA IN THE SECOND DEGREE, in violation of Section 220.50(3) of the

Penal Law of the State of New York, in that he, the said MUSA RAMADAN, on or about the 28th

day of March 2022, in Erie County, knowingly possessed scales and balances used or designed

for the purpose of weighing or measuring controlled substances, under circumstances evincing an

intent to use, or under circumstances evincing knowledge that some person intends to use the same

for the purpose of unlawfully manufacturing, packaging, or dispensing of any narcotic drug or

stimulant.

ONE HUNDRED TWENTY-SEVENTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, ERIC RICHMOND, of the crime of CRIMINAL POSSESSION OF

CANNABIS IN THE FIRST DEGREE, in violation of Section 222.40(1) of the Penal Law of

the State of New York, in that he, the said ERIC RICHMOND, on or about the 28th day of March

2022 in, Erie County, knowingly and unlawfully possessed cannabis and such cannabis weighed

more than ten pounds.

ONE HUNDRED TWENTY-EIGHTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of OPERATING AS A MAJOR

TRAFFICKER, in violation of Section 220.77(2) of the Penal Law of the State of New York, in

that he, the said CHARLES SIMS, on or about and between the 21st day of October 2021 and the

48
28th day of March 2022, in Erie County and elsewhere, as a profiteer, knowingly and unlawfully

sold, on one or more occasions within six months or less, a narcotic drug, to wit: cocaine, and the

proceeds collected or due from such sale or sales had a total aggregate value of seventy-five

thousand dollars or more.

ONE HUNDRED TWENTY-NINTH COUNT

AND THE GRAND JURY OF THE COUNTY OF ERIE, by this indictment, further

accuses the defendant, CHARLES SIMS, of the crime of OPERATING AS A MAJOR

TRAFFICKER, in violation of Section 220.77(3) of the Penal Law of the State of New York, in

that he, the said CHARLES SIMS, on or about and between the 21st day of October 2021 and the

28th day of March 2022, in Erie County and elsewhere, as a profiteer, knowingly and unlawfully

possessed, on one or more occasions within six months or less, a narcotic drug, to wit: cocaine,

with the intent to sell same, and such narcotic drugs had a total a total aggregate value of seventy-

five thousand dollars or more.

NICOLE KEARY
Deputy Attorney General
New York State Organized Crime Task Force

_____________________________________
BY: NATHANAEL KAPPERMAN
Assistant Deputy Attorney General
New York State Organized Crime Task Force

__________________________
Acting Foreperson
Erie County Grand Jury

Dated: October ____, 2022

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